Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 59024

Received: 13/12/2021

Respondent: Ivor Beamon

Representation Summary:

The importance of providing sufficient custom build plots for meeting the local housing need has not been adequately addressed in this Policy. Custom build is not in conflict with either the local rural exception policies, National Exception Sites contained in the NPPF or the emerging First Homes policies.

Full text:

The importance of providing sufficient custom build plots for meeting the local housing need has not been adequately addressed in this Policy. Custom build is not in conflict with either the local rural exception policies, National Exception Sites contained in the NPPF or the emerging First Homes policies.
Meeting Local Need through providing Sufficient Custom Build Plots.

Providing plots for custom build is meeting a housing need as required by Government Policy. Each Local Authority is required to keep a register. It is evident from the Greater Cambs Self Build Register that even on a fundamental basis of those registered that would wish to have the opportunity of building their own home cannot be met by any implementable planning permissions. For the previous three reporting years as identified on the summary there appears to be demand for 481 plots where no new permissions have been granted.

The custom build register is currently an inadequate evidence base as it does not provide any detailed information as to what plots are being considered and their location. The statement on the South Cambs Register describe that part of their function is to look for plots for custom build homes opportunities. As there are no plots with planning permission the assumption must be that the Officers have not identified suitable plots for this purpose.

It is therefore unrealistic to rely on the council to find suitable sites. What are the alternatives?

1. Rely on Windfall Sites
There is no specific total of housing delivery from this source expected through the Plan period but normally represents 5-10% of developments obtaining consent per annum. This figure does not and should not include an allowance for custom build plots as required by national policy. The 481 plot requirement should be from other sources supported by specific policies in this Plan as to where these allocations may be suitable. This is a separate issue to the general provision of housing in Policy SS/SH where there are indicative maximums to development in various settlements. The availability of custom build plots should be treated in the same way as a specific local housing need as is dealt with by the Rural Exception Policy H/ES regarding sites for Affordable Housing.

2. 5% Provision within Major Housing Allocations.
This Policy is purely to provide the proportionate number of custom build plots from newly identified housing allocation to address the current lack of provision on the South Cambs Register for the local need of 481 individuals.

In Policy S/DS there are 11,596 new homes to be delivered on the allocations. Assuming 10,000 of the homes would be on sites greater than 20 dwellings to satisfy the Policy this would yield 500 dwellings. Thus, in Policy terms it appears the Council have identified an appropriate supply that meet the current back log of demand.
This does not however consider the suitability of plots from this source. In my opinion the majority would not be deemed to meet the requirements of the custom build group of the community requiring a home to suit their needs.

At the time of submission, the ‘e-form’ to register was inaccessible and are therefore unaware if questions were asked as to what would constitute a suitable location both in setting and settlements within the District. In the absence of this the likely reasons for persons to build their own home would be:
- not to be within a large development site
- a project for a very extraordinary home.
- the approach to use modern methods of construction
-Greater quality and energy efficiency than currently required to meet national building standards
-To have a more independent lifestyle
-Located in a rural setting.

If this assertion is correct national housebuilders in meeting a Policy Requirement will simply not provide very many suitable plots for custom build purposes.

To address this, policies dealing with custom build housing in the rural areas of the District should be positive and actively encourage landowners to identify sites for this purpose which currently is not the case.

3. Suitable sites and delivery in the rural areas

The most likely source of plots to meet both the Local Plan requirement and the Self-build and Custom Housebuilding Act 2015 is sites that are sustainable in Minor Rural Centres or Group Villages.

A suitable source of custom build plots will not be from home-builders but rely on partnerships between landowners and local contractors to provide the serviced plots.

Windfall sites submitted under Policy S/SH are less likely to be available to individual custom builders but sold to small/medium developers. As such custom build sites which do not form part of the major development sites should have a stronger policy basis in the absence of what is very unlikely to be sufficient plots from either the Council finding suitable sites or from the 5% requirement from the major housing allocations.

4. Evidence Base

There appears no record in the evidence base to support the Policy that sufficient plots would be made available via the 5% reserve on future housing allocations on sites greater than 20 dwellings. There is no data to what has been provided where a custom build requirement has formed part of any existing planning agreement.

It is likely that the requirement to provide 5% of the site for this purpose would be time limited. There will more than likely be paragraphs in the planning obligations which permits the developer to revert to speculative housing prior to the completion of any phase or within two years of a custom build plot being serviced or made available.

The Council should provide a table that demonstrates how many custom build plots were identified under the Policy and the number which were sold for individual custom builders as defined in the Act.

If this does not provide sufficient evidence that the number of custom build plots can be made available to meet the need on the Register then the 5% of allocated site Policy is flawed. This would give support that further policies are required to encourage landowners to release sites for this purpose rather than through the more speculative development route of Policy S/SH

5. Exception Site Conflict

It is not agreed that any specific self-build policy on encouraging sites for this purpose specifically in Group Villages would conflict with the delivery of affordable exception sites.

Affordable exception sites are identified based on local need where guidance is obtained from either the councils housing register or a discreet housing need survey for the particular village. Should a need be identified the affordable housing providers would assess suitable sites for this purpose and speak directly to owners as to the availability. More often than not subsidies on the land purchase would be provided from Homes England via Strategic Partnership Funding.

For custom build housing there is no such support. If the Local Plan is there to meet the housing need of all groups in society a reliable source of land for this purpose needs to be identified.

The only way this will be achieved is to have a similar policy basis for landowners to make available suitable plots for the self-build community.