ipswich.gov.uk

Object

Proposed Submission Core Strategy and Policies Development Plan Document Review

Representation ID: 5549

Received: 02/03/2015

Respondent: Home Builders Federation Ltd (HBF)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy DM1: Sustainable design and construction

Elements of the policy are unsound because the requirements conflict with national policy.

Full text:

Policy DM1: Sustainable design and construction

Elements of the policy are unsound because the requirements conflict with national policy.

We recommend that the requirement in the policy part A for residential development to comply with Code for Sustainable Homes level 4 is deleted because this is contrary to the Government's intention to remove the Code as a national standard but to incorporate elements in the revised and expanded Building Regulations. This is set out the Government's Housing Standards Review.

The last part of the policy states that the standards stipulated are the minimum. This is vague and will result in uncertainty for the applicant and the decision-maker. This would be contrary to the NPPF which requires that the local authority's policy on local standards is set out in the local plan (paragraph 174). This is necessary to provide clarity for the applicant to know what he or she needs to do to comply with local policy and so that the decision-maker knows how to assess the application (see paragraph 154 of the NPPF). Having clear policies is important in order to provide a practical framework to enable planning applications to be made with a high degree of predictability and efficiency (NPPF, paragraph 17).

We recommend that this part of the policy is deleted because it lacks clarity. We also recommend it is deleted because the outcome of the Government's Housing Standards Review will only require developers to comply with the Building Regulations. Local authorities will not be able to specify compliance with any other standard.