Comment

Representation ID: 22410

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

3.1 Draft Policy DEL3 states all developments of ten or more dwellings “will be required to deliver Fibre to the Premises (FTTP) capacity / infrastructure to all individual properties”.
3.2 St Philips recognises that new residential development should have infrastructure to facilitate access to high-speed broadband connections. However, the BCA should not impose new electronic communications requirements beyond the provision of infrastructure as set out in statutory Building Regulations.
3.3 In the Budget (11th March 2020), the Government confirmed future legislation to ensure that new build homes are built with gigabit-capable broadband. The Government will amend Part R
“Physical Infrastructure for High-Speed Electronic Communications Networks” of the Building Regulations to place obligations on housing developers to work with network operators to install gigabit broadband, where this can be done within a commercial cost cap.
3.4 Draft Policy DEL3 is unsound because it fails the four tests of soundness as per NPPF paragraph 35 as it is not positively prepared, justified, effective and consistent with national policy.