Comment

Draft Black Country Plan

Representation ID: 44967

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

Representation Summary:

7.0 Policy DEL3 - Promotion of Fibre to the
Premises and 5G Networks
7.1 Whilst Taylor Wimpey generally supports the delivery of high-speed broadband it considers that
the BCP should not impose new electronic communications requirements beyond the provision
of infrastructure as set out in statutory Building Regulations.
7.2 In the March 2020 Budget, 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. This will apply to all
new builds. The inclusion of a policy in the BCP is not therefore necessary.
7.3 We also note that the delivery of broadband service connections is reliant on a third-party
contractor over which a developer is unlikely to have any control and therefore cannot confirm
availability at first occupation.
7.4 In addition, it is not clear what costs for the provision of this infrastructure have been factored
into the BCP viability work.
7.5 With regard to this policy requirement the Viability and Delivery Study states24:
“Most developers will want to provide full fibre to the premises as it is increasingly considered
an essential utility by house purchasers and/or commercial occupiers. The cost of utilities
provision is included in our external works allowance”.
7.6 No detail is provided to confirm what cost has been factored in to cover this element of external
works so it is not clear whether the cost applied is realistic.
7.7 For the above reasons we consider that Parts 1 to 3 of Policy DEL3 should be deleted.
24 Black Country Plan Viability and Delivery Study (May 2021) , page 24