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ID sylw: 107906

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Terra is supportive of the SWA’s efforts to improve housing standards by requiring
developments to meet Nationally Described Space Standards [NDSS]. However, Terra
wishes to highlight that this requirement will need to be sufficiently justified.
2.93 Footnote 51 of NPPF paragraph 135(f) states that policies may “make use of the nationally
described space standard, where the need for an internal space standard can be justified.”
As noted above, the NPPF is clear that plans should be underpinned by relevant and up-todate
evidence that is adequate, proportionate and focussed tightly on supporting and
justifying the policies concerned (Para 32). In addition, the NPPF is also clear that planning
policies should have regard to the economic viability of sites (Para 72) and should not
undermine the deliverability of the Local Plan (Para 35) – this is supported by the PPG.9
2.94 Terra acknowledges that the PO’s supporting text states the SDC Housing Strategy 2021
evidence log notes that poor space standards on units on developer-led s106 sites (for
affordable housing) are an issue and that a further assessment is being undertaken on the
extent of non-compliance with NDSS and whether this is more prevalent for certain types of
residential development, alongside viability testing the NDSS requirement (Pg.62).
2.95 In this context, Terra would suggest that the SWAs publish a Topic Paper evidencing the
need for NDSS, alongside a Viability Assessment that tests the impact of policy
requirements on the viability of sites allocated in the SWLP in accordance with the NPPF
and PPG in due course. This would be critical evidence to underpin the SWLP’s proposed
policy approach and will be necessary to ensure that the policy is found to be sound.