Testun llawn:
A presumption against demolition is considered onerous and unnecessary and is not supported by national policy.
HBF also questions how this policy will impact the level of windfall sites that will be delivered by the plan. Windfall allowances are based on past build rates; the previous plan did not have a similar policy, so brownfield windfall sites will have been more likely to have delivered a higher number of units as a result of site demolition and clearance before redevelopment.
The HBF notes that several sites identified in the Council's BP19 Urban Capacity Study have existing buildings on them; however, no mention is made of how a presumption against demolition might affect their delivery capacity.
This policy adds additional burden on SME developers, who are more likely to develop windfall and brownfield sites with existing buildings, with yet more reports required as part of a planning application.
HBF suggests that adequate wording is already provided at point 2 of Policy SP16 - CLIMATE CHANGE MITIGATION AND ADAPTATION.
