Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Object

Representation ID: 1231

Received: 02/02/2026

Respondent: Home Builders Federation

Additional contributions for employment space, especially on sites with low land values, difficult geology or high Biodiversity Net Gain costs, could undermine housing delivery and should be avoided.

Comment

Representation ID: 1232

Received: 02/02/2026

Respondent: Home Builders Federation

The Plan should include a clear, robust five‑year housing trajectory and demonstrate a sustainable supply of deliverable housing land in line with the NPPF and Policy HO3.

Support

Representation ID: 1233

Received: 02/02/2026

Respondent: Home Builders Federation

At least 10 % of new homes should be allocated to sites smaller than one hectare, with a recommendation to increase this proportion where possible to support small‑scale developers.

Comment

Representation ID: 1234

Received: 02/02/2026

Respondent: Home Builders Federation

Support for small and medium builders should extend beyond sub‑one‑hectare sites to include non‑strategic sites of up to 100 units, expanding market choice.

Comment

Representation ID: 1235

Received: 02/02/2026

Respondent: Home Builders Federation

The upcoming NPPF consultation may extend the small‑site requirement to medium sites; the Council should consider this direction when shaping site allocations.

Support

Representation ID: 1236

Received: 02/02/2026

Respondent: Home Builders Federation

The wording of Policy INS: Sustainable Infrstructure does not make it clear how a developer would show compliance with the Policy, and seems to potentially be in conflict with Policy IN1 which recognises not all the infrastructure requests being sought by the Council may be able to be provided by the developers for reasons of viability, and therefore a prioritisation for contributions is set out. It is also unclear how the CIL payments would impact the other requirements of this policy. It will be important to avoid any double dipping.

Support

Representation ID: 1238

Received: 02/02/2026

Respondent: Home Builders Federation

DEFRA’s recent consultation proposes exempting sites smaller than 0.2 ha from the Biodiversity Net Gain requirement; the Plan should reflect this potential change.

Comment

Representation ID: 1239

Received: 02/02/2026

Respondent: Home Builders Federation

Whole‑plan viability testing should retain flexibility because individual sites may be unviable due to local cost or value variations, and the policy must accommodate such cases.

Comment

Representation ID: 1240

Received: 02/02/2026

Respondent: Home Builders Federation

The Council’s intention to update the 2022 Planning Contributions and Affordable Housing SPD lacks a timetable, and such SPDs are not part of the new plan‑making system.

Support

Representation ID: 1241

Received: 02/02/2026

Respondent: Home Builders Federation

As highlighted earlier HBF would question the range and scope of this Chapter especially in light of the proposed new approach to Local Plan content set out in the current Dec 2025 NPPF consultation. It will be important for this suite of policies to be fully evidenced and justified and not repeat national policy. Government has made its intention clear that the once the new (Dec 2025) NPPF is in
place policies in Local Plans that duplicate or conflict with it will no longer be relevant for decision making. This is likely to require the Council to rethink its approach to the detailed DM policies being proposed in this Plan.

Although HBF recognises the role that developers can play in helping to mitigate and address climate change and increase energy efficiency we would caution against policies that seek to go further and faster than national legislation and policy changes. This would lead to the creation of a patchwork of differing local policies which could inadvertently undermine the delivery of the wider
environmental objectives the Council is seeking and create unnecessary delays to much needed new housing.

HBF does not consider that the Council setting its own standards is the appropriate. We are concerned about Councils adding to the complexity of policy, regulations and standards that housebuilders are already expected to comply with. The key to success is standardisation and avoidance of individual Councils specifying their own policy approach, which undermines economies of scale forproduct manufacturers, suppliers and developers. The impact of these cumulative local requirements along with others Section 106 asks may have considerable viability implication and may lead to the non-delivery homes and needs to be fully considered within the Viability Assessment.

HBF do not support Local Plan policies on matters that are already addressed by Building Regulations and other regulatory regimes. A plethora of local standards can actually undermine the objectives the Council is seeking to achieve, for example by seeking to introduce uncertainty and variability to the timetable for the introduction of the national Future Homes Standard.

We also note that reference is made in this chapter to several Supplementary Planning Document (SPD) that the Council intends to prepare to provide further Guidance on the policies in this Chapter, and again no timeframe has been provided for this work. The opportunity to prepare SPDs does not form part of the new plan-making system.