Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

While HBF welcomes the support for the provision of specialist accommodation the Council should be seeking to identify sites that support such development rather than rely on sites of 50 dwellings or more to provide such development. The Council needs to engage with the developers and providers and specialist accommodation and work with them to identify appropriate sites rather than rely on more speculative approaches to meeting the needs of older people.

With regard to the requirement for 5% of market homes to and 10% of affordable homes to be built to part M4(3) of the building regulations it is notable that the council have chosen to base their assessment of need on data relating to individuals who use a wheelchair both inside and outside the home rather than just those who use a wheelchair inside the home and who will require it to be built to part M4(3). The figures are quite different with only 0.7% of owner occupier using a wheelchair both inside and outside the home. While HBF recognise the need for some home to be built to part M4(3) where required there is a danger that the council’s assessment over estimates the demand for such homes. HBF would suggest the council reconsider the evidence and examine need on the basis of those who use a wheelchair inside the home.

This policy requires 2% of homes on sites of 150 + homes to be provided as self-build plots. Firstly, HBF could not find the evidence as the demand for self-build homes in Colchester. Secondly if there is demand for self-build homes then the Council must first consider alternative options for providing self-build plots it has considered before placing the burden of meeting these needs on house builders. PPG sets in paragraph 57-025 that planning authorities should not only use planning policies to meet needs but also whether they could use their own land to meet those needs, how have they engaged directly with landowners to try and bring forward specific sites for self-build. It is essential that these mechanism are considered prior to setting requirements in local plans for plot delivery on larger sites.

The Council also needs to consider the difficulties in providing self-build plots on new housing developments and how there are coordinated with the development of a wider site. At any one time, there are often multiple contractors and large machinery operating on-site and therefore from both a practical and health and safety perspective, it is difficult to envisage the development of single plots by individuals operating alongside this construction activity. It may also be the case that it is unfeasible to provide self-build plots on sites taking in-to account topography and access and the degree to which self-build and the rest of the side can be developed separately. HBF would therefore recommend that in part 2 of the policy that where developer can show that provision of plots is either unfeasible or unviable then they will not need to be provided.

In conclusion HBF does not consider this policy to be justified or effective at present. Without further evidence the HBF would suggest that the requirement in this policy has not been robustly justified. We would also suggest that the Council consider allocating specific sites for self-builders which are more likely to meet the needs of those households as well as avoiding the potentially harmful impacts of mixing the delivery of self-build units alongside commercial housebuilding.

The policy states that all major residential development must assess the ne for new sport provision. It should not be for individual development to assess the need for sport provision on their sites. This should be set out in the local plan to ensure that there is transparency about what is needed and ensure that any provision is fully accounted for within the viability assessment.