Comment

Representation ID: 21263

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy HOU3 – Delivering Affordable, Wheelchair Accessible and Self Build/ Custom Build Housing
Policy HOU3 requires 20% affordable housing to be delivered on major greenfield sites in medium value zones. We support reference to viability within the policy and that the tenure and type of affordable homes sought will be determined on a site by site basis.

The Policy requires greenfield sites in medium value zones to deliver 15% of their homes in accordance with M4(3) regulations and all remaining homes should meet M4(2) regulations. The PPG states that Councils have the option to “set additional technical requirements exceeding the minimum standards required by Building Regulations in respect of access” where there is a justified need for this requirement (Reference ID: 56-002-20160519). The NPPF also requires all policies to underpinned by relevant and up to date evidence which should be adequate, proportionate and focused on supporting and justifying planning policies (paragraph 31). The PPG (Reference ID: 56-005- 20150327 to 56-011-20150327) sets out the evidence necessary to justifying a policy requirement for optional standards which includes:
• the likely future need;
• the size, location, type and quality of dwellings needed;
• the accessibility and adaptability of the existing stock;
• variations in needs across different housing tenures: and
• viability.

The PPG does not state what level of requirement should be required within Local Plan policies. It is considered that in requiring all new dwellings to be built to the Category M4(2) standards, it will result in larger dwellings and in turn less dwellings being delivered on sites. The NPPF is clear that planning policies should support development that makes efficient use of land (Paragraph 124). Furthermore, the BCA is constrained by Green Belt with limited brownfield redevelopment opportunities (Urban Capacity Report 2021) and the BCA is claiming that it cannot meet its own housing needs (NPPF Paragraph 125). The Council should be making the most efficient use of land on the Green Belt sites proposed to be released in order to avoid significant Green Belt release in future Local Plan Reviews. We therefore consider that the requirement to build all dwellings to Category M4(2) standards is not consistent with national planning policy.

The Policy also requires that on sites of 100+ dwellings, where there is a need for self-build and custom build plots on the Council’s register, at least 5% of plots should be made available for self-build or custom build or sufficient to match the current number on the register if lower. We object to this requirement and do not consider that the Council has provided sufficient evidence to support this approach or requirement. The Planning Practice Guidance (PPG) (Reference ID: 57-025-201760728) sets out ways in which the Council should consider supporting self and custom build which includes: developing policies in their Local Plan for self-build and custom housebuilding and “engaging with landowners who own sites that are suitable for housing and encouraging them to consider self-build and custom housebuilding” [Savills emphasis]. There is no requirement in the PPG for self or custom build plots to be provided as part of allocations and landowners should only be ‘encouraged to consider’ promoting their land for self and custom build housing.

Paragraph 6.29 states that there is a total of 32 individuals registered on Walsall’s self-build register. The register may provide an indication of the level of interest, but this needs to be analysed in further detail to uncover the specific requirements of respondents (e.g. type of property and location desired). Additionally, if all strategic sites proposed in Walsall are delivered (5,418 dwellings) and they all provide 5% self-build plots, this would equate to 271 self-build plots which is significantly greater than the number on Walsall’s housing register.

Furthermore, this register does not test whether people have the means to acquire the land and privately construct their own property. Furthermore, there are also practical issues to consider in providing self and custom building housing plots on an allocated site. For example, the day to day operation of such sites and consideration of potential health and safety issues of having multiple individual construction sites within one development. Other considerations are where a site being brought forward by a national housebuilder is the subject of a design code, what approach in the Council expecting self-build projects to take?

The provision of self or custom build plots should be the subject of discussion with those who have expressed an interest, and once the Council has an understanding of the type and range of sites that are sought allocations (for example in the form of clusters) should be identified and allocated as self and custom build opportunities around the BCA. Further clarity is request on whether the Council in its call for sites exercise sought to identify landowners willing to bring their land forward for small scale development (e.g. less than 10 dwellings) where bespoke self and custom build housing could be better delivered than simply sought through a blanket 5% request from major sites.