Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 10067

Received: 28/07/2022

Respondent: Richborough Estates

Agent: Fisher German LLP

This representation has been prepared on behalf of Richborough Estates in respect of their land interests at Land at to the east of Newton Lane, Turvey as illustrated on Figure 1 below. This site is an omission site in the emerging Bedford Local Plan 2040.
1.2 The site is considered suitable for allocation in the scenario that further housing sites are required to enable the Local Plan to be found sound (as we consider to be the case as set out within these representations).
Figure 1: Opportunities and Constraints Plan: Land at Newton Lane East, Turvey

Turvey is a sustainable settlement designated in the adopted Local Plan as a Rural Service Centre.
Turvey is one of the highest scoring Rural Service centres in the Borough, scoring only a few points
less than settlements designated as Key Service Centres (Settlement Hierarchy 2030 (Addendum April 2022) Figure 3). The adopted Local Plan seeks to deliver 25 - 50 dwellings through the emerging Neighbourhood Plans (this is in contrast to the 500 dwellings in the Key Service Centres, which Turvey falls just outside of). In historic iterations of the Bedford Local Plan (2015 consultation paper) the Council produced evidence which demonstrated that the Rural Service Centres could each accommodate up to 150 dwellings. The Council recognised the benefits of delivering larger developments in the Rural Service Villages advising that:
“Some villages have experienced the loss of vital services such as shops and pubs in recent years. Changing the current strategy of restraint in the rural policy area could increase the population and change the age profile of rural villages. An increase in activity and spending power would support existing vulnerable village services and facilities, and possibly lead to new provision. Furthermore, larger developments would be likely to bring with them a range of types and sizes of housing, which would provide more choice for existing residents wanting to stay within a village but down-size.” (Development Strategy and Site Selection Methodology Background Paper, September 2015)
1.4 The draft policies at that time supported such an allocation. Despite this latent capacity, the Council ultimately sought to reduce the quantum of housing to be delivered within the Rural Service Centres in favour of a new settlement, however, when the viability and deliverability of this was challenged the Plan period was reduced with an early review mechanism. Richborough
Estates and a number of interested parties objected to this approach of the new settlement and the reduced Plan period allowing the Plan to be found sound with the new settlement removed.
1.5 Turvey Neighbourhood Plan has since progressed to referendum on 15th July 2021. The result was marginal with 52% of votes in favour of the Neighbourhood Plan and 48% against. The Neighbourhood Plan was ‘Made’ on 1 September 2021.
1.6 The Neighbourhood Plan identifies land to deliver 50 dwellings across two allocations. Notwithstanding this, as has previously been evidenced by the Council, settlements such as Turvey remain well positioned to provide additional sites to ensure the Council can meet its future housing needs. Sites in the Rural Service Centres can deliver quickly and ensure that the step
change in delivery is met in the initial years of the Plan period whilst maintaining the vitality and viability of the services and facilities these settlements offer.
1.7 The land east of Newton Lane can deliver circa 80 dwellings, as demonstrated in the Vision Statement which is again submitted alongside these representations (having previously been sent to the Council through previous consultations). It is considered this is commensurate with the size and sustainability of the settlement and combined with the 50 dwellings to be delivered through the Neighbourhood Plan would still be below of the 150 dwellings the Council has previously evidenced the settlement could deliver within the Local Plan period to 2030. Indeed having regard to the sustainability of the settlement, and its place within the settlement hierarchy, just below those settlements which are expected to deliver 500 dwellings in the adopted Plan, it is considered that the capacity of Turvey to accommodate new homes could be far greater than
150 dwellings.
1.8 Richborough Estates are a respected land promotor who contribute high quality new residential development land and who have a strong track record of delivery in the local region.
1.9 This representation follows policies in the order that they appear in the consultation document.

It is our view, for the reasons set out below, that the Local Plan is not sufficiently justified, is not effective and is not consistent with National Policy. It therefore fails to meet the legal tests of soundness.

The overarching aims and ambitions of the Spatial Hierarchy are generally supported. However, we have concerns that the approach adopted underutilises the role of existing sustainable settlements, including the Rural Service Centres, and places a significant overreliance on the delivery of new settlements and is not therefore sound because it has not taken full account of all the reasonable alternatives. Reasonable alternatives are discussed within the ‘Development Strategy Topic Paper’ (May 2022). It notes that the Arc impacts are not yet known and so the growth strategy focuses only on Bedford’s own growth requirements.
2.5 Through previous consultations, the following growth options were put forward:
- Option 1a – development in and around the urban area only
- Option 1b – sites within the urban area at enhanced density
- Option 2a: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south.
- Option 2b: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south, plus one new settlement.
- Option 2c: Development in and around the urban area, plus A421 transport corridor with rail-based growth, plus two new settlements.
- Option 2d: Development in and around the urban area, plus A421 transport corridor with rail-based growth – south and east, plus one new settlement:
- Option 3a: Development in and around the urban area, plus four new settlements.
- Option 3b: Development in and around the urban area, plus two new settlements, plus key service centres.
- Option 3c: Development in and around the urban area, plus two new settlements plus key service centres, plus rural service centres.
- Option 4: A421 transport corridor with rail-based growth, plus key service centres, plus rural service centres.
- Option 5: A421 transport corridor with rail-based growth, plus two new settlements.
- Option 6: A421 transport corridor with rail-based growth, plus two new settlements, plus key service centres, plus rural service centres.
- Option 7: Development in two new settlements, plus key service centres, plus rural service centres.
2.6 Within the topic paper, the Council consider that a reasonable alternative for the purposes of the NPPF test was an alternative that could provide dwelling growth within 10% of the required need. Option 2D was identified as a reasonable alternative.
2.7 As detailed in response to Policy DS3 and DS5, there seems an absolute reluctance by Bedford Borough to allocate any further additional growth at the Rural Services Centres despite the acknowledged available capacity and the benefit being that some proportionate growth would be delivered earlier in the Plan period rather than almost solely relying on the delivery of strategic sites. In the context of immediate housing need and with the current cost of living crisis, failure to deliver housing (both market and affordable) in settlements such as Turvey will result in more and more young people being forced out of the settlements in which they may currently live and continue to suppress natural household formation. Your attention is brought to the LPDF publication ‘The Housing Emergency’ (appended for information), which sets out key impacts of the housing crisis and demonstrates the need for increased housebuilding nationally. Key metrics demonstrating the scale and impact of the crisis include the increase of age of first time buyers from 27 in 2007 (in 26 it was 1997) to 34 in 2020. In addition, over the last 11 years the number of households renting has gone up 24%; during this time average rents have increased by 46%, far in excess of wage growth. Nationally there are 3.66 million concealed or overcrowded houses. 17.5 million people are impacted by the housing emergency, living in overcrowded, dangerous, unstable or unaffordable housing. 1 in 5 adults regard housing issues as having a negative impact on their mental health.
2.8 All settlements, but particularly sustainable settlements with a service offer, need proportionate and commensurate growth to ensure they do not age and stagnate.
2.9 Land east of Newton Lane, Turvey has shown that there would not be any adverse impact on the landscape and settlement character as a result of the site coming forward for development. In terms of the reduced ability for rural sites to be accessible to rail by active travel, it is important to note that some sites would be accessible by active travel, but more broadly they would be accessible by green travel through the ongoing transition to hybrid and electric cars, public transport and cycling. Moreover, due to an increased prevalence in home working and online deliveries, people are able to live more sustainably in what was traditionally considered to be a less sustainable location. The evidence which supports the Neighbourhood Plan confirms that the land East of Newton Lane is the best remaining available site within the village (Turvey Site Assessments and Allocations Report (April 2020).
2.10 The Plan and Strategy has a deliberate disregard of the role that Neighbourhood Plans should be playing in accommodating growth beyond their current period to 2030. Neighbourhood Plans should be policy bound to allocate an amount of growth up to 2040, as they were obliged to within the 2030 plan (see current policy 4S). NPPF Paragraph 66 sets out that Strategic Policies should “set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations”. Clearly to reflect the overall strategy as required by the NPPF, this must extend requirements up to 2040.

Comment

Representation ID: 10068

Received: 28/07/2022

Respondent: Richborough Estates

Agent: Fisher German LLP

Policy DS3(S) outlines the Council’s preferred approach to the delivery of housing, including the housing requirement and the delivery of housing over the Plan period. This includes a ‘stepped trajectory’, with the housing requirement to increase throughout the Plan period.
2.12 The Plan utilises the baseline Local Housing Need (LHN) as the housing requirement, equating to 27,100 dwellings over the Plan period. The PPG is clear that when establishing a housing requirement “the standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area… Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.” [our emphasis] (Paragraph: 010 Reference ID: 2a-010-20201216). Examples of scenarios which may justify an increase of housing requirement include growth strategies, the delivery of strategic infrastructure improvements or the requirement of an authority to take on unmet need from a neighbouring authority.
2.13 It is important to note that the PPG sets out that the consideration of whether uplifts to the housing requirement from LHN are necessary should be undertaken prior to and independently of any consideration of the ability of an area to meet that need.
2.14 The Plan discusses the housing requirement at Paragraphs 4.7 and 4.8 of the reasoned justification, albeit there is no discussion as to whether a higher housing requirement would be justified. The reasoned justification seems to challenge, informally, the LHN requirement. The Plan asserts that population would need to increase by 50,000 people with in-migration of more than 22,000 a year above existing trends to populate homes within Bedford at the standard method rate of 1,355 dwellings per year. However, it is significant to note, and acknowledged within the Plan, that Bedford Borough falls within the Oxford Cambridge Arc. Whilst there is a lack of clarity on the onwards direction of the top-down vision for the Arc, accelerated growth is likely to occur irrespective, led through economic demands which will drive an above historic trend rate of growth and migration. Furthermore, the Plan’s assumptions do not reflect a higher level of natural household formation rate, which may currently be suppressed due to a lack of housing or house prices more generally. Looking at historic rates of delivery could therefore become a self-fulfilling prophecy in that historic suppressed growth and/or suppressed household formation rates could be used to feed into justification for any subsequent strategies and serve to further suppress latent growth.

The LP2040 is not consistent with national policy because it does not plan for sufficient housing to meet future needs and does not proactively plan for any uplift as a result of the Arc Framework. It remains our view that a higher housing figure beyond the Local Housing Need Figure (which is intended to be a minimum figure within the PPG) should be planned for within the LP2040 in order to ensure a sound Plan.
Timing of housing growth
2.16 The stepped trajectory is proposed as follows:
• 5 years 970 dpa = 4,850 dwellings during the period 20/21-24/25
• 5 years 1,050 dpa = 5,250 dwellings during the period 25/26-29/30
• 10 years 1,700 dpa = 17,000 dwellings during the period 30/31-39/40
• 20 years average = 1,355 dwellings during period 20/21-39/40
2.17 The stepped trajectory as proposed results in the delivery of 4,850 dwellings in the first 5 years, 5,250 in the next 5 years (10,100 dwellings in the first 10 years). This then dramatically steps up to 1,700 dwellings per annum over the next 10 years equating to 17,000 dwellings. This is an almost 70% increase from the requirement in the latter years. To deliver this quantum of housing, the Council is relying on delivery of 600 dwellings per annum in the two new settlements.
2.18 Paragraph 4.27 of the emerging Plan advises that there is limited opportunity to bring forward additional sites in the early years of the Plan period due to the requirements for the delivery of strategic sites and the inter reliance on new development and the completion of major infrastructure projects which is why the stepped trajectory is required with significant growth pushed back to the latter part of the Plan period.
2.19 The approach oversimplifies matters and fails to recognise the latent capacity within the wider Plan area for existing sustainable settlements to deliver growth through smaller sustainable sites; which collectively could deliver a significant quantum of supply. Crucially, this supply can be front loaded in the Plan period, as sites within the smaller sustainable settlements are generally ‘shovel ready’, essentially meaning following allocation housebuilders are able to start quickly and deliver quickly. Paragraph 69 of the NPPF confirms this stating “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly” [our emphasis]. In addition to this, the delivery of such sites ensures the Council’s overall housing portfolio is varied, appealing to both a wide range of housebuilders and housing markets, thus ensuring the greatest choice and competition in the market, which ultimately drives delivery whilst protecting the continued over inflation of house prices.
2.20 The Council’s own evidence, which supported the preparation of the current Local Plan identified that the Rural Service Centres were able to deliver up to 150 dwellings in each settlement; the only Plan progressed a target of 25 to 50 dwellings to be delivered through Neighbourhood Plans. It is clear therefore that the existing settlements have capacity to accommodate additional growth through this Plan and that there is an opportunity to allocate sustainable sites in villages such as Turvey to support the delivery of housing and importantly, support the delivery of housing in the early part of the Plan period so that housing need can be met immediately and not delayed as currently proposed. Further, the Council have not sufficiently justified that there are any adverse impacts that would preclude the delivery of more units in such settlements, the delivery of which would enable expedited growth in the early years of the Plan period. This approach would further ensure a buffer should the strategic allocations/new settlements fail to deliver as anticipated, which we consider will be the case.
2.21 It is considered that the timing of delivery from the new settlements is overly ambitious and fails to reflect past delivery rates and evidence associated with brining forward similar sites.
2.22 The Wixams is an example. The site was first identified as a location for new housing in the late 1990s through the Elstow New Settlement: Planning and Development Brief, which was adopted in September 1999. The role of the document was to provide the framework for the submission of both the outline and reserved matters planning applications for the timely delivery of the settlement. The outline planning application for the core site was submitted in November 1999. In September 2005 the Council, in consultation with the land promoters, published and adopted The Wixams Strategic Design Guide SPD, to further guide and expedite delivery of the site. At this stage, it was anticipated that the entire development would be delivered within 15 years; this would have meant that the site would have been close to being fully built out in 2022.
2.23 However, despite this and the intervening 17-year period, the most recent monitoring report, confirms that only the initial phases have been completed in full with significant development still to be brought forward, despite construction commencing as far back as 2007 (15 years ago).
2.24 The Wixam’s highlights the complexity associated with the delivery of new settlements. Whilst the continued delivery of the site is of course promising, the difficulty in reaching this stage, on a site within Bedford Borough, should act as a severe warning as to the obvious pitfalls associated with strategic delivery of new settlements and should be factored into the Plan’s strategy and its over reliance on new settlements delivering the whole of the LHN moving forward.
2.25 Despite the significant delays associated with the delivery at Wixams, and also evidenced through other Local Plans which failed due over reliance on strategic sites (Charnwood, Rushcliffe, West Northamptonshire, etc), the Council have seemingly wed themselves to a strategy which once again, places an over reliance of strategic development, including new settlements. This approach is not justified and therefore not sound.
2.26 Start to Finish (Nathanial Lichfields) reinforces the examples above and sets out that applications for schemes over 500 dwellings are unlikely to make a contribution in the first five years. This is primarily due to the complex planning issues related to both the principle of development and the detail of implementation. Where applications have been determined more quickly than the average, this is as a result of matters being substantially addressed prior to submission which, when combined with the determination period, still adds up to the same amount of time; as the report states “there is rarely a way to short-circuit planning”.
2.27 The NLP report goes on to state:
“Planned housing trajectories should be realistic, accounting and responding to lapse rates, lead-in times and sensible build rates. This is likely to mean allocating more sites rather than less, with a good mix of types and sizes, and then being realistic about how fast they will deliver so that supply is maintained throughout the plan period. Because no one site is the same – and with significant variations from the average in terms of lead-in time and build rates – a sensible approach to evidence and justification is required.”
2.28 Whilst the site promoter may point to more optimistic timescales, a far more cautious and evidenced approach is required, with smaller and more deliverable sites allocated to deliver immediately, in order to ensure a sound Plan.
2.29 In relation to the Kempston Hardwick New Settlement (Policy HOU14), it is noted that the site has no current planning status according to the Council’s online mapping. Land Registry details confirm that the site is in multiple ownership. It is not clear to what extent the landowners are in agreement as to the delivery of the site or whether there is agreement between all parties to bring the site forward. As set out above and demonstrated through the complex history associated with the Wixams, strategic scale development is difficult to deliver and takes a significant amount of time. These difficulties are compounded when the development covers multiple land ownerships.
2.30 The Little Barford proposed allocation (Policy HOU19) appears to be within a single land ownership, but will still require significant time to deliver. The site is attached to St Neots, a town within neighbouring Huntingdonshire District. It is not clear whether Huntingdonshire have commented or agreed to this proposal. Clearly by locating development here, residents are most likely to work and spend in St Neots, not within Bedford. This therefore limits the benefits provided by this housing, without any compelling justification. Bedford’s LHN should be met, and development located where the need is. There is no compelling justification for the approach adopted by the Council and this is a significant concern.
2.31 In addition to the above, the viability of both sites is considered to be “challenging” at current costs and values as identified in the Borough Wide Viability Study, April 2022 (para 1.7). Neither site is viable or deliverable having regard to the Council’s planning policy requirements, including affordable housing (para 8.15). The Viability Study seems to dismiss this advising that developers will “rely on value growth through regeneration premiums and maturity factors” to deliver the sites “particularly given the significant upfront infrastructure costs associated with their delivery” (8.18). Such funding mechanisms may address the cashflow associated with phasing but will not address overall site viability. It is clear that the new settlements will struggle to deliver the required infrastructure and are unlikely to make any meaningful contribution, if any, to affordable housing need in the Borough. Reliance on these sites to deliver the Borough’s housing need, both market and affordable is unjustified.
2.32 Not only is the delivery of the new settlements not sound, the overall approach of directing almost all of Borough’s housing need to new settlements is also unjustified and fails to reflect the housing needs of the Borough as a whole. The proposed approach to the distribution of development fails to recognise the role smaller settlements, including the Rural Service Centres play. The delivery of housing to new settlements only fails to help young people remain in the settlements where they currently live, forcing younger people and families out of villages and contributing to a lack of social diversity within existing settlements. It also fails to support the vitality and viability of existing businesses and services in rural settlements, potentially risking their ongoing operation.
The approach also fails deliver a variety of housing to the housing market, preventing choice and competition as advocated in the NPPF and in the Letwin Review.
2.33 To ensure a sound Plan allocating suitable shovel ready sites in sustainable settlements such as Turvey to deliver in the early part of the Plan period will lessen the reliance on complex sites to deliver in the latter stages of the Plan bringing delivery targets down to more reasonable and deliverable levels. This revised approach would enable the Council will deliver more homes in the short term, securing jobs and helping to slow the inflation on house prices. There will be further social benefits through the delivery of affordable housing at a time when there is an acute need. It will help maintain the viability and vitality of existing and ensure choice and competition in the market for housing assisting delivery and market absorption. It will also ensure the Council can maintain a five-year housing land supply; which currently looks to be marginal even on adoption, if it can be demonstrated at all. This approach is a fundamental risk as the Plan cannot be found sound if there is no five-year housing land supply at adoption and will weaken the plans effectiveness if Paragraph 11 is regularly engaged. Allocating sufficient sites to ensure a robust five-year housing land supply at adoption and throughout the Plan is therefore considered to be a fundamentally benefit as the Plan cannot be adopted or reasonably function without it. If the Council are to continue with the proposed strategy, a comprehensive review and monitoring policy is required to ensure an immediate response should failures to meet appropriate milestones to deliver the Plan’s proposed housing trajectory occur.

Comment

Representation ID: 10070

Received: 28/07/2022

Respondent: Richborough Estates

Agent: Fisher German LLP

Emerging policy DS5 sets out where growth is to be located. It takes into account existing commitments together with the additional growth required to meet needs to 2040.
2.35 Emerging policy DS5(S) sets out the following distribution of housing growth:
Location - within the urban area, dwellings - 1200, Employment land (ha) - 5
Location - Strategic locations adjacent to the urban area which contribute to delivering the Forest of Marston Vale
incorporating the Bedford Milton Keynes Waterway Park and the Bedford River Valley Park, dwellings - 1500, Employment land (ha) - 7

Location -Growth locations on the A421 transport corridor and with the potential for rail based growth
- South of Bedford including new settlement (land parcels at Wixams, Shortstown and Elstow) - dwellings - 7,050, employment land (ha) 70
- Little Barford new settlement, dwellings 3,800, employmnet (ha) 4
- Other employment sites (50ha)

Location - Some development will take place beyond the plan period - dwellings - 400

location - Remaining rural area / villages (including Tuvey)
dwellings - Completion of sites previously allocated in local plans and neighbourhood plans

As detailed in response to Policy DS2 it is considered that the Council’s preferred strategy is over reliant on strategic sites and new settlements and is not sound. The approach proposed risks the delivery of the Plan as it is highly vulnerable to delayed or non-delivery. If one of the strategic sites does not deliver than the Plan will fail. Further, the approach adopted by the Council does not provide for choice and competition in the housing land market, which is likely to result in land price inflation given most the new housing is under the control of a limited number of landowners. Moreover, it largely rules out developments being brought forward by SME housebuilders, instead creating a monopoly of sites which can likely only be delivered by the larger housebuilders who will benefit from the economies of scale. As a result, there will also be a limited variety of houses realising to the market concurrently, slowing market absorption which will have high consequences in the latter years of the Plan period in terms of satisfying the Housing Delivery Test or demonstrating a five-year housing land supply.
2.37 The Plan states that there will continue to be growth in villages as a result of policies in the Local Plan 2030 which allocate growth to some Key Service Centres and Rural Service Centres however, no new/additional allocations are made in these villages in the Local Plan 2040.
2.38 The Plan instead advises that some Parish Councils may choose to allocate further sites for development in their Neighbourhood Plan; there is no requirement for this.

absence of small and medium growth in the rural villages misses an opportunity to deliver some of the housing requirement earlier on in the Plan period, rather than relying on some 10,000 dwellings to be delivered through new settlements which are significantly reliant on the delivery of large-scale infrastructure. As detailed in response to PolicyDS3 it is not an appropriate strategy to place such a reliance on strategic infrastructure to deliver such a large proportion of a housing need, particularly when the Council’s own evidence (Bedford Local Plan 2040 – Borough Wide Viability Study, April 2022) confirms that strategic sites will not be able to deliver the policy requirements, including affordable housing. Allocating small to medium sites, will ensure that the Borough’s housing needs are delivered, quickly, at policy compliant levels, delivering homes for all need which will not be achieved through the new settlements.
2.40 The evidence base which supported the previous Local Plan 2030 and initial drafts of that Local Plan confirmed that there is capacity within the smaller settlements to deliver a higher quantum of growth than was adopted through the Plan (up to 150 dwellings in each settlement rather than the 25 – 50 dwellings detailed within the Plan). The Plan states that it is not possible to provide additional housing in the early years of the Plan period, but this is not justified. Its own evidence has clearly demonstrated that settlements such as Turvey are suitable for a higher quantum of growth than currently being delivered under the adopted Plan.
2.41 The distribution of growth within the LP2040 is not effective. As detailed in response to Policy DS3, such a reliance on strategic sites is not deliverable over the Plan period (it is already noted in policy DS5(S) that 400 dwellings will be delivered beyond the plan period, before accounting for any delays in site assembly, unlocking and delivering the required infrastructure, and actually delivering homes on sites included within the plan period).

Comment

Representation ID: 10071

Received: 28/07/2022

Respondent: Richborough Estates

Agent: Fisher German LLP

Emerging policy DM5 requires an element of self-build plots to be provided on all sites other than developments of 1 – 4 dwellings. Land east of Newton Lane, Turvey has the potential to deliver up to 80 dwellings and theoretically, using the current draft policy, would be expected to provide 6 self-build plots.
2.43 There are issues with providing self-build plots within standard open market sites in terms of achieving a comprehensive design and issues with who is responsible for installing utilities (and to what point). There is also the risk that plots will sit undeveloped for long periods of time if they are not sold, whilst the required marketing and viability evidence is gathered in the result that demand is low or non-existent in a location.
2.44 The Self-Build and Custom Housebuilding Topic Paper (April 2022) identifies that through the current allocations and self-build projections, there is capacity to deliver 644 self-build plots. The Topic Paper also notes that there are currently 90 people on the self-build register. The provision of 644 self-build plots through the Local Plan 2040 is significantly above the current demand.
2.45 The policy should be re-worded to encourage the inclusion of self-build plots rather than require them. In its current form it is too prescriptive and will lead to issues with overall site completion. It will also lead to a significant surplus in the provision of self-build plots for which there is unlikely to be what would need to a 7-fold increase in demand over the plan-period (from 90 to 644). This surplus of self-build plots will lead to the Council using more of their valuable time assessing numerous marketing and viability reports in order to meet the requirements of Policy DM5 to seek to change them to standard market housing plots when it transpires that demand is low.