BASE HEADER

Yes

ID sylw: 108370

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

10.1 Yes, Mackenzie Miller Homes is supportive of the SWC’s efforts to improve housing
standards by requiring developments to meet Nationally Described Space Standards
[NDSS]. However, it is considered that this requirement will need to be sufficiently
justified.
10.2 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.”
10.3 Moreover, as noted above, Paragraph 32 of the NPPF makes it clear that plans should be
underpinned by relevant and up-to-date evidence that is adequate, proportionate and
focussed tightly on supporting and justifying the policies concerned. Furthermore,
Paragraph 72 of the NPPF is also clear that planning policies should have regard to the
economic viability of sites and Paragraph 35 states that they should not undermine the
deliverability of the Local Plan, which is also supported by the PPG.6
10.4 Mackenzie Miller Homes recognises 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).
10.5 Given the above context, Mackenzie Miller Homes would suggest that the SWCs 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.