Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9890

Received: 28/07/2022

Respondent: FP Tinsley Estate

Agent: Aragon Land and Planning

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.

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

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;

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.

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. This revised advice needs to be reflected in the methodology for counting self build in Bedford Brough and the Self build topic paper 6.3 needs to be revised. Single plots can be self build, but they need to exercise a discount because not all these granted single plots are self build. The monitoring does not fully identify the issue and the policy does not address the production of single self build and custom plots.

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 DM5 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 DM5 provides for a requirement for self-build dwellings as part of larger housing sites but it needs to recognise that single plots can contribute to the supply for self and custom build.

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 may not be identified in neighbourhood plans and para 6.46 accepts the point, however it could be made clearer. The main focus of delivery for self-building is as part of larger sites; however, the policy needs to be revised to make a stronger reference to single plots providing delivery. These smaller and single plots have a significant impact on delivery, and they are not properly addressed in the evidence and the policy.

Comment

Representation ID: 9891

Received: 28/07/2022

Respondent: FP Tinsley Estate

Agent: Aragon Land and Planning

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.

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

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;

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.

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. This revised advice needs to be reflected in the methodology for counting self build in Bedford Brough and the Self build topic paper 6.3 needs to be revised. Single plots can be self build, but they need to exercise a discount because not all these granted single plots are self build. The monitoring does not fully identify the issue and the policy does not address the production of single self build and custom plots.

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 DM5 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 DM5 provides for a requirement for self-build dwellings as part of larger housing sites but it needs to recognise that single plots can contribute to the supply for self and custom build.

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 may not be identified in neighbourhood plans and para 6.46 accepts the point, however it could be made clearer. The main focus of delivery for self-building is as part of larger sites; however, the policy needs to be revised to make a stronger reference to single plots providing delivery. These smaller and single plots have a significant impact on delivery, and they are not properly addressed in the evidence and the policy.