Regulation 18 Draft Local Plan

Object

Representation ID: 1774

Received: 25/04/2024

Respondent: Home Builders Federation

Wish to see the Plan set out a logical settlement hierarchy which meets all the housing needs and addresses all areas of the housing market, with a range of sites proposed for allocation. The spatial strategy of the Plan should also recognise that there may be clusters of villages that provide a range of services for that area within reasonable travelling distance of each other, so villages may need to be grouped together. These areas might be able to sustainably support a substantial level of development but may not have all the services within one particular village. The Local Plan should recognise that settlements that currently do not have services could expand to include those services if new development is allocated in those areas. The current range of village services should not be used as a basis for only locating development close to existing services, it could in fact also identify where services could be improved through new development. Allocating housing sites in rural areas can also provide opportunities for small sites which are particularly helpful for SME builders.

Object

Representation ID: 1775

Received: 25/04/2024

Respondent: Home Builders Federation

Welcomes the Council’s committed to delivering its housing need through the allocation of suitable, available, and deliverable sites. HBF supports meeting the housing needs of South Kesteven through allocations, and agree it is essential that any allocations to be rolled forward remain deliverable. Supports the inclusion of a buffer and inclusion of a clear housing trajectory.
HBF are of the view that any allowance for windfall should not be included until the fourth year of a housing trajectory, given the likelihood that dwellings being completed within the next three years will already be known about (as they are likely to need to have already received planning permission to be completed within that timeframe). We are also of the view that any buffer provided by windfall sites should be in addition to the buffer added to the housing need figures derived from the Standard Method to provide choice and competition in the land market.

Object

Representation ID: 1776

Received: 25/04/2024

Respondent: Home Builders Federation

HBF does not comment on individual sites, other than to say the Plan should provide for a wide range of deliverable and developable sites across the area in order to provide competition and choice to ensure that housing needs are met in full. The Council should set out in the Plan’s policies and evidence base to set out how the plan will deliver 10% of homes on sites of less than one hectare, as required by paragraph 70 of the NPPF. The HBF advocate that a higher percentage of small sites are allocated if possible. HBF also note that support for small and medium builders need not be limited to only small sites of less than 1Ha.

Object

Representation ID: 1777

Received: 25/04/2024

Respondent: Home Builders Federation

It is not appropriate for Affordable Housing requirements to be expressed as a range. A policy seeking 27-57% affordable housing subject to the findings of the whole plan viability assessment would be contrary is to the PPG. The Viability PPG (Paragraph: 001 Reference ID: 10-001-20190509) clearly states that “policy requirements should be clear so that they can be accurately accounted for in the price paid for land. To provide this certainty, affordable housing requirements should be expressed as a single figure rather than a range. Different requirements may be set for different types or location of site or types of development”.

Object

Representation ID: 1778

Received: 25/04/2024

Respondent: Home Builders Federation

HBF agree that it will be important for the Plan to meet all local housing needs, including delivering an appropriate mix of housing and specialist housing. We also agree that it will be important to improve access to affordable housing. It will be important for the Plan to make housing available to people in need taking into account requirements of location, size, type and affordability and it will be important to improve the quality of housing stock and makes homes more liveable. However, the policy ask must be considered in the round to ensure development remains viable. Therefore, flexibility within the policy is needed.

Object

Representation ID: 1779

Received: 25/04/2024

Respondent: Home Builders Federation

HBF considers that a policy which encourages self and custom-build development and sets out where it will be supported in principle would be more appropriate. HBF considers that the Councils can play a key role in facilitating the provision of land as set in the PPG. This could be done, for example, by using the Councils’ own land for such purposes and/or allocating sites specifically for self and custom-build home builders- although this would need to be done through discussion and negotiation with landowners. The HBF does not consider that requiring major developments to provide for self-builders is appropriate.

Support

Representation ID: 1780

Received: 25/04/2024

Respondent: Home Builders Federation

HBF welcomes the policy on BNG and clarity provided in the recognition of the role of BNG mitigation hierarchy. HBF is pleased to see that the Council has acknowledged that on-site BNG may not always be the best solution and that there may be occasions where off-site BNG offers greater benefits. It is HBF’s opinion that the Council should not deviate from the Government’s requirement for 10% biodiversity net gain as set out in the Environment Act. There are significant additional costs associated with biodiversity gain, which should be fully accounted for in the Council’s viability assessment. It is important that BNG does not prevent, delay or reduce housing delivery.
HBF would also encourage the Council to ensure the Local Plan fully considers and evidence how BNG should inform the site selection process.

Object

Representation ID: 1781

Received: 25/04/2024

Respondent: Home Builders Federation

As previously mentioned HBF do not comment on individual sites but would encourage the Council to revisit its allocations to ensure on-site delivery of BNG has been properly factored into their housing capacity calculations.

Object

Representation ID: 1782

Received: 25/04/2024

Respondent: Home Builders Federation

Development can only be required to mitigate its own impacts and cannot be required to address existing issues and shortfalls in provision. It would be unreasonable and fail the CIL tests for developers to be expected to pay to address existing deficiencies.

Object

Representation ID: 1783

Received: 25/04/2024

Respondent: Home Builders Federation

HBF agree that the Plan should include a Monitoring Framework which sets out the targets for housing (and other matters) that will be monitored and the triggers for action being taken, and what that action will be.
Do not support the inclusion of policies within a Local Plan that merely triggers a review of the Local Plan if monitoring shows housing delivery is not occurring as expected. HBF would suggest, as a minimum, explicit reference should be made within the Plan’s policy and monitoring framework to the potential to bring forward additional housing supply earlier. The Monitoring Framework needs to set out how and when monitoring will be undertaken, and more information is needed on what action(s) will be taken and when, if monitoring shows under delivery of housing.