Regulation 19 - Proposed Draft Local Plan Submission

Object

Representation ID: 13858

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

the delivery of BNG is impacting on achievable densities. It will be important for the BNG requirements of a site to be understood to ensure that the implications of providing the required development densities and on-site BNG are appropriate and deliverable. The HFB recommend that the Council consider the baseline BNG as part of the site allocation process.

The HBF would expect the Council to ensure that the policy is applied flexibly and makes allowance for home builders to provide alternative housing mixes as is required by the market.

Object

Representation ID: 13859

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

The HBF also note that the viability of older person’s housing is different to other forms of housing as such should be considered separately in the Whole Plan Viability Assessment. We would question the effectiveness and justification of this policy.

Object

Representation ID: 13860

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

The HBF considers that the Council’s evidence does not show that there is a demand from custom and self-builders to live on sites within a larger residential development scheme.

The HBF does not consider that requiring developments of 40 or more homes to provide for self-builders is appropriate. Instead, the HBF advocates for self and custom-build policies that encourage self and custom-build development by setting out where it will be supported in principle.

It is considered unlikely that the provision of self and custom build plots on new housing developments can be co-ordinated with the development of the wider site due to practical and health and safety issues.

If a self-build policy is be pursued, then the HBF agrees that if demand for plots is not realised, it is important that plots should not be left empty to the detriment of neighbouring properties or the whole development. The HBF would therefore suggest that any unsold plots should revert to the original developer after a six-month marketing period.

The HBF considers that alternative policy mechanisms could be used to ensure a reliable and sufficient provision of self & custom build opportunities

Support

Representation ID: 13861

Received: 05/05/2025

Respondent: Home Builders Federation

It is the HBF’s opinion that the Council should not deviate from the Government’s requirement for 10% biodiversity net gain as set out in the Environment Act.

There is need for the policy wording and/or supporting text to be clear about the differentiation between the mitigation hierarchy (which seeks to avoid harm in the first place, then mitigate and only then compensate it in relation to protected habitats) and the BNG delivery hierarchy (which prioritises on-site BNG delivery, then off-site units and finally allows for statutory credits).

Object

Representation ID: 13865

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HBF welcome the Plan’s commitment to monitoring Monitor, Manage approach, We welcome the inclusion of a Review policy but suggest that the delivery of housing to meet the unmet needs of Leicester within Harborough could usefully be set out and monitored separately.

Object

Representation ID: 13866

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

concerned that the viability study highlights areas where the 40% affordable housing target is already challenging; suggesting 20% maximum affordable housing on lower value greenfield and 10% for lower value brownfield.
There also a number of current and emerging policy requirements both locally and nationally that are putting viability under pressure

The Viability Assessment should clearly set out how it considered the implications of mandatory BNG and how it arrived at the most up to date BNG costs information available to use. The HBF suggests the costs of BNG should been considered as part of the planning obligations and should be specified as a single specific item. There are significant additional costs associated with biodiversity net gain, which should be fully accounted for in the Council’s viability assessment, some of which are unknown at this time.

The HBF notes that the level of open-market housing provided may also impact on the amount of affordable housing that can be developed. It is therefore important to understand if there any geographically specific viability considerations, such as whether higher levels of open-market housing are required in particular areas in order to secure increased delivery of affordable housing in that location in a way that remains viable.

It should also be noted that viability issues may not just be limited to the delivery of affordable housing delivery. For example, a lack of BNG credits