Policy should be deleted.

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.

Amend the wording of the policy accordingly in line with the above comments.

The words 'including a minimum of 3,070 affordable homes' should be changed to ' a target of 3,070 affordable homes'. The reason for this is that a minimum suggests it should be more; however, other relevant housing policies are worded to provide for a defined number or target and do not provide for more to be delivered. This change of wording does not stop more affordable homes from being provided, should developers choose to do so.

Additional wording should be included at the end of the policy:

'The mix of affordable housing will also take into account the character of the site and its surroundings to ensure the development creates a sustainable community in line with placemaking principles.'

Amend the text accordingly.

The requirement for an 'open space strategy' for all housing development is considered onerous and unnecessary. What guidance exists on what this document should contain, and how would it differ from the submission of a landscape scheme/planning statement/design and access statement, as part of the planning application?

If the requirement is retained, it should be set at a threshold of sites larger than 100 units so as not to cause additional work for SME developers.

Delete the wording 'the provision of affordable housing will be negotiated on a site-by-site basis, considering the evidenced viability of the development.'

Reword the policy point on unviable sites to include the ability to negotiate the level of affordable homes.

The following wording in the policy should be deleted:

'The provision of affordable housing will be negotiated on a site-by-site basis, considering the evidenced viability of the development.'

The policy sets the required level of affordable homes, so there is no need to negotiate it on a site-by-site basis. This would create uncertainty for developers when negotiating site purchases and could also delay the delivery of new homes. It is also contrary to PPW 12 para 4.2.22, where it states, 'It is for either the applicant or the planning authority to demonstrate that particular exceptional circumstances justify the need for a viability assessment at the application stage.'

The flexibility to negotiate the level of affordable housing is a part of a later point in the policy where it deals with situations where sites are unviable to deliver the level of affordable hosuign required.

The last sentence of the policy should be reworded, as it currently creates uncertainty for developers when negotiating site purchases. It is also noted that a similar point is made at the end of Policy SP7, so the wording repeats another policy but uses different wording, adding to the confusion.

Delete or amend the policy in accordance with the comments above.

The HBF objects to this policy, as it considers that controlling how a property is built should be achieved through Building Regulations, as it has historically been the case.

This is a position in part is supported by the Council in para 6.60 of BP42 Viability Assessment, where it states:

‘As discussed in BP33A Net Zero Buildings, .... then consideration should be given to whether it remains appropriate to have a planning policy that is broadly similar, as it would be more desirable to deal with the relevant assessments through the Building Control process rather than the planning system'

Such policies are also creating inconsistent standards across LPAs, as each is choosing slightly different standards and ways to measure compliance, making it harder to deliver new homes at scale.

In particular, concern is raised about the operational element of this policy and the future monitoring. This type of assessment relies on assumptions and averages, and is likely to change over time. This makes it almost impossible to monitor or enforce, and is therefore not considered appropriate as a planning policy.

The Welsh Government recently confirmed that the new Part L & F Building Regulations will come into force in the spring/summer of 2026. This means that this higher standard will apply to the housing allocations in this plan.

HBF notes that this is an issue which has also arisen in Local Plans in England; where it appears that the Government has decided to clarify the position in its latest consultation (Dec 2025) on the NPPF, where it states:

'Streamlining local standards. - We want to promote certainty for applicants and speed up local plan production by limiting quantitative standards in development plans to only those specific issues where local variation is justified. We also want to limit duplication of matters which are covered by the Building Regulations – other than where there is the existing ability to use ‘optional technical standards.'