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ID sylw: 108287

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

We are generally supportive of requirements of Draft Policy Direction 38, however, it is noted that the Policy makes reference to the SWLP exploring evidence to seek higher percentage of BNG than the statutory 10% requirement. There is no national policy requirement for this. Any proposal of this nature must be viability tested.
BNG provision can have significant implications on the viability of development sites and their capacity. In order for Councils to seek greater than 10% BNG, robust viability evidence must be presented. It must be demonstrated that the Councils have an understanding of the ability and potential of housing allocations to deliver 15% BNG without adversely affecting their capacity or compromising any other planning obligations.