Publication Plan April 2024

Object

Representation ID: 7327

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy HC4 is unsound because it is not positively prepared, is not effective or justified, and does not comply with national policy. 46. The policy should not require all development to meet M4(2), however this standard will be superseded by changes to residential Building Regulations. The Government response to ‘Raising accessibility standards for new homes’ states that the Government proposes to mandate the current M4(2) requirement in Building Regulations as a minimum for all new homes, with M4(1) applying in exceptional circumstances. There is therefore no need for this element of the proposed new policy. 49. The PPG sets out some of the circumstances where it would be unreasonable to require M4(2) compliant dwellings. Such factors include flooding, typography and other circumstances. HBF suggest that flexibility is needed in the application of these standards to reflect site specific characteristics, and the policy wording should reflect this.

Object

Representation ID: 7328

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy HC8 is unsound because it is not effective or justified, and does not comply with national policy.
50. HBF advocates for self and custom-build policies that encourage self and custom-build development by setting out where it will be supported in principle. HBF considers that Councils can play a key role in facilitating the provision of land as set in the PPG. This could be done, for example, by using the Councils’ own land for such purposes and/or allocating sites specifically for self and custom-build home builders- although this would need to be done through discussion and negotiation with landowners.
It is considered unlikely that the provision of self and custom build plots on new housing developments can be co-ordinated with the development of the wider site.
HBF also question is there is a mismatch between the kind of plots and locations that self-builders are looking for, and the kind of plots that would result from this policy.
52. It is important that plots should not be left empty to the detriment of neighbouring properties or the whole development. The timescale for reversion of these plots to the original housebuilder should be as short as possible from the commencement of development. HBF suggest this should be a maximum of six months.

Object

Representation ID: 7329

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy HC10 is unsound because it is not positively prepared, is not effective or justified, and does not comply with national policy.
It is not appropriate for Criterion a) and Criterion m) of this policy to seek to give Local Plan status to the existing South Staffordshire Design Guide SPD and the Affordable Housing SPD, especially when the policies that the SPD hangs from are to be replaced by the new Local Plan. Reference to the SPD should be relocated to the supporting text.

Object

Representation ID: 7330

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy HC12 is unsound because it is not positively prepared, is not effective or justified, and does not comply with national policy.

HBF does not support the introduction of the optional Nationally Described Space Standard though policies in individual Local Plans. If the Council wanted to do this they would need robust justifiable evidence to introduce the NDSS, as any policy which seeks to apply the optional nationally described space standards (NDSS) to all dwellings should only be done in accordance with the NPPF which states that “policies may also make use of the NDSS where the need for an internal space standard can be justified”.
The HBF highlight potential implications on housing need, viability and timing. 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. If the proposed requirement for NDSS is carried forward, then the Council should put forward proposals for transitional arrangements and not apply to resereve matters applications.

Object

Representation ID: 7331

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy NB6A is unsound because it is not positively prepared, is not effective or justified, and does not comply with national policy. The proposed wording suggests that the Council is seeking to move away from the carbon reduction methods set out in Part L of the Building Regulations. HBF supports the Council in seeking to minimise carbon emissions and reduce heat and power demand through energy efficient design. However, the HBF does not consider that the Council setting its own standards is the appropriate method to achieve these outcomes. To be consistent with national policy, HBF request the Council rely on the Building Regulations process as the way to manage improving energy efficiency standards and as such no policy on this issue is needed in the Local Plan. The Written Ministerial Statement clearly states that any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned building regulations should be rejected at examination if they do not have a well-reasoned and robustly costed rationale. HBF also note efforts to decarbonise the national grid, and this raises questions about the whether it is actually appropriate and sustainable to have on-site renewables and/or energy storage when the grid is moving to renewable sources. The HBF also raise concerns over the effective implementation and monitoring of the policy.

Object

Representation ID: 7332

Received: 31/05/2024

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

The monitoring framework in the Plan is unsound because it is not positively prepared, is not effective or justified, and does not comply with national policy.
In light of the failure of this plan to properly address the issue of unmet need and the wider role South Staffordshire should play in meeting the housing needs of the wider West Midlands region, and the economic impacts of not doing so, HBF would request that this plan is subject to an early review policy. This will be essential to ensure that the Plan delivers the housing needed and action is taken to address the unmet needs of the wider HMA as soon as possible.