Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9425

Received: 29/07/2022

Respondent: L&Q Estates Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Council does not have robust evidence that justifies the inclusion of this policy in the plan. There is concern that as currently proposed this policy will not assist in boosting housing supply and may limit the deliverability of some sites. There is no evidence to confirm that large scale developments are a preferred location for self-build plots. Any evidence must be supported by thorough viability and impact assessments. There is always a danger of gaps in the street scene, or unfinished properties, by including self-build plots into development proposals. This needs to be avoided to ensure consistent developments.

Full text:

These representations have been submitted by Pegasus Group on behalf of L & Q Estates Limited in response to the Local Plan 2040: Plan for Submission consultation.
These representations are made in relation to our clients' interests in land to the East of Wixams, which forms the proposed residential site allocation HOU16.
The following sections set out our comments on relevant sections and policies in the plan.
Policy DM5 sets out proposed requirements for self-build and custom house building, requiring new housing development to include a number of plots for self-build and custom housebuilders depending on the overall size of the development. Under the Self Build and Custom Housebuilding Act 2015 and the NPPF, it is the Council's responsibility, not landowners or developers, to ensure sufficient permissions are granted to meet demand. The NPPG outlines ways Councils should consider supporting self and custom build housing through engagement with developers and encouraging them to consider self and custom build where they are interested.
The issue of self and custom build units on larger developments was a matter addressed by the Inspector examining the Blaby Part 2 Local Plan. In this case the Inspector noted that whilst the Self-Build and Custom Build Register may indicate an interest in this type of housing, it was not clear how this evidence translated into actual demand, with potential issues of double counting where individuals register with more than one Council. In proposing a Modification to the plan to remove the requirement for self-build housing on larger sites, the Inspector concluded that the requirement was not justified by the available evidence, there were potential viability issues and there may be negative consequences for the provision of affordable housing (paras 73-79, Inspector's Report, Blaby Part 2 Local Plan, 21st December 2018).
The Council does not have robust evidence that justifies the inclusion of this policy in the plan. There is a concern that as currently proposed this policy will not assist in boosting the supply of housing and may even limit the deliverability of some sites and homes. There is also no evidence to confirm that large scale developments are a preferred location for self-build plots. Any evidence must be supported by a thorough viability and impact assessment. There is always a danger of gaps in the street scene, or unfinished properties, by including self-build plots into development proposals and this needs to be avoided to ensure cohesive and consistent developments.