Policy DM6 Residential space standards

Object

Representation ID: 9426

Received: 29/07/2022

Respondent: L&Q Estates Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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.

Object

Representation ID: 9759

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As it stands the plan in our view is not sound on the following tests under paragraph 35 of the
National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
Whilst we agree that all homes should be delivered to a high standard and be of good quality, we also consider that space standards can, in some instances, have a negative impact by reducing customer choice and increasing affordability issues. Developers tend to provide entry-level one and two-bedroom properties which may not always meet the optional nationally described space standards, but which would be affordable for the number of required bedrooms.
Given that no evidence is presented with regard to the need for space standards, the policy is unjustified, and as such, unsound.

Support

Representation ID: 9819

Received: 25/07/2022

Respondent: Pertenhall & Swineshead Parish Council

Policy DM6 Residential space standards – “The Council will require all new dwellings to conform to nationally described space standards as a minimum.” - As it should be and welcome.

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).

Object

Representation ID: 9979

Received: 29/07/2022

Respondent: Gladman Developments Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DM6 Residential Space Standards
Policy DM6 seeks compliance with the Nationally Described Space Standards (NDSS), or any replacement standards produced by the Government, for all new homes including from change of use and conversion.
If the Council wishes to apply the optional NDSS to all dwellings, then this should only be done in accordance with paragraph 130f and footnote 49 of the NPPF. Footnote 49 confirms:
“49. Planning policies for housing should make use of the Government’s optional technical standards for accessible and adaptable housing, where this would address an identified need for such properties. Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified.”
Furthermore, with reference to the NDSS, the PPG confirms:
“Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies”.
If the Council wishes to adopt this optional standard, it should be justified by meeting the criteria set out in the national policy, including need, viability and impact on affordability.

Object

Representation ID: 9997

Received: 27/07/2022

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy is unsound as it has not been justified.
32. It is important to recognise that the optional technical standards can, as set out in footnote 49 of the NPPF and paragraph 56-002 of Planning Practice Guidance (PPG), only be introduced where they are needed. However, the only justification provided by the Council in the local plan is that these standards are now mandatory on new dwellings developed under permitted development rights. This
may be the case, but this does not remove the ned to show that these standards are needed.
33. Whilst the HBF share the Council desires to see good quality homes delivered within Tendring we also consider that space standards can, in some instances, have a negative impact upon affordability issues and reduce customer choice. In terms of choice, for example, some developers will provide entry level two, three and four-bedroom properties which may not meet the optional nationally described space standards, but which would allow on lower incomes can afford a property which has their required number of bedrooms.

Comment

Representation ID: 10273

Received: 29/07/2022

Respondent: Central Bedfordshire Council

13.5 Central Bedfordshire Council also support the requirement for residential space standards in line with Nationally Described Space Standards. However, as identified within our response to the previous consultation in September 2021, the policy (DM6) requires all residential developments to conform to the standards ‘as a minimum’. This implies that there may be cases where higher space standards may be sought. If this is the case, the scenario/type of development to which higher standards may be sought should be set out in the policy or the supporting text.

Support

Representation ID: 10292

Received: 29/07/2022

Respondent: Roxton Parish Council

Sections 6.54 to 6.57:
RPC support the introduction of policy DM6.

Comment

Representation ID: 10503

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Hallam Land Management considers that the proposed Policy for Residential Space Standards set out in Policy DM6, whilst welcome, deserves expansion to encourage new developments to embrace the changes to working patterns with a housing offer that can facilitate choices to work from home, reflecting changes to working patterns arising through the Covid-19 pandemic. Offering a wider choice of homes that make provision for working from home would be beneficial in further reducing the need to travel and increasing support for local services and facilities.

Object

Representation ID: 10533

Received: 26/07/2022

Respondent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

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).