Proposed Submission Draft Local Plan Sustainability Appraisal

Object

Representation ID: 14199

Received: 02/05/2025

Respondent: William Davis Homes

Agent: WSP UK Ltd

DRAFT POLICY HN05 – HOUSING NEED: SELF AND CUSTOM BUILD HOUSING
William Davis Homes recognise that there is a local demand for self- and custom-build housing
plots, however it is not appropriate to assume 10% of all dwellings on residential sites of 40 dwellings or more should accommodate this.
Table 7.12 of the Local Housing and Employment Land Evidence Report (ref. EMP-NLP 2) identifies that in the most recent period (2023/24) there were 16 individuals on the register, however this data does not extend to the specific requirements of these individuals, such as
location. Although there is local interest, this does not necessarily translate to an interest in providing suitable plots across all large residential sites within the HDC. The evidence base therefore fails to provide adequate justification for this requirement and going above and beyond the currently adopted position (per Policy H5) of “the provision of land… as part of an appropriate
mix of dwellings”. As such, the choice of 10% (compared to an alternative proportion of sites) appears arbitrary; alternative levels of provision have not been tested within the Sustainability Appraisal to determine that this is the most appropriate.
While the policy states that a lower level of provision may be permitted where there is clear evidence of lower demand, there is limited provision in the policy for the point at which this will be considered adequate, stating this would only be the case if evidence is provided that a thorough marketing exercise has been undertaken over a period of at least 18 months. This would likely
result in vacant plots and require a new planning permission following this period. Unless the draft policy recognised that a reduced (e.g. 3-month) period was more appropriate, the requirements would limit the ability for sites to deliver their full development guideline, thus making the plan ineffective (per paragraph 36 of the NPPF) in reducing its ability to deliver the local housing need.
Therefore, a review mechanism should be built into the policy with explicit timescales of when plots identified to be delivered as self- and custom-build housing plots may be returned to the delivery of market housing.
Furthermore, the delivery of self- and custom-build housing plots is overly complex and unlikely to be feasible in a practical or logistical sense in the delivery of wider residential sites. As a result, there are likely to be health and safety implications through the co-delivery of the wider site with these self- and custom-build plots, which has not been reflected in the Sustainability Appraisal. The
Sustainability Appraisal (Table 7.6) has assumed positive effects for objectives 6, 7 and 9, however this is assuming (per the Health Impact Assessment, ref. PRE-NLP 4) that these levels are carried out across all sites, which is unlikely. Instead, there would be vast significant negative effects as a result of these plots not coming forward.
In recognition of the appropriacy of particular locations for the delivery of self- and custom-build housing plots, in their attractiveness to individuals on the local register and suitability of sites for allowing plots to come forward separately without negatively impacting delivery, the current position of adopted Policy H5 should be continued. This will ensure there is sufficient flexibility that correlates with the unpredictability of this specific market, rather than seeking these plots to deliver the objectively assessed local housing need of HDC, in addition to the draft expectations for affordable and specialist housing.

HN01 – HOUSING NEED: AFFORDABLE HOUSING
While William Davis Homes recognise the value in delivering affordable housing, the proposed continuation of the adopted requirement for 40% of homes on new developments to be affordable is inflexible and has not been adequately informed by the draft Plan’s evidence base.
The Local Housing and Employment Land Evidence Report (ref. EMP-NLP 2) assesses local housing needs and demographics by sub-areas within the District, recognising the spatial variation, including between rural and urban areas. Table 5.3 (Lower Quartile Prices and Market Rents) is broken down by sub-area, highlighting those rural areas, Kibworth and the Leicester Fringe are the least affordable. Table 5.5 (Estimated Household income Required to Buy and Privately Rent by sub-area) further demonstrates that Rural Areas, Kibworth, Great Glen and the Leicester Fringe area experience the largest income gap. This analysis is culminated in Tables 5.7 and 5.10, noting that the greatest need for social/affordable rented housing and affordable home ownership are within the rural areas.
However, this has not been translated into the draft policy requirements, as a blanket requirement of 40% affordable housing has been given across the District, despite the evidence base looking at a finer scale; the conclusions have been overgeneralised. Rather, the draft policy should focus the requirement to deliver affordable housing in rural areas, and the Leicester Fringe, in recognition of the proportion of the plan’s housing requirement in contributing towards the unmet housing needs of Leicester City. A lower proportion, in recognition of the findings of the evidence base, should apply to areas such as Lutterworth which are already more affordable, with a boost in housing delivery supporting this further. Therefore at present, the draft policy cannot be considered justified per the requirements for soundness in paragraph 36 of the NPPF.
Although the position of draft Policy HN01 is a continuation of the existing local plan position (adopted policy H2), this has not been effective. The East of Lutterworth Strategic Development Area has a pending application (ref. 24/01135/S106) to vary the Section 106 Agreement to remove the requirement to achieve a minimum of 40% affordable housing on each sub-phase, to a minimum of 10% and a maximum of 40%, in recognition that this will ensure the development can continue to be viable. Particularly given the location of this development within Lutterworth, this demonstrates that a blanket 40% affordable housing requirement is not feasible, and there should be a level of variation within draft Policy HN01 to reflect the sub-areas, and local market conditions.
WDH have instructed Brookbanks to undertaken a review of the Aspinall Verdi HDC Local Plan Viability Report (ref. INF NLP 2, January 2025), with a particular focus on the implications of development viability, which is provided within Appendix A of these representations.
The report identifies several fundamental input parameters that cannot be considered sufficiently robust to support a blanket 40% affordable housing provision across the high and medium value zones within the District. Furthermore, the report identifies that schemes in Lutterworth and Market Harborough did not meet the Benchmark Land Value when modelling 40% affordable housing provisions. A blanket 40% requirement for affordable housing is therefore not consistent with the Planning Practice Guidance on Viability2 which requires policy requirements to be informed by a proportionate assessment of viability, and the policy requirement should be reduced.
By not introducing flexibility to the local affordable housing requirement, the plan may be unable to be effective in delivering the objectively assessed housing needs of HDC, per the requirements of paragraph 36 of the NPPF.
In amending the wording of draft Policy HN01, Sustainability Appraisal objectives 6 (health and wellbeing), 7 (social inclusion) and 9 (housing) can continue to be met, in a way that is more appropriate with the spatial context of specific developments