Question 32: Do you support, object or have any comments relating to the approach to Self/Custom-Build?

Comment

Representation ID: 20103

Received: 25/02/2020

Respondent: RJ Baker & Sons

Agent: Cheffins

See text

(Summary - entered by GNLP team
- General support for the idea of an element of self build plots
- Typically these need to be reasonably generously sized plots
- There is a relationship between housing mix and the potential for self build
The threshold of 40 dwelling developments needs further justification)

Comment

Representation ID: 20852

Received: 13/03/2020

Respondent: Welbeck Strategic Land III LLP

Agent: Bidwells

The majority of sites that are identified to meet the housing growth targets are likely to be in excess of 40 dwellings. This is likely to provide substantially more than units than the 113 people on the self and custom build register in the Greater Norwich Area (2018/19).

The inclusion within the policy that for self and custom build units will be subject to evidence of need is supported. The policy should recognise that as well as the self build / custom build register, data from secondary sources should be considered to understand demand for self and custom build plots.

Object

Representation ID: 21190

Received: 16/03/2020

Respondent: Hopkins Homes, Persimmon Homes and Taylor Wimpey

Agent: Bidwells

The proposal to require ll developments of 40+ dwellings to provide 5% of plots as serviced self/custom build plots is considered inappropriate and unjustified. The proposed policy will result in a level of supply which significantly exceeds the demand. Furthermore, particularly for the larger sites, it will have a significant impact on continuity in delivery, which is critical for both the developers and for the Councils in ensuring they are able to maintain a 5-year land supply.

Object

Representation ID: 21214

Received: 16/03/2020

Respondent: Kier Living Eastern Ltd

Agent: Bidwells

The proposal to require all developments of 40+ dwellings to provide 5% of plots as serviced self/custom build plots is considered inappropriate and unjustified. The proposed policy will result in a level of supply which significantly exceeds the demand. Furthermore, particularly for the larger sites, it will have a significant impact on continuity in delivery, which is critical for both the developers and for the Councils in ensuring they are able to maintain a 5-year land supply.

Object

Representation ID: 21325

Received: 16/03/2020

Respondent: Lanpro Services

Agent: Stephen Flynn

Instead of having a requirement for at least 5% of plots on residential schemes over 40 dwellings to provide serviced self/custom build plots we suggest that a policy approach similar to that in the South Northamptonshire Local Plan (which has gone through examination but is not yet adopted) should be pursued. This offers a more flexible approach that is more appropriate to the custom build market.

Object

Representation ID: 21409

Received: 16/03/2020

Respondent: Glavenhill Ltd

Agent: Stephen Flynn

Instead of having a requirement for at least 5% of plots on residential schemes over 40 dwellings to provide serviced self/custom build plots we suggest that a policy approach similar to that in the South Northamptonshire Local Plan (which has gone through examination but is not yet adopted) should be pursued. This offers a more flexible approach that is more appropriate to the custom build market.

Comment

Representation ID: 21583

Received: 16/03/2020

Respondent: Hingham Town Council

Whilst the Council believes that there should be no development until the present allocations have been built on it does believe that planners should give careful consideration to allowing more self build across the district and that they should be willing to allow some experimental green initiative building that takes account the need to address climate change/the climate emergency

Object

Representation ID: 21702

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

Persimmon Homes (Anglia) acknowledge the role that self-build housing plays in meeting the needs of groups with specific housing requirements. However, the imposition of a requirement to provide 5% of plots on residential proposals of 40 dwellings or more is not considered to be necessary nor the most appropriate mechanism for ensuring that sufficient planning permissions are granted to meet the demand for self-build and custom housebuilding across the housing area.

Support

Representation ID: 21758

Received: 16/03/2020

Respondent: Brown & Co

We support the approach to self/custom-build housing.
The proposed new settlement Honingham Thorpe would provide fully serviced plots for those looking to design and/or build their own home.

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.

Comment

Representation ID: 22324

Received: 16/03/2020

Respondent: Hopkins Homes

Whilst Hopkins Homes understands the Government’s desire to promote the development of housing via Self and Custom-Build, it is common knowledge that the vast majority of demand for such housing is upon smaller and individual development sites in predominantly rural locations, rather than as a small portion of a larger development site.

To this end, it is suggested that specific smaller sites in rural locations should be allocated for such uses, rather than seeking to require such provision as a portion of larger sites.

Comment

Representation ID: 22338

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

5. POLICY 5 – HOMES
5.1 Policy 5 identifies that proposals should address the need for homes for all sectors of the community having regard to the latest evidence which is to be supported.
Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.
Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. None were built in South Norfolk leaving a residual need for 679. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
5.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure. 5.14 The site at Land off Station Road, Hethersett offers a suitable location for such provision and provides sufficient scope to address a significant element of the residual need for bedspaces in a care home and/or sheltered/extra care accommodation within a care village.
5.15 The Policy requires proposals for major housing development to provide;
“...at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.16 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.17 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.
Self/Custom-Build
5.18 There does not appear to have been any assessment of the need for self/custombuild housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
5.19 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
5.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed.
5.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Comment

Representation ID: 22375

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

5. POLICY 5 – HOMES
5.1 Policy 5 identifies that proposals should address the need for homes for all sectors of the community having regard to the latest evidence which is to be supported.
Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.
Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
5.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure.
5.14 The Policy requires proposals for major housing development to provide; “..at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.15 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.16 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.
Self/Custom-Build
5.17 There does not appear to have been any assessment of the need for self/custombuild housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
5.18 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
5.19 Pigeon are supportive of providing self-build plots and their proposals at Diss allow for such development. Indeed, the Diss site allows for a discrete area of 10 self-build plots allowing for mutual support amongst the self-build community and bespoke design solutions to come forward.
5.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed. 5.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. As such, provision for approximately 10 self-build plots is made as part of the proposal on land to the east of Walcot Green Lane. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Comment

Representation ID: 22435

Received: 16/03/2020

Respondent: Gladman Developments

Question 32: Self Build Plots 6.3.1 Policy 5 outlines a requirement for all housing sites (allocated or windfall except for flats / apartments) which comprise 40 or more dwellings to set aside a minimum of 5% of the net developable area for serviced plots to be offered for self-build.
6.3.2 Gladman objects to the inclusion of a fixed percentage requirement in relation to the provision of serviced self-build plots.
6.3.3 Whilst recognising the role attributed towards self-build in national planning policy as a source of housing land supply, we do not consider the inclusion of a requirement for all housing schemes over 40 dwellings to commit to onsite provision forms the most effective approach of responding to this source of housing need.
6.3.4 Gladman believes that those wishing to bring forward a self-build or custom build house are unlikely to wish to do this alongside a large-scale housing development. Consequently, rather than including a strict requirement for this provision Gladman would recommend the policy encourages the consideration of the provision of self-build plots in locations where the demand exists.
6.3.5 Gladman would prefer to see policy which seeks self-build plots being considered on an ad hoc basis as windfall rather than as a percentage requirement of larger development schemes. We consider this approach to be more in line with the wants and needs for the individuals seeking the plot and the developer’s requirements for larger sites.
6.3.6 Should a percentage approach be taken forward, the requirement should be supported by and proportionate to clear and robust evidence of this source of housing need. Gladman recommends that any policy requirement in relation to self-build housing has an element of flexibility built in to allow for negotiation over self-build plots on the basis of viability to ensure that site delivery is not delayed or prevented from coming forward. Any specific requirement to include self-build plots should be tested through the Council’s viability assessment of the Local Plan policies to ensure that the cumulative impacts of all proposed local standards and policy requirements do not put the implementation of the Plan as a whole at risk.
6.3.7 Gladman notes that the proposed policy does include a mechanism which allows developers the opportunity after 12 months to either continue to market the plots for self-build or to revert back to them being delivered as part of the wider market housing scheme. Gladman supports the inclusion of this policy mechanism as it is necessary to ensure that housing land is not unnecessarily prevented from being brought forward. This helps to provide flexibility and helps to ensure that the required housing is delivered. If there is genuine demand for self-build housing it is likely that these plots would be brought forward relatively quickly.

Comment

Representation ID: 22523

Received: 16/03/2020

Respondent: Broadland Green Party

Para 251: Support the general policy to facilitate self-build schemes but to also add support for self-build cooperative schemes to build affordable homes. There are very inspiring case studies of cooperative housing schemes that have multiple benefits :
• Pooling of resources & capital - stronger together.
• Community involvement with the process from finding a site to delivery.
• Design of homes to fit wants, needs and aspirations.
• Select build method & contractors.
• Significant cost savings - sometimes as much as 40%.
• The building of relationships with neighbours and the wider community.

Comment

Representation ID: 22639

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: Bidwells

Comments
The objective of providing self and custom build is generally supported. However, the proposed threshold (5% of plots on residential proposals of 40 dwellings or more) is questioned, given that it would result in the delivery of substantially more self build and custom build units than for which there is an identified need. For example on large strategic sites, such as that covered by Policy GNLP0337, this would result in provision of approximately 70 self and custom build units.
The majority of sites that are identified to meet the housing growth targets are likely to be in excess of 40 dwellings. If, as a very broad calculation, the threshold is applied to only the new allocations identified in the draft GNLP (7,840 homes), this would result in the provision of approximately 392 units self and custom build units. This is substantially more than the 113 people on the self and custom build register in the Greater Norwich Area (2018/19). The figure would substantially increase were the threshold applied to existing commitments which are yet to granted planning permission.
Therefore, the inclusion within the policy that the requirement for self and custom build units will be subject to evidence of need is supported. The policy should, in accordance with the PPG, recognises that as well as the self build / custom build register, additional data from secondary sources should be considered to better understand the demand for self and custom build plots.

Object

Representation ID: 22682

Received: 16/03/2020

Respondent: Mrs Nicole Wright

Policy 5: Homes

We support this policy except for the part on Self/ Custom- Build Homes

This part of the policy does not address the real need to respond to the demand and choice of bespoke homes in the locations where they are needed.

It does not show a positive, sound and justified approach in the spirit of the NPPF. (Paragraph 16 of the NPPF)

An approach more akin to the Breckland strategy and consistent with the NPPF would be more appropriate.

Paragraph 251 of the Draft GNLP states that: “In line with the Right to Build and the NPPF, self and custom-build housing delivery is promoted through the GNLP on a range of sites. This policy sets a requirement for larger sites to provide self and custom-build plots. The thresholds have been set to ensure that plots are provided across Greater Norwich. Policies 7.4 and 7.5 also promote self and custom-build on smaller scale windfall sites. Overall, this comprehensive approach will both increase the supply of housing in urban and rural areas and provide opportunities for small and medium enterprises to build houses, as well as for self-build.”

However, Draft Policy 7.4 provides no guidance or criteria in relation to self-build and custom housebuilding.

Draft Policy 7.5 needs to allow for consideration of new self/custom-built homes being adjacent to what it describes as “a recognisable group of dwellings”. Please refer to the new Breckland Local Plan (adopted November 2019)



(For refrence:
Policy HOU 05 of the Breckland Local Plan (adopted November 2019)

Policy HOU 05 - Small Villages and Hamlets Outside of Settlement Boundaries
Development in smaller villages and hamlets outside of defined settlement boundaries will be limited, apart from where it would comply with other policies within the development plan* and if all of the following criteria are satisfied:
1. The development comprises of sensitive infilling and rounding off of a cluster of dwellings with access to an existing highway;
2. It is of an appropriate scale and design to the settlement;
3. The design contributes to enhancing the historic nature and
4. connectivity of communities; and
5. The proposal does not harm or undermine a visually important gap that
6. contributes to the character and distinctiveness of the rural scene.
Opportunities for self-build dwellings which meet the criteria set out above will be supported.
Farmsteads and sporadic small scale groups of dwellings are considered as lying in the open countryside and are not classed as small villages and hamlets. These, and isolated locations in the countryside, are unlikely to be considered acceptable.)

The GNLP Homes Objective is defined in the Draft Plan - To enable delivery of high-quality homes of the right density, size, mix and tenure to meet people's needs throughout their lives and to make efficient use of land.

We support this objective

However, the Monitoring Framework, Indicator Code GNLP 39 and indicator demonstrates the shortcomings of this Draft Policy in identifying the sole indicator for monitoring custom housebuilding as:
‘Percentages of sites of 40 dwellings or more (excluding flats) where 5% of plots are provided for custom build.’

Comment

Representation ID: 22702

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
48. The requirement for self/custom-build within Policy 5 – Homes of the Draft Strategy requires 5% of plots on residential proposals of over 40 dwellings to be serviced self/custom build plots unless a lack of a need can be demonstrated or plots have been marketed for 12 months and not sold. This approach is considered to represent too high a proportion and if implemented would deliver significantly more plots than there is currently demand for. Currently there are 113 people on the self and custom build register in the Greater Norwich Area (2018/19). This is not a significant number of plots to identify and if some of the reasonable alternative sites were reviewed, a range of smaller dedicated self and custom build sites could potentially be allocated across the Plan area. These sites could also contribute to site allocations of less than 1 ha, which would equate to the need to find approximately six sites to meet the demand on the current register rather than requiring inclusion on larger sites.
49. Furthermore, self/custom-build units are considered slower to deliver on larger sites when they are expected to be brought forward alongside mainstream construction. If specific sites were allocated, construction activities could be managed phased without conflicting with mainstream construction which would demonstrably deliver new homes at a much faster rate than can be achieved through the self and custom build route. As such, it would be our recommendation that the requirement for such plots should be based on a locally identified need or demand rather than blanket approach of 5% across the Plan area with the identification of specific self and custom build site allocations.

Object

Representation ID: 22792

Received: 16/03/2020

Respondent: Strutt & Parker LLP

The requirement for self/custom-build within Policy 5 – Homes of the Draft Strategy requires 5% of plots on residential proposals of over 40 dwellings to be serviced self/custom build plots unless a lack of a need can be demonstrated or plots have been marketed for 12 months and not sold. This approach is considered to represent too high a proportion and if implemented would deliver significantly more plots than there is currently demand for. Currently there are 113 people on the self and custom build register in the Greater Norwich Area (2018/119). This is not a significant number of plots to identify and if some of the Reasonable Alternative sites were reviewed, a range of smaller dedicated self and custom build sites could potentially be allocated across the Plan area. These sites could also contribute to site allocations of less than 1 ha which would equate to approximately six sites, to meet the demand on the current register.

Furthermore, self/custom-build units are considered slower to deliver on larger sites when they are expected to be brought forward alongside main stream construction. If specific sites were allocated, construction activities could be managed phased without conflicting with mainstream construction which would demonstrably deliver new homes at a much faster rate than can be achieved through the self and custom build route. As such, it would be our recommendation that the requirement for such plots should be based on a locally identified need or demand rather than blanket approach of 5% across the Plan area with the identification of specific self and custom build site allocations.

Object

Representation ID: 22808

Received: 16/03/2020

Respondent: Peter Rudd

Agent: Pegasus Planning Group

the policy imposes a blanket requirement of at least 5% self/custom build plots on residential proposals of 40 dwellings or more. Such an approach does not appear to be supported by any evidence to demonstrate that there is a need for such a scale of provision and does not allow for the specifics of an individual site to be considered (e.g. is it a suitable site, does it impact on viability?). It is wrong to assume that those in search of self/custom build plots wish to be located within a wider site for housing.

Furthermore, the policy allows for the requirement to be avoided if the developer can prove that there is not a need for it. That is entirely the wrong way road – the policy requirement must be justified in the first place and the relevant Local Planning Authorities are responsible for holding a register of those searching for such plots. Such registers need to be regularly updated and cross referenced with neighbouring registers to eliminate double counting. This is not the responsibility of an individual developer and so it is wrong to identify this as a reason to overcome the policy requirement.

We suggest that the policy be amended to encourage the provision of such plots rather than require them and cross-refer to a policy intention to monitor the supply of such plots against demand with associated future policy amendments should this be required. Instead, we consider that the delivery of self/custom build plots would be more appropriate as a requirement for windfall sites under policy 7.5.

Comment

Representation ID: 22887

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Comments.
The objective of providing self and custom build is generally supported. However, the proposed threshold (5% of plots on residential proposals of 40 dwellings or more) is questioned, given that it would result in the delivery of substantially more self build and custom build units than for which there is an identified need.

The majority of sites that are identified to meet the housing growth targets are likely to be in excess of 40 dwellings. If, as a very broad calculation, the threshold is applied to only the new allocations identified in the draft GNLP (7,840 homes), this would result in the provision of approximately 392 units self and custom build units. This is substantially more than the 113 people on the self and custom build register in the Greater Norwich Area (2018/19). The figure would substantially increase were the threshold applied to existing commitments which are yet to granted planning permission.

Therefore, the inclusion within the policy that the requirement for self and custom build units will be subject to evidence of need is supported. The policy should, in accordance with the PPG, recognises that as well as the self build / custom build register, additional data from secondary sources should be considered to better understand the demand for self and custom build plots. For example, the demand for self / custom build units may be for stand alone or small development opportunities, not the large estate style developments that would be required to deliver self / custom build units under the policy.

Object

Representation ID: 22977

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

Whilst our client acknowledges the statutory requirement for the Councils’ to promote self-build housing they believe that requiring at least 5% of plots on residential proposals of 40 dwellings or more as serviced self/custom-build plots is not the right approach. Moreover, it is questioned whether the Council’s approach would accord with national policy, specifically paragraph 57-025 of PPG, which outlines that Councils should ‘encourage’ developers to consider self-build and custom housebuilding.

On larger sites the cost of delivering infrastructure can often impact negatively on the percentage of affordable housing that is delivered. A requirement for self-build plots, which generate less revenue for developers than finished homes, has the potential to further reduce the level of affordable housing on these large sites. Our client is committed to the delivery of affordable housing on their site but recognise that for any scheme to come forward it has to be commercially viable. Therefore, they are concerned about the negative impact upon viability that providing 5% of plots as serviced self/custom-build plots on sites of 40 dwellings or more will have on the delivery of affordable housing on sites across the Greater Norwich area. It seems contrary to the Councils’ wider aim to deliver more affordable homes that the needs of people with the financial means to build their own homes could be prioritised over the needs of low earning residents who cannot afford to buy or rent homes in the Greater Norwich area.

Moreover, the need for self-build plots can be often be overstated by self-build registers. In particular, many registers are rarely updated to remove those no longer in need of a self-build plot or to assess whether there is double counting across registers. Given the attractiveness of the Greater Norwich area as a place to live and work there is also the concern that the Councils’ self-build registers have been inflated by people with aspirations to live in the area, meaning that there is an artificially high number of people on the registers compared to neighbouring authorities. With this in mind, it will be important for the Councils to ensure that their evidence on the need for self-build homes has been effectively reviewed if it is to offer a robust position on the demand for this type of development. Especially given the potential number of plots that could be secured across the entire Greater Norwich area on sites of 40 dwellings or more if Policy 5 were adopted. Based on the fact that there are 113 people on the self-build register for the Greater Norwich Area it is likely that the number of plots that will be delivered on sites of 40 dwellings or more will far exceed demand.

Our client believes that rather than targeting major developments the Councils should prioritise self-build plots on the edges of settlements. These more rural locations are predominantly where self-builders would prefer to live rather than on residential estates. It will also mean that sites come forward as and when they are needed based on market demand, rather than in large numbers on larger development sites, which might make them more difficult to market and sell within the 12 months identified in Policy 5. Further comments on how the Councils could achieve this are provided in response to question 47. It is recommended that the Councils prioritise the delivery of self-build plots on the edges of development boundaries where the development of small sites and residential gardens for self-build homes are less likely to result in wider harm. By prioritising self-build plots through Policy 7.5 the Councils will ensure that the development of sites on the edge of development boundaries help to boost the supply of housing, addressing the Councils’ self-build registers and provides a continued source of employment for small builders and tradespeople.

Comment

Representation ID: 23027

Received: 13/03/2020

Respondent: Bidwells

Comments.
The objective of providing self and custom build is generally supported. However, the proposed threshold (5% of plots on residential proposals of 40 dwellings or more) is questioned, given that it would result in the delivery of substantially more self build and custom build units than for which there is an identified need.

The majority of sites that are identified to meet the housing growth targets are likely to be in excess of 40 dwellings. If, as a very broad calculation, the threshold is applied to only the new allocations identified in the draft GNLP (7,840 homes), this would result in the provision of approximately 392 units self and custom build units. This is substantially more than the 113 people on the self and custom build register in the Greater Norwich Area (2018/19). The figure would substantially increase were the threshold applied to existing commitments which are yet to granted planning permission.

In addition, consideration needs to be given to local need within a specific area. For example, on sites in Key Service Centres, such as that covered by Policy GNLP0520, this would result in provision of approximately 10 self and custom build units. This may be substantially more than the local need.

Therefore, the inclusion within the policy that the requirement for self and custom build units will be subject to evidence of need is supported. The policy should, in accordance with the PPG, recognises that as well as the self build / custom build register, additional data from secondary sources should be considered to better understand the demand for self and custom build plots. For example, the demand for self / custom build units may be for stand alone or small development opportunities, not the large estate style developments that would be required to deliver self / custom build units under the policy.

Comment

Representation ID: 23047

Received: 16/03/2020

Respondent: Hingham Town Council

Whilst the Council believes that there should be no development until the present allocations have been built on it does believe that planners should give careful consideration to allowing more self build across the district and that they should be willing to allow some experimental green initiative building that takes account the need to address climate change/the climate emergency.

Object

Representation ID: 23145

Received: 16/03/2020

Respondent: Hopkins Homes

Agent: Bidwells

The proposal to require all developments of 40+ dwellings to provide 5% of plots as serviced
self/custom build plots is considered inappropriate and unjustified. The supporting text indicates that at
present there are 113 people on the Self Build Register in the Greater Norwich Area. The proposed
policy will result in a level of supply which significantly exceeds the demand. Furthermore, particularly
for the larger sites, it will have a significant impact on continuity in delivery, which is critical for both the
developers and for the Councils in ensuring they are able to maintain a 5-year land supply.
In addition, it may make it difficult to achieve a well-integrated development from a design perspective.
Self/Custom Build plots should be secured on a site-by-site basis, dependent on local need at the time
of the development, or alternatively an exception site approach could be taken to stimulate supply.

Comment

Representation ID: 23172

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Self/Custom-Build
6.17 There does not appear to have been any assessment of the need for self/custom-build housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
6.18 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
6.19 Pigeon are supportive of providing self-build plots and their proposals at Reepham allow for such development.
6.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed.
6.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Comment

Representation ID: 23197

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

Orbit Homes does not object to setting a percentage requirement for self/custom-build dwellings in principle, but consider that any requirement set needs to be sufficiently evidence based. The Councils’ self-build registers should provide a broadly accurate indication of demand for self-build plots (although there may be some duplication with people registering in more than one authority) and also of the type of plots in demand. This data should be used to inform the policy. 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. We are also aware from other LPA’s self-build registers that the actual demand for self-build plots has been for individual plots in rural locations, as opposed to plots on suburban housing estates. We therefore recommend that in addition to reviewing the percentage requirement, additional flexibility is allowed for the development of self/custom-build dwellings on sites adjoining existing settlements.