Policy SB1

Object

Representation ID: 3498

Received: 26/07/2021

Respondent: Accessibility Bedford

Local Plan 2030 Policy 59S which requires dwellings built to Part M (Building Regs) Accessible Standards according to the number of dwellings should be retained. In view of the UK’s aging population, it would be beneficial to improve on this policy by a requirement for bungalows on sites of more than 20 dwellings.

Support

Representation ID: 3554

Received: 11/08/2021

Respondent: Ms Claudia Dietz

In addition to the above objectives and requirements, it is vital to also require the delivery of a design strategy for approved plots to ensure high quality design and consistency across a site or area for the future self-builder.

Object

Representation ID: 3834

Received: 26/08/2021

Respondent: Roxton Parish Council

RPC suggests the marketing time frames for all project types should be doubled.

Object

Representation ID: 4987

Received: 02/09/2021

Respondent: Bates Bros (Farms) Limited

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.
The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.
Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.
There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.
Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.
The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.
There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.
We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.
There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.
To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 5278

Received: 03/09/2021

Respondent: L&Q Estates Limited

Agent: Pegasus Group

The Council does not have robust evidence that justifies the inclusion of this policy in the plan. Any evidence must be supported by a thorough viability and impact assessment.

Object

Representation ID: 5412

Received: 03/09/2021

Respondent: Landcrest Developments Ltd

Agent: Woods Hardwick Planning

See detailed representation

Support

Representation ID: 5457

Received: 03/09/2021

Respondent: Mr Daniel Kownacki

Opportunities for self build plots welcomed. However, I would like to see much more ambition in encouraging people to self build and a greater proportion of developments reserved for self or custom build.

Object

Representation ID: 5522

Received: 06/09/2021

Respondent: Mrs Clare Szczepanski

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 5532

Received: 06/09/2021

Respondent: Mr Bernard Cornwell

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 5539

Received: 06/09/2021

Respondent: EF Wootton and Son

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 5552

Received: 06/09/2021

Respondent: Mr R Pinfold

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 5553

Received: 06/09/2021

Respondent: Mr R Pinfold

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 5815

Received: 07/09/2021

Respondent: Mr Glen Moore

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.
The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.
Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.
There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.
Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.
The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.
There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.
We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.
There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.
To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 5827

Received: 08/09/2021

Respondent: Persimmon Homes Midlands

Agent: Planning Prospects Ltd

Persimmon note the council are seeking to address the requirement for self build opportunities within the Plan
under new Policy SB1 and in this regard the following comments are provided;
- The Council should more appropriate pursue an approach which specifically seeks to allocate sites for self
build – it is not straight forward to include self build plots within wider more general housing schemes for
reason of design, layout and continuity of build. Self build plots require an degree of flexibility on design
and layout and that often is not available of on wider development sites which have been carefully planned
with a range of integrated and considered house types.
- The requirements for the number of plots to be made available by size of the development appears
arbitrary
- Some sites may be completely unsuitable for self build, given the types housing eg apartments and
arrangement of the scheme – there should be provision within the policy to allow justification for
exceptions to provision on site
- The policy implications need to be factored into the plan viability and in the absence of value being gained
through the build phase and developers having to sell off build plots, the policy has significant implications
for development viability
- The policy also has implications for build trajectory as self build plots inevitably take longer to come
forward
- The approach to marketing of the site needs justification – the periods set out are far too long as
development schemes could well be completed whilst self build plots are being marketed
- It needs to be explicit in the policy that development sites may have specific design and delivery
requirements in order to allow for self build – it would not be acceptable to allow new house occupiers to
be affected by undelivered or partially built properties for considerable periods of time
- Self build plots should at the very least be excluded from the qualifying plots against which the affordable
housing percentage for the site is calculated.

Object

Representation ID: 6052

Received: 09/09/2021

Respondent: x Gates/Kitchiner

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 6060

Received: 09/09/2021

Respondent: Mrs V Bates

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 6071

Received: 09/09/2021

Respondent: Countryside Properties

Agent: Phillips Planning Services

3.27. The objective of this policy can only be delivered if there is a reasonable and proportionate distribution of growth along the corridor in desirable places where a need is identified on the Self Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of self build plots in and around the urban area. The Government’s objective in bringing in the self-build requirement was for that untapped part of the sector to start making a contribution towards housing delivery.

3.28. This means that self-build plots should be provided where they are wanted, and as the register shows a broad range of desirable locations, if the objectives of SB1 are to be realised, then a commensurate range of sites should be provided.

Object

Representation ID: 6083

Received: 09/09/2021

Respondent: Mr J Wright

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 6162

Received: 09/09/2021

Respondent: Savills

Agent: Savills

We do not agree with the proposed sliding scale for delivery of self-build and custom build housing because
we consider this is not consistent with the NPPF paragraph 62. Under section 1 of the Self Build and Custom
Housebuilding Act 2015, local authorities are required to keep a register of those seeking to acquire serviced
plots in the area for their own self-build and custom house building. A blanket policy comprising a sliding
scale of provision such as Policy SB1 is not evidence-based and hence would not be sound. There is no
explanation as to the forecasted delivery under the sliding scale and how this might compare to evidence of
need for self-build and custom housing.

Object

Representation ID: 6249

Received: 09/09/2021

Respondent: IM Land

Agent: Barton Willmore

Self-build and custom housebuilding
Footnote 28 of the NPPF confirms that “under section 1 of the Self Build and Custom Housebuilding Act 2015, local authorities are required to keep a register of those seeking to acquire serviced plots in the area for their own self-build and custom house building. They are also subject to duties under sections 2 and 2A of the Act to have regard to this and to give enough suitable development permissions to meet”.
We understand that the Council has a duty to provide serviced plots to meet the demand on Part 1 of its Self-build and Custom Housebuilding Register, but will take into account the demand shown by both parts of the register in considering planning applications. The proposed ‘Policy SB1 – Self-build and custom housebuilding’ sets out that new housing development must include a number of plots for self-build and custom housebuilders in accordance with the following, based on the overall number of net-additional dwellings proposed:
• 1-4 dwellings = no requirement
• 5-9 dwellings = 1 plot
• 10-29 dwellings = 2 plots
• 30-49 dwellings = 3 plots
• 50-69 dwellings = 5 plots
• 70-89 dwellings = 6 plots
• 90-100 dwellings = 7 plots
• 100+ dwellings = by negotiation
The proposed Policy SB1 requires that for sites of 50 dwellings or more:
“Plots will be marketed solely to individuals and associations on Part 1 of the Council’s Register in the first instance for an initial period of two months (minimum) from the commencement of the site being marketed.
- Following the initial marketing period, the offer of any unreserved plots will be extended to those on Part 2 of the Council’s Register and any new registrants to Part 1 having joined during the initial period. If the developer can provide evidence to the satisfaction of the Council that suitable purchasers from the Register have not been forthcoming within 6 months (minimum) of commencement of marketing the plots, they may be offered for unrestricted market sale to self-build and custom homebuilders including industry sector specialist companies
- Any plots not reserved within a further 6 months (minimum) will be released from this specific policy requirement, following a total of 12 months of marketing.”
As of 28th July 2021, the Bedford Borough Council Self-build and Custom Housebuilding Register consists of the following:
• Individuals Part 1 = 41
• Individuals Part 2 = 133
• Associations Part 1 = 0
• Associations Part 2 = 0
• Total entries on register = 174
On this basis, it is unclear why the requirement of the proposed ‘Policy SB1 – Self-build and custom housebuilding’ is so high (considering the current level of demand). For larger sites, there is a total minimum marketing window of 12 months, which will have a detrimental impact on delivery and site build out. We would welcome a site-specific policy, which allows consideration of the level of demand for self-build and custom housing and a requirement for a proportionate level of self-build and custom plots at the time a planning application is submitted. Whilst we welcome a clause in the Section 106 Agreement, for the release of a plot from the requirement of Policy SB1 after a period of marketing, we consider a 12 month minimum marketing period to be unreasonable and unjustified.

Object

Representation ID: 6263

Received: 10/09/2021

Respondent: Mr A Sarro

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 6276

Received: 10/09/2021

Respondent: Mr Bernard Cornwell

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 6302

Received: 10/09/2021

Respondent: Messrs A Porter, H Fowler, W Salsbury Ltd

Agent: DLP Planning Limited

Our client objects to Policy SB1 as drafted on the basis of soundness concerns with the proposed approach (not effective; not justified).
Further clarification is required as to the evidence that would be required to be submitted where an expression of i nterest in a plot has been rejected by the developer as to why it was not suitable. It is also not clear from the policy as to how plots for custom build will be determined and where the relevant applicant can obtain registered evidence of demand as the register is not publicly available.
Please refer to our supporting representations for further information.

Object

Representation ID: 6385

Received: 13/09/2021

Respondent: Mr Sandy Gery

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Support

Representation ID: 6479

Received: 13/09/2021

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

1. 2. 3. 4. 5. 6. 7. 8. The number of self-build plots required through Policy SB1 relative to the number of dwellings at a given site is too high relative to the evidence of demand demonstrated through the evidence base, particularly in the case of the explicit and anticipated requirements suggested for larger developments, particularly the evidence base leaves a large degree of uncertainty about demand. The ‘Self-build and Custom Housebuilding Guidance’ states in paragraph 11 that “Local planning authorities should use the demand data from the registers in their area, supported as necessary by additional data from secondary sources (as outlined in the housing and economic development needs guidance), to understand and consider future need for this type of housing in their area”. The “Bedford Borough Local Housing Needs Assessment Self-build and Custom Housebuilding Report of Findings April 2021” document within the evidence base states that “the current assumed supply of self-build and custom housebuilding is currently measured only by those properties with permission for a single dwelling. In practice it is likely that at least some properties on sites with more than one dwelling will also fall within the definition of being self-build and custom housebuilding.” Therefore by its own admission, the evidence base document is of limited accuracy in terms of the demand for self-build plots and the number of plots available. Measuring need in this way does not take into account how many permissions for single dwellings have been built out and it is also unclear “how many households from the register have been able to access these plots because the information is not recorded”. Furthermore, paragraph 1.20 of the same evidence base document also states that “Bedford Borough Council is currently providing sufficient single dwelling plots to comply with its requirement to meet the needs of those on Part 1 of its own self-build and custom housebuilding register. This has been achieved without any designated policy requirement for either allocated sites for serviced plots, or a requirement for a proportion of plots on larger sites to be made available”. This draws into question the justification for Policy SB1 being so specific in stating plot numbers relative to the size of a given scheme when sufficient provision is already being achieved without such a policy. The requirements are relatively high when compared to the size of the developments specified. For example, a requirement of 2 self and custom build plots on a 10 dwelling sites equates to 20% provision, and a requirement of 7 self and custom build plots on a 90 dwelling site equates approximately to 8% provision. This when typically many local plans require roughly 5% provision or are negotiated on a case by case basis based on evidence of need. This also represents an unbalance in how much provision is sought based on the scale of a site, when there is no evidence to support such an approach. Furthermore, there is a fundamental question as to whether the provision of self-build plots on all allocations actually meets the desires and aspirations of self-builders, who often want to deliver a house on a standalone plot or with increased external space, which would not be available when delivered as part of a large site. In addition, there are issues in terms of phasing, delivery and health and safety implications from such an approach. Therefore, given the commentary provided through the evidence base and the admitted need for more information to be gathered, we consider that a Policy in the form of SB1, requiring specific numbers of plots to be self-build on developments of various scales, is not justified by the evidence base. Such an unjustified approach may lead to unnecessary delays and uncertainty to the delivery of dwellings across the district in potentially requiring relatively large proportions of self and custom build plots which may not be taken up as such. It is therefore suggested that the policy be amended to make an allowance for small exception sites to be delivered on land adjacent to settlement boundaries, which has been done successfully in other Districts, such as South Northamptonshire (as was, now West Northamptonshire). If there is to be an allowance on large sites in addition to the above then we would suggest that this is set at up to 3% 10 provision to be negotiated on a case by case basis if there is a lower level of need identified. This will help to facilitate the speedy delivery of new dwellings across the borough and accounts for the identified need for the evidence base to be further developed. 9. Additional point for Policy SB1: “Proposals for single self or custom build sites immediately adjoining the confines of settlements will normally be permitted where they help to meet demand as demonstrated by Part 1 of the council’s Self and Custom Housebuilding Register and are compliant with other policies of this plan.” 10. Revised wording to Point ‘I’ of Policy SB1 is suggested below: “The Council will require applications for new housing development to make up to 5% of the plots available on site as serviced self or custom build plots, subject to negotiation based on evidence of identified local need.”

Object

Representation ID: 6567

Received: 13/09/2021

Respondent: Challenger Multi Academy Trust

Agent: Fisher German LLP

Self-build and custom housebuilding
2.26 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 internally consistent with how the Council has interpreted other evidence and how such 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.
2.27 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 are sufficient units being delivered.
2.28 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 estate. Our experience is that for the most part that they are instead looking for more bespoke rural opportunities.
2.29 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.
2.30 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.
2.31 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.
2.32 It is noted that Council’s evidence as suggested that sufficient small-scale windfall housing sites are expected to come forward to negate the need for a specific policy or allocations to guarantee the 10% small sites requirement. This is a very similar position to self-build/custom-build, where the evidence suggests there is not a need for a policy intervention and as such none is suggested. This is entirely at odds with the self/custom build policy, which again is clearly not necessary, but the approach adopted is entirely different. The Council should be guided by its evidence and remove this policy requirement.

Object

Representation ID: 6573

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Self-build and custom housebuilding
2.32 The approach adopted by the Council in respect of Policy SB1 - Self-build and custom housebuilding
with how the Council has interpreted other evidence and how such 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.
2.33 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 are
sufficient units being delivered.
2.34 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 estate.
Our experience is that for the most part that they are instead looking for more bespoke rural
opportunities.
2.35 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.
2.36 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.
2.37 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.
2.38 It is noted that Council's evidence as suggested that sufficient small-scale windfall housing sites are
expected to come forward to negate the need for a specific policy or allocations to guarantee the 10%
small sites requirement. This is a very similar position to self-build/custom-build, where the evidence
suggests there is not a need for a policy intervention and as such none is suggested. This is entirely at
odds with the self/custom build policy, which again is clearly not necessary, but the approach adopted
is entirely different. The Council should be guided by its evidence and remove this policy requirement.

Object

Representation ID: 7157

Received: 17/09/2021

Respondent: Mr Richard Hull

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 7165

Received: 17/09/2021

Respondent: Davison & Co (Barford) Ltd

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.

Object

Representation ID: 7182

Received: 17/09/2021

Respondent: The Palmer Family Trust

Agent: Phillips Planning Services

Policy SB1 (Self-Build and Custom Housebuilding) is not consistent with the objectives of Self-Build and what it can achieve. The policy is far too narrow as it is only focussed on delivering Self-Build plots as part of wider development schemes, not on delivering them where they are wanted.

The Self-Build community tend to want unique plots in low density rural areas which have a particular character, outlook, landscape value etc, so that they can build a bespoke dwelling which is suitable for that type of location. People building their own home do not want uniform plots which are situated next to standard houses on large estates. Conversely, people wanting to purchase a standard house type on an estate may be put off buying next to a Self-Build plot as they won’t know what exactly their property will be adjoining, and this could cause issues for the housebuilders.

Furthermore, the policy does not make clear where abouts in the estate the Self-Build plots will be located. Will they be dispersed throughout the development, or located in an area of their own? Are the Self-Builders supposed to follow the design and material selection of the major housebuilders, or are they able to utilise the more innovative designs which Self-Build is supposed to offer? There are likely be conflicts in the design and character of the houses built on the Self-Build plots and the standard house types on the rest of the estate.

There is therefore a fundamental difference between the objectives of policy SB1 and what Self-Builders actually want. The policy does nothing to address locational needs with regards to providing plots where they are wanted. As such, if there is a village with a degree of interest for Self-Build but which is not earmarked for growth, then the policy would fail to deliver this. The policy should therefore facilitate for Self-build plots be provided where they are wanted or it will not drive Self-Build provision. As the Self-Build Register shows a broad range of desirable locations, then a commensurate range of sites should be provided if the objectives of SB1 are to be realised.

Self-Build is an area of housing which is very economically viable and supports small and medium scale contractors. One of the advantages of Self-Build, is that Self-Builders are more likely to take risks and push for unique technology, and implement bespoke design etc. The purpose of the Governments Self-Build policy is to encourage housing delivery through a part of the market which is not currently well catered for. Only a very small provision of Self-Build housing is delivered in England when compared to other western countries. This is an untapped part of the market which has very limited opportunities due to the constraints of the planning system.

The Self-Build Register creates an avenue for people to identify their interest in Self Build and their locational requirements in order to connect people to plots that may secure planning permission for this purpose.

There are very few “true” Self-Build plots that are delivered through the planning process. Some provision is needed for Self-Build opportunities to be considered as exceptions to the normal rural restraint policies. Some neighbouring authorities including Central Bedfordshire have facilitated this.

We would advocate the use of exception site polices for Self-Build as set out in Point 3 of the National Custom & Self-Build Association’s manifesto which sets out ten areas where Government Support can help the custom and self-build sector fix the broken housing market. Suitable safeguards such as a local connection test and standardised legal structures are available to ensure that such sites are restricted to the delivery of Self-Build.

There are lots of small sites across the district which in or adjacent to existing Settlement policy Areas, or close to the built up areas of small settlements which could come forward to meet this type of provision.

To conclude, the objectives of policy SB1 can only be delivered if there is a reasonable and proportionate distribution of growth in desirable places where a need is identified on the Self-Build Register. If development is too narrowly focused around the urban area, such as indicated in option 2a, then policy SB1 will result in an over provision of Self-Build plots in and around the urban area, and a lack of sites where they are needed.