Comment

Representation ID: 21337

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY DEL1 – INFRASTRUCTURE PROVISION: COMMENT
WDH recognises the intention of Policy DEL1 and the importance of delivering the infrastructure required to support sustainable development. In that regard, it is important that the policy recognises the role of a wide range of actors in delivering infrastructure. In doing so, the policy policy should be more explicit to encourage the proactive involvement of actors within infrastructure delivery. For example, the policy should reflect that it is the responsibility of the utilities company to provide necessary water supply and wastewater infrastructure to support development. Their investment programmes are not necessarily integrated with Local Plans, and often will not address the development requirements for an area until specific proposals become committed, normally through the grant of planning permission.

Furthermore, it is noted that Policy DEL1 states that the BCAs will “set out in Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents, and where appropriate, Masterplans” the infrastructure that is to be provided or supported, the prioritisation of and resources for infrastructure provision, the scale and form of obligation or levy to be applied to each type of infrastructure, and the procedure for maintenance payments and charges for preparing agreements. However, in order to give clarity to developers as to the scale and form of the infrastructure provision and contributions required, it is important that this is set out within the BCP itself, rather than being deferred to DPDs, SPDs, and Masterplan Reports that are produced thereafter. Indeed, recent case law has confirmed that policies that have a cost implication on development proposals cannot be deferred to an SPD or alike.

WDH does, however, welcome that the policy makes provision for “material considerations” that may indicate that some elements of required infrastructure cannot be delivered; which is an entirely sensible approach.