Object

Representation ID: 23675

Received: 12/03/2021

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The proportion of homes required to be affordable, and the adoption of space standards are both unsound as they have not be adequately justified.
Affordable housing
21. In the GNLP it is stated in paragraph 271 that the SHMA has identified need for 11,030 affordable homes between 2015 and 2038 – 28% of housing need identified at that point. However, the Greater Norwich Authority Monitoring Report (GNAMR) last year shows that between 2015/16 and 2017/18 a total of 1,209 affordable homes were delivered in the Greater Norwich area. This would mean that over the plan period there would be a need to deliver 9,281 affordable homes – around 23% of the housing requirement and 18% of expected supply. We recognise that only major development will be required to deliver new affordable homes and as such a higher percentage is required in policy to ensure needs are met. However, we have calculated on the basis of table 6 and appendix B of the GNAMR that the Councils expect to deliver 40,531 of the homes to be built in the remaining plan period will be on sites defined as major allocations2. This would mean that affordable housing needs was 23% of planned supply. If supply in 2018/19 of 724 new affordable homes is taken into account this reduces to 21%. It would appear on the basis of the evidence presented that the affordable housing policy is likely to deliver an oversupply of affordable homes in the Greater Norwich area and that the requirement in Policy 5 should be reduced accordingly.

Affordable home ownership
22. This policy states that the mix of tenure for affordable homes will include 10% for affordable home ownership. This policy is not consistent with paragraph 64 of the NPPF which expects 10% of all homes provided on major development to made available for affordable home ownership. It is also important to note that this 10% forms part of the affordable housing provision. The only reason why this national policy should not be adopted by the Council are if it application would exceed the overall level of affordable housing required for an area or significantly prejudice the Councils ability to meet the needs of specific groups should this requirement not be applied. Unless compelling evidence is provided to the contrary the GNLP should therefore be amended to reflect national policy.

Space standards
23. The Councils are seeking to adopt the national described space standards across the Greater Norwich Area. Whilst the HBF share the Council desire good quality homes delivered within Watford it is essential that the Council provide the necessary justification, as required by footnote 46 of paragraph 127 of the NPPF which states:
“Policies may also make use of the nationally described space standard, where the need for an internal space standard is justified.”
24. It is important the space standards are justified as space standards can, in some instances, have a negative impact upon affordability issues and reduce customer choice. In terms of choice, for example, some developers will provide entry level two, three and four-bedroom properties which may not meet the optional nationally described space standards, but which would allow on lower incomes can afford a property which has their required number of bedrooms.
25. Given the poor affordability of property across the Greater Norwich area it is important that the Council can provide, in line with PPG, robust evidence that there is a need to introduce the optional space standards – that these standards are a must have rather than a nice to have policy. However, we could not find any evidence prepared by the Councils to suggest that development below space standards is an endemic concern within the Greater Norwich area. As such we would suggest that the requirement to meet NDSS is deleted from the plan. This would give the Council greater flexibility to maximise the number of sites that are developable as well as extending consumer choice to more households.

Self-Build/ Custom Housebuilding
26. Whilst the HBF support the encouragement of self-build housing through local plans, we do not consider the requirement for all development of 40 or more dwellings to set aside 5% of homes on site to be delivered through serviced plots for self-build and custom housebuilding to be justified or consistent with national policy.
27. As the Council will be aware the proposed policy must be based on robust evidence of both the demand for self-build plots and a consideration as to the impact on viability of this policy. With regard to the evidence on needs the states that there are currently 113 applicants on the self-build register across Greater Norwich.
28. Firstly. this does not suggest that there is a high level of demand for self-build plots that requires five percent of all market homes on sites of over 40 units to be offered as plots to self-builders. The Council will therefore need to consider how many homes their policy is likely to provide and whether it is proportionate to the evidence. It is also necessary for the Council to indicate how many self-build homes have been granted permission since the requirement to maintain a self-build register was introduced. This will give a clearer indication as to how many plots are provided as windfall and will need to be taken into account in assessing how demand for self-build plots can be met.
29. Secondly, the Council will also need to consider the robustness of their self-build register as an evidence base indicating demand for self-build plots. This is vital as the data on self-build registers is often flawed in that it does not consider whether individuals on such registers are on other registers in neighbouring areas and whether those on the list are still seeking a self-build plot. If the register has not been reviewed in this manner, we would suggest this is undertaken prior to the submission of the local plan.
30. Thirdly, it is important to recognise that paragraphs 57-024 and 57-025 of the PPG sets out a variety of approaches that need to be considered – including the use of the Council’s 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. We would suggest that in the first instance rather than place additional burdens on house builders for the provision of self-build plots it should utilise its own land or seek to engage with landowners to identify suitable sites on which to deliver serviced self-build plots. Therefore, on the basis of the evidence presented we would suggest that there is, at present, insufficient justification for that 5% of plots on developments of 40 units or more should be provided for self-build or custom housebuilding.