BASE HEADER

No

ID sylw: 107948

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The justification for this policy is weak. No evidence is provided that the size of new homes is diminishing and only two appeal decisions have been considered. The Homes England Capital Funding Guide does not require NDSS compliance. 85% of NDSS is generally accepted as the benchmark for grant-led affordable homes. Robust justification, viability testing, and evidence will be required to justify this policy. If pursued, the policy should be flexible enough to allow well-designed house types slightly below NDSS, particularly on sites where most dwellings comply. There should be provision for additional flexibility for affordable housing as many registered providers have their own requirements.

The draft policy also states homes should be provided to M4(2) and M4(3) standards. This must be based on evidence to be justified as per Footnote 51 of the NPPF. The HEDNA recommends that all should meet M4(2) standards and 10% M4(3) but the HEDNA is now out of data so a refreshed study would need to look at this issue. Rainier Developments believe this policy is unnecessary as Building Regulations Part M provides specific requirements for M4(2), M4(3) standards, which do not need to be repeated in development plan policy.