Bloor Homes do not object to the overarching objective of Policy H5, as it seeks to secure good quality housing design and maximise the efficient use of land by optimising the density of development on sites that are accessible to a full range of local services and facilities.

Housing Standards
However, the requirement in Part 1b of the policy for developments to meet the Nationally Described Space Standard (NDSS) has not been appropriately justified. The Written Ministerial Statement dated 25th March 2015 confirms that "the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG". Therefore, if the Council wishes to adopt the NDSS up to date evidence of local need, together with assessments of the cumulative impact of the policy on viability, the implications of costs to being passed on to homebuyers, and the potential impact development delivery rates must be provided. That evidence has not been provided and the imposition of this blanket requirement has not, therefore, been justified in accordance with the requirements of the National Planning Practice Guidance (NPPG Paragraph: 020 Reference ID: 56-020-20150327) .

Similarly the prescriptive blanket approach to the provision of accessible and adaptable compliant homes in Part 3 of the policy has not been appropriately justified.

Mix
The emphasis in Part 2 of the policy for a flexible approach to the determination of housing mix that is informed by up to date evidence is welcomed and, indeed, is critical in order to reflect changing need across the District and over the plan period.

However, paragraph 50 of the NPPF states that in order to deliver a wide choice of high quality homes, widen the opportunities for home ownership and create sustainable, inclusive and mixed communities, planning authorities should consider both the needs of different groups and local demand for such. It is, therefore, essential that the difference between need and demand is recognised in the Submission Plan, as for instance whilst the need arising from smaller households might be for smaller properties, the actual demand is commonly still for larger properties. This is not surprising as the benefits to smaller households of having more flexible living accommodation in both the short and long terms are clear, and ultimately more sustainable.

This point is acknowledged in the HEDNA (Leicester and Leicestershire Authorities - Main Report January 2017). Paragraph 8.36 states that the conclusions on the mix of market housing are strategic and goes on to state that care should be taken in "applying these prescriptively to individual development sites, where consideration should be given to the mix of housing locally, the setting of the site and character of the area, and local demand evidence."

Self Build
It is acknowledged that self-build and custom house building is an element of the Government's housing strategy. However, the Council's approach to self / custom build should be to increase the total amount of new housing developed by supporting development on small windfall sites as well as allocating more small sites rather than by setting a restrictive policy requirement for inclusion of such housing on larger allocated sites. Indeed the Submission Plan itself acknowledges that only 57 people had registered an interest in self-build and custom house building plots on the Council's website. Notably, those registered are not required to be means tested and, therefore, in reality the demand is likely to be significantly lower. Moreover, the requirement has not been justified or tested in terms of the potential impact on the deliverability of development schemes as required by the NPPF.


Conclusion
These matters will have a critical affect on the viability of new housing development in the District, and the deliverability sustainable development cannot be compromised by unduly onerous requirements. The policy should, therefore, include a caveat in relation to the critical need to maintain the viability of the required development.
In the first instance, however, the Council must demonstrate that the policy and infrastructure requirements in the Submission Plan (cumulatively) in terms of financial contributions are achievable and do not render development unviable (NPPF paragraphs 158, 173-174). That must be considered at this stage. There is no evidence to that effect at this point in time as these policy requirement have not been robust considered Local Plan's Viability Report.

Soundness:
For the reasons set out above, Bloor Homes object to Policy H5, which is considered unsound on the basis that it:
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies; and
- is inconsistent with national guidance in that it does not fully reflect the Government's objective to ensure the housing requirements are not prohibitive to the delivery of development.

Proposed Changes:
To remedy the flaws in the soundness of the plan the evidence required to support the imposition of the housing standards and self build requirements must be provided and the cumulative impact on the viability of sustainable development examined. The policy should then also be revised to incorporate an appropriate caveat in relation to scheme viability and the importance of considering demand as well as need in relation to the required mix of housing.