Support

Representation ID: 8496

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

2.33 The approach adopted by the Council in respect of Policy SB1 - Self-build and custom housebuilding is not supported and is not consistent with the Council’s own evidence and is not consistent with how evidence has informed other policies within the Plan. The Council has published evidence on the topic in the document the Bedford Borough Local Housing Needs Assessment Self-build and Custom Housebuilding (April 2021). This document concludes that the desires of self-builders is to build large, expensive properties and that currently sufficient single dwelling permissions adequately caters for this need. This accords with our understanding of self-build, wherein people are seeking bespoke and unique opportunities, not simply adjacent to a modern housing development.
2.34 Despite this, and for no justified reason, the Council have opted to seek to promote a policy which requires serviced plots to be delivered on the majority of new housing sites. This approach is not effective, consistent with evidence and as such is not supported nor considered sound. It is not clear what the housing target is for self or custom build, and how this has informed the policy, particularly having regard for the conclusions of the evidence document which demonstrates that there is sufficient units being delivered.
2.35 It is well established that such criteria are difficult to deliver on modern housing developments and do not serve to provide additional units. In reality, such requirements may impede development unnecessarily, adding to developer burden with little merit. Such proposals can create enclaves within or adjacent to housing schemes, with designs which may be entirely at odds with the aesthetic of the rest of the scheme, which will have been specifically designed as a collective whole. In our experience, self-builders generally do not want to buy serviced plots within or adjacent to a modern housing estates. Our experience is that for the most part that they are instead looking for more bespoke rural opportunities.
2.36 We are yet to see evidence that this method of delivery has been successful. Furthermore, just because individuals are registered on the self-build register it does not mean that they will all build their own property, even if suitable land was available. The reality is the difficulty and skills required will mean only a small percentage of those on the register will ever develop a self-build property. It is also important to note that individuals can be on multiple self-build registers, even with a local connection test, which inflates the figures across a number of areas. Unless demand for plots is means tested, with expressions of interest supported by evidence of finances to build such a house, to simply just deliver self-build plots on strategic sites is an arbitrary approach which lacks nuance and will harm more justified housing delivery.
2.37 This policy requirement will serve to frustrate and slow housing delivery, given special consideration would need to be given to the location of the plots and how they can be accessed safely and independently from the typical development parcels. The delivery of plots following unsuccessful marketing is also more complex than suggested within the policy. The Policy assumes such plots could simply just be built out by the developer; the nature of the plots may not however lend themselves to being built by the developer and as such could leave undeveloped plots for significant period of time. Such requirements will also deter developers, given the increased complexity and lack of certainty of outcomes. Custom build may not be in the business model of some housebuilders, which may preclude them from bidding for sites if such a requirement is retained. Self and Custom build is a market choice and should be led by the free-market, it is not and should not be treated as a need to be satisfied in the same manner as affordable housing. If there is sufficient demand for such units, and people are willing to pay a premium, then it will be adopted by more housebuilders.

2.38 The Council should instead seek to ensure the continuation of a positive policy environment where suitable self-build schemes, either of individual units or larger schemes or specific schemes providing serviced plots will be treated favourably. This encourages delivery in line with the Council’s statutory duties, without compromising sites which make up a vital facet of the Council’s overall proposed housing supply. It will also more likely better serve the self-build market by enabling development in line with the wishes of perspective self-builders. Having regard for the evidence, this policy is not sound, as it is not effective nor justified.
2.39 The Council should be guided by its evidence and remove this policy requirement. Without such alteration this policy is considered unsound as it is not justified, effective or consistent with national policy.