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ID sylw: 107907

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

As a part of the PO, the SWAs have recognised a need to ensure provision for self-build and
custom housebuilding (“SBCH”) is made over the plan period to meet their needs, with
Draft Policy B (Providing Custom and Self Building Housing Plots) requiring all large
developments (100 or more dwellings) to make provision for SBCH on 5% of the
developable area of a site.
2.97 This, although not explicitly stated in the PO, appears to be underpinned by the HEDNA,
which sets out evidence regarding the need for SBCH plots based on the individuals who
have expressed demand for serviced plots since 1st April 2016. The HEDNA, in Table 13.1,
identified an annual average need of 38 and 93 SBCH plots in Stratford-on-Avon and
Warwick respectively. Extrapolated over the plan period, this would equate to a need for
3,275 SBCH plots. In general, this would equate to c.5% of the SWA’s housing need over the
plan period.
2.98 Paragraph 63 of the NPPF, the SWAs should also assess and reflect in policy the need for
(inter alia) people wishing to commission or build their own homes. The PPG is also clear that there are several measures which can be used to do this, including but not limited to
encouraging developers to consider making provisions for SBCH.10
2.99 Whilst supportive in principle, Terra has some concerns regarding the SWA’s proposed
approach to delivering SBCH. In particular, Terra is concerned that there is no evidence
which explains the 100-dwelling threshold, or 5% requirement set out within the policy. As
noted above, the NPPF is clear that plans should underpinned by relevant and up-to-date
evidence that is adequate, proportionate and focused tightly on supporting and justifying
the policies concerned (Para 32). Whilst Terra recognises the ‘demand’ would broadly align
with the 5% requirement, the SWAs must demonstrate how the 100-dwelling threshold and
5% requirement align with the identified need.
2.100 Terra is also concerned that the policy as drafted applies SWLP-wide and offers no
flexibility to respond to local circumstances. Whilst there is evidence of a need for self-build
plots across SWLP-area, this does not automatically mean that there is demand in every
location. Terra therefore considers that further evidence is needed which justifies the policy
applying SWLP-wide.
2.101 Finally, whilst the draft policy requires a marketing strategy for the plots, Terra notes that
the draft policy provides no clarity in circumstances where the SBCH properties have been
marketed but received no interest. Policies must be sufficiently flexible, fit for purpose and
be clearly written and unambiguous (Para 16d). To this end, Terra considers that the policy
should provide clarity as to the approach the SWAs will take if the plots are marketed
unsuccessfully. By way of example, other LPAs have included caveats within similar policies
that have enabled the SBCH plots to revert back to affordable or general housing if there is
a lack of interest after 12 months.