Object

Representation ID: 21347

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY HOU3 – DELIVERING AFFORDABLE, WHEELCHAIR ACCESSIBLE AND SELF BUILD / CUSTOM BUILD HOUSING
WDH notes the requirement for 30% of dwellings to be delivered as affordable houses within the Higher Value Zone “where this is financially viable.” In addition, WDH welcomes the flexibility afforded by the policy in relation to tenure splits and types of affordable houses delivered, which Policy HOU3 states will be “determined on a site by site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations.” With that said, it is important for the plan’s viability assessment to consider a range of tenure splits to ensure that they are viable on all site typologies.

In relation to accessible dwellings, Policy HOU3 requires a minimum of 15% of dwellings to be delivered to M4(3) standard, with the remainder to meet M4(2) standards within higher value zones. However, that policy requirement is not justified based on proportionate evidence as required by NPPF paragraph 35b. Rather, the SHMA suggests that there is a need for just 23% M4(2) delivery, with evidence of only limited M4(3) need. As such, the requirement for accessible housing should reflect this need, rather than being artificially boosted without any evidence or justification.

Furthermore, the level of accessible housing delivery that is defined (once justified by evidence) must be considered within a viability assessment that must demonstrate that the cumulative cost impact of all policy requirements in the plan does not render the plan unviable and thus undeliverable. However, with that said, the reference that any provision being more flexible to account for viability and site characteristics is supported.

Policy HOU3 also requires at least 5% of plots on sites of 100 dwellings or more to be made available for self-build or custom build “where there is currently a need for self-build and custom build plots identified in the self-build and custom build register for the local authority where the site is located”, “or sufficient to match the current number on the register if lower.” WDH has concerns in relation to that requirement, noting that custom and self-build (CSB) registers are not means tested, meaning an individual’s registration seldom equates to a genuine desire and ability to develop a CSB plot. Rather, registrations on CSB registers often relate to a desire for CSB housing in a specific location, rather than within estate-like housing developments. As such, to require CSB delivery when registrations are, by the BCPs own admission, “modest” when compared to neighbouring authorities does not seem to be a justified approach.

Moreover, the delivery of CSB housing is subject to practical difficulties, and is often dependent on the ability for sites to provide independent construction access and infrastructure, and deal with difficult health and safety issues. Furthermore, CSB housing has the potential to undermine the realisation of consistent design principles across a scheme, and can also negatively impact on delivery timescales. Thus, it would be more suitable for the BCAs only to support CSB housing on specific CSB housing sites, and to remove the blanket requirement of 5% CSB delivery on sites of 100+ dwellings.

Despite the above concerns, however, WDH welcomes the allowance made for financial viability assessments and the variation of actual housing delivery from the requirements set out in Policy HOU3 to a viable level. Indeed, that is an entirely appropriate and justified approach.