Object

Representation ID: 21911

Received: 12/03/2020

Respondent: Home Builders Federation

Whilst the HBF supports the encouragement of self-build housing through the local plan, we do not consider the requirement for sites of over 40 dwellings or more to provide 5% of plots on as serviced plots for self and custom house building to be justified or consistent with national policy. Whilst we recognise that Local Planning Authorities now have a duty to promote self-build housing, we have three concerns with the Councils’ approach. Firstly, we consider the policy to be inconsistent with the third bullet point of paragraph 57-025 of PPG. This 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 landowners to bring forward plots.
Secondly, we do not consider the Council to have looked at sufficient options with regard to how it can provide plots to support self-builders. 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 57-014 of the PPG which sets out the need for Council’s to consider how they can support the delivery of self-build plots through their housing strategy, land disposal and regeneration functions. However, it would appear that the Council is seeking to place the burden for delivery of self-build plots on larger sites without any evidence that an investigation into alternative approaches have taken place. We would suggest that it should conclude such an investigation before requiring the provision of service plots on larger sites.
Finally, we do not consider the evidence to provide the necessary justification for 5% of plots to be provided as self-build units. Paragraph 250 notes that at present there are 113 people on the self-build register for the Greater Norwich Area. Given the number of sites which would be required to meet this policy then it is likely that the number of plots will far exceed demand.
In addition, there have always been concerns that self and custom build registers alone do not provide a sufficiently robust evidence base against which to assess needs with significant potential for double counting with other areas and no review as to whether those on the list are still interested in self-building or are able to self-build. However, the Government has recognised this situation and amended PPG to include paragraph 57-011 which requires additional data from secondary sources to be considered to better understand the demand for self-build plots. In particular we are concerned that planning policies, such as the ones proposed in the draft local plan, will deliver plots on major house building sites whereas the demand for self-build plots may be for individual plots in more rural locations. Without the necessary evidence to show that there is demand for self-build plots on such sites the proposed approach in policy 5 cannot be considered either justified or effective and should be deleted.
A more effective approach to meeting the needs of self-builders is through policy 7.5 and it is a policy approach we support. However, we would amend this policy to allow developments of up to 5 dwellings. This would provide greater scope for development to meet the needs of those residents wishing to self-build.