Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24341

Received: 06/12/2018

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Whilst we support the encouragement of self-build custom housebuilding through the local plan, we do not consider the requirements in DHG6 to be justified or consistent with national policy. We could find no information on the level of demand for such homes. If the Council is to have a requirement for sites to provide plots for self-builders, this must be based on evidence that there is a realistic chance that such plots will be taken up.

Given that the likely demand for such plots will be limited we would suggest that rather than require 5-10% of plots on 20+ units the Council would be best served by seeking alternative approaches to their delivery. Government guidance on this issue is more focussed on engaging with land owners to identify appropriate sites. The approach taken by the Council moves beyond encouragement and requires land owners to bring forward plots.

In addition, the PPG sets out a variety of approaches that need to be considered - including the use of Councils' own land. We could not find any evidence that the Council have examined these options and have instead looked to place the burden of their duty on to the house building industry.

Full text:

DHG6: Self Build and Custom Housebuilding

The policy unsound as it is inconsistent with national policy and unjustified
Whilst we support the encouragement of self-build custom housebuilding through the local plan, we do not consider the requirements in DHG6 to be justified or consistent with national policy. Firstly, we could find no information on the level of demand for such homes. The Council refer to this register in the Local Plan and in the Council's most recent Authority Monitoring Report but provide no indication as to how many people have registered an interest. There is clearly concern that there may be an over provision of such sites within the Borough given the Council's decision to reduce the requirement on strategic sites. If the Council is to have a requirement for sites to provide plots for self-builders, this must be based on evidence that there is a realistic chance that such plots will be taken up.
Given that the likely demand for such plots will be limited we would suggest that rather than require between 5% and 10% of plots on all sites of over 20 units the Council would be best served by seeking alternative approaches to their delivery. In fact, we consider Government guidance on this issue to be more focussed on engaging with land owners to identify appropriate sites rather than requiring plots to be provided on by the housing building industry for self-builders. Paragraph 57-025 of PPG, for example, outlines that the Council should engage with landowners and encourage them to consider self-build and custom housebuilding. The approach taken by the Council moves beyond encouragement and requires land owners to bring forward plots. As such we consider the policy to be inconsistent with current guidance.

In addition, paragraph 57-024 of the PPG sets out a variety of approaches that need to be considered - including the use of their own land. This is reiterated in para 57-14 of the PPG which sets out the need for Council's to consider how they can support the delivery of self-build custom housebuilding plots through their housing strategy, land disposal and regeneration functions. We could not find any evidence that the Council have examined these options and have instead looked to place the burden of their duty on to the house building industry.

Recommendation

We recommend that the policy is amended to outline that the Council will work with land owners and developers to encourage the provision of land and plots to support self-build and custom housebuilding.