3.28
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 4395
Received: 31/08/2021
Respondent: Mr Kulwinder Rai
BCC's response on the Small Sites is is one that will be echoed by most local councils across the UK. That is why the government needs to look at its policy to encourage the growth small and medium sized builders again. The qualifying size of Small Sites in its policy should be reduced from a hectare to an acre, otherwise it will not have the positive effect that it originally hoped for.
BCC's response on the Small Sites is is one that will be echoed by most local councils across the UK. That is why the government needs to look at its policy to encourage the growth small and medium sized builders again. The qualifying size of Small Sites in its policy should be reduced from a hectare to an acre, otherwise it will not have the positive effect that it originally hoped for.
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 4902
Received: 02/09/2021
Respondent: Mrs Janet Goodland
The availability of small sites often arises in the short term, so early allocation will tend to stifle opportunities
The availability of small sites often arises in the short term, so early allocation will tend to stifle opportunities
Support
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5245
Received: 03/09/2021
Respondent: Mrs Clare Buddle
Smaller sites are a recognised, accepted and important residential land source.
Smaller sites are a recognised, accepted and important residential land source.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5246
Received: 03/09/2021
Respondent: Mrs Clare Buddle
Whilst housing is an important community resource, consideration must also be given to whether such sites could fulfil greater roles in creating vibrant, sustainable communities, for example as a location for surgeries, nurseries, work hubs.
Whilst housing is an important community resource, consideration must also be given to whether such sites could fulfil greater roles in creating vibrant, sustainable communities, for example as a location for surgeries, nurseries, work hubs.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 5941
Received: 08/09/2021
Respondent: Mr Tom Tagg
Please refer to my response to 3.2.
With the excessive housing requirement set by the standard method, BBC need to mitigate this with the contingencies that they currently hold. Specific examples are:
• Windfall sites; The Small Sites Topic Paper demonstrates that for the last 5 years BBC easily meets it’s 10% housing requirement on small sites by windfall development. Windfall development is held as a contingency outside the current plan allocation. In the face of the excessive standard method demands, BBC should include windfall development of 10% within the additional 12,500 dwellings needed thus reducing this figure by approx. 1,250 houses.
• The Small Sites Topic Paper demonstrates an expected excess of small sites over the 10% requirement to 2040 of 920 houses. This should also be used to reduce the 12,500 figure.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 6301
Received: 10/09/2021
Respondent: Messrs A Porter, H Fowler, W Salsbury Ltd
Agent: DLP Planning Limited
The opportunity for the Local Plan 2040 to be prepared taking a more flexible approach towards the requirements of national policy is supported in principle. For example, where any allocations proposed would offer the opportunity for early delivery and the potential to introduce multiple developers to relevant sites it would be appropriate to treat the 1 hectare threshold pragmatically, recognising that the revised strategy will itself provide substantial opportunities for diversification.
Please refer to our supporting representations for further information.
Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 7899
Received: 24/09/2021
Respondent: Home Builders Federation
he HBF is concerned with the statement in paragraph 3.28 that the Council will not allocate small sites simply to satisfy the requirement set out in paragraph 68 of the NPPF that 10% of all homes should come forward on small sites that are either allocated in the local plan or identified in the brownfield register. The Council argue that this it is not necessary to apply national policy as the there is a consistent supply of such sites coming through as windfall. This position completely misunderstands the reasons for allocating small sites rather than rely wholly on these to be brought forward as windfall sites.
13. The Government has been keen to support small and medium (SME) sized housebuilders deliver more new homes across the country. Up until the 1980s, small developers once accounted for the construction of half of all homes built in this country resulting in greater variety of product, more competition, and faster build-out rates. Since then, the number of small companies has fallen by 80% following the introduction of the plan-led system in 1990.
14. The HBF has undertaken extensive consultation with its small developer members and one of the chief obstacles for small developers is that funding is extremely difficult to secure without a full, detailed, and implementable planning permission. Securing an implementable planning permission is extremely difficult if small sites are not allocated. Without implementable consents lenders are uneasy about making finance available or else the repayment fees and interest rates they set will be very high. Small developers, consequently, need to invest a lot of money and time up-front in the risky business of trying to secure an allocation and a planning permission, and this is money that many small developers do not have and can be a barrier to entry for new housebuilders.
15. If the Council are to ensure there is a wide variety of SME house builders operating in its administrative area, and the benefits it brings to the speed of delivery and variety of homes, it must ensure that there is a variety of sites. This is why the Government, through the NPPF, now requires local authorities to allocate sites of varying sizes. The fact that such sites currently come through from windfall is therefore not a justification for this proposed inconsistency with national policy.