H5 clause 4

We object to Part 4 of the Policy, requiring self-build/custom build on all sites of 250 dwellings plus. This Policy is not supported. Placing a specific requirement for self-build and custom housing proposals of 250 or more homes places a burden on all larger development sites and may impact upon the rate of housing delivery in the district. It shifts development from the private house building sector, where there is a guarantee of production, to an unknown area which may or may not deliver homes at the required trajectory. If these self-build plots are not developed in a timely manner or remain undeveloped then the Council will have effectively caused an unnecessary delay to delivery.

The Council should give detailed consideration to the practicalities (for example health & safety implications, working hours, length of build programme, etc.) of implementing any such policy requirements. The provision of self-build/custom build plots will often conflict with health and safety practices on major sites for instance by virtue of the fact that they are likely to be built out at weekends and evenings. They will also create uncertainty over the form and character of development in these areas of the site which may make it difficult to sell adjoining plots; ultimately, having a detrimental effect on delivery rates.

The above considerations mean that provision should be sought by negotiation rather than as a requirement for all sites as the ability to overcome such difficulties will vary depending on site conditions.

It is considered that the Council should adopt a positive approach to attaining an appropriate level of self-build homes without placing unnecessary pressure on major and medium sized house builders. The use of exception sites or specific allocation of sites for Self-build/Custom build should be considered as options that would effectively, efficiently and sustainably add to these figures (including perhaps Council owned land).

For the above reasons, the Policy is seen to be unsound and not in accordance with the NPPF tests. Due to implications for overall housing delivery the Policy is not appropriately 'justified' and is not 'positively prepared'.

Part 4 of the policy proposes that housing development of 250 dwellings or more should provide land for self-build and custom build dwellings to help meet identified local demand. The policy is considered to be vague in terms of its specific requirements. Furthermore, whilst the Council has confirmed it has had 57 individual registrations for self build, the HEDNA concludes that such registrations should be treated with some caution (paragraph 9.56) and that an 'interest' in self-build does not take into account market factors (9.58). HEDNA concludes that most new delivery of self-build is expected to come forward on small windfall sites, and whilst there is the potential to encourage developers of larger schemes to designate custom build plots, "it is likely to be difficult to demonstrate concrete evidence of demand at a local level, albeit those local authorities are required to maintain registers of those with an interest in doing so" (paragraph 9.58)

Whilst the Planning Practice Guidance confirms that landowners can be encouraged to consider self-build, it is considered that on the basis of the HEDNA conclusions and the lack of clarity with the policy wording, part 4 of Policy H5 is not justified.

Refer to attached document.