Local Development Framework Consultation

General Requirements for all Development

Representation on behalf of the Cumbria House Builders Group (CHBG).
Consultation Questions for General Requirements
1. Which option do you think is appropriate?

Option 2: Condense requirements as referred to above into a new single or small number of development management general requirements policies that can be applied to any new type of development. Where other requirements may need to be applied additional policies would be adopted.

2. If you support the idea of such a policy what should it contain?


The new policy should seek to supersede and consolidate saved local plan policies in their entirety.

Housing - Housing Optional Technical Standards

Representation made on behalf of the Cumbria House Builders Group (CHBG)

Consultation Questions for Housing Optional Technical Standards

3. Which option do you think is appropriate?

Option 1: Maintain the current policy position

The CHBG are concerned about the impact of any additional requirements and the impact on viability and therefore the delivery of housing. Analysis of housing completions against Core Strategy housing requirements, indicates that only half the number of dwellings have been delivered in the period up to 31st March 2015, as indicated in the table sent in a separate email. [SEE ATTACHED DOCUMENT] This is a major concern.

Housing delivery significantly below housing requirements can only have an upward pressure on house prices thereby exacerbating affordability issues.
We do not yet know the implications of the introduction of the Community Infrastructure Levy of £50 per sq.m for housing starts on sites granted planning permission since 1st June 2015.

Planning Practice Guidance (PPG) requires planning authorities to consider the impact of using these additional standards as part of a Local Plan viability assessment. On the costs side, PPG recommends that authorities take into account the most recent Impact Assessment issued alongside the Housing Standards Review. This Assessment explains the historic background of the difficulties presented to house-builders of different planning authorities adopting different standards and therefore a move to encourage simplification and rationalisation of standards i.e. through the provisions set out within Building Regulations.

There must be legitimate and clear local need for standards to be set beyond the minimum requirements of Building Regulations.

Access to and use of dwellings
Access to and use of dwellings is covered by the requirements of Part M of the Building Regulations, that came into effect on 1st October 2015.

Part M4(1) requires that all new dwellings are “Visitable dwellings” (unless the optional requirements of M4(2) or M4(3) apply) and therefore specific standards for the approach to a dwelling, entrance, corridor widths, entry level sanitary facilities and services apply to all dwellings.

PPG indicates that planning authorities should indicate how they intend to approach demonstrating the need for Requirement M4(2) (accessible and adaptable dwellings) and/or M4(3) (wheelchair user dwellings), if they wish to apply these optional standards.

SLDC will need to research and provide evidence of need for each standard and determine the size, location and type of dwellings to meet any identified need if they are to progress such additional standards.

The CHBG will consider any evidence that SLDC might produce in terms of the need to go beyond Part M4 (1).

If SLDC are intent on progressing additional requirements in this regard there will need to be a consideration of the overall impact on viability given increased costs. This may require a review of other planning policy requirements that impact on site viability. If any other new planning policy requirements are imposed then these will also need to be considered as part of a viability assessment.

Internal Space Standards

SLDC already apply space standards for affordable dwellings in the context of SLDC Affordable Housing Guidance for Developers (updated 1st December 2015). As the Core Strategy refers to a requirement for 35% affordable housing, there is already control over a significant proportion of new build dwellings.

The imposition of space standards may preclude the provision of smaller open market dwellings in the future. This will have an implication for the price of dwellings. Put simply if the size of dwellings is to increase, then the price will also increase, which is most likely to have an impact on first time buyers. A 60 sq.m house will not have the same open market value as a 70 sq.m house. There is a danger that there will be some who are priced out of the market, who are too wealthy to be eligible for an affordable dwelling but not wealthy enough to afford the new increased entry level sized dwelling.

There will be viability implications for any increased space standards.

Water efficiency

South Lakeland is not an area of ‘water stress’ so there is no justification of any additional standards in this regard.

4. Should any of the optional standards be applied?

No.

a) Which ones and why?

Not applicable.

b) To all new homes or just a percentage/just in certain locations?

Not applicable.

SUSTAINABILITY APPRAISAL

Task A2-Establishing the Base Line

Policy Theme – Housing

This should be a little more expansive and not just refer to housing completions over the last two years. Housing completions are half the Core Strategy requirement as indicated in the above table. This should be highlighted.

Task A3-Identifying Sustainability Issues and Problems:Housing

Sustainability Issues/Problems – Housing affordability

The house price: income ratio in South Lakeland will be affected by the significant number of retired people living in owner occupied dwellings without a mortgage.

SP3 To provide everyone with a decent home

The questions are not just – if the policy will help meeting local housing needs by providing housing that is of appropriate quality and affordable or will the policy provide housing which is resource efficient etc, BUT will the policy limit the actual provision of new housing to meet Core Strategy housing targets?

Matrix

Provides a different definition to SP3 than “provide everyone with decent home”.

Appendix 2: Indicators and Baseline Data

Housing

There is no indicator that refers to net housing completions in totality. There must be a target to meet Core Strategy housing requirements. One cannot simply ignore the issue because completion rates are in fact only half the requirement.

There is no indicator that refers to net housing completions by settlement type i.e. Principal, Key and Local Service Centres or small villages/hamlets as set out in the Core Strategy.

House Price: Income Ratio – a reduction is more likely to occur if housing supply is in line with Core Strategy targets and the target is recognised.

Housing - Starter Homes Exceptions Site Policy

Representations made on behalf of the Cumbria House Builders Group (CHBG).

Consultation Questions for Starter Homes Exceptions Site Policy
5. Which option do you think is appropriate?

Option 1 Rely on national policy.

6. If a new policy is needed, what considerations should it address?

Not applicable

7. What are your views on the possible implications for planning policy in the District of the recent Government announcement on Starter Homes?

If it has local planning authority support then it will hopefully result in increased housing completions and widen housing choice.

If Starter Homes becomes part of the NPPF affordable housing definition this will assist in increasing housing provision.

Housing - Self-Build and Custom Build Housing

Representation on behalf of the Cumbria House Builders Group (CHBG).

Consultation Questions for Self-Build/Custom Build Housing
8. Which option do you think is appropriate?

Option 1 Maintain the current policy position.

9. Have you evidence which supports the case for Option 3?

CHBG does not support Option 3.

One needs to consider the type of plots self-builders and custom builders seek and the impact of providing specific plots on allocated sites. There are two sides to this issue:-

1. CHBG are sceptical that self-builders or custom builders actually seek plots on a large developments. Instead it is their perception that such builders seek either individual plots or small site schemes. SLDC will no doubt seek direct feed- back from those on the Register. SLDC’s Housing Monitoring Report 2015 shows a significant number of small sites with planning permission (631 dwellings on 375 small sites). These are available to self-builders and custom builders if they wish to acquire those sites. SLDC’s latest five year land supply assessment indicates that, in addition to small sites with planning permission, the authority anticipates 285 dwellings will be completed on small sites and a 357 dwellings completed in small villages, hamlets and the open countryside (most likely to be principally small sites) in the next five years.
2. Simply identifying plots on sites which are allocated and contracted to house builders, such as CHBG members, will create considerable difficulties. Apart from contractual difficulties, potential new house purchase customers may be discouraged from purchasing because of concerns and uncertainty of the nature of the self-build dwellings and the timing of delivery. This has an impact on both viability and deliverability. There are also practical concerns over start and finish of construction, the provision of services and health and safety management issues.

Economy, Town Centres and Tourism - Loss of Employment Sites and Premises

Representation on behalf of the Cumbria House Builders Group (CHBG).

Consultation Questions for Loss of employment sites and premises
20. Which option do you think is appropriate?

Option 2 (in part only) No longer rely on Policy E6 but there will be a need for a new policy that takes into account NPPF paragraph 22 which indicates that where there is no reasonable prospect of a site being used for employment purposes then alternative uses should be considered.

Quality Environment and Quality Design - Quality Design

Representation on behalf of Cumbria House Builders Group (CHBG).

Consultation Questions for Quality Design
35. Which option do you think is appropriate?

Option 2 Adopt a new policy setting out a list of specific design principles…

36. If a new policy is needed what should it contain?

Consolidate existing policy advice into a limited number of policies to encourage good quality design. Specific policy in relation to residential development.

If there are density and cost implications there must be viability considerations.

37. If a Design SPD is needed what should it include?

Not needed.

Quality Environment and Quality Design - Trees and Landscaping

Representation on behalf of the Cumbria House Builders Group (CHBG).

Consultation Questions for Trees and Landscaping

41. Which option do you think is appropriate?

Option 2 Adopt a new policy to consolidate and refine saved local plan policy.


42. If a new policy is needed should it:
(a) Incorporate only the requirements of the extant local plan policies into one new policy?

Yes

(b) Include additional or alternative new criteria/requirements/guidance? If so, what

No

Quality Environment and Quality Design - Sustainable Drainage Systems

Representation on behalf of Cumbria House Builders Group (CHBG).

Consultation Questions for Sustainable Drainage
45. Which option do you think is appropriate?

Option 2 rely on NPPF etc.

The CHBG would be concerned at proposals that add another tier of policy beyond the requirements of Cumbria County Council.

Any cost implications would have to be considered in a viability assessment.

46. If a new policy is preferable what should this contain?

Not applicable.

Quality Environment and Quality Design - Pollution

Representation on behalf of the Cumbria House Builders Group (CHBG).

Consultation Questions for Pollution
49. Which option do you think is appropriate?

Option 2 Rely only on NPPF and associated guidance

50. If a new policy is preferable what should this contain?

Not applicable.

Sustainable Communities and Health & Wellbeing - Green Infrastructure and Open Space

Representation on behalf of the Cumbria House Builders Group (CHBG).

Consultation Questions for Green Infrastructure
51. Which option do you think is appropriate?

Option 2 Adopt a new policy…
Current Core Strategy policy on open space requirements does not provide clear guidance on open space requirements within new developments.

52. If a new policy is needed should it be informed by a new Open Spaces, Sports and Recreation Study?

Yes.
a) At this stage?
Yes.
b) When a combined Local Plan is produced?
No.

53. Whichever option is chosen, should the policy position be supported by a Green Infrastructure Supplementary Planning Document?
No.
a) At this stage?
Not applicable.
b) When a combined Local Plan is produced?
Not applicable.