Policy DQ1

Object

Representation ID: 3835

Received: 26/08/2021

Respondent: Roxton Parish Council

RPC suggests the policy should be extended to include a requirement for 10% of all new dwellings should be ‘Life Time Homes’ standards and in rural areas 5% of new dwellings should be bungalows.

Object

Representation ID: 5268

Received: 03/09/2021

Respondent: L&Q Estates Limited

Agent: Pegasus Group

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.

Support

Representation ID: 5363

Received: 03/09/2021

Respondent: Mrs Clare Buddle

Thoroughly support as good for residents and sustainability and building longevity.

Object

Representation ID: 5667

Received: 07/09/2021

Respondent: Hallam Land Management

Agent: David Lock Associates

Hallam Land Management considers that the proposed Policy for Residential Space Standards set out in Policy DQ1, 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: 5829

Received: 08/09/2021

Respondent: Persimmon Homes Midlands

Agent: Planning Prospects Ltd

New policy DQ1 is noted which requires future developments to adopt NDSS – the approach to a national space
standard as opposed to LPA standards is supported by Persimmon however in line with PPG, the Council should
properly assess its implications to development viability and delivery noting that build costs rise with NDSS and the
scale of development achievable on sites can also be less with schemes compliant to NDSS.

Object

Representation ID: 6163

Received: 09/09/2021

Respondent: Savills

Agent: Savills

We do not agree with the proposed policy DQ1 as this is not consistent with national policy. The nationally
described space standards deals with internal space within new dwellings. It sets out requirements for the
gross internal floor area of new dwellings at a defined level of occupancy as well as floor areas and
dimensions for key parts of the home, notably bedrooms, storage and floor to ceiling height. There has to be
flexibility to this as the policy as drafted provides no flexibility. Where a need for internal space standards is
identified, local planning authorities should provide justification for requiring internal space policies. This is a
requirement under the NPPF and PPG.

Object

Representation ID: 6250

Received: 09/09/2021

Respondent: IM Land

Agent: Barton Willmore

Quality of development and space standards
Footnote 49 of the NPPF states that “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” (our emphasis).
The proposed ‘Policy DQ1 – Residential space standards’ requires that “the Council will require all new dwellings to conform to nationally described space standards as a minimum”. However, there does not appear to be any justification for this policy requirement, and we therefore do not consider that the inclusion of this additional policy would meet the requirements of the NPPF.

Object

Representation ID: 6568

Received: 13/09/2021

Respondent: Challenger Multi Academy Trust

Agent: Fisher German LLP

Residential space standards
2.33 The requirement for all new dwellings to meet prescribed national space standards as a minimum, as proposed through Policy DQ1 – Residential space standards is not supported and has not been justified. The justification provided is that the standards have been mandated for homes delivered through permitted development rights. This was however in response to a specific issue identified with homes delivered through PD rights, with many being delivered in former office blocks or other buildings which resulted in smaller dwellings. This does not justify the approach adopted by the Council in respect of new build units. If the Council is to introduce this policy, it must have evidence to point to a specific issue existing in Bedford Borough and the issues this is causing and hence why a policy intervention is necessary. Without this the Council is not justified in relation to this policy. Moreover, the Council should be aware of delivering such requirements and the impacts on sale prices, as larger dwellings will attract higher prices, having a disproportionate impact on larger families who do not qualify for social housing, but require a larger property.

Object

Representation ID: 6574

Received: 13/09/2021

Respondent: Clarendon Land and Development Ltd

Agent: Fisher German LLP

Residential space standards
2.39 The requirement for all new dwellings to meet prescribed national space standards as a minimum, as
proposed through Policy DQ1 Residential space standards is not supported and has not been justified.
The justification provided is that the standards have been mandated for homes delivered through
permitted development rights. This was however in response to a specific issue identified with homes
delivered through PD rights, with many being delivered in former office blocks or other buildings which
resulted in smaller dwellings. This does not justify the approach adopted by the Council in respect of
new build units. If the Council is to introduce this policy, it must have evidence to point to a specific issue
existing in Bedford Borough and the issues this is causing and hence why a policy intervention is
necessary. Without this the Council is not justified in relation to this policy. Moreover, the Council should
be aware of delivering such requirements and the impacts on sale prices, as larger dwellings will attract
higher prices, having a disproportionate impact on larger families who do not qualify for social housing,
but require a larger property.

Support

Representation ID: 7244

Received: 01/09/2021

Respondent: Martin Cavalier

Agent: Neame Sutton Limited

De Merke Estates agrees with this policy to echo national requirements for space standards.

Object

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.

Object

Representation ID: 7901

Received: 24/09/2021

Respondent: Home Builders Federation

Whilst National Described Space Standards have become mandatory for all new dwellings developed under permitted development rights this does not mean that all new homes should be built to this standard. The NPPF and PPG still requires Council’s to provide evidence as to the need for these standards and an assessment as to the impact on viability of their application. Whilst the HBF shares the Council’s desire to see good quality homes delivered across Bedford 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 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. Given the poor affordability of property in the area it is important that the Council can provide robust evidence that there is a need to introduce the optional space standards – that these standards are a must have rather than a nice to have policy.

Object

Representation ID: 8413

Received: 03/09/2021

Respondent: Fisher German LLP

The requirement for all new dwellings to meet prescribed national space standards as a minimum, as proposed through Policy DQ1 – Residential space standards is not supported and has not been justified. The justification provided is that the standards have been mandated for homes delivered through permitted development rights. This was however in response to a specific issue identified with homes delivered through PD rights, with many being delivered in former office blocks or other buildings which resulted in smaller dwellings. This does not justify the approach adopted by the Council in respect of new build units. If the Council is to introduce this policy, it must have evidence to point to a specific issue existing in Bedford Borough and the issues this is causing and hence why a policy intervention is necessary. Without this the Council is not justified in relation to this policy. Moreover, the Council should be aware of delivering such requirements and the impacts on sale prices, as larger dwellings will attract higher prices, having a disproportionate impact on larger families who do not qualify for social housing, but require a larger property.

Support

Representation ID: 8498

Received: 27/09/2021

Respondent: Anwyl Land

Agent: Fisher German LLP

2.40 The requirement for all new dwellings to meet prescribed national space standards as a minimum, as proposed through Policy DQ1 – Residential space standards is not supported and has not been justified. The justification provided is that the standards have been mandated for homes delivered through permitted development rights. This was however in response to a specific issue identified with homes delivered through PD rights, with many being delivered in former office blocks or other buildings which resulted in smaller dwellings. This does not justify the approach adopted by the Council in respect of new build units. If the Council is to introduce this policy, it must have evidence to point to a specific issue existing in Bedford Borough and the issues this is causing and hence why a policy intervention is necessary. Without this the Council is not justified in relation to this policy. Moreover, the Council should be aware of delivering such requirements and the impacts on sale prices, as larger dwellings will attract higher prices, having a disproportionate impact on larger families who do not qualify for social housing, but require a larger property.