These representations have been submitted by Pegasus Group on behalf of L & Q Estates Limited in response to the Local Plan 2040: Plan for Submission consultation
These representations are made in relation to our clients' interests in land to the East of Wixams, which forms the proposed residential site allocation HOU16.
The following sections set out our comments on relevant sections and policies in the plan.
Policy DM6 requires all new dwellings to conform to nationally described space standards as a minimum.
If the Borough Council wishes to adopt the optional nationally described space standards, then this should only be done in accordance with the National Planning Policy Framework (NPPF) (para 130f & Footnote 49). Footnote 49 of the NPPF states that “policies may also make use of the NDSS where the need for an internal space standard can be justified”. The NPPF states that policies 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 (para 31). The Borough Council has not provided any evidence to determine whether there is a need for additional standards in their area and justify setting appropriate policies in the Local Plan.
There is also no evidence to show that the Borough Council has considered the impacts on need, viability, and timing before introducing the nationally describe space standards.
The requirement for compliance with the Space Standards for all new development may impact on affordability and customer choice. It is important that that the Borough Council presents clear local evidence of need and impacts on viability to justify the inclusion of the policy in the plan.