Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

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.