Object

Draft Black Country Plan

Representation ID: 23332

Received: 11/10/2021

Respondent: Bloor Homes

Representation Summary:

Self build/custom build housing
Policy HOU3 states that on developments of 100 or more dwellings, where there is currently a need for self-build and custom build plots identified in the relevant LPA register, at least 5% plots should be made available for self-build or custom build, or sufficient to match the current number of the register if lower. Any plots that have not been sold after 12 months of appropriate
marketing will revert to the developer to build. BHL object to the inclusion of this part of the policy. In accordance with paragraph 62 of the NPPF 2021 and under The Self and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016), the responsibility for keeping a self-build and custom housebuilding register falls to “relevant authorities” i.e. District Councils, County Councils, in order to support development opportunities for self-build and custom housebuilding by increasing awareness among landowners, builders and developers of the level and nature of the demand for self-build and custom
housebuilding in the local area. BHL wish to emphasise that there is currently no legislative or national policy basis for imposing an obligation on landowners or developers to set aside 5% of plots on sites of more than 100 dwellings. BHL considers that it is the responsibility of the BCA, not landowners and developers, to ensure sufficient permissions are given to meet demand. BHL also seek further clarification on the justification of the identified threshold.

Additionally, as stated in the NPPG, the self-build register only needs to include the name and address of the association/lead contact and the number of serviced plots of land in the relevant authority’s area the association are seeking to acquire: no information is requested on the financial resources for each association. Therefore, BHL consider that the demand of the 153 individuals on the BCA register could in fact be an expression of interest rather than actual demand.

Moreover, in addition to increasing the complexity of an already complicated construction process, BHL consider that it is extremely unlikely that self and custom build serviced plots on new housing developments of over 100 dwellings will appeal to those wishing to build their own home. BHL consider that BCA should include an alternative policy to allocate small parcels of land
specifically for self-build and custom housebuilding. Further clarification is also requested on the ambiguous term of “appropriate marketing”.