Draft Submission Plan (Regulation 19)
Scope of the Plan Comment
Plan Period
47.This plan is to cover the period from 1st April 2026 to 31st March 2043. This is on the basis that evidence is available that will be relevant to a start date of 2026 and if the plan is adopted on or before March 2028, then it will have a 15-year period post adoption (i.e. 2028 to 2043). Therefore, the plan will cover 17 years. Comment
Approach to DM Policies
48.The 2026 NPPF includes a set of National Development Management Polices (NDMPs). These have been introduced for the first time. This will have implications for the nature and scope of policies that can be included in local plans since it is indicated that in preparing plans, Council’s should not “duplicate, substantially restate” NDMPs, or introduce new local policies that “are inconsistent with the content of national decision-making policies”[10]. Comment
49.For decision making, the new policies in the NPPF must be taken into account from the date of its publication (17th August 2026). Comment
50.The implementation provisions[11] include the following: Comment
“Development plan policies (or parts of those policies) which are materially inconsistent with national decision-making policies in this Framework should be given very limited weight. The only exception to this is where they have been examined and adopted or made against this Framework.[12] ”
51.This implies that any local policies in plans pursued under the 2024 NPPF would effectively be obsolete on adoption if they were inconsistent with the new NDMPs. Therefore, this plan does not seek to set out a raft of DM related policies, but rather to provide local specificity where implementation of NDMPs would benefit from additional detail. Comment
Minerals & Waste
52.This scope of this plan does not include policies relating to the nature and scale of minerals and waste provisions that should be included in a plan. The intension is that a separate minerals and waste plan will be pursued under the new plan-making arrangements. This will be reflective of the ongoing work across the region through the West Midlands Waste Planning Group and the expected strategic consideration of waste and minerals within the West Midlands Mayoral SDS. In the interim, relevant planning applications relating to minerals will be considered under NDMPs M3 – M6. Comment
53.Notwithstanding this approach, it is considered necessary that a criteria-based policy for new waste management facilities should be provided. This is set out in the Waste Management chapter. Comment
[10] Policy PM6 1c.
[11] Annex A, paragraph 2.
[12] NPPF 2026 Annex A Paragraph 2.
