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ID sylw: 108276

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Whilst we have support the use of NDDS in principle we have concerns relating to the evidence base used to justify the NDDS requirements of Draft Policy A.
The policy supporting text advises that further viability testing is required to ensure the NDSS will not have a material impact or deliverability of housing schemes. This work needs to be completed as, at the moment, there is no uncertainty whether full NDSS compliance will be viable.
Footnote 51 to the NPPF advises that Local Authorities may include policies in their Plan requiring schemes to comply with NDSS where the need for internal space standards can be justified. The supporting text to draft Policy A makes reference to the HEDNA and SDC housing strategy to support the suggestion that an NDDS policy is required. However, neither of these documents suggest that all of the SWLP housing requirement should be NDSS compliant. In order for the Plan to include a policy that requires 100% NDSS provision there must be clear robust evidence that the equivalent of 54,700 additional NDSS dwellings are required. No such evidence is provided.