Draft Regulation 18 Sandwell Local Plan

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Object

Draft Regulation 18 Sandwell Local Plan

Policy SCC2 – Energy Infrastructure

Representation ID: 962

Received: 13/12/2023

Respondent: Home Builders Federation

Representation Summary:

51. The Council’s proposed policy approach is unnecessary seeks to go beyond the 2021 Part L Interim Uplift and the Future Homes Standard without justification. It is the Government’s intention to set standards for energy efficiency through the Building Regulations. The key to success is standardisation and avoidance of individual Council’s specifying their own policy approach to energy efficiency, which undermines economies of scale for product manufacturers, suppliers and developers.

52. The Council should be aware that the long awaited consultation on the Future Homes standard was published on Dec 13th 2023 and consultation closes in 6 March 2024. The consultation documents can be found online at https://www.gov.uk/government/consultations/the-future-homes-and- buildings-standards-2023-consultation

Object

Draft Regulation 18 Sandwell Local Plan

Policy SCC6 – Renewable and Low Carbon Energy and BREEAM Standards

Representation ID: 964

Received: 13/12/2023

Respondent: Home Builders Federation

Representation Summary:

Policy SCC6 – Renewable and Low Carbon Energy and BREEAM Standards

53. HBF is concerned about any policies which mandate on-site renewable energy generation. HBF considers that it is important that this is not seen as a requirement and is instead implemented on a flexible basis. HBF recognises that there may be potential for renewable energy generation on- site, however, it may be more sustainable and efficient to use larger scale sources rather than small-scale, it is also noted this policy also takes no account of the fact that over time energy supply from the national grid will be decarbonised.

Comment

Draft Regulation 18 Sandwell Local Plan

Justification

Representation ID: 970

Received: 13/12/2023

Respondent: Home Builders Federation

Representation Summary:

Policy SHW1– Health Impact Assessments


54. HBF is unclear why the Health Impact Assessment is seeking to assess if a development “will provide a range of housing types and tenures that meet the needs of all sectors of the population including for older people and those with disabilities requiring varying degrees of care; extended families; low-income households; and those seeking to self-build as set out in Polices SHO3, SHO4 and SHO5”. This matter is already adequately addressed in the specific housing policies and should not need to be repeated in a HIA.

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SHO1 - Delivering Sustainable Housing Growth

Representation ID: 971

Received: 13/12/2023

Respondent: Home Builders Federation

Representation Summary:

55. In relation to criteria one, HBF’s detailed comments in relation to the amount of housing needed in Sandwell can be found in our response to policy SD1: Development Strategy. In summary, HBF request that the standard method LHN should be the minimum starting point for establishing the housing requirement and the Council should then fully considers all of the issues that may result in a need for a higher housing requirement, including the need to provide a range and choice of sites, the need for flexibility, viability considerations and whether higher levels of open-market housing are required in order to secure increased delivery of affordable housing. HBF suggests that these considerations should result in a higher housing requirement for Sandwell which set be set out in the Local Plan. Only then should consideration around deliverability and housing land supply come into play, the housing requirement should be established first.

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SHO1 - Delivering Sustainable Housing Growth

Representation ID: 972

Received: 13/12/2023

Respondent: Home Builders Federation

Representation Summary:

56. In relation to criteria two, HBF note that the Council is looking to phase the plan and delivery of the housing requirement. For the plan to be effective and justified, a clear explanation of this approach and the reasoning behind for it is needed. As HBF is of the view that the overall housing requirement for Sandwell should be higher, it follows that our view is that the numbers in each phase should be higher too.

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SHO1 - Delivering Sustainable Housing Growth

Representation ID: 973

Received: 13/12/2023

Respondent: Home Builders Federation

Representation Summary:

57. HBF supports the principal of discounting the housing land supply assumptions to take account of non-implementation rates. We note that site with planning permission include a lapse rate of 5% other commitments are SHLAA are discounted by 10% and occupied employment land discounted by 15%, but these figures should be clearly evidenced. HBF also notes that no allowance is made for non-delivery of windfall sites and we believe one is needed. HBF would question if the discount rates should in fact be higher especially for sites that are currently occupied in employment use. The anticipated loss of current employment sites to housing further underlines the need for housing and employment to be considered together, and for the potential implications of not meeting with the housing and employment need of the borough to present the exceptional circumstances required to justify Green Belt release.

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SHO1 - Delivering Sustainable Housing Growth

Representation ID: 974

Received: 13/12/2023

Respondent: Home Builders Federation

Representation Summary:

59. The NPPF requires Local Plans to identify land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, unless there are strong reasons why this cannot be achieved. HBF has undertaken extensive consultation with its small developer members. One of the chief obstacles for small developers is that funding is extremely difficult to secure without a full, detailed, and implementable planning permission. Securing an implementable planning permission is extremely difficult if small sites are not allocated. Without implementable consents lenders are uneasy about making finance available or the repayment fees and interest rates they set will be very high. Small developers, consequently, need to invest a lot of money and time up-front in the risky business of trying to secure an allocation and a planning permission, and this is money that many small developers do not have.

60. HBF would therefore wish to see the 10% small sites allowance delivered through allocations. Indeed, we would advocate that a higher percentage of small sites are allocated if possible. Such sites are important for encouraging the growth in SME housebuilders who will tend to develop these sites but rarely see the benefits that arise from the allocation of sites in a local plan. Up until the 1980s, small developers accounted for the construction of half of all homes built in this country resulting in greater variety of product, more competition, and faster build-out rates. Since then, the number of small companies has fallen by 80%.

61. HBF also note that support for small and medium builders need not be limited to only small sites of less than 1Ha. SMEs also deliver on other types of non- strategic sites (for example up to 100 units). The inclusion of additional non- strategic allocations would expand the range of choice in the market, and be of a scale that can come forward and making a contribution to housing numbers earlier in the plan period.

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SHO1 - Delivering Sustainable Housing Growth

Representation ID: 975

Received: 13/12/2023

Respondent: Home Builders Federation

Representation Summary:

62. In relation to criteria three, HBF notes that NPPF (para 71) only permits an allowance for windfall sites if there is compelling evidence that such sites have consistently become available and will continue to be a reliable source of supply. HBF 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. However, by including windfalls within the Plan’s housing requirement supply, any opportunity for windfalls to provide some additional housing numbers and flexibility is removed. Windfalls do not provide the same choice and flexibility in the market as additional allocations.

Comment

Draft Regulation 18 Sandwell Local Plan

Policy SHO1 - Delivering Sustainable Housing Growth

Representation ID: 976

Received: 13/12/2023

Respondent: Home Builders Federation

Representation Summary:

63. Criteria 3 indicates that regular monitoring will be undertaken annually of housing delivery, but this does not tally with the Monitoring Framework at the end of the Plan. It should also be possible to see from Housing Trajectory how much reliance is being made on windfalls, or from when. To be both justified and effective the Housing Trajectory should include break down the housing numbers into different sources of supply. 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).

Comment

Draft Regulation 18 Sandwell Local Plan

Delivery, Monitoring, and Implementation

Representation ID: 977

Received: 13/12/2023

Respondent: Home Builders Federation

Representation Summary:

63. Criteria 3 [policy SHOU1] indicates that regular monitoring will be undertaken annually of housing delivery, but this does not tally with the Monitoring Framework at the end of the Plan. It should also be possible to see from Housing Trajectory how much reliance is being made on windfalls, or from when. To be both justified and effective the Housing Trajectory should include break down the housing numbers into different sources of supply. 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).

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