Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 14945

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Para. 384-385:
- Service delivery for broadband connections is the responsibility of service providers. Council should acknowledge these expectations are beyond the control of developers.

Object

Representation ID: 14946

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P15 (Bullet Point 3):
- HBF supports use of best practice guidance, but should remain voluntary.
- Council should note that Building for Life 12 had been superseded by Building for a Healthy Life

Object

Representation ID: 14947

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P15 (Bullet Point 4):
- Council should be aware that design principles set out in the specified documents are not always compatible
- NPPF Para. 16f confims Local Plans should avoid unnecessary duplication.

Object

Representation ID: 14948

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SPDs:
- Number of policies refer to SPDs and other guidance (see separate representations):
o P4A (2), P4E (4), P9 (1), P15 (5), P18 (10).
o Such references 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.

Object

Representation ID: 14949

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P4A (2):
- References to SPDs and 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.

Support

Representation ID: 14950

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Policy P4E (4):
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.

Object

Representation ID: 14951

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

P9 (1):
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.

Object

Representation ID: 14952

Received: 14/12/2020

Respondent: The Home Builders Federation Midland Region

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy P15 (5):
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

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.