Persimmon Homes (Anglia) acknowledge that the provision of adequate space in homes is an important element of good design and influences the take up and delivery of new housing. However, there is insufficient evidence to suggest that homes slightly below national space standards are not meeting a need and demand for this size of housing.

The Council’s approach of collating evidence of the size of dwellings completed does not, in itself, accurately and robustly reflect need, the requirement for which is set out in the NPPG or local demand as set out in the NPPG. The evidence base should also take account of market indicators such as quality of life impacts or reduced sales in areas where the standards are not currently being met.

There is no evidence provided that the size of the homes being completed are not meeting the housing needs of those purchasing them or that these homes are struggling to be sold in comparison to homes that do meet the standards. In terms of supporting evidence, the Council largely base its assessment upon a sample size of 245 homes across the Greater Norwich Area, the results of which show that 75% of homes have achieved NDSS GIA requirements.

The Council’s evidence base fails to take account of market information reflecting customer levels of satisfaction for new homes. In neglecting to take account of customer satisfaction levels, the Council have failed to demonstrate a need to adopt an internal space standard, as required by the NPPF (footnote 46).

Persimmon Homes (Anglia) does not therefore support the introduction of residential space standards and take the view that there is a lack of evidence to demonstrate a need to adopt space standards in Greater Norwich. Persimmon Homes prides itself on building well-designed homes that are more affordable by those on average household incomes, helping many households step onto the housing ladder. The adoption of residential space standards would worsen affordability issues and reduce the overall number of homes delivered. If space standards are to be introduced it is suggested that a more appropriate approach would be to require a proportion of new homes to be built to NDSS. This would then enable the continued delivery of well-designed, smaller and more affordable units to meet local household need.