Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Object

Representation ID: 25167

Received: 23/03/2021

Respondent: Home Builders Federation

This policy looks for residential sites of over 100 dwellings to provide at least 5% of the dwelling plots for sale to self-builders. Many of our members will be able to assist the custom build sector either through the physical building of dwellings on behalf of the homeowner or through the provision of plots for sale to custom builders. The HBF are, therefore, not opposed to the idea of increasing the self-build and custom build sector for its potential contribution to the overall housing supply. However, most of the Council’s approach is restrictive rather than permissive by requiring the inclusion of such housing on developments of over 100 dwellings. This policy approach only changes the house building delivery mechanism from one form of house building company to another without any consequential additional contribution to boosting housing supply. Meaning that as currently proposed this policy will not assist in boosting the supply of housing and may even limit the deliverability of some sites and homes. The HBF would recommend appropriate evidence is collated to ensure that house building delivery from this source provides an additional contribution to boosting housing supply. This is likely to include engaging with landowners and working with custom build developers to maximise opportunities.

The HBF does not consider that the Council has appropriate evidence to support the requirement for 5% of the total plots on developments of over 100 dwellings to provide service plots for custom or self-build housing. PPG sets out how custom and self-build housing needs can be assessed. The SHMA (2019) highlights that 1,175 people were registered on the Council’s self-build register, it provides no analysis or evaluation of this figure, and does not provide any other evidence or information.

Comment

Representation ID: 25168

Received: 23/03/2021

Respondent: Home Builders Federation

34. This policy states that where development falls within Use Class C3, affordable housing provision will be required in line with Policy HO5 Affordable Housing. The HBF considers that the Council will need to ensure that this requirement is appropriate in terms of viability for these types of developments.

Object

Representation ID: 25169

Received: 23/03/2021

Respondent: Home Builders Federation

All new build dwellings should meet Building Regulation requirement M4(2) 'accessible and adaptable dwellings'.

On major development sites over 0.5 hectare or 10 or more homes a minimum of 5% of dwellings should meet the Building Regulations requirement M4(3) 'wheelchair user dwellings', designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users.

The HBF is generally supportive of providing homes that are suitable to meet the needs of older people and disabled people. However, if the Council wishes to adopt the higher optional standards for accessible, adaptable and wheelchair homes the Council should only do so by applying the criteria set out in the PPG.

PPG identifies the type of evidence required to introduce such a policy, including the likely future need; the size, location, type and quality of dwellings needed; the accessibility and adaptability of the existing stock; how the needs vary across different housing tenures; and the overall viability. It is incumbent on the Council to provide a local assessment evidencing the specific case for Bradford which justifies the inclusion of optional higher standards for accessible and adaptable homes in its Local Plan policy. If the Council can provide the appropriate evidence and this policy is to be included, then the HBF recommends that an appropriate transition period is included within the policy.

The PPG also identifies other requirements for the policy including the need to consider site specific factors such as vulnerability to flooding, site topography and other circumstances, this is not just in relation to the ability to provide step-free access.

Object

Representation ID: 25170

Received: 23/03/2021

Respondent: Home Builders Federation

The policy goes on to require all new market and affordable homes should, as a minimum, meet the Nationally Described Space Standard (NDSS) for internal space in new dwellings. The NDSS as introduced by Government, are intended to be optional and can only be introduced where there is a clear need and they retain development viability. As such they were introduced on a ‘need to have’ rather than a ‘nice to have’ basis.

PPG identifies the type of evidence required to introduce such a policy. It states that ‘where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:
•Need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.
•Viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.
•Timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions’.

The Council will need robust justifiable evidence to introduce the NDSS, based on the criteria set out above. The HBF considers that if the Government had expected all properties to be built to NDSS that they would have made these standards mandatory not optional.

Object

Representation ID: 25171

Received: 23/03/2021

Respondent: Home Builders Federation

The council will encourage the use of new and innovative smart waste collection systems including underground bin systems where appropriate and feasible, in particular, on larger strategic sites and developments of 500 properties or more or for high density developments. The HBF has concerns about the viability of this policy, at the moment it is not clear what the costs for these smart waste collections might be, but it is likely any underground provision would add significantly to the cost of any development. The HBF also has concerns in relation to the waste authority’s ability to work with these waste requirements, and whether they will be committed to working with these smart solutions for the life of the dwellings, buildings or developments provided.

Comment

Representation ID: 25172

Received: 23/03/2021

Respondent: Home Builders Federation

All development (except householder applications) should deliver a measurable net gain in biodiversity value compared with the pre-development baseline. Proposals should be supported by evidence to demonstrate a biodiversity net gain using the current Defra Biodiversity Metric.

The Council will know that the Government is already looking at the most appropriate approach to biodiversity net gain. The HBF considers that the Council should not deviate from the Government’s proposals on biodiversity gain as set out in the Environment Bill. This legislation will require development to achieve a 10% net gain for biodiversity. It is the Government’s opinion that 10% strikes the right balance between the ambition for development and reversing environmental decline. 10% gain provides certainty in achieving environmental outcomes, deliverability of development and costs for developers. 10% will be a mandatory national requirement, but it is not a cap on the aspirations of developers who want to voluntarily go further. The mandatory requirement offers developers a level playing field nationally and reduced risks of unexpected costs and delays.

The Council’s policy approach should also reflect the Government’s proposals for a transition period of two years as set out in the Environment Bill. The Government proposes to work with stakeholders on the specifics of this transition period, including accounting for sites with outline planning permission, in order to provide clear and timely guidance on understanding what will be required and when.

The Government will issue guidance to Councils on the importance of proportionality in their application of planning policy. So that sites without reasonable opportunities to achieve net gain through on-site habitat delivery will not face risks of delay through rigid or prescriptive requirements.

There are significant additional costs associated with biodiversity gain, which should be fully accounted for in the Council’s updated viability assessment. The Government has confirmed that more work needs to be undertaken to address viability concerns raised by the housebuilding industry in order that net gain does not prevent, delay or reduce housing delivery.

Object

Representation ID: 25173

Received: 23/03/2021

Respondent: Home Builders Federation

New trees and woodland should be planted on all new developments in both public and private areas, including a fruit tree in every garden. The HBF would like to know what the justification and evidence is for the requirement for a fruit tree in every garden, this is an additional cost, that a new resident may not want and may remove once moved into the property. The HBF recommends that this part of the policy is deleted.

Where existing trees have been identified as suitable for removal at pre-application stage, then replacements should be planted within public areas of the development at a ratio of three new trees for every tree lost. The HBF would like to know what the justification and evidence is for this ratio of replacement. It is considered that if the Council are seeking a ‘net environmental’ gain that this could be achieved in many other ways than seeking a 3:1 tree ratio. The HBF recommends that this part of the policy is deleted.

Comment

Representation ID: 25174

Received: 23/03/2021

Respondent: Home Builders Federation

This policy looks for all new residential developments to maximise opportunities for the use of on-site renewable and low carbon energy sources, where this is practical and viable. It goes on to state that all major residential developments should look to provide a site wide heating and cooling system where reasonable and practical and to connect to wider district heating and cooling networks both for energy supply and export, especially where these utilise renewable energy. It also states that residential development of 50 or more dwellings should strongly aim to achieve zero net-carbon emissions, with all residential developments to meet Future Homes Standard by 2025.

It is noted that this policy is setting a target ahead of the Government target of net Zero Carbon by 2050. The HBF does not generally object to encouragement for the need to minimise the carbon emissions. The HBF supports moving towards greater energy efficiency via a nationally consistent set of standards and a timetable for achieving any enhancements which is universally understood and technically implementable. The HBF acknowledges that the Government has not enacted its proposed amendments to the Planning & Energy Act 2008 to prevent the Council from stipulating energy performance standards that exceed the Building Regulations. However, the HBF considers that the key to success is standardisation and avoidance of every Council in the country specifying its own approach to energy efficiency, which would undermine economies of scale for both product manufacturers, suppliers and developers.

The Government has consulted on The Future Homes Standard. The UK has set in law a target to bring all its greenhouse gas emission to net zero by 2050. New and existing homes account for 20% of emissions. It is the Government’s intention to future proof new homes with low carbon heating and world-leading levels of energy efficiency. The Government wants to create certainty and consistency. An uplift to Part L standards will improve the energy efficiency of new homes and prepare housebuilders and supply chains in readiness for the further uplift in 2025 to meet the Future Homes Standard.