7.1 - Whilst we would agree that early engagement with the Council is preferable, the pre-application service is extremely slow, and became so congested in 2024 that it had to be suspended for several months. It is therefore unrealistic to expect applicants for small schemes to engage in the pre-app service, as it is uneconomical and not a good use of the Council’s resources. Arguably, the SPD, if worded correctly, should reduce the need for pre-application advice in any case.

7.2 - There is an inconsistency here that will cause problems at the application determination stage and requires attention. 8.25 rightly states that in the case of outline applications, conditions will be applied to the permission, and the eligibility test will be used at reserved matters stage, which is sensible. 7.2 suggests otherwise. The document needs to be amended to make this clearer, or outline applications will be wrongfully refused when landowners, developers etc apply for outline planning permission for self and custom build schemes.
Suggested wording: ‘In the case of a full or reserved matters application, for a scheme to be acceptable, applicants will need to demonstrate that they fulfil the criteria in paragraph 5.7 above even if they have not formally joined the register. For outline applications, no such test will be required, but conditions will be applied to the planning permission to ensure that the plots can only be developed by self or custom builders, with the test applied at the reserved matters stage’.

A series of questions raised in relation to the approach:
• Where there are plots (of a potentially unknown size/design), not knowing what will be nearby/neighbouring will have an adverse effect on the demand for, and sales of, nearby houses.
• Additional planning costs will need to be passed onto a purchaser of a custom-build plot.
• Is it necessary for every full application to be a hybrid application, if the design of some (custom build) plots are to be ‘reserved’? What timescales for Reserved Matters submission/s are to be applied for a number/series of reserved custom build plots within such a scheme?
• The process (flexible yet imprecise) will inevitably constrain the ability for house buyers to borrow (mortgages), and exchange contracts.
• What are the implications for subsequent NMAs or S.73s, specific to individual custom build plots on a larger scheme?
• How does this dovetail with the Building Regulations process?
• Against whom would any enforcement/non-compliance with condition action be made (housebuilder or custom builder)?

Where outline permission has been granted, consideration should be given to any subsequent changes in design to ensure that properties sit in proportion to the size of the plot. Where applicable consideration should be made to comply with Design Codes where a Neighbourhood Plan is in place.

7.2 – In addition to including a reference to custom or self-build in the description, it may be useful to highlight any additional sections of the planning application, or requirements for additional information, applicants might be required to provide. The example standard conditions and legal agreements should be included in the SPD as an appendix.