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ID sylw: 108194

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy B- Providing Custom and Self Building Housing Plots? 2.82 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. 2.83 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. 2.84 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.11 2.85 Whilst supportive in principle, St Philips has some concerns regarding the SWA’s proposed approach to delivering SBCH. In particular, St Philips is concerned that there is no evidence that 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 St Philips 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. 2.86 In addition, the NPPF is also clear that planning policies should have regard to the economic viability of sites (Para 72) and should not undermine the deliverability of the Local Plan (Para 35). To this end, the SWLP will need to be supported by a viability assessment that cumulatively tests the impact of policy requirements on the viability of sites allocated in the SWLP – including the impact of requiring delivering SBCH if these approaches are proposed. 2.87 St Philips 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. St Philips therefore considers that further evidence is needed to justify the policy applying SWLP-wide. 2.88 Finally, whilst the draft policy requires a marketing strategy for the plots, St Philips 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, St Philips 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.