Object
Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
Representation ID: 7445
Received: 03/09/2021
Respondent: Mr D De Massey
Agent: CC Town PLanning
In terms of residential space standards, the client holds concerns over the proposed
approach advocated within draft Policy DQ1. Footnote 49 on page 39 of the NPPF is
clear that “policies may also make use of the NDSS where the need for an internal
space standard can be justified”. In line with Para 31 of the NPPF, policies such as
DQ1 should be underpinned by relevant and up to date evidence, which should be
adequate, proportionate and focused tightly on supporting and justifying the policies
concerned and this is expanded by the NPPG which rehearses that “where a need for
internal space standards is identified, the authority should provide justification for
requiring internal space policies. Authorities should take account of the following
areas need, viability and timing”. The evidence base which supports the consultation
document is currently void of any such evidence.