Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1330

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Policy DLP42: Energy Infrastructure is considered unsound by the Home Builders Federation (HBF) for being unjustified, ineffective, and not in line with national policy.

Key concerns raised by HBF:

Mandatory District Heating Networks: HBF opposes mandatory requirements for developments to connect to district heating networks. They argue that this should be implemented flexibly. Currently, most district heating networks rely on gas-fired combined heat and power (CHP) plants, and transitioning to low-carbon alternatives (like large heat pumps, hydrogen, or waste-heat recovery) will be costly and economically unfeasible for the foreseeable future. The Council should consider alternative energy provisions, as low-carbon technology adoption remains financially challenging.

Government Consultation on Heat Network Zoning: HBF highlights a Government consultation that identifies exemptions to mandatory connections, such as where a connection would result in sub-optimal outcomes, affect consumer bills, or be impractical due to distance from the network.

Consumer Satisfaction and Costs: HBF points out that consumers using heat networks often face higher costs and lower satisfaction compared to traditional gas and electricity network consumers. Heat network consumers also lack the ability to switch suppliers, unlike other utility users, which raises concerns over consumer protection.

Excessive Requirements on Energy Efficiency: HBF argues that the policy goes beyond national standards like the 2021 Part L Interim Uplift and Future Homes Standard without justification. They stress that energy efficiency standards should be standardized through national regulations, rather than being set locally, to avoid undermining economies of scale for manufacturers, suppliers, and developers.

On-Site Renewable Energy Generation: HBF raises concerns about mandatory on-site renewable energy generation, suggesting it may not be suitable for all developments. They reference their comments in response to Policy DLP47.

HBF urges the Council to align with national energy efficiency and decarbonization strategies and avoid imposing unnecessary and potentially uneconomical requirements on developers.

Object

Representation ID: 1332

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP47: Renewable and Low Carbon Energy and BREEAM Standards is considered unsound by the Home Builders Federation (HBF) for being unjustified, ineffective, and not in line with national policy.

HBF's concerns include:

Mandatory On-Site Renewable Energy Generation: HBF opposes mandatory requirements for on-site renewable energy generation, suggesting that it should be applied flexibly. While acknowledging the potential for on-site energy generation, they argue that larger-scale, more efficient sources might be more sustainable. Additionally, the policy does not account for the decarbonization of the national grid over time, which will reduce reliance on on-site renewable energy.
HBF advocates for flexibility in the implementation of renewable energy generation and emphasizes that national grid decarbonization should be considered in the policy.

Object

Representation ID: 1333

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP49: Green Belt is considered unsound by the Home Builders Federation (HBF) for being unjustified, ineffective, and not aligned with national policy.

HBF's concerns include:

Housing Crisis: HBF highlights the ongoing housing crisis and stresses that Dudley Borough must allocate sufficient sites to meet housing requirements. This includes a mix of open market and affordable housing, with careful monitoring to ensure delivery.

Green Belt Review: HBF argues that Dudley should explore all options to meet housing needs, including a Green Belt review. They suggest that the exceptional circumstances of the housing crisis may justify releasing land from the Green Belt to address housing shortages.

Monitoring and Green Belt Release: HBF recommends that Dudley should monitor housing delivery across the wider region. However, they believe Dudley should do more to meet its own housing needs, including through Green Belt release, and that the Green Belt policy should be revised to reflect necessary changes in the Plan.

Object

Representation ID: 1334

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP63: Public Open Space within New Large Housing Developments is considered unsound by the Home Builders Federation (HBF) for being unjustified, ineffective, and not in line with national policy.

HBF's concerns are:

SPDs in Local Plan Policy: Criteria 2 and 3 of the policy seek to give Local Plan policy status to Supplementary Planning Documents (SPDs), which HBF deems inappropriate and contrary to national guidance. HBF emphasizes that planning policy should be made through the Local Plan process and subject to public consultation and independent scrutiny during the Examination process.

Object

Representation ID: 1335

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP64: Children’s Play Areas is considered unsound by the Home Builders Federation (HBF) for being unjustified, ineffective, and not in line with national policy.

HBF's concern is:

SPDs in Local Plan Policy: Criteria 3 of the policy attempts to give Local Plan policy status to Supplementary Planning Documents (SPDs), which HBF argues is inappropriate and contrary to national guidance. HBF stresses that planning policy should be developed through the Local Plan process and subjected to public consultation and independent scrutiny during the Examination process.

Object

Representation ID: 1336

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP83: Access for All is considered unsound by the Home Builders Federation (HBF) as it is unjustified, ineffective, and not in line with national policy.

Key concerns:

SPDs in Local Plan Policy: HBF supports the need for accessible environments but argues that Criteria 2 seeks to give SPD status to Local Plan policy, which is inappropriate and goes against national guidance. Planning policies should be made through the Local Plan process with public consultation and independent scrutiny during examination.

Need for Delivery, Monitoring, and Implementation:

HBF advocates for a monitoring framework within the Plan, allowing it to respond to changing circumstances. HBF opposes policies that only trigger a review if housing delivery falls short, arguing they are ineffective in addressing the housing crisis.
Action on Housing Under-Delivery: HBF suggests incorporating measures to address under-delivery more quickly than a full plan review, such as bringing forward reserve sites or making explicit reference to earlier delivery if under-performance is observed.
Housing Requirement and Needs: HBF stresses the importance of the housing requirement reflecting the Borough's needs and growth aspirations, rather than being constrained by capacity limits. This should be addressed before considering how much housing the borough can realistically accommodate.

Monitoring and Regional Coordination: HBF recommends the inclusion of a monitoring framework at the end of the Plan, ensuring that Dudley addresses its housing needs and actively participates in monitoring unmet housing needs from neighboring authorities.

Comment

Representation ID: 1337

Received: 28/11/2024

Respondent: Home Builders Federation

Dudley Local Plan: Part Two - HBF's Summary and Comments:

Site Allocation:

HBF does not comment on individual sites but stresses the importance of providing a wide range of deliverable and developable sites to ensure competition, choice, and a buffer to fully meet housing needs. The soundness of site allocations, whether brownfield or greenfield, will be evaluated during the Local Plan Examination.
Biodiversity Net Gain (BNG):

HBF suggests that the implications of BNG should be considered in the plan allocation process, referring to their earlier comments in Part One of the Dudley Plan.
Participation in Local Plan Examination:

HBF requests to participate in the Hearing Sessions of the Local Plan Examination to ensure the home building industry can address housing-related issues raised during the sessions.
Future Engagement:

HBF expresses its willingness to discuss the issues further or facilitate broader discussions within the home building industry as the plan progresses.