BASE HEADER

Yes

ID sylw: 108190

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy
Direction 5- Infrastructure Requirements and Delivery?
2.55 In general, St Philips agrees with the SWA’s proposed approach of requiring developments
to make contributions towards the delivery of infrastructure. It is entirely appropriate for
development to mitigate their impacts, and where possible and necessary make
contributions towards associated infrastructure. However, as the SWAs will be aware, these
contributions must:
a necessary to make the development acceptable in planning terms;
b directly related to the development; and
c fairly and reasonably related in scale and kind to the development (Para 58,
NPPF).
2.56 As such, as the SWAs progress the SWLP, it will be critical that an Infrastructure Delivery
Plan [IDP] is prepared, which identifies the infrastructure necessary to mitigate proposed
development allocations – this will be particularly critical for any SGLs or New Settlements.
2.57 However, the NPPF is clear that planning policies should be “clearly written and
unambiguous, so it is evident how a decision maker should react to development
proposals” (Para 16d). In addition, Paragraph 34 clearly states that:
“Plans should set out the contributions expected from development. This should include
setting out the levels and types of affordable housing provision required, along with other
infrastructure (such as that needed for education, health, transport, flood and water
management, green and digital infrastructure). Such policies should not undermine the
deliverability of the plan.” (Emphasis Added)
2.58 Therefore, it will be critical that the SWLP is clear through site-specific allocations what
infrastructure improvements are required for each development allocation.
2.59 In addition, and as stated throughout St Philips’ response, the NPPF is also clear that
planning policies should have regard to the economic viability of sites (Para 68) and should
not undermine the deliverability of the Local Plan (Para 34). To this end, the SWLP will
need to be supported by a Viability Assessment that cumulatively tests the impact of policy
and infrastructure requirements on the viability of sites allocated in the SWLP. This should
include any site-specific infrastructure required to support the delivery of some sites, as
well as any Community Infrastructure Levy.