It is recognised that some of the matters raised in this objection may be suggested by the Council to be included in the proposed Supplementary Planning Document (SPD) but the policy context must be properly established in the Local Plan. Accordingly, the changes sought to make Policy P4D more effective are:
a) A more refined approach to the location of self and custom build plots across the Borough, reduce reliance on allocated housing sites delivering plot and specific self and custom build plots across the Borough.
b) The trigger for self and custom build plots being based upon the number of market dwellings not all dwellings on a site
c) Submission of a ‘sales strategy’ for self and custom build plots. This would apply to all sites where such housing is provided. The content of what might be in a strategy can be included in the SPD.
d) Deletion of any valuation requirement in favour of the ‘sales strategy’. If the valuation requirement is maintained then the purchaser must pay.

1. Richborough Estates Limited supports the principle of the Council meeting its statutory duty to provide plots for self-build and custom homes on the register. However, the approach being adopted is crude and lacks any real thought about what types of sites people on the register may wish to build upon. Accordingly, an objection is made to Policy P4D which requires amendment to make it more effective.

2. The supply of plots for self-builders and those wishing to erect custom homes is fundamentally based upon a requirement for developers of allocated sites (of over 100 dwellings) to make the plots available based upon 5% of open market dwellings. The policy does include some criteria which may result in a different provision being made. However, there are 5 matters which justify further consideration being given to the supply of self and custom build plots.

3. Firstly, although a Borough wide figure is provided, there is no analysis of where the greatest demand for such plots exist. Someone living at Tidbury Green may not want a plot a Meriden and visa versa. A refinement is required whereby the provision of plots, up-to a maximum of 5% on allocations if this remains the approach to delivery, reflects demand based upon the register.

4. Second, consideration will need to be given to the cumulative number of market dwellings being provided within a particular locality. For example, is there sufficient demand for self and custom build plots to be provided on all the allocated sites at Balsall Common or within Blythe Ward?

5. Thirdly, an important factor is that will those people included on the register who want to build their own homes be happy erecting their property in the middle of a large housing allocation? Will there be the demand for such plots and where is the evidence to demonstrate this will be the case when drafting Policy P4D? As already noted, such allocations are the only source of supply of self and custom build plots under Policy P4D.

6. Fourthly, it can reasonably be expected that a Design and Access Statement and potentially a Design Code will be required for any large allocation. Such documents will establish the design and architectural approach to the development of a housing site. Will the parameters and constraints associated with a Design Code be conducive and attractive to those on the register wanting a self or custom build plot? The architectural freedom of the prospective self-builders will be curtailed.

7. A related point will be that the self-builders would be the subject of the same implementation conditions and planning obligations as the housebuilder. The Council will need to consider how this interaction would work if a self-builder failed to satisfy a condition of the outline consent or meet an obligation. Purchasers of market dwellings do not have to be concerned about such matters because they are generally the responsibility of the housebuilder to satisfy.

8. Finally, the requirement for self and custom build plots is based upon 5% of the market dwellings being provided on a site. It would, therefore, be more appropriate if the policy referred to the size threshold triggering the requirement being based upon 100 market dwelling rather than all dwellings. This would ensure a consistent approach otherwise there should be provision for 5% of the affordable homes being self-build.

9. In Richborough Estates’ view, it would be more appropriate for the Council to give consideration to the diversification of supply by the specific allocation of a range of smaller sites across the Borough for self and custom builders. These sites can be targeted to where there is a known demand based upon the register. The provision of dedicated sites is the approach adopted by Stratford on Avon District Council in its emerging Sites Allocations Plan (it has reached Regulation 18 stage).

10. The drafting of Policy P4D also needs to be revisited, specifically Criterion 2. As part of a larger allocation it may not be possible to offer such plots into the market fully serviced to the boundary and with unconstrained access to the highway. The development of the plots would need to follow the phasing of a scheme which may mean that the plots have to be sold in advance of these requirements being met. Further, it is also the case that what happens if plots are left vacant for 12 months because there is no interest and how would a traditional housebuilder be able to come back and erect their own houses?

11. It would be more appropriate, by a condition, for a ‘sales strategy’ to be submitted and approved as part of the first reserved and for the self and custom build plots to be brought forward in accordance with the approved details.

12. There is no justification as to why the value of the plots will need to be the subject of an independent valuation by a Registered Surveyor. If the plots are offered to the market in an agreed form via the ‘sales strategy’ (e.g. via approaching people on the register, posting details on a specialist website, asking a local agent to market the plots or placing plots in a specialist Auction) then the market will determine what price is paid. Incidentally, who will pay for the independent valuation the seller or the purchaser? It will need to be the purchaser.

13. Although unlikely to be a significant issue for the majority of allocations, sight should not be lost of viability considerations because, if it is necessary, at application stage an assumption would need to be made about the likely revenue from the sale of self and custom build plots.