BASE HEADER

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ID sylw: 106371

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

This draft policy A proposes the blanket application of Nationally Described Space Standards (NDSS) for all new residential developments. There are concerns that the blanket application of the NDSS across all residential development, including affordable tenures, will undermine the viability of many development schemes. This will potentially result in fewer affordable homes being delivered as optional technical standards have implications for build costs and sales values, with implications in turn for development viability.
We highlight that the Planning Practice Guidance (PPG) requires local authorities to justify the need for
NDSS through considering need, viability and timing.
In light of the above, it is not clear that the Council has provided evidence demonstrating the need for
NDSS across all new developments in SW. If the Council continues to seek the NDSS requirement, then it must do so in line with the PPG to ensure the policy is justified and found sound at examination.
It is also relevant that Homes England only requires affordable homes to meet 85% of the NDSS to receive funding. For affordable housing in particular, there may be instances where achieving NDSS is impractical and unnecessary, as it may result in for example, higher rental and heating costs.
On sites that deliver 100% affordable housing, NDSS presents issues in that it increases the risk of financial impairment.
With regards to accessible living standards, it is proposed that all new housing, including conversions and subdivisions, must meet accessibility and adaptability standards (M4(2)) and on developments of 10 or more homes, at least 10% of market homes and 25% of affordable homes must be wheelchair friendly (M4(3)). Whilst the WMHAPC accepts that there is a growing need for accessible and adaptable homes, there is however concern that the 10% requirement for M4(3) dwellings could have considerable implications on viability and overall affordable housing delivery in SW. Some sites and/or schemes do not lend themselves to the statutory provision of M4(3) units. In light of this, the WMHAPC requests that the Council exercises an element of discretion when considering proposals.