Object

Representation ID: 7900

Received: 24/09/2021

Respondent: Home Builders Federation

16. Firstly, the Council state in paragraph 7.13 that whilst high density flatted development may not mean individual plots can be made available for self-build that such dwellings provide opportunities for custom build. We would disagree and consider that flatted development does not fall under the definition of a self and custom build dwelling as defined by the Self-Build and Custom Housebuilding Act 2015. Section 1(A2) of this act specifically excludes the building of a house on a plot acquired from a person who builds the house wholly or mainly to the plans or specifications decided or offered by that person. This was considered by the inspector at the examination of the Windsor and Maidenhead Borough Local Plan which similarly looked to apply self-build requirements to flatted development. In her post hearing advice1 she concluded at paragraph 12 that such an approach was not justified on the basis that it was inconsistent with the relevant legislation. As such it is equally unjustified for this policy to be applied to all qualifying schemes and specific exclusion from this policy for flatted development should be specified.
Secondly, The Council do not set out in this consultation document how many self-build plots it would expect to deliver through this policy and whether it is necessary to meet the estimated need for such plots over the plan period. The evidence published by the Council with regard the need for self-build homes indicates that at present the Council is meeting its requirements without a designated policy and on this basis, there does not seem to be sufficient justification for this policy. However, PPG does set out that other evidence as to self-build demand should be considered. The council’s assessment of self-build demand indicates that this could be in the region of 97 dwellings per annum if national perceptions as to demand for self-build of 10% of total stock are applied. However, these are national perceptions as to self-build and custom housebuilding and as is noted in the Council’s evidence paper would represent a significant step up compared to the self-build register. As such if the Council is to justify such an onerous policy, in particular on smaller plots which could see 20% of plots given over to self-build the Council will need to provide compelling justification.
Finally, the Council must recognise that the provision of serviced plots on housing developments adds to the complexity and logistics of developing such sites and therefore potentially slower delivery. It is unlikely that the provision of self-build plots on new housing developments can be co-ordinated with the development of the wider site. At any one time, there are often multiple contractors and large machinery operating on-site from both a practical and health & safety perspective, it is difficult to envisage the development of single plots by individuals operating alongside this construction activity. Any differential between the lead-in times /build out rates of self-build plots and the development of the wider site means unfinished plots next to completed and occupied dwellings resulting in consumer dissatisfaction, construction work outside of specified working hours, building materials stored outside of designated compound areas, etc. As such the most appropriate approach, and one that is consistent with PPG, to delivering self-build plots is through the Council either using its own land or working with local land owners to identify appropriate sites where self-build homes can be delivered.