Object

Representation ID: 14953

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P18 (10):
o References to SPDs and other guidance are inappropriate and non-compliant with the Regulations.
o Regulations are clear that development management policies should be set out in Local Plan policies. Council’s approach of requiring compliance with adopted SPDs is giving Development Management Plan Document (DPD) status to documents which are not part of the Local Plan, and have not been subject to the same process of preparation, consultation and examination.
o For policy to be effective should be clearly written and unambiguous, set out in sufficient detail, so it is evident how a decisionmaker should react to development proposals and not reliant on other criteria or guidance set out in a separate SPD.
o NPPF and PPG confirm scope and nature of SPDs and that they should not introduce new planning policies nor add unnecessary financial burdens on development.