Comment

Representation ID: 9951

Received: 25/07/2022

Respondent: Barton Willmore

Draft Policy DM6 (Residential Space Standards) requires all new dwellings to conform to the nationally described space standards as a minimum. Footnote 49 of the NPPF states that policies may make use of the nationally described space standard, where the need for an internal space standard can be justified (our emphasis). The NPPG identifies that evidence should consist of need, viability and timing, in order to demonstrate that such standards are appropriate for the local area and would not for example have a detrimental impact on meeting demand for starter homes or on the affordability of properties (Paragraph: 020 Reference ID: 56-020-20150327).
However, the only justification provided for this requirement appears to be that these standards have recently become mandatory for all new dwellings developed under permitted development rights. As such, the requirements of the draft policy are not considered to be adequately evidenced and therefore justified in this instance, having regard to the PPG criteria for optional technical standards.
In order to be considered ‘sound’, the Council should provide relevant and up to date evidence which is proportionate and focused tightly on supporting the policy concerned (Paragraph 31 of the NPPF).