Main Modifications Consultation
Search representations
Results for Home Builders Federation search
New search New searchObject
Main Modifications Consultation
MM1
Representation ID: 9176
Received: 07/09/2026
Respondent: Home Builders Federation
This Modification needs updating to reflect that the provision of in the LURA about the new plan-making system have now been enacted. For the reasons set out in our general comments section above HBF also suggests that this section now needs updating to reflect the new NPPF and the existence of the new national Development Management Policies.
Rutland Local Plan Main Modifications Consultation Sept 2026
1. Thank you for consulting with the Home Builders Federation (HBF) on the Rutland Local Plan Main Modifications Consultation Sept 2026.
2. HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which include national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing.
3. HBF welcomes the Council’s efforts to ensure that they have an up-to-date Local Plan. Plan-making is a fundamental part of a Local Authority’s role and is essential to support the delivery new homes and jobs. Government policy remains clear that a significant increase in house building is needed in order to deliver the 1.5 million new homes in this Parliament. Full Local Plan coverage is also important .
4. We note that the new NPPF has been released during the consultation period. HBF are keen to understand the implications of this on both the content of the current Plan and the EIP process. As the whole purpose of a Local Plan is to help in the determination of planning applications, we are keen to understand how the Council intends to reflect the fact that the new NPPF introduces national development management policies that apply immediately.
5. The Proposed Main Modifications seek to address concerns about soundness of the Plan raised during the Examination process. However, there have also been developments in national planning and other policy areas that suggest further Main Modifications to the Rutland Plan may be needed. We have therefore set out these broader observations first and then our specific comments on the Main Modifications themselves.
Impacts of the new NPPF
6. As you will also be aware the Government published its long-awaited new NPPF on 17th August 2026. This sets out national planning in a new way, separating policies for plan-making from those for determining planning applications. The new NPPF introduces national development management policies that apply immediately. This includes the presumption in favour of development within settlements.
7. The new NPPF clearly sets out that the Government’s view that Local Policies which conflict with the new guidance should not be able to be taken into account in decision-making. It is important that plan-users understand how the new NPPF and the new Rutland Plan will work together for decision-making. HBF therefore suggest that further modifications to supporting text of the Plan are needed to explain this new situation. We would also strongly encourage the Council to also consider the implications of the new approach on the proposed suite of Development Management policies in the Rutland Plan to see if they have been impacted, effectively replaced or made redundant by the new NPPF.
Revision to National Biodiversity Net Gain (BNG) Policy
8. As you will know the Government published its responses to the BNG consultation on 15th April 2026. See the links below:
Improving the implementation of BNG for minor, medium and brownfield development
Biodiversity net gain for nationally significant infrastructure projects
9. The first raft of intended changes have now been implemented with the introduction of a 0.2 Ha exemption and small sites being able to deliver off-site. Further changes, including revisions to the statutory metric are expected shortly.
Worsening Viability
10. HBF are also mindful of the recent ministerial letter about viability and Local Plans. However, our members’ experience suggests that the viability challenges facing developers are not just a short-term issue triggered by geo-political events. Although this has undoubtedly made viability worse, even without this recent turmoil viability would be difficult due to increasing cost burdens and policy requirements.
11. HBF recently published our ‘Viability Crunch report’ https://www.hbf.co.uk/research-insight/viability-crunch/ which details the cumulative impact of increasing regulatory, and other requirements, on the viability and deliverability of development. This has added an average of £76,00 to the cost of a new home over compared to five years ago. We remain concerned that the ever-increasing regulatory burden will have an impact on both the viability and deliverability of this Plan.
MM1
12. This Modification needs updating to reflect that the provision of in the LURA about the new plan-making system have now been enacted. For the reasons set out in our general comments section above HBF also suggests that this section now needs updating to reflect the new NPPF and the existence of the new national Development Management Policies.
MM2
13. Now that the Future Homes Standard has bene published, HBF do not think any reference to other standards, such as Passivhaus, are needed or appropriate.
MM5 and MM6
14. Now that the Future Homes Standard has been published, HBF suggests the wording of this policy and supporting text may need further revisions, and this Main Modification is no longer appropriate.
MM7
15. Now that the Future Homes Standard has been published, the wording of this policy and supporting text may need further revisions.
MM12
16. HBF support the additional of the reference to the guidance provided in the PPG.
MM15
17. For the reason set out in our general comments section above HBF suggests that this policy and/or the supporting text may now need updating to reflect the new NPPF.
MM39
18. For the reasons we have set out in our general comments about viability HBF suggests that this policy needs to include additional flexibility. The new (2026) NPPF also set out a wider variety of circumstances that would enable site specific viability to be assessed.
MM71
19. HBF object to the inclusion of any locational hierarchy for off-site BNG. Such policies are contrary to national BNG policy and guidance. The metric already penalises development that needs to utlise off-site BNG units located further away from the development, and it is not justified, appropriate or sound for the Rutland Plan to introduce any further policy restrictions about this. The new NPPF is very explicit that Local Plans should not seek to add to, augment or supplement national BNG policy and guidance with locally distinctive requirement like this Main Modification proposed policy. Such an approach is therefore inconsistent with both the previous and current NPPF guidance and should be deleted.
20. The reference to statutory credits is also incorrect as national policy states these are to be used as a last resort. There is no justification for any further requirements and as such reference to following the locational criteria in this section is both unnecessary and unsound.
Monitoring Framework- MM99 and MM100
21. Monitoring is an essential part of the plan, monitor, approach. However, to be effective and justified the Monitoring Framework needs to set out what actions would be taken if monitoring identified any issues with the Local Plan policies. For example, what would the Council do if there was an under-delivery of housing in one year. We suggest therefore that there needs to be an action column added to the Monitoring Framework and further Main Modifications are needed. It is not really the monitoring of a policy itself that is important, but what actions are taken if any issues are found that are important for the effectiveness of the Plan.
Future Engagement
22. I trust that the Council will find these comments useful as it continues to progress its Local Plan. I would be happy to discuss these issues in greater detail or assist in facilitating discussions with the wider house-building industry.
23. HBF would like to be kept up to date about the progress of the Rutland Local Plan and associated documents. Please use the contact details provided below for future correspondence.
Attachments:
- Main Modification Response Redacted (84.25 KB)
- Main Modifications Consultation - HBF Email Redacted (214.39 KB)
Object
Main Modifications Consultation
MM4
Representation ID: 9177
Received: 07/09/2026
Respondent: Home Builders Federation
Now that the Future Homes Standard has been published, HBF do not think any reference to other standards, such as Passivhaus, are needed or appropriate.
Rutland Local Plan Main Modifications Consultation Sept 2026
1. Thank you for consulting with the Home Builders Federation (HBF) on the Rutland Local Plan Main Modifications Consultation Sept 2026.
2. HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which include national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing.
3. HBF welcomes the Council’s efforts to ensure that they have an up-to-date Local Plan. Plan-making is a fundamental part of a Local Authority’s role and is essential to support the delivery new homes and jobs. Government policy remains clear that a significant increase in house building is needed in order to deliver the 1.5 million new homes in this Parliament. Full Local Plan coverage is also important .
4. We note that the new NPPF has been released during the consultation period. HBF are keen to understand the implications of this on both the content of the current Plan and the EIP process. As the whole purpose of a Local Plan is to help in the determination of planning applications, we are keen to understand how the Council intends to reflect the fact that the new NPPF introduces national development management policies that apply immediately.
5. The Proposed Main Modifications seek to address concerns about soundness of the Plan raised during the Examination process. However, there have also been developments in national planning and other policy areas that suggest further Main Modifications to the Rutland Plan may be needed. We have therefore set out these broader observations first and then our specific comments on the Main Modifications themselves.
Impacts of the new NPPF
6. As you will also be aware the Government published its long-awaited new NPPF on 17th August 2026. This sets out national planning in a new way, separating policies for plan-making from those for determining planning applications. The new NPPF introduces national development management policies that apply immediately. This includes the presumption in favour of development within settlements.
7. The new NPPF clearly sets out that the Government’s view that Local Policies which conflict with the new guidance should not be able to be taken into account in decision-making. It is important that plan-users understand how the new NPPF and the new Rutland Plan will work together for decision-making. HBF therefore suggest that further modifications to supporting text of the Plan are needed to explain this new situation. We would also strongly encourage the Council to also consider the implications of the new approach on the proposed suite of Development Management policies in the Rutland Plan to see if they have been impacted, effectively replaced or made redundant by the new NPPF.
Revision to National Biodiversity Net Gain (BNG) Policy
8. As you will know the Government published its responses to the BNG consultation on 15th April 2026. See the links below:
Improving the implementation of BNG for minor, medium and brownfield development
Biodiversity net gain for nationally significant infrastructure projects
9. The first raft of intended changes have now been implemented with the introduction of a 0.2 Ha exemption and small sites being able to deliver off-site. Further changes, including revisions to the statutory metric are expected shortly.
Worsening Viability
10. HBF are also mindful of the recent ministerial letter about viability and Local Plans. However, our members’ experience suggests that the viability challenges facing developers are not just a short-term issue triggered by geo-political events. Although this has undoubtedly made viability worse, even without this recent turmoil viability would be difficult due to increasing cost burdens and policy requirements.
11. HBF recently published our ‘Viability Crunch report’ https://www.hbf.co.uk/research-insight/viability-crunch/ which details the cumulative impact of increasing regulatory, and other requirements, on the viability and deliverability of development. This has added an average of £76,00 to the cost of a new home over compared to five years ago. We remain concerned that the ever-increasing regulatory burden will have an impact on both the viability and deliverability of this Plan.
MM1
12. This Modification needs updating to reflect that the provision of in the LURA about the new plan-making system have now been enacted. For the reasons set out in our general comments section above HBF also suggests that this section now needs updating to reflect the new NPPF and the existence of the new national Development Management Policies.
MM2
13. Now that the Future Homes Standard has bene published, HBF do not think any reference to other standards, such as Passivhaus, are needed or appropriate.
MM5 and MM6
14. Now that the Future Homes Standard has been published, HBF suggests the wording of this policy and supporting text may need further revisions, and this Main Modification is no longer appropriate.
MM7
15. Now that the Future Homes Standard has been published, the wording of this policy and supporting text may need further revisions.
MM12
16. HBF support the additional of the reference to the guidance provided in the PPG.
MM15
17. For the reason set out in our general comments section above HBF suggests that this policy and/or the supporting text may now need updating to reflect the new NPPF.
MM39
18. For the reasons we have set out in our general comments about viability HBF suggests that this policy needs to include additional flexibility. The new (2026) NPPF also set out a wider variety of circumstances that would enable site specific viability to be assessed.
MM71
19. HBF object to the inclusion of any locational hierarchy for off-site BNG. Such policies are contrary to national BNG policy and guidance. The metric already penalises development that needs to utlise off-site BNG units located further away from the development, and it is not justified, appropriate or sound for the Rutland Plan to introduce any further policy restrictions about this. The new NPPF is very explicit that Local Plans should not seek to add to, augment or supplement national BNG policy and guidance with locally distinctive requirement like this Main Modification proposed policy. Such an approach is therefore inconsistent with both the previous and current NPPF guidance and should be deleted.
20. The reference to statutory credits is also incorrect as national policy states these are to be used as a last resort. There is no justification for any further requirements and as such reference to following the locational criteria in this section is both unnecessary and unsound.
Monitoring Framework- MM99 and MM100
21. Monitoring is an essential part of the plan, monitor, approach. However, to be effective and justified the Monitoring Framework needs to set out what actions would be taken if monitoring identified any issues with the Local Plan policies. For example, what would the Council do if there was an under-delivery of housing in one year. We suggest therefore that there needs to be an action column added to the Monitoring Framework and further Main Modifications are needed. It is not really the monitoring of a policy itself that is important, but what actions are taken if any issues are found that are important for the effectiveness of the Plan.
Future Engagement
22. I trust that the Council will find these comments useful as it continues to progress its Local Plan. I would be happy to discuss these issues in greater detail or assist in facilitating discussions with the wider house-building industry.
23. HBF would like to be kept up to date about the progress of the Rutland Local Plan and associated documents. Please use the contact details provided below for future correspondence.
Attachments:
- Main Modification Response Redacted (84.25 KB)
- Main Modifications Consultation - HBF Email Redacted (214.39 KB)
Object
Main Modifications Consultation
MM5
Representation ID: 9178
Received: 07/09/2026
Respondent: Home Builders Federation
Now that the Future Homes Standard has been published, HBF suggests the wording of this policy and supporting text may need further revisions, and this Main Modification is no longer appropriate.
Rutland Local Plan Main Modifications Consultation Sept 2026
1. Thank you for consulting with the Home Builders Federation (HBF) on the Rutland Local Plan Main Modifications Consultation Sept 2026.
2. HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which include national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing.
3. HBF welcomes the Council’s efforts to ensure that they have an up-to-date Local Plan. Plan-making is a fundamental part of a Local Authority’s role and is essential to support the delivery new homes and jobs. Government policy remains clear that a significant increase in house building is needed in order to deliver the 1.5 million new homes in this Parliament. Full Local Plan coverage is also important .
4. We note that the new NPPF has been released during the consultation period. HBF are keen to understand the implications of this on both the content of the current Plan and the EIP process. As the whole purpose of a Local Plan is to help in the determination of planning applications, we are keen to understand how the Council intends to reflect the fact that the new NPPF introduces national development management policies that apply immediately.
5. The Proposed Main Modifications seek to address concerns about soundness of the Plan raised during the Examination process. However, there have also been developments in national planning and other policy areas that suggest further Main Modifications to the Rutland Plan may be needed. We have therefore set out these broader observations first and then our specific comments on the Main Modifications themselves.
Impacts of the new NPPF
6. As you will also be aware the Government published its long-awaited new NPPF on 17th August 2026. This sets out national planning in a new way, separating policies for plan-making from those for determining planning applications. The new NPPF introduces national development management policies that apply immediately. This includes the presumption in favour of development within settlements.
7. The new NPPF clearly sets out that the Government’s view that Local Policies which conflict with the new guidance should not be able to be taken into account in decision-making. It is important that plan-users understand how the new NPPF and the new Rutland Plan will work together for decision-making. HBF therefore suggest that further modifications to supporting text of the Plan are needed to explain this new situation. We would also strongly encourage the Council to also consider the implications of the new approach on the proposed suite of Development Management policies in the Rutland Plan to see if they have been impacted, effectively replaced or made redundant by the new NPPF.
Revision to National Biodiversity Net Gain (BNG) Policy
8. As you will know the Government published its responses to the BNG consultation on 15th April 2026. See the links below:
Improving the implementation of BNG for minor, medium and brownfield development
Biodiversity net gain for nationally significant infrastructure projects
9. The first raft of intended changes have now been implemented with the introduction of a 0.2 Ha exemption and small sites being able to deliver off-site. Further changes, including revisions to the statutory metric are expected shortly.
Worsening Viability
10. HBF are also mindful of the recent ministerial letter about viability and Local Plans. However, our members’ experience suggests that the viability challenges facing developers are not just a short-term issue triggered by geo-political events. Although this has undoubtedly made viability worse, even without this recent turmoil viability would be difficult due to increasing cost burdens and policy requirements.
11. HBF recently published our ‘Viability Crunch report’ https://www.hbf.co.uk/research-insight/viability-crunch/ which details the cumulative impact of increasing regulatory, and other requirements, on the viability and deliverability of development. This has added an average of £76,00 to the cost of a new home over compared to five years ago. We remain concerned that the ever-increasing regulatory burden will have an impact on both the viability and deliverability of this Plan.
MM1
12. This Modification needs updating to reflect that the provision of in the LURA about the new plan-making system have now been enacted. For the reasons set out in our general comments section above HBF also suggests that this section now needs updating to reflect the new NPPF and the existence of the new national Development Management Policies.
MM2
13. Now that the Future Homes Standard has bene published, HBF do not think any reference to other standards, such as Passivhaus, are needed or appropriate.
MM5 and MM6
14. Now that the Future Homes Standard has been published, HBF suggests the wording of this policy and supporting text may need further revisions, and this Main Modification is no longer appropriate.
MM7
15. Now that the Future Homes Standard has been published, the wording of this policy and supporting text may need further revisions.
MM12
16. HBF support the additional of the reference to the guidance provided in the PPG.
MM15
17. For the reason set out in our general comments section above HBF suggests that this policy and/or the supporting text may now need updating to reflect the new NPPF.
MM39
18. For the reasons we have set out in our general comments about viability HBF suggests that this policy needs to include additional flexibility. The new (2026) NPPF also set out a wider variety of circumstances that would enable site specific viability to be assessed.
MM71
19. HBF object to the inclusion of any locational hierarchy for off-site BNG. Such policies are contrary to national BNG policy and guidance. The metric already penalises development that needs to utlise off-site BNG units located further away from the development, and it is not justified, appropriate or sound for the Rutland Plan to introduce any further policy restrictions about this. The new NPPF is very explicit that Local Plans should not seek to add to, augment or supplement national BNG policy and guidance with locally distinctive requirement like this Main Modification proposed policy. Such an approach is therefore inconsistent with both the previous and current NPPF guidance and should be deleted.
20. The reference to statutory credits is also incorrect as national policy states these are to be used as a last resort. There is no justification for any further requirements and as such reference to following the locational criteria in this section is both unnecessary and unsound.
Monitoring Framework- MM99 and MM100
21. Monitoring is an essential part of the plan, monitor, approach. However, to be effective and justified the Monitoring Framework needs to set out what actions would be taken if monitoring identified any issues with the Local Plan policies. For example, what would the Council do if there was an under-delivery of housing in one year. We suggest therefore that there needs to be an action column added to the Monitoring Framework and further Main Modifications are needed. It is not really the monitoring of a policy itself that is important, but what actions are taken if any issues are found that are important for the effectiveness of the Plan.
Future Engagement
22. I trust that the Council will find these comments useful as it continues to progress its Local Plan. I would be happy to discuss these issues in greater detail or assist in facilitating discussions with the wider house-building industry.
23. HBF would like to be kept up to date about the progress of the Rutland Local Plan and associated documents. Please use the contact details provided below for future correspondence.
Attachments:
- Main Modification Response Redacted (84.25 KB)
- Main Modifications Consultation - HBF Email Redacted (214.39 KB)
Object
Main Modifications Consultation
MM6
Representation ID: 9179
Received: 07/09/2026
Respondent: Home Builders Federation
Now that the Future Homes Standard has been published, HBF suggests the wording of this policy and supporting text may need further revisions, and this Main Modification is no longer appropriate.
Rutland Local Plan Main Modifications Consultation Sept 2026
1. Thank you for consulting with the Home Builders Federation (HBF) on the Rutland Local Plan Main Modifications Consultation Sept 2026.
2. HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which include national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing.
3. HBF welcomes the Council’s efforts to ensure that they have an up-to-date Local Plan. Plan-making is a fundamental part of a Local Authority’s role and is essential to support the delivery new homes and jobs. Government policy remains clear that a significant increase in house building is needed in order to deliver the 1.5 million new homes in this Parliament. Full Local Plan coverage is also important .
4. We note that the new NPPF has been released during the consultation period. HBF are keen to understand the implications of this on both the content of the current Plan and the EIP process. As the whole purpose of a Local Plan is to help in the determination of planning applications, we are keen to understand how the Council intends to reflect the fact that the new NPPF introduces national development management policies that apply immediately.
5. The Proposed Main Modifications seek to address concerns about soundness of the Plan raised during the Examination process. However, there have also been developments in national planning and other policy areas that suggest further Main Modifications to the Rutland Plan may be needed. We have therefore set out these broader observations first and then our specific comments on the Main Modifications themselves.
Impacts of the new NPPF
6. As you will also be aware the Government published its long-awaited new NPPF on 17th August 2026. This sets out national planning in a new way, separating policies for plan-making from those for determining planning applications. The new NPPF introduces national development management policies that apply immediately. This includes the presumption in favour of development within settlements.
7. The new NPPF clearly sets out that the Government’s view that Local Policies which conflict with the new guidance should not be able to be taken into account in decision-making. It is important that plan-users understand how the new NPPF and the new Rutland Plan will work together for decision-making. HBF therefore suggest that further modifications to supporting text of the Plan are needed to explain this new situation. We would also strongly encourage the Council to also consider the implications of the new approach on the proposed suite of Development Management policies in the Rutland Plan to see if they have been impacted, effectively replaced or made redundant by the new NPPF.
Revision to National Biodiversity Net Gain (BNG) Policy
8. As you will know the Government published its responses to the BNG consultation on 15th April 2026. See the links below:
Improving the implementation of BNG for minor, medium and brownfield development
Biodiversity net gain for nationally significant infrastructure projects
9. The first raft of intended changes have now been implemented with the introduction of a 0.2 Ha exemption and small sites being able to deliver off-site. Further changes, including revisions to the statutory metric are expected shortly.
Worsening Viability
10. HBF are also mindful of the recent ministerial letter about viability and Local Plans. However, our members’ experience suggests that the viability challenges facing developers are not just a short-term issue triggered by geo-political events. Although this has undoubtedly made viability worse, even without this recent turmoil viability would be difficult due to increasing cost burdens and policy requirements.
11. HBF recently published our ‘Viability Crunch report’ https://www.hbf.co.uk/research-insight/viability-crunch/ which details the cumulative impact of increasing regulatory, and other requirements, on the viability and deliverability of development. This has added an average of £76,00 to the cost of a new home over compared to five years ago. We remain concerned that the ever-increasing regulatory burden will have an impact on both the viability and deliverability of this Plan.
MM1
12. This Modification needs updating to reflect that the provision of in the LURA about the new plan-making system have now been enacted. For the reasons set out in our general comments section above HBF also suggests that this section now needs updating to reflect the new NPPF and the existence of the new national Development Management Policies.
MM2
13. Now that the Future Homes Standard has bene published, HBF do not think any reference to other standards, such as Passivhaus, are needed or appropriate.
MM5 and MM6
14. Now that the Future Homes Standard has been published, HBF suggests the wording of this policy and supporting text may need further revisions, and this Main Modification is no longer appropriate.
MM7
15. Now that the Future Homes Standard has been published, the wording of this policy and supporting text may need further revisions.
MM12
16. HBF support the additional of the reference to the guidance provided in the PPG.
MM15
17. For the reason set out in our general comments section above HBF suggests that this policy and/or the supporting text may now need updating to reflect the new NPPF.
MM39
18. For the reasons we have set out in our general comments about viability HBF suggests that this policy needs to include additional flexibility. The new (2026) NPPF also set out a wider variety of circumstances that would enable site specific viability to be assessed.
MM71
19. HBF object to the inclusion of any locational hierarchy for off-site BNG. Such policies are contrary to national BNG policy and guidance. The metric already penalises development that needs to utlise off-site BNG units located further away from the development, and it is not justified, appropriate or sound for the Rutland Plan to introduce any further policy restrictions about this. The new NPPF is very explicit that Local Plans should not seek to add to, augment or supplement national BNG policy and guidance with locally distinctive requirement like this Main Modification proposed policy. Such an approach is therefore inconsistent with both the previous and current NPPF guidance and should be deleted.
20. The reference to statutory credits is also incorrect as national policy states these are to be used as a last resort. There is no justification for any further requirements and as such reference to following the locational criteria in this section is both unnecessary and unsound.
Monitoring Framework- MM99 and MM100
21. Monitoring is an essential part of the plan, monitor, approach. However, to be effective and justified the Monitoring Framework needs to set out what actions would be taken if monitoring identified any issues with the Local Plan policies. For example, what would the Council do if there was an under-delivery of housing in one year. We suggest therefore that there needs to be an action column added to the Monitoring Framework and further Main Modifications are needed. It is not really the monitoring of a policy itself that is important, but what actions are taken if any issues are found that are important for the effectiveness of the Plan.
Future Engagement
22. I trust that the Council will find these comments useful as it continues to progress its Local Plan. I would be happy to discuss these issues in greater detail or assist in facilitating discussions with the wider house-building industry.
23. HBF would like to be kept up to date about the progress of the Rutland Local Plan and associated documents. Please use the contact details provided below for future correspondence.
Attachments:
- Main Modification Response Redacted (84.25 KB)
- Main Modifications Consultation - HBF Email Redacted (214.39 KB)
Object
Main Modifications Consultation
MM7
Representation ID: 9180
Received: 07/09/2026
Respondent: Home Builders Federation
Now that the Future Homes Standard has been published, the wording of this policy and supporting text may need further revisions.
Rutland Local Plan Main Modifications Consultation Sept 2026
1. Thank you for consulting with the Home Builders Federation (HBF) on the Rutland Local Plan Main Modifications Consultation Sept 2026.
2. HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which include national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing.
3. HBF welcomes the Council’s efforts to ensure that they have an up-to-date Local Plan. Plan-making is a fundamental part of a Local Authority’s role and is essential to support the delivery new homes and jobs. Government policy remains clear that a significant increase in house building is needed in order to deliver the 1.5 million new homes in this Parliament. Full Local Plan coverage is also important .
4. We note that the new NPPF has been released during the consultation period. HBF are keen to understand the implications of this on both the content of the current Plan and the EIP process. As the whole purpose of a Local Plan is to help in the determination of planning applications, we are keen to understand how the Council intends to reflect the fact that the new NPPF introduces national development management policies that apply immediately.
5. The Proposed Main Modifications seek to address concerns about soundness of the Plan raised during the Examination process. However, there have also been developments in national planning and other policy areas that suggest further Main Modifications to the Rutland Plan may be needed. We have therefore set out these broader observations first and then our specific comments on the Main Modifications themselves.
Impacts of the new NPPF
6. As you will also be aware the Government published its long-awaited new NPPF on 17th August 2026. This sets out national planning in a new way, separating policies for plan-making from those for determining planning applications. The new NPPF introduces national development management policies that apply immediately. This includes the presumption in favour of development within settlements.
7. The new NPPF clearly sets out that the Government’s view that Local Policies which conflict with the new guidance should not be able to be taken into account in decision-making. It is important that plan-users understand how the new NPPF and the new Rutland Plan will work together for decision-making. HBF therefore suggest that further modifications to supporting text of the Plan are needed to explain this new situation. We would also strongly encourage the Council to also consider the implications of the new approach on the proposed suite of Development Management policies in the Rutland Plan to see if they have been impacted, effectively replaced or made redundant by the new NPPF.
Revision to National Biodiversity Net Gain (BNG) Policy
8. As you will know the Government published its responses to the BNG consultation on 15th April 2026. See the links below:
Improving the implementation of BNG for minor, medium and brownfield development
Biodiversity net gain for nationally significant infrastructure projects
9. The first raft of intended changes have now been implemented with the introduction of a 0.2 Ha exemption and small sites being able to deliver off-site. Further changes, including revisions to the statutory metric are expected shortly.
Worsening Viability
10. HBF are also mindful of the recent ministerial letter about viability and Local Plans. However, our members’ experience suggests that the viability challenges facing developers are not just a short-term issue triggered by geo-political events. Although this has undoubtedly made viability worse, even without this recent turmoil viability would be difficult due to increasing cost burdens and policy requirements.
11. HBF recently published our ‘Viability Crunch report’ https://www.hbf.co.uk/research-insight/viability-crunch/ which details the cumulative impact of increasing regulatory, and other requirements, on the viability and deliverability of development. This has added an average of £76,00 to the cost of a new home over compared to five years ago. We remain concerned that the ever-increasing regulatory burden will have an impact on both the viability and deliverability of this Plan.
MM1
12. This Modification needs updating to reflect that the provision of in the LURA about the new plan-making system have now been enacted. For the reasons set out in our general comments section above HBF also suggests that this section now needs updating to reflect the new NPPF and the existence of the new national Development Management Policies.
MM2
13. Now that the Future Homes Standard has bene published, HBF do not think any reference to other standards, such as Passivhaus, are needed or appropriate.
MM5 and MM6
14. Now that the Future Homes Standard has been published, HBF suggests the wording of this policy and supporting text may need further revisions, and this Main Modification is no longer appropriate.
MM7
15. Now that the Future Homes Standard has been published, the wording of this policy and supporting text may need further revisions.
MM12
16. HBF support the additional of the reference to the guidance provided in the PPG.
MM15
17. For the reason set out in our general comments section above HBF suggests that this policy and/or the supporting text may now need updating to reflect the new NPPF.
MM39
18. For the reasons we have set out in our general comments about viability HBF suggests that this policy needs to include additional flexibility. The new (2026) NPPF also set out a wider variety of circumstances that would enable site specific viability to be assessed.
MM71
19. HBF object to the inclusion of any locational hierarchy for off-site BNG. Such policies are contrary to national BNG policy and guidance. The metric already penalises development that needs to utlise off-site BNG units located further away from the development, and it is not justified, appropriate or sound for the Rutland Plan to introduce any further policy restrictions about this. The new NPPF is very explicit that Local Plans should not seek to add to, augment or supplement national BNG policy and guidance with locally distinctive requirement like this Main Modification proposed policy. Such an approach is therefore inconsistent with both the previous and current NPPF guidance and should be deleted.
20. The reference to statutory credits is also incorrect as national policy states these are to be used as a last resort. There is no justification for any further requirements and as such reference to following the locational criteria in this section is both unnecessary and unsound.
Monitoring Framework- MM99 and MM100
21. Monitoring is an essential part of the plan, monitor, approach. However, to be effective and justified the Monitoring Framework needs to set out what actions would be taken if monitoring identified any issues with the Local Plan policies. For example, what would the Council do if there was an under-delivery of housing in one year. We suggest therefore that there needs to be an action column added to the Monitoring Framework and further Main Modifications are needed. It is not really the monitoring of a policy itself that is important, but what actions are taken if any issues are found that are important for the effectiveness of the Plan.
Future Engagement
22. I trust that the Council will find these comments useful as it continues to progress its Local Plan. I would be happy to discuss these issues in greater detail or assist in facilitating discussions with the wider house-building industry.
23. HBF would like to be kept up to date about the progress of the Rutland Local Plan and associated documents. Please use the contact details provided below for future correspondence.
Attachments:
- Main Modification Response Redacted (84.25 KB)
- Main Modifications Consultation - HBF Email Redacted (214.39 KB)
Support
Main Modifications Consultation
MM12
Representation ID: 9181
Received: 07/09/2026
Respondent: Home Builders Federation
HBF support the additional of the reference to the guidance provided in the PPG.
Rutland Local Plan Main Modifications Consultation Sept 2026
1. Thank you for consulting with the Home Builders Federation (HBF) on the Rutland Local Plan Main Modifications Consultation Sept 2026.
2. HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which include national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing.
3. HBF welcomes the Council’s efforts to ensure that they have an up-to-date Local Plan. Plan-making is a fundamental part of a Local Authority’s role and is essential to support the delivery new homes and jobs. Government policy remains clear that a significant increase in house building is needed in order to deliver the 1.5 million new homes in this Parliament. Full Local Plan coverage is also important .
4. We note that the new NPPF has been released during the consultation period. HBF are keen to understand the implications of this on both the content of the current Plan and the EIP process. As the whole purpose of a Local Plan is to help in the determination of planning applications, we are keen to understand how the Council intends to reflect the fact that the new NPPF introduces national development management policies that apply immediately.
5. The Proposed Main Modifications seek to address concerns about soundness of the Plan raised during the Examination process. However, there have also been developments in national planning and other policy areas that suggest further Main Modifications to the Rutland Plan may be needed. We have therefore set out these broader observations first and then our specific comments on the Main Modifications themselves.
Impacts of the new NPPF
6. As you will also be aware the Government published its long-awaited new NPPF on 17th August 2026. This sets out national planning in a new way, separating policies for plan-making from those for determining planning applications. The new NPPF introduces national development management policies that apply immediately. This includes the presumption in favour of development within settlements.
7. The new NPPF clearly sets out that the Government’s view that Local Policies which conflict with the new guidance should not be able to be taken into account in decision-making. It is important that plan-users understand how the new NPPF and the new Rutland Plan will work together for decision-making. HBF therefore suggest that further modifications to supporting text of the Plan are needed to explain this new situation. We would also strongly encourage the Council to also consider the implications of the new approach on the proposed suite of Development Management policies in the Rutland Plan to see if they have been impacted, effectively replaced or made redundant by the new NPPF.
Revision to National Biodiversity Net Gain (BNG) Policy
8. As you will know the Government published its responses to the BNG consultation on 15th April 2026. See the links below:
Improving the implementation of BNG for minor, medium and brownfield development
Biodiversity net gain for nationally significant infrastructure projects
9. The first raft of intended changes have now been implemented with the introduction of a 0.2 Ha exemption and small sites being able to deliver off-site. Further changes, including revisions to the statutory metric are expected shortly.
Worsening Viability
10. HBF are also mindful of the recent ministerial letter about viability and Local Plans. However, our members’ experience suggests that the viability challenges facing developers are not just a short-term issue triggered by geo-political events. Although this has undoubtedly made viability worse, even without this recent turmoil viability would be difficult due to increasing cost burdens and policy requirements.
11. HBF recently published our ‘Viability Crunch report’ https://www.hbf.co.uk/research-insight/viability-crunch/ which details the cumulative impact of increasing regulatory, and other requirements, on the viability and deliverability of development. This has added an average of £76,00 to the cost of a new home over compared to five years ago. We remain concerned that the ever-increasing regulatory burden will have an impact on both the viability and deliverability of this Plan.
MM1
12. This Modification needs updating to reflect that the provision of in the LURA about the new plan-making system have now been enacted. For the reasons set out in our general comments section above HBF also suggests that this section now needs updating to reflect the new NPPF and the existence of the new national Development Management Policies.
MM2
13. Now that the Future Homes Standard has bene published, HBF do not think any reference to other standards, such as Passivhaus, are needed or appropriate.
MM5 and MM6
14. Now that the Future Homes Standard has been published, HBF suggests the wording of this policy and supporting text may need further revisions, and this Main Modification is no longer appropriate.
MM7
15. Now that the Future Homes Standard has been published, the wording of this policy and supporting text may need further revisions.
MM12
16. HBF support the additional of the reference to the guidance provided in the PPG.
MM15
17. For the reason set out in our general comments section above HBF suggests that this policy and/or the supporting text may now need updating to reflect the new NPPF.
MM39
18. For the reasons we have set out in our general comments about viability HBF suggests that this policy needs to include additional flexibility. The new (2026) NPPF also set out a wider variety of circumstances that would enable site specific viability to be assessed.
MM71
19. HBF object to the inclusion of any locational hierarchy for off-site BNG. Such policies are contrary to national BNG policy and guidance. The metric already penalises development that needs to utlise off-site BNG units located further away from the development, and it is not justified, appropriate or sound for the Rutland Plan to introduce any further policy restrictions about this. The new NPPF is very explicit that Local Plans should not seek to add to, augment or supplement national BNG policy and guidance with locally distinctive requirement like this Main Modification proposed policy. Such an approach is therefore inconsistent with both the previous and current NPPF guidance and should be deleted.
20. The reference to statutory credits is also incorrect as national policy states these are to be used as a last resort. There is no justification for any further requirements and as such reference to following the locational criteria in this section is both unnecessary and unsound.
Monitoring Framework- MM99 and MM100
21. Monitoring is an essential part of the plan, monitor, approach. However, to be effective and justified the Monitoring Framework needs to set out what actions would be taken if monitoring identified any issues with the Local Plan policies. For example, what would the Council do if there was an under-delivery of housing in one year. We suggest therefore that there needs to be an action column added to the Monitoring Framework and further Main Modifications are needed. It is not really the monitoring of a policy itself that is important, but what actions are taken if any issues are found that are important for the effectiveness of the Plan.
Future Engagement
22. I trust that the Council will find these comments useful as it continues to progress its Local Plan. I would be happy to discuss these issues in greater detail or assist in facilitating discussions with the wider house-building industry.
23. HBF would like to be kept up to date about the progress of the Rutland Local Plan and associated documents. Please use the contact details provided below for future correspondence.
Attachments:
- Main Modification Response Redacted (84.25 KB)
- Main Modifications Consultation - HBF Email Redacted (214.39 KB)
Object
Main Modifications Consultation
MM15
Representation ID: 9182
Received: 07/09/2026
Respondent: Home Builders Federation
For the reason set out in our general comments section above HBF suggests that this policy and/or the supporting text may now need updating to reflect the new NPPF.
Rutland Local Plan Main Modifications Consultation Sept 2026
1. Thank you for consulting with the Home Builders Federation (HBF) on the Rutland Local Plan Main Modifications Consultation Sept 2026.
2. HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which include national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing.
3. HBF welcomes the Council’s efforts to ensure that they have an up-to-date Local Plan. Plan-making is a fundamental part of a Local Authority’s role and is essential to support the delivery new homes and jobs. Government policy remains clear that a significant increase in house building is needed in order to deliver the 1.5 million new homes in this Parliament. Full Local Plan coverage is also important .
4. We note that the new NPPF has been released during the consultation period. HBF are keen to understand the implications of this on both the content of the current Plan and the EIP process. As the whole purpose of a Local Plan is to help in the determination of planning applications, we are keen to understand how the Council intends to reflect the fact that the new NPPF introduces national development management policies that apply immediately.
5. The Proposed Main Modifications seek to address concerns about soundness of the Plan raised during the Examination process. However, there have also been developments in national planning and other policy areas that suggest further Main Modifications to the Rutland Plan may be needed. We have therefore set out these broader observations first and then our specific comments on the Main Modifications themselves.
Impacts of the new NPPF
6. As you will also be aware the Government published its long-awaited new NPPF on 17th August 2026. This sets out national planning in a new way, separating policies for plan-making from those for determining planning applications. The new NPPF introduces national development management policies that apply immediately. This includes the presumption in favour of development within settlements.
7. The new NPPF clearly sets out that the Government’s view that Local Policies which conflict with the new guidance should not be able to be taken into account in decision-making. It is important that plan-users understand how the new NPPF and the new Rutland Plan will work together for decision-making. HBF therefore suggest that further modifications to supporting text of the Plan are needed to explain this new situation. We would also strongly encourage the Council to also consider the implications of the new approach on the proposed suite of Development Management policies in the Rutland Plan to see if they have been impacted, effectively replaced or made redundant by the new NPPF.
Revision to National Biodiversity Net Gain (BNG) Policy
8. As you will know the Government published its responses to the BNG consultation on 15th April 2026. See the links below:
Improving the implementation of BNG for minor, medium and brownfield development
Biodiversity net gain for nationally significant infrastructure projects
9. The first raft of intended changes have now been implemented with the introduction of a 0.2 Ha exemption and small sites being able to deliver off-site. Further changes, including revisions to the statutory metric are expected shortly.
Worsening Viability
10. HBF are also mindful of the recent ministerial letter about viability and Local Plans. However, our members’ experience suggests that the viability challenges facing developers are not just a short-term issue triggered by geo-political events. Although this has undoubtedly made viability worse, even without this recent turmoil viability would be difficult due to increasing cost burdens and policy requirements.
11. HBF recently published our ‘Viability Crunch report’ https://www.hbf.co.uk/research-insight/viability-crunch/ which details the cumulative impact of increasing regulatory, and other requirements, on the viability and deliverability of development. This has added an average of £76,00 to the cost of a new home over compared to five years ago. We remain concerned that the ever-increasing regulatory burden will have an impact on both the viability and deliverability of this Plan.
MM1
12. This Modification needs updating to reflect that the provision of in the LURA about the new plan-making system have now been enacted. For the reasons set out in our general comments section above HBF also suggests that this section now needs updating to reflect the new NPPF and the existence of the new national Development Management Policies.
MM2
13. Now that the Future Homes Standard has bene published, HBF do not think any reference to other standards, such as Passivhaus, are needed or appropriate.
MM5 and MM6
14. Now that the Future Homes Standard has been published, HBF suggests the wording of this policy and supporting text may need further revisions, and this Main Modification is no longer appropriate.
MM7
15. Now that the Future Homes Standard has been published, the wording of this policy and supporting text may need further revisions.
MM12
16. HBF support the additional of the reference to the guidance provided in the PPG.
MM15
17. For the reason set out in our general comments section above HBF suggests that this policy and/or the supporting text may now need updating to reflect the new NPPF.
MM39
18. For the reasons we have set out in our general comments about viability HBF suggests that this policy needs to include additional flexibility. The new (2026) NPPF also set out a wider variety of circumstances that would enable site specific viability to be assessed.
MM71
19. HBF object to the inclusion of any locational hierarchy for off-site BNG. Such policies are contrary to national BNG policy and guidance. The metric already penalises development that needs to utlise off-site BNG units located further away from the development, and it is not justified, appropriate or sound for the Rutland Plan to introduce any further policy restrictions about this. The new NPPF is very explicit that Local Plans should not seek to add to, augment or supplement national BNG policy and guidance with locally distinctive requirement like this Main Modification proposed policy. Such an approach is therefore inconsistent with both the previous and current NPPF guidance and should be deleted.
20. The reference to statutory credits is also incorrect as national policy states these are to be used as a last resort. There is no justification for any further requirements and as such reference to following the locational criteria in this section is both unnecessary and unsound.
Monitoring Framework- MM99 and MM100
21. Monitoring is an essential part of the plan, monitor, approach. However, to be effective and justified the Monitoring Framework needs to set out what actions would be taken if monitoring identified any issues with the Local Plan policies. For example, what would the Council do if there was an under-delivery of housing in one year. We suggest therefore that there needs to be an action column added to the Monitoring Framework and further Main Modifications are needed. It is not really the monitoring of a policy itself that is important, but what actions are taken if any issues are found that are important for the effectiveness of the Plan.
Future Engagement
22. I trust that the Council will find these comments useful as it continues to progress its Local Plan. I would be happy to discuss these issues in greater detail or assist in facilitating discussions with the wider house-building industry.
23. HBF would like to be kept up to date about the progress of the Rutland Local Plan and associated documents. Please use the contact details provided below for future correspondence.
Attachments:
- Main Modification Response Redacted (84.25 KB)
- Main Modifications Consultation - HBF Email Redacted (214.39 KB)
Object
Main Modifications Consultation
MM39
Representation ID: 9183
Received: 07/09/2026
Respondent: Home Builders Federation
For the reasons we have set out in our general comments about viability HBF suggests that this policy needs to include additional flexibility. The new (2026) NPPF also set out a wider variety of circumstances that would enable site specific viability to be assessed.
Rutland Local Plan Main Modifications Consultation Sept 2026
1. Thank you for consulting with the Home Builders Federation (HBF) on the Rutland Local Plan Main Modifications Consultation Sept 2026.
2. HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which include national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing.
3. HBF welcomes the Council’s efforts to ensure that they have an up-to-date Local Plan. Plan-making is a fundamental part of a Local Authority’s role and is essential to support the delivery new homes and jobs. Government policy remains clear that a significant increase in house building is needed in order to deliver the 1.5 million new homes in this Parliament. Full Local Plan coverage is also important .
4. We note that the new NPPF has been released during the consultation period. HBF are keen to understand the implications of this on both the content of the current Plan and the EIP process. As the whole purpose of a Local Plan is to help in the determination of planning applications, we are keen to understand how the Council intends to reflect the fact that the new NPPF introduces national development management policies that apply immediately.
5. The Proposed Main Modifications seek to address concerns about soundness of the Plan raised during the Examination process. However, there have also been developments in national planning and other policy areas that suggest further Main Modifications to the Rutland Plan may be needed. We have therefore set out these broader observations first and then our specific comments on the Main Modifications themselves.
Impacts of the new NPPF
6. As you will also be aware the Government published its long-awaited new NPPF on 17th August 2026. This sets out national planning in a new way, separating policies for plan-making from those for determining planning applications. The new NPPF introduces national development management policies that apply immediately. This includes the presumption in favour of development within settlements.
7. The new NPPF clearly sets out that the Government’s view that Local Policies which conflict with the new guidance should not be able to be taken into account in decision-making. It is important that plan-users understand how the new NPPF and the new Rutland Plan will work together for decision-making. HBF therefore suggest that further modifications to supporting text of the Plan are needed to explain this new situation. We would also strongly encourage the Council to also consider the implications of the new approach on the proposed suite of Development Management policies in the Rutland Plan to see if they have been impacted, effectively replaced or made redundant by the new NPPF.
Revision to National Biodiversity Net Gain (BNG) Policy
8. As you will know the Government published its responses to the BNG consultation on 15th April 2026. See the links below:
Improving the implementation of BNG for minor, medium and brownfield development
Biodiversity net gain for nationally significant infrastructure projects
9. The first raft of intended changes have now been implemented with the introduction of a 0.2 Ha exemption and small sites being able to deliver off-site. Further changes, including revisions to the statutory metric are expected shortly.
Worsening Viability
10. HBF are also mindful of the recent ministerial letter about viability and Local Plans. However, our members’ experience suggests that the viability challenges facing developers are not just a short-term issue triggered by geo-political events. Although this has undoubtedly made viability worse, even without this recent turmoil viability would be difficult due to increasing cost burdens and policy requirements.
11. HBF recently published our ‘Viability Crunch report’ https://www.hbf.co.uk/research-insight/viability-crunch/ which details the cumulative impact of increasing regulatory, and other requirements, on the viability and deliverability of development. This has added an average of £76,00 to the cost of a new home over compared to five years ago. We remain concerned that the ever-increasing regulatory burden will have an impact on both the viability and deliverability of this Plan.
MM1
12. This Modification needs updating to reflect that the provision of in the LURA about the new plan-making system have now been enacted. For the reasons set out in our general comments section above HBF also suggests that this section now needs updating to reflect the new NPPF and the existence of the new national Development Management Policies.
MM2
13. Now that the Future Homes Standard has bene published, HBF do not think any reference to other standards, such as Passivhaus, are needed or appropriate.
MM5 and MM6
14. Now that the Future Homes Standard has been published, HBF suggests the wording of this policy and supporting text may need further revisions, and this Main Modification is no longer appropriate.
MM7
15. Now that the Future Homes Standard has been published, the wording of this policy and supporting text may need further revisions.
MM12
16. HBF support the additional of the reference to the guidance provided in the PPG.
MM15
17. For the reason set out in our general comments section above HBF suggests that this policy and/or the supporting text may now need updating to reflect the new NPPF.
MM39
18. For the reasons we have set out in our general comments about viability HBF suggests that this policy needs to include additional flexibility. The new (2026) NPPF also set out a wider variety of circumstances that would enable site specific viability to be assessed.
MM71
19. HBF object to the inclusion of any locational hierarchy for off-site BNG. Such policies are contrary to national BNG policy and guidance. The metric already penalises development that needs to utlise off-site BNG units located further away from the development, and it is not justified, appropriate or sound for the Rutland Plan to introduce any further policy restrictions about this. The new NPPF is very explicit that Local Plans should not seek to add to, augment or supplement national BNG policy and guidance with locally distinctive requirement like this Main Modification proposed policy. Such an approach is therefore inconsistent with both the previous and current NPPF guidance and should be deleted.
20. The reference to statutory credits is also incorrect as national policy states these are to be used as a last resort. There is no justification for any further requirements and as such reference to following the locational criteria in this section is both unnecessary and unsound.
Monitoring Framework- MM99 and MM100
21. Monitoring is an essential part of the plan, monitor, approach. However, to be effective and justified the Monitoring Framework needs to set out what actions would be taken if monitoring identified any issues with the Local Plan policies. For example, what would the Council do if there was an under-delivery of housing in one year. We suggest therefore that there needs to be an action column added to the Monitoring Framework and further Main Modifications are needed. It is not really the monitoring of a policy itself that is important, but what actions are taken if any issues are found that are important for the effectiveness of the Plan.
Future Engagement
22. I trust that the Council will find these comments useful as it continues to progress its Local Plan. I would be happy to discuss these issues in greater detail or assist in facilitating discussions with the wider house-building industry.
23. HBF would like to be kept up to date about the progress of the Rutland Local Plan and associated documents. Please use the contact details provided below for future correspondence.
Attachments:
- Main Modification Response Redacted (84.25 KB)
- Main Modifications Consultation - HBF Email Redacted (214.39 KB)
Object
Main Modifications Consultation
MM71
Representation ID: 9184
Received: 07/09/2026
Respondent: Home Builders Federation
HBF object to the inclusion of any locational hierarchy for off-site BNG. Such policies are contrary to national BNG policy and guidance. The metric already penalises development that needs to utlise off-site BNG units located further away from the development, and it is not justified, appropriate or sound for the Rutland Plan to introduce any further policy restrictions about this. The new NPPF is very explicit that Local Plans should not seek to add to, augment or supplement national BNG policy and guidance with locally distinctive requirement like this Main Modification proposed policy. Such an approach is therefore inconsistent with both the previous and current NPPF guidance and should be deleted.
The reference to statutory credits is also incorrect as national policy states these are to be used as a last resort. There is no justification for any further requirements and as such reference to following the locational criteria in this section is both unnecessary and unsound.
Rutland Local Plan Main Modifications Consultation Sept 2026
1. Thank you for consulting with the Home Builders Federation (HBF) on the Rutland Local Plan Main Modifications Consultation Sept 2026.
2. HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which include national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing.
3. HBF welcomes the Council’s efforts to ensure that they have an up-to-date Local Plan. Plan-making is a fundamental part of a Local Authority’s role and is essential to support the delivery new homes and jobs. Government policy remains clear that a significant increase in house building is needed in order to deliver the 1.5 million new homes in this Parliament. Full Local Plan coverage is also important .
4. We note that the new NPPF has been released during the consultation period. HBF are keen to understand the implications of this on both the content of the current Plan and the EIP process. As the whole purpose of a Local Plan is to help in the determination of planning applications, we are keen to understand how the Council intends to reflect the fact that the new NPPF introduces national development management policies that apply immediately.
5. The Proposed Main Modifications seek to address concerns about soundness of the Plan raised during the Examination process. However, there have also been developments in national planning and other policy areas that suggest further Main Modifications to the Rutland Plan may be needed. We have therefore set out these broader observations first and then our specific comments on the Main Modifications themselves.
Impacts of the new NPPF
6. As you will also be aware the Government published its long-awaited new NPPF on 17th August 2026. This sets out national planning in a new way, separating policies for plan-making from those for determining planning applications. The new NPPF introduces national development management policies that apply immediately. This includes the presumption in favour of development within settlements.
7. The new NPPF clearly sets out that the Government’s view that Local Policies which conflict with the new guidance should not be able to be taken into account in decision-making. It is important that plan-users understand how the new NPPF and the new Rutland Plan will work together for decision-making. HBF therefore suggest that further modifications to supporting text of the Plan are needed to explain this new situation. We would also strongly encourage the Council to also consider the implications of the new approach on the proposed suite of Development Management policies in the Rutland Plan to see if they have been impacted, effectively replaced or made redundant by the new NPPF.
Revision to National Biodiversity Net Gain (BNG) Policy
8. As you will know the Government published its responses to the BNG consultation on 15th April 2026. See the links below:
Improving the implementation of BNG for minor, medium and brownfield development
Biodiversity net gain for nationally significant infrastructure projects
9. The first raft of intended changes have now been implemented with the introduction of a 0.2 Ha exemption and small sites being able to deliver off-site. Further changes, including revisions to the statutory metric are expected shortly.
Worsening Viability
10. HBF are also mindful of the recent ministerial letter about viability and Local Plans. However, our members’ experience suggests that the viability challenges facing developers are not just a short-term issue triggered by geo-political events. Although this has undoubtedly made viability worse, even without this recent turmoil viability would be difficult due to increasing cost burdens and policy requirements.
11. HBF recently published our ‘Viability Crunch report’ https://www.hbf.co.uk/research-insight/viability-crunch/ which details the cumulative impact of increasing regulatory, and other requirements, on the viability and deliverability of development. This has added an average of £76,00 to the cost of a new home over compared to five years ago. We remain concerned that the ever-increasing regulatory burden will have an impact on both the viability and deliverability of this Plan.
MM1
12. This Modification needs updating to reflect that the provision of in the LURA about the new plan-making system have now been enacted. For the reasons set out in our general comments section above HBF also suggests that this section now needs updating to reflect the new NPPF and the existence of the new national Development Management Policies.
MM2
13. Now that the Future Homes Standard has bene published, HBF do not think any reference to other standards, such as Passivhaus, are needed or appropriate.
MM5 and MM6
14. Now that the Future Homes Standard has been published, HBF suggests the wording of this policy and supporting text may need further revisions, and this Main Modification is no longer appropriate.
MM7
15. Now that the Future Homes Standard has been published, the wording of this policy and supporting text may need further revisions.
MM12
16. HBF support the additional of the reference to the guidance provided in the PPG.
MM15
17. For the reason set out in our general comments section above HBF suggests that this policy and/or the supporting text may now need updating to reflect the new NPPF.
MM39
18. For the reasons we have set out in our general comments about viability HBF suggests that this policy needs to include additional flexibility. The new (2026) NPPF also set out a wider variety of circumstances that would enable site specific viability to be assessed.
MM71
19. HBF object to the inclusion of any locational hierarchy for off-site BNG. Such policies are contrary to national BNG policy and guidance. The metric already penalises development that needs to utlise off-site BNG units located further away from the development, and it is not justified, appropriate or sound for the Rutland Plan to introduce any further policy restrictions about this. The new NPPF is very explicit that Local Plans should not seek to add to, augment or supplement national BNG policy and guidance with locally distinctive requirement like this Main Modification proposed policy. Such an approach is therefore inconsistent with both the previous and current NPPF guidance and should be deleted.
20. The reference to statutory credits is also incorrect as national policy states these are to be used as a last resort. There is no justification for any further requirements and as such reference to following the locational criteria in this section is both unnecessary and unsound.
Monitoring Framework- MM99 and MM100
21. Monitoring is an essential part of the plan, monitor, approach. However, to be effective and justified the Monitoring Framework needs to set out what actions would be taken if monitoring identified any issues with the Local Plan policies. For example, what would the Council do if there was an under-delivery of housing in one year. We suggest therefore that there needs to be an action column added to the Monitoring Framework and further Main Modifications are needed. It is not really the monitoring of a policy itself that is important, but what actions are taken if any issues are found that are important for the effectiveness of the Plan.
Future Engagement
22. I trust that the Council will find these comments useful as it continues to progress its Local Plan. I would be happy to discuss these issues in greater detail or assist in facilitating discussions with the wider house-building industry.
23. HBF would like to be kept up to date about the progress of the Rutland Local Plan and associated documents. Please use the contact details provided below for future correspondence.
Attachments:
- Main Modification Response Redacted (84.25 KB)
- Main Modifications Consultation - HBF Email Redacted (214.39 KB)
