Babergh and Mid Joint Local Plan (Reg 18)

Representation by Pelham Structures Ltd

September 2019

Introduction

1.1 This representation is submitted by Pelham Structures Ltd, who are actively promoting Land adjacent to . A location plan is provided at appendix A.

1.2 Established in 1993 Pelham Structures is a family-run business, that over the past 26 years has established a reputation for building attractive bespoke homes across the South East of , examples of our previous projects are provided at Appendix B. A large proportion of the homes we have built have been for individuals looking for input into the design and to ultimately build their dream home.

1.3 We also manufacture timber frames at our base in Butts Green, . We use these on our own projects, as well as supplying a number of self-builders and small building companies.

1.4 The site is a former quarry, associated with the historic Ballingdon brickworks and totals 5.15ha (12.7 acres). The quarry has never been restored and is currently a site of multiple levels. A large proportion of the site is occupied by self-seeded non-native woodland, which is generally of low quality.

1.5 The site is considered suitable for a small scale- self build development that would assimilate well into the woodland setting and would enable improvements to the biodiversity of the site. The site has the potential to provide 5-10 plots in a sustainable location within close proximity of the settlement of Sudbury.

1.6 Due to the topography and self-seeded nature of the woodland there are natural clearings that lend themselves well to self-build plots. The plots would be invisible from the outside world and would provide an opportunity for those looking to build their own home.

1.7 In its current state the site is of limited ecological value and its biodiversity could be significantly improved by the management that could be undertaken following development of part of the site. It is proposed to plant additional native species trees to replace any trees that are removed for the purpose of development. This will better support flora and other wildlife.

1.8 Pelham Structure is actively promoting the site for the development of Self-build and Custom homes. The site is both suitable and available for development and has the potential to deliver quickly.

2. Self- Build and Custom Homes

2.1 The UK has a much lower rate of self-building than other European countries. The sector currently accounts for between 7-10% of completions while in Austria it accounts for around 80%. Evidence suggests that there may be significant unmet demand for self-build in the UK. A survey commissioned by the Building Societies Association (BSA), published in October 2011, suggested that 53% of people in the UK would consider building their own home given the opportunity. Around 100,000 people subscribe to one of the main plot-finding websites.1

2.2 The Self-build and Custom Housebuilding Act 2015 place a duty on local councils in England to keep and have a register of people who are interested in self-build or custom-build projects in the area. Subsequently with the introduction of the revised NPPF July the requirement to cater for this need was added to Planning Policy. At NPPF Paragraph 61 its states:

“Within this context, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to, those who require affordable housing, families with children, older people, students, people with disabilities, service families, travellers25, people who rent their homes and people wishing to commission or build their own homes26).”

2.3 Footnote 23 further clarifies that “Under section 1 of the Self Build and Custom Housebuilding Act 2015, local authorities are required to keep a register of those seeking to acquire serviced plots in the area for their own self-build and custom house building. They are also subject to duties under sections 2 and 2A of the Act to have regard to this and to give enough suitable development permissions to meet the identified demand. Self and custom-build properties could provide market or affordable housing.”

2.4 Research from the National Custom & Self Build Association (NACSBA) (Press Release 30th November 2017) found that over 33,000 people had signed up to Right to Build registers across England as at November 2017. This represented an 80% increase from the 18,000 registered a year earlier. In the context of the policies above Local Authorities across England must give permission for sufficient serviced building plots to meet this growing demand. Given them until 31st October 2020 to consent 33,000 serviced plots, with around half of these to be consented by 31st October 2019.

2.5 As of April 2018, there were 164 people on the self-build register all with a variety of land and locational requirements. The Council’s website shows a limited number of self-build plots approved within the past 3 years.

2.6 PPG Paragraph 0232 clarifies a Councils Duty to Grant and states that: “The first base period begins on the day on which the register (which meets the requirement of the 2015 Act) is established and ends on 30 October 2016. Each subsequent base period is the period of 12 months beginning immediately after the end of the previous base period. Subsequent base periods will therefore run from 31 October to 30 October each year.

At the end of each base period, relevant authorities have 3 years in which to permission an equivalent number of plots of land, which are suitable for self-build and custom housebuilding, as there are entries for that base period.”

2.7 The Council therefore needs to have consented enough houses by the 31st of October starting this year.

2.8 There is considerable evidence that the supply of suitable sites is constrained: 41% of users of the Self Build portal cite that “Finding Land” is the biggest hurdle for their project.3

1 Commons Library Briefing, 1 March 2017 2 ID: 57-023-201760728 3 NACSBA August 2013- Progress Report to Government on the implementation of the Action Plan to promote the growth of self-building housing

3. Policy LP10 Self Build and Custom Build Homes

3.1 We are supportive of the inclusion of a policy promoting Self Build and Custom Build Housing. However, we have concerns that as currently proposed it will not cater for the demand/ need that is identified and that is supporting by the NPPF.

Policy LP10 - Self-Build and Custom-Build

1. The Councils will support proposals for self-build/custom-build housing or proposals that make a proportion of serviced dwelling plots available for sale to self-builders or custom builders, on appropriate sites and where in compliance with all other relevant policies of this Joint Local Plan.

3.2 The current drafting of the policy as set out above will not deliver the self-build houses demanded. For example: paragraph one says they will only “…be supported where in compliance with all other relevant policies within this Joint Local Plan”. This means that they will only be permitted on sites where housing would be approved anyway, meaning any landowner/ promoter will be highly unlikely to restrict the development of their site to self-build and custom homes.

3.3 Therefore, it is our view that as currently drafted the policy will not cater for the demand within the district and therefore needs reconsidered because it doesn’t meet the requirements of NPPF Paragraph 61.

3.4 In this context the PPG is not specific about how a Council should approach increasing the number of planning permission by Paragraph 0254, which is as follows: “Relevant authorities should consider how they can best support self-build and custom housebuilding in their area. This could include: • developing policies in their Local Plan for self-build and custom housebuilding; • using their own land if available and suitable for self-build and custom housebuilding and marketing it to those on the register; • engaging with landowners who own sites that are suitable for housing and encouraging them to consider self-build and custom housebuilding and facilitating access to those on the register where the landowner is interested; and • working with custom build developers to maximise opportunities for self-build and custom housebuilding.”

3.5 The appeal decision Hepworth Road, Woodville5 highlights the legal reequipment to grant planning permission and critically highlights that Councils need to grant permission and that a policy doesn’t necessarily achieve this. As suggested in our Regulation 19 representation we feel that the Council should be undertaking the suggestions at PPG paragraph 025 bullet points 3 and 4 above. We are a custom build developer and are promoting a site in Sudbury. The site is capable of delivering circa 5-10 self-build/ custom build properties and would make a meaningful contribution to the Councils need.

4 ID: 57-025-201760728 5 Land off Hepworth Road, Woodville DE11 7DW, APP/G235/W18/3214451

3.6 It is our view that to deliver enough self-build and custom homes it either needs to be delivered as an exception policy and/or there needs to be specific allocations for this type of house. These are approaches being taken in other Districts, but we would suggest the most appropriate course of action is to take a hybrid approach, introducing an exception policy for smaller sites and the allocation of larger one, exclusively self-build and custom homes sites.

3.7 For example: Council have proposed the following Policy within their emerging plan:

“The Council will encourage the provision of opportunities for constructing Self-Build and Custom-Built Homes as part of the mix of housing on large residential developments and the one-for-one replacement of an existing dwelling, of any size, in the countryside outside of settlement development boundaries with a single unit of Self-Build Housing, unless the impacts of development would conflict with other policy requirements in this Local Plan.

The Council will also consider, on their merits, proposals for Self-Build and Custom-Built Homes on land outside of settlement development boundaries, not involving the replacement of an existing dwelling, where they will still support a sustainable pattern of growth in the District. Such developments must either: a. be located on a site safely accessible on foot within 600 metres of the edge of the settlement development boundary of one the District’s ‘strategic urban settlements’, ‘smaller urban settlements’ . b. be located on a site safely accessible on foot within 400 metres of the edge of the settlement development boundary of one of the District’s ‘rural service centres’; or c. involve the redevelopment of vacant or redundant previously developed land that can be shown, with evidence, to be unviable for employment use.”

3.8 It is considered that this is a positive Policy that will support the development of Self-Build and Custom homes in a sustainable location that wouldn’t otherwise be granted planning permission for residential development.

3.9 We are also in the process of preparing a medium sized development of Self-Build and Custom Homes within District. The site is allocated within the emerging local plan for approximately 22 self/build dwellings (Policy GtDun7). The allocation of this site as Self- Build and Custom Homes means that it will come forward as required and not as conventual residential, which is the likelihood with this Councils policy as drafted.

3.10 In regard this site, we are working with the Local Authority to ensure that the site is delivered as a genuine self-build development. With the intention for us as developer to service the site with roads, infrastructure and foundations implemented to oversight. Individuals will then be able to purchase the plot and complete the build themselves. We will also be offering purchasers the option to buy timber frame kits from us, watertight shell and turnkey solutions should they require it but with no obligation for them to use us. This is a model that we believe can be used across the country to deliver schemes of this kind in safe and efficient way, whilst giving the self-builder the flexibility and input to suit their personal requirements.

3.11 The site referred to also seeks to deliver 30% affordable housing, in the form of discount market housing. It has been agreed via the s.106 that 30% of the plots will be sold at a 30% discount. Again, this is a policy that we would be encouraged in relation to Self-Build and Custom homes because it caters for an additional tenure and group of people as supported by NPPF Paragraph 61. 4. Summary

4.1 Policy LP10 as currently drafted will not deliver the amount of Self-build and Custom Homes that are required within the district. It is suggested that it is amended as set out above to allow exception sites for schemes less than 5 dwellings and that larger strategic allocations are made within the Local Plan.

4.2 Pelham Structures are a developer who specialise in delivering Self-build and Custom homes and are actively promoting land adjacent to Grove House, Sudbury. It therefore proposed that Policy LP10 is amended accordingly to addresses the need for Self-build and Custom homes within the district.