Policy SB1

Support

Representation ID: 7234

Received: 17/09/2021

Respondent: L&Q Estates Limited

Agent: Barton Willmore

The Promoters do not object to the proposed new policy and support the flexibility shown to larger sites which
allows for negotiation on the number of self-build and custom build dwellings. However, whilst we support clarity on timing, it is not clear how these may be delivered from a design perspective, particularly with larger sites currently requiring a design code to be
submitted with an application (adopted Policy 29). It would be useful to understand the Council’s expectation on larger sites, how these may be design ‘coded in’ i.e. smaller clusters around a site, with a design passport to be provided to potential purchasers of plots.
It is also unclear how specific percentages required by different scales of development have been arrived at. For example, a requirement of 2no. self and custom build plots on a 10 dwelling site equates to 20% provision, and a requirement of 7no. self and custom build plots on a 90 dwelling site equates approximately to 8% provision. Typically many local plans require roughly 5% provision or are negotiated on a case by case basis according to 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.

Support

Representation ID: 7422

Received: 03/09/2021

Respondent: Thakeham

Thakeham supports the Council’s policy to include self-build, and acknowledges the number of units provided in development over 100+ is by negotiation. However, as is the case across the country, any specific amount of self-build should be evidenced by demand in the area, rather than an arbitrary number based on the scale of development proposed.
Thakeham supports the Council’s inclusion of a deadline for marketing plots for self-build after which they would be released from the self-build policy requirement. However, we believe that 12 months is too long, as land would remain fallow for the entire marketing period, plus the time then taken to obtain planning permission for conversion to alternative housing or uses.

Support

Representation ID: 7444

Received: 03/09/2021

Respondent: Mr D De Massey

Agent: CC Town PLanning

The client has also afforded thought to the proposed development management
policies as set out at Section 7 of the LP. In response to SB1, our client recognizes
the need to provide custom and self-build plots and appreciated the LPA’s efforts to
include this policy within the draft LP. However, there are concerns that the approach
taken could stifle certain development sites, particularly those held by larger volume
housebuilders, where self and custom build plots do not form part of their business
offer at this point in time.

Object

Representation ID: 7536

Received: 21/09/2021

Respondent: EF Wootton and Son

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 are also significant site management problems in seeking to deliver self-build opportunities in this manner, that will prevent this approach from working, and house builders will not want the potential conflict to arise between their building operations and those of separate self-build commissioned contractors. There is a likelihood that plots will be left vacant until an appropriate time is considered for their release, however, the vacant plots will be unsightly and hamper the sale of adjoining housing. You then have the dilemma of how to manage the later construction of these plots when those around it have been occupied. For example, if the plot needs piled foundations, you will have issues of vibration, noise and disturbance to existing occupiers. We would argue it is highly unlikely that plots surrounding a self-build or group of self-build plots will sell, until purchasers know what will be constructed next to them, and arguably will want to be constructed prior to their occupation.

Therefore, we believe there is 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: 7546

Received: 21/09/2021

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: 7789

Received: 23/09/2021

Respondent: Mr A Sarro

Agent: Phillips Planning Services

3.21. 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.

3.22. 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.

Support

Representation ID: 7876

Received: 23/09/2021

Respondent: Central Bedfordshire Council

Policy SB1 and the supporting text is well-worded and meets the legislation.
It is interesting to see the clearly defined set of site thresholds within the policy. This represents a graduated approach to the policy which ranges from circa 20% self-build delivery on the smaller applications, reducing to circa 7% on the larger sites.
It is also noted that applications of 100+ dwellings are able to negotiate on the level of provision, however this provides no certainly to BBC or the developers in terms of delivery of Self & custom build homes on large, strategic sites.

Overall, the graduated approach is sensible as it requires higher delivery (proportionately) to the smaller sites in order to target self-build delivery. This may accord with demand data from your register so it may be useful to make this clearer in supporting text if this is the case. It may also be useful to make some reference to any viability studies BBC has to evidence that delivery at these various site thresholds is viable.

CBC’s evidence demonstrates that self & custom build provision does not to diminish land value in any way and we would be happy to share any viability information with Bedford if this is helpful.

Support

Representation ID: 7940

Received: 20/09/2021

Respondent: Pavenham Parish council

At present, the Parish Council’s draft Neighbourhood Plan does not contain policies on self-building. Only one of the allocated residential development sites would fall within the thresholds proposed by Policy SB1 – namely the 10 to 29 dwellings threshold requiring the provision of two plots – and the Parish’s likely allocated site falls at the very lower end of the scale. In view of the statutory right to build and the fact that the Neighbourhood Plan has to be in compliance with the extant Local Plan, this emerging policy will be referenced in the Parish’s Neighbourhood Plan.

Object

Representation ID: 8069

Received: 03/09/2021

Respondent: FP Tinsley Estate

Agent: Aragon Land and Planning

This is a submission on behalf of F P Tinsley Estate who have submitted some small sites in and round Clapham for self-build and or custom Housing.

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 the identified demand.

National Planning Guidance Comments:

Most local planning authorities (including all district councils and National Park Authorities) are now required to keep a register of individuals and associations of individuals who are seeking to acquire serviced plots of land in their area in order to build their own home. The Self-build and Custom Housebuilding (Register) Regulations 2016 set out these requirements.

For further details, see guidance on self-build and custom housebuilding registers.
To obtain a robust assessment of demand for this type of housing in their area, local planning authorities should assess and review the data held on registers. This assessment can be supplemented with the use of existing secondary data sources such as building plot search websites, ‘Need-a-Plot’ information available from the Self Build Portal and enquiries for building plots from local estate agents.
The current policies in the Bedford Local plan 2030 comment on self-build and it has a number of polices of relevance. Policy 7s states (see Local Plan 2030)
7s supports a community need and with Parish support the proposal will be in accordance with 7s. The mantle also is taken up in the new Policy 59s comments:

New housing developments will be expected to provide a mix of dwelling size and type to meet the identified needs of the community including families with children, older people, people wishing to build their own homes and people with disabilities and special needs in accordance with the Council’s current Strategic Housing Market Assessment and other current assessments of housing need including the Older Person’s Accommodation Strategy, the Learning Disabilities Accommodation Strategy, the Mental Health Accommodation Strategy and evidence in respect of the needs of other specialist groups.

i. All developments of 500 dwellings or more in suitable locations, will be required to include self-contained older persons housing, and/or supported living accommodation in accordance with the Council’s most up to date statement of need on older person’s accommodation.

ii. All developments of 100 dwellings or more in suitable locations, will be required to include specialist housing including the needs of those with a learning disability or mental health need in accordance with the Council’s most up to date statement of need.

iii. On sites of 3 or more dwellings 49% of all new residential development should meet Category 2 (Accessible and Adaptable dwellings) of approved Document M; Volume 1, and on sites of 20 or more dwellings a minimum of 5% of all market housing and 7% of affordable housing should meet Category 3 requirements.

iv. All specialist housing for older people should meet Category 3 requirements.

v. The Council will support Self Build and Custom Build housing developments.

It is the last criteria which is important and demonstrates support from the planning authority for self-build. The plan goes on further to comment and support self-build.

10.32 The Council introduced its register in April 2016 and is monitoring the demand for serviced plots that has followed. A serviced plot is defined by the Act as a plot that has access to a public highway and ready connections for electricity, water and waste water, or that can be provided with these in specified circumstances or within a specified period (which will normally be 3 years to reflect a conditional planning permission). The Council already collects, in addition to the Government’s statutory requirements, information on the local connection between those registering with Bedford Borough Council and seeking a plot, namely:

• Those currently living in the borough
• Those working in the borough
• Those born (and raised) in the borough

10.33 The Council has the ability to sub-divide its register into two parts, giving priority to those who satisfy this local connection and who provide the target number for delivering appropriate planning permissions. When doing so it must also have regard armed services personnel and ex-service personnel (with a time limit applying to the latter) who are exempted from local connection criteria.

The Council’s approach currently adds.

10.34 The Council is keen to ensure that the self-build sector is supported and encouraged in Bedford by providing opportunities for it to become an established part of the local housing supply industry. It particularly wishes to encourage self-build and custom housebuilding that can meet the needs of those who require assistance in becoming established as new owner-occupiers locally or in competing in the owner-occupied housing sector. Self-build and custom build housing is not an alternative to affordable housing. Where the affordable housing requirement has been met opportunities to work with the development industry, including in the process of negotiating s106 agreements, are an important method of promoting self-build and custom build.

The Council is also pursuing other means of providing sites through;
i) its own land ownership
ii) its partnerships with other providers
iii) as part of the negotiated housing mix (Policy 59S) iv) on rural exception sites and
v) through Neighbourhood Plans.


The Bedford Borough Housing Monitor comments between October 2018 and October 2019 (the self-build register’s monitoring period) 27 planning applications were granted planning permission for developments of a single dwelling in the Borough, which although not explicitly submitted as self-build applications, provide potential opportunities for self-build and custom build housing due to the size of development. Four of these permissions were for change of use from another use. This does not demonstrate a clear pathway for deliverability of sufficient self-build dwellings and the council are obliged to grant sufficient self-build dwellings. It does not look like the council are meeting their duty under Section 2A.
The support in the current polices needs to be updated following on from new guidance and new evidence. As part of the evidence base the Council Local Needs Housing Assessment and Self Build Custom House buildings report of findings April 2021 has updated the self-build provision.

The Bedford Borough Housing Monitor April 2021 comments between October 2016 -2020 (the self-build register’s monitoring period) 192 single dwellings were granted planning permission for developments of a single dwelling in the Borough, which although not explicitly submitted as self-build applications, provide potential opportunities for self-build and custom build housing due to the size of development. For example, four of these permissions were for change of use from another use. In February 2021 the Government updated the Planning Practice Guidance to update the definition of self-build and custom housing. Any single dwellings granted planning permission where the initial owner has no primary input into final design and layout will not be a self-build. These single plots need to be discounted from the self-build and custom housebuilding.

The council basis for considering they have self-build dwellings is in the grant of single plots. They are not controlled by any mechanism which would secure delivery of self-build or custom housing. These single plot permissions should be removed from the calculations. The revised policy SB1 makes reference to s106 obligations to help delivery, and this supports the view that the current method of calculation is not correct. The evidence therefore does not provide a correct position on the supply of self-build and custom housing. A number of these single plots will be self-build, but not all.

The proposed policy SB1 provides for a requirement for self-build dwellings as part of larger housing sites but needs to provide a commentary for smaller sites of 1-10 dwellings where a provider might want to provide a self-build site dwellings in total for the site or in greater number than the threshold suggests.

The policy details a very prescriptive marketing campaign where houses are part of larger sites, however the policy should have some commentary for single plots where single plots do not need such marketing when the applicant is a self-builder.

A lot of these smaller sites will not be identified in neighbourhood plans and 7.10 does not preclude such sites coming forward. Para 7.11 and the main focus of delivery is from self-building as part of larger sites; however, the policy needs to address smaller numbers of plot delivery where the whole site could provide several self-build or custom houses. These smaller and single plots have a significant impact on delivery, and they are missed off the evidence and policy.

Object

Representation ID: 8096

Received: 02/09/2021

Respondent: G Morroll

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: 8412

Received: 03/09/2021

Respondent: Fisher German LLP

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.

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.

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.

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.

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.

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.

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: 8485

Received: 27/09/2021

Respondent: Richborough Estates

Agent: Fisher German LLP

The approach adopted by the Council in respect of Policy SB1 - Self-build and custom housebuilding is not supported, is not consistent with the Council’s own evidence, and is not consistent with how evidence has informed other policies within the Plan. The Council has published evidence on the topic in the document the Bedford Borough Local Housing Needs Assessment Self-build and Custom Housebuilding (April 2021). This document concludes that the desires of self-builders is to build large, expensive properties and that currently sufficient single dwelling permissions adequately caters for this need. This accords with our understanding of self-build, wherein people are seeking bespoke and unique opportunities, not simply adjacent to a modern housing development.
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 to the conclusions of the evidence document which demonstrates that there are sufficient units being delivered.
It is well established that such criteria are difficult to deliver on modern housing developments and do not serve to provide additional units. In reality, such requirements may impede development unnecessarily, adding to developer burden with little merit. Such proposals can create enclaves within or adjacent to housing schemes, with designs which may be entirely at odds with the aesthetic of the rest of the scheme, which will have been specifically designed as a collective whole. In our experience, self-builders generally do not want to buy serviced plots within or adjacent to a modern housing estates. Our experience is that for the most part that they are instead looking for more bespoke rural opportunities.
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.
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.
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.
The Council should be guided by its evidence and remove this policy requirement. Without such alteration this policy is considered unsound as it is not justified, effective or consistent with national policy.

Support

Representation ID: 8655

Received: 28/09/2021

Respondent: Mr Chris Bearman

Agent: Fisher German LLP

Self-build and custom housebuilding
2.20 The approach adopted by the Council in respect of Policy SB1 - Self-build and custom housebuilding is not supported, is not consistent with the Council’s own evidence, and is not consistent with how evidence has informed other policies within the Plan. The Council has published evidence on the topic in the document the Bedford Borough Local Housing Needs Assessment Self-build and Custom Housebuilding (April 2021). This document concludes that the desires of self-builders is to build large, expensive properties and that currently sufficient single dwelling permissions adequately caters for this need. This accords with our understanding of self-build, wherein people are seeking bespoke and unique opportunities, not simply adjacent to a modern housing development.
2.21 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 to the conclusions of the evidence document which demonstrates that there are sufficient units being delivered.
2.22 It is well established that such criteria are difficult to deliver on modern housing developments and do not serve to provide additional units. In reality, such requirements may impede development unnecessarily, adding to developer burden with little merit. Such proposals can create enclaves within or adjacent to housing schemes, with designs which may be entirely at odds with the aesthetic of the rest of the scheme, which will have been specifically designed as a collective whole. In our experience,

self-builders generally do not want to buy serviced plots within or adjacent to a modern housing estates. Our experience is that for the most part that they are instead looking for more bespoke rural opportunities.
2.23 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.
2.24 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.
2.25 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.

2.26 The Council should be guided by its evidence and remove this policy requirement. Without such alteration this policy is considered unsound as it is not justified, effective or consistent with national policy.

Object

Representation ID: 8831

Received: 29/09/2021

Respondent: Rosconn Strategic Land

Agent: Phillips Planning Services

Policy SB1 – Self Buid And Custom Housebuilding
3.32. The objective of this policy can only be delivered if there is a reasonable and proportionate distribution of growth in 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 forward the self-build requirement was for that untapped part of the sector to start making a contribution towards housing delivery.

3.33. 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. The residual land at Hill Farm could make a contribution towards meeting this Government objective.

Object

Representation ID: 8861

Received: 29/09/2021

Respondent: Woodland Manor Hotel

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: 8867

Received: 29/09/2021

Respondent: Mrs Alison Myers

7 Self Build Plots Policy SB1
Ravensden is only expected to deliver minor numbers of new dwellings over the Plan period. The recent development at The Curry Mansion, for 12 homes, would in theory have needed to provide a self build property. This would not have been practical at this site, as some of the units were gained from the conversion of an existing building. The requirement to provide self build opportunities would constrain developments of a small scale and could also lead to incongruous properties within the development. In my experience, self build plots lead to a maximum building on the plot, with little room for garden space ,trees of substance and with little regard to neighbours. This has been the outcome when an existing property has been demolished and a new build of a totally different scale has been proposed ( example being Glendale on Bedford Road ) - leading to major impacts for neighbours and a high level of input required from the Planning Officers to moderate the design.
In my view it would be preferable to locate self builds within a particular development or restrict the policy to larger developments of 30 plus homes.

Support

Representation ID: 8955

Received: 01/10/2021

Respondent: Snelsons Farm Partnership

Agent: DLP Planning Limited

3.44 The policy sets out the requirement for new developments to include a proportion of self/custom build housing as part of the proposals. Our clients support Policy SB1, but would advise on additional parameters and wording to be included within the policy.
Reasoning
3.45 The wording of the prospective policy does not indicate whether the required plot provision is a maximum or a minimum figure, which could result in different interpretations.
3.46 Also. the current structure of the policy does not envisage the provision of development sites
that are entirely self-build or custom houses, which would enable the creation of distinctive developments, that can meet a greater demand on a single site.
3.47 By reliance on a variety of sites providing self build opportunities, the policy risks failing to meet demand because those wishing to self build are not usually looking to do so on larger standard estate type developments and in such circumstances the ringfencing of self build plots may lead to some developments not being completed and, overall a shortfall in meeting housing targets.
Remedy
3.48 The wording of the policy should be amended to allow for whole sites to be self-build or custom developments as well as encouraging self build opportunities as a complementary element of allocated sites. The wording should also seek to establish provision as a minimum whilst encouraging scope to deliver sites which are approved solely for such housing – and therefore more likely by definition to appeal to those who want to participate in self build.

Support

Representation ID: 8975

Received: 01/10/2021

Respondent: Dacorum Borough Council

We note that Bedford Borough Council have recently implemented Part 2 of the Register. This Council presently maintains only Part 1 although we have recently embarked on a review of our approach to self-build and custom housebuilding which is in its early phases. We broadly support the approach set out in the policy SB1. Our emerging Local Plan proposes in Policy DM8 that on housing developments with 40 or more new houses that 5% of house plots should available as serviced plots to enable the delivery of self and custom build housing. We note the proposed scale of provision in your draft policy SB1 and consider that further elucidation of the criteria used in arriving at the proposed numbers would be helpful both by way of explanation and justification for the numbers.
We hope that you find the above responses constructive in taking forward your emerging Local Plan.