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ID sylw: 108376

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

15.1 Paragraph 7 of the NPPF states that the purpose of the planning system is to contribute to
the achievement of sustainable development and Paragraph 8 of the NPPF is clear that
sustainable development comprises three overarching objectives: economic, social and
environmental. It is also clear that opportunities should be taken to achieve net gains (Para
8). On the face of it, the delivery of Environmental Net Gain [ENG] would align with the
NPPF and also be appropriate given that the SWCs have declared climate emergencies – it
would also align with WDC’s ‘Climate Emergency Action Programme’ and SOADC’s
‘Council Plan 2019-2023’. As such, Mackenzie Miller Homes broadly supports the SWC’s
wider sustainable development aspirations and the principle of ENG.
15.2 Mackenzie Miller Homes recognises that ENG involves a series of comprehensive 'net
improvements' to nature, including enhancements to water and air quality. Despite
Mackenzie Miller Homes overall support, the SWCs should consider Paragraph 16(f) of the
NPPF, which emphasizes serving a clear purpose and avoiding unnecessary duplication. It's
crucial to read Development Plans in their entirety. Therefore, Mackenzie Miller Homes
believes that, in its current form, the draft policy does not 'serve a clear purpose' or avoid
'unnecessary duplication,' as decision-makers must consider the broader SWLP policies,
such as draft Policy Directions 22, 24, 29, and 39, when interpreting the SWLP as a whole
15.3 Furthermore, Paragraph 16(b) of the NPPF is clear that policies should be aspirational, but
deliverable and Paragraph 16(d) sets out that policies should be clearly written and
unambiguous, so it is evident how a decision-maker should react to development proposals.
15.4 While it is acknowledged that the SWCs are in the early stages of plan-making, Mackenzie
Miller Homes is currently concerned that the SWCs may aim to establish a policy that is
'aspirational' but not 'deliverable.' At present, the policy is 'unclear' due to the absence of an
existing ENG framework. The SWCs themselves acknowledge this in the PO (Pg.158),
noting that such a framework has not yet been formulated.