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ID sylw: 108619

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Draft Policy A – Providing the Right Size of Homes
5.8.
The policy states that new residential development must comply with the Nationally Described Space Standards (NDSS). Footnote 51 of the NPPF is clear that planning policies should only refer to NDSS where the need for this can be justified. The justification within the supporting text is unconvincing. No evidence is provided to demonstrate that the size of new homes is diminishing, as alleged, and only two appeal decisions have been considered; indeed, the Councils acknowledge that further research and analysis is required, as well as viability testing, which will be essential to ensure that the plan is effective. A
n additional reason to require NDSS compliance offered by the Councils is that Homes England wish for NDSS to be met in grant funded schemes. However, the Homes England Capital Funding Guide does not require this, and 85% of NDSS is generally accepted as the benchmark for grant-led affordable homes. Therefore, at present, the required robust justification for a NDSS policy is lacking, and therefore the draft policy is unsound on this basis.
5.9.
If the use of NDSS is subsequently justified and pursued, the policy should be sufficiently flexible to recognise that well-designed house types, which fall slightly below NDSS, will be acceptable, particularly on sites where the majority of the dwellings comply. The policy should also make provision for additional flexibility in relation to affordable housing as many registered providers have their own requirements.
5.10.
The draft policy also states that homes should be provided to M4(2) and M4(3) standards. This aspect of the policy must be based on evidence to be justified. Footnote 51 of the NPPF allows for these optional technical standards for accessible and adaptable housing to be introduced through planning policy ‘where this would address an identified need for such properties’. The HEDNA does provide some support for this, with the study ultimately recommending that all dwellings should meet M4(2) standards and 10% should meet M4(3). However, as discussed elsewhere in these representations, the HEDNA is now out-of-date, and a refreshed study should be produced to determine whether there is a need for M4(2) and M4(3) properties to justify a policy relating to accessible and adaptable dwellings.
5.11.
Notwithstanding, it is unnecessary to include an M4(2) and/or M4(3) requirement in the SWLP Part 1. The Building Regulations 2010 'Access to and use of buildings' Approved document Part M already provides specific requirements for M4(2) dwellings in relation to Accessible and Adaptable Homes and M4(3)/M4 (3)(2)(a) dwellings in relation to Wheelchair Adaptable Homes housing. It is not necessary for this to be repeated in a development plan policy, also because developers are already aware they need to deliver to this standard. Therefore, it is suggested that reference to accessible living standards can be deleted from the draft policy.