Question 28: Do you support, object or have any comments relating to the approach to space standards?

Comment

Representation ID: 20084

Received: 24/02/2020

Respondent: Mr Norman Castleton

No mention of space for nature. This was specifically mentioned in a BBC TV documentary where of all kinds of life needs space within the built up environment. Trees are needed to soak up pollution. They will be cut down in Thorpe Woods. The parks did this in the past and still continue to have a role although many are careworn through lack of care, misuse and overuse. The remaining open spaces are now being clogged up with intensive housing. All life needs space otherwise societies start to crumble through the presses of the rat race.

Comment

Representation ID: 20851

Received: 13/03/2020

Respondent: Welbeck Strategic Land III LLP

Agent: Bidwells

Whilst the general principle of providing development that adheres to space standards is supported, the policy should incorporate a degree of flexibility to ensure that consideration is given to site specific issues, as well as need and financial considerations. For example, there may be circumstances where there is a clear need for homes which fall below the space standards. The lack of flexibility within the policy would prevent this need from being satisfied.

Support

Representation ID: 20977

Received: 14/03/2020

Respondent: Mr Andrew Cawdron

Essential. What about the 1 in 4 that slipped through ?

Comment

Representation ID: 21189

Received: 16/03/2020

Respondent: Hopkins Homes, Persimmon Homes and Taylor Wimpey

Agent: Bidwells

In accordance with PPG requirements, space standards should only be introduced where there is robust evidence to demonstrate that they are required. The evidence referenced within the draft Plan indicates that, in fact, 75% of homes in Greater Norwich were delivered to the necessary standards between 2016-2018, which calls into question the need for a policy requiring strict adherence.

Notwithstanding the above, the policy should include flexibility in its wording to allow delivery of homes that are below the space standards, where they are well-designed and meet specific needs.

Comment

Representation ID: 21213

Received: 16/03/2020

Respondent: Kier Living Eastern Ltd

Agent: Bidwells

In accordance with PPG requirements, space standards should only be introduced where there is robust evidence to demonstrate that they are required. The evidence referenced within the draft Plan indicates that, in fact, 75% of homes in Greater Norwich were delivered to the necessary standards between 2016-2018, which calls into question the need for a policy requiring strict adherence. Notwithstanding the above, the policy should include flexibility in its wording to allow delivery of homes that are below the space standards, where they are well-designed and meet specific needs.

Comment

Representation ID: 21275

Received: 16/03/2020

Respondent: Hannah Guy

We broadly welcome the continued strive towards homes for all and the Space Standards are Nationally recognized and continue to be supported.

Comment

Representation ID: 21320

Received: 16/03/2020

Respondent: Lanpro Services

Agent: Stephen Flynn

Please see our answers to questions 23 and 24 setting out our concerns regarding the delivery of infrastructure to meet the needs of small rural cluster village sites. Our conclusion is that dispersal to small rural cluster villages outside of the old NPA area is not sustainable.

Comment

Representation ID: 21407

Received: 16/03/2020

Respondent: Glavenhill Ltd

Agent: Stephen Flynn

Please see our answers to questions 23 and 24 setting out our concerns regarding the delivery of infrastructure to meet the needs of small rural cluster village sites. Our conclusion is that dispersal to small rural cluster villages outside of the old NPA area is not sustainable.

Object

Representation ID: 21700

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

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.

Support

Representation ID: 21754

Received: 16/03/2020

Respondent: Brown & Co

We support the approach to space standards.
Clarion believe that a home is the beginning of everything, so providing suitable high quality space is imperative to ensure a good quality of life.

Object

Representation ID: 21909

Received: 12/03/2020

Respondent: Home Builders Federation

If the Council is considering adopting any of the optional technical standards in the GNLP the Council will need to ensure that they provide the necessary evidence, as set out in PPG, on the need for such homes and their impact on development viability. However, we have some concerns that strict adherence to space standards could limit well designed and more affordable smaller homes that better meets the needs and
budgets of some households. As such there must be clear evidence that a significant proportion of new homes are coming forward well below standards. If such evidence is provided, we would also recommend that the policy include some flexibility to allow for the delivery of homes that are smaller than space standards where they are well designed and meet the identified accommodation needs of local households.

Comment

Representation ID: 21950

Received: 13/03/2020

Respondent: UEA Estates & Buildings

Agent: Bidwells

The Nationally Described Space Standards are only applicable to individual residential dwellings, and are not applicable to purpose built student accommodation. Accordingly, accordance with the space standards should not be sought for GNLP0133-C and GNLP0133-E.

Comment

Representation ID: 22173

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.

Comment

Representation ID: 22287

Received: 16/03/2020

Respondent: Hugh Crane Ltd

Agent: Savills

Broad support is given to the identification of an approach to facilitate development at village locations. However, objection is made to the indicative amount of growth proposed for each cluster as the approach is considered to be arbitrary; particularly where it is proposed that sustainable development sites will been unnecessary limited.

Strong support is given to the identification of ‘Land to the east of Woodbastwick Road, Blofield Heath’ (Policy GNLP1048) It is considered that additional housing should be allocated at ‘Land to the east of Woodbastwick Road, Blofield Heath’ (Policy GNLP1048).

The precise amount of housing should be identified in discussion with the landowner.

Comment

Representation ID: 22335

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

5. POLICY 5 – HOMES
5.1 Policy 5 identifies that proposals should address the need for homes for all sectors of the community having regard to the latest evidence which is to be supported.
Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.
Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. None were built in South Norfolk leaving a residual need for 679. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
5.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure. 5.14 The site at Land off Station Road, Hethersett offers a suitable location for such provision and provides sufficient scope to address a significant element of the residual need for bedspaces in a care home and/or sheltered/extra care accommodation within a care village.
5.15 The Policy requires proposals for major housing development to provide;
“...at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.16 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.17 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.
Self/Custom-Build
5.18 There does not appear to have been any assessment of the need for self/custombuild housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
5.19 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
5.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed.
5.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Comment

Representation ID: 22372

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

5. POLICY 5 – HOMES
5.1 Policy 5 identifies that proposals should address the need for homes for all sectors of the community having regard to the latest evidence which is to be supported.
Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.
Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
5.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure.
5.14 The Policy requires proposals for major housing development to provide; “..at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.15 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.16 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.
Self/Custom-Build
5.17 There does not appear to have been any assessment of the need for self/custombuild housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
5.18 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
5.19 Pigeon are supportive of providing self-build plots and their proposals at Diss allow for such development. Indeed, the Diss site allows for a discrete area of 10 self-build plots allowing for mutual support amongst the self-build community and bespoke design solutions to come forward.
5.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed. 5.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. As such, provision for approximately 10 self-build plots is made as part of the proposal on land to the east of Walcot Green Lane. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Comment

Representation ID: 22637

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: Bidwells

Comments
Whilst the general principle of providing development that adheres to space standards is supported, the policy should incorporate a degree of flexibility to ensure that consideration is given to site specific issues, as well as need and financial considerations. For example, there may be circumstances where there is a clear need for homes which fall below the space standards. The lack of flexibility within the policy would prevent this need from being satisfied.

Support

Representation ID: 22678

Received: 16/03/2020

Respondent: Mrs Nicole Wright

Policy 5: Homes

We support this policy except for the part on Self/ Custom- Build Homes

This part of the policy does not address the real need to respond to the demand and choice of bespoke homes in the locations where they are needed.

It does not show a positive, sound and justified approach in the spirit of the NPPF. (Paragraph 16 of the NPPF)

An approach more akin to the Breckland strategy and consistent with the NPPF would be more appropriate.

Paragraph 251 of the Draft GNLP states that: “In line with the Right to Build and the NPPF, self and custom-build housing delivery is promoted through the GNLP on a range of sites. This policy sets a requirement for larger sites to provide self and custom-build plots. The thresholds have been set to ensure that plots are provided across Greater Norwich. Policies 7.4 and 7.5 also promote self and custom-build on smaller scale windfall sites. Overall, this comprehensive approach will both increase the supply of housing in urban and rural areas and provide opportunities for small and medium enterprises to build houses, as well as for self-build.”

However, Draft Policy 7.4 provides no guidance or criteria in relation to self-build and custom housebuilding.

Draft Policy 7.5 needs to allow for consideration of new self/custom-built homes being adjacent to what it describes as “a recognisable group of dwellings”. Please refer to the new Breckland Local Plan (adopted November 2019)



(For refrence:
Policy HOU 05 of the Breckland Local Plan (adopted November 2019)

Policy HOU 05 - Small Villages and Hamlets Outside of Settlement Boundaries
Development in smaller villages and hamlets outside of defined settlement boundaries will be limited, apart from where it would comply with other policies within the development plan* and if all of the following criteria are satisfied:
1. The development comprises of sensitive infilling and rounding off of a cluster of dwellings with access to an existing highway;
2. It is of an appropriate scale and design to the settlement;
3. The design contributes to enhancing the historic nature and
4. connectivity of communities; and
5. The proposal does not harm or undermine a visually important gap that
6. contributes to the character and distinctiveness of the rural scene.
Opportunities for self-build dwellings which meet the criteria set out above will be supported.
Farmsteads and sporadic small scale groups of dwellings are considered as lying in the open countryside and are not classed as small villages and hamlets. These, and isolated locations in the countryside, are unlikely to be considered acceptable.)

The GNLP Homes Objective is defined in the Draft Plan - To enable delivery of high-quality homes of the right density, size, mix and tenure to meet people's needs throughout their lives and to make efficient use of land.

We support this objective

However, the Monitoring Framework, Indicator Code GNLP 39 and indicator demonstrates the shortcomings of this Draft Policy in identifying the sole indicator for monitoring custom housebuilding as:
‘Percentages of sites of 40 dwellings or more (excluding flats) where 5% of plots are provided for custom build.’

Support

Representation ID: 22886

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Support, with comments.
Whilst the general principle of providing development that adheres to space standards is supported, the policy should incorporate a degree of flexibility to ensure that consideration is given to site specific issues, as well as need and financial considerations. For example, there may be circumstances where there is a clear need for homes which fall below the space standards. The lack of flexibility within the policy would prevent this need from being satisfied.

In addition, whilst the provision of space standards in relation to internal room size is supported, the Council should not place undue restrictions on developer by enforcing requirements in relation to storage space. Developers ultimately need to have flexibility to react to buyer / market demands whilst operating within an overall minimum space standard regime.

Comment

Representation ID: 22912

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Comments.
The Nationally Described Space Standards are only applicable to individual residential dwellings, and are not applicable to purpose built student accommodation. Accordingly, accordance with the space standards should not be sought for GNLP0133-C and GNLP0133-E.

Object

Representation ID: 22925

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

Overall, it is evident that the requirement in Policy 5 of the GNLP that all new homes must meet the Government’s Nationally Described Space Standard for any internal space, has not been properly and sufficiently justified.

Comment

Representation ID: 22944

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Comments.
The Nationally Described Space Standards are only applicable to individual residential dwellings, and are not applicable to purpose built student accommodation. Accordingly, accordance with the space standards should not be sought for GNLP0133-C and GNLP0133-E.

Comment

Representation ID: 22964

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Comments.
The Nationally Described Space Standards are only applicable to individual residential dwellings, and are not applicable to purpose built student accommodation. Accordingly, accordance with the space standards should not be sought for GNLP0133-C and GNLP0133-E.

Object

Representation ID: 22975

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

We object to the approach on space standards due to the lack of evidence regarding the impact of this on the deliverability of schemes. The relevant NDSS Study (August 2019) and the Interim Viability Study (November 2019) make unsubstantiated assumptions and do not provide the level of evidence that is required by the NPPF. Further work is necessary to justify the inclusion of the NDSS as a mandatory requirement.

Furthermore, the blanket requirement of this standard does not allow for the site-specific considerations to be taken into account and therefore a further amendment to allow for such eventualities is recommended.

Comment

Representation ID: 23000

Received: 13/03/2020

Respondent: Bidwells

Comments.
The Nationally Described Space Standards are only applicable to individual residential dwellings, and are not applicable to purpose built student accommodation. Accordingly, accordance with the space standards should not be sought for GNLP0133-C and GNLP0133-E.

Support

Representation ID: 23026

Received: 13/03/2020

Respondent: Bidwells

Support, with comments.
Whilst the general principle of providing development that adheres to space standards is supported, the policy should incorporate a degree of flexibility to ensure that consideration is given to site specific issues, as well as need and financial considerations. For example, there may be circumstances where there is a clear need for homes which fall below the space standards. The lack of flexibility within the policy would prevent this need from being satisfied.
In addition, whilst the provision of space standards in relation to internal room size is supported, the Council should not place undue restrictions on developers by enforcing requirements in relation to storage space. Developers ultimately need to have flexibility to react to buyer / market demands whilst operating within an overall minimum space standard regime.

Comment

Representation ID: 23144

Received: 16/03/2020

Respondent: Hopkins Homes

Agent: Bidwells

In accordance with PPG requirements, space standards should only be introduced where there is
robust evidence to demonstrate that they are required. The evidence referenced within the draft Plan
indicates that, in fact, 75% of homes in Greater Norwich were delivered to the necessary standards
between 2016-2018, which calls into question the need for a policy requiring strict adherence.
Notwithstanding the above, the policy should include flexibility in its wording to allow delivery of homes
that are below the space standards, where they are well-designed and meet specific needs.

Comment

Representation ID: 23170

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Space Standards
6.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
6.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
6.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
6.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
6.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
6.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby
5 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/524531/160519_Nationally_Described_Space_Standard____Final_Web_version.pdf
6 NPPG Housing Optional Space Standards: Paragraph: 003 Reference ID: 56-003-20150327 Revision date: 27 03 2015.
affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.

Comment

Representation ID: 23195

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

The policy requires all dwellings to meet the nationally described space standards. Orbit Homes

recognises the good intention behind this policy, but is very concerned about its impact on the viability of affordable housing developments. As a Registered Social Landlord (RSL), Orbit Homes has access to Homes England grants to fund the delivery of affordable housing, but these grants are based on a maximum floorspace per size of dwelling (i.e. number of bedrooms) that is approximately 85% of that required to meet the nationally described space standards. Policy 5, as currently worded, would therefore have a significant negative impact on Orbit Homes’ and other RSL’s ability to deliver affordable housing in the area as their funding would not cover the costs of building the larger dwellings. In order to resolve this issue, we recommend that the policy is amended to allow flexibility where the grants available for affordable housing delivery would fail to fully fund the costs of delivering larger dwellings.