Object

Representation ID: 5119

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policies should only be included where the standards can be “justified” (NPPF footnoted 49).
The Internal Space Standards Topic Paper does not justify the requirement for use of space standards. It identifies a series of generic matters that are relevant throughout the country. There is no information to suggest that the existing stock of housing cannot meet the requirements for NDDS housing.
Furthermore, Local Plans should not simply require all developments to provide NDSS housing. They should identify how many properties are required to be NDDS and the policies should seek to deliver this amount. The policy should work in a similar fashion to the affordable housing policy and require, for example, 30% of all
properties to meet NDDS if that meets the identified level of provision.
Requiring all properties to meet NDDS will make smaller properties more expensive, as they will be larger and more expensive to construct. It could also adversely affect density requirements as these properties will take up more space than smaller properties. The Council needs to recognise that if they require all properties to be
NDSS compliant, it will have a direct impact on densities and viability, due to potentially increased building costs.
We also note that the policy requires set spacing distances between dwellings. This will be difficult to achieve on small brownfield sites that are unusually shaped, which could adversely affect the Council’s windfall delivery aspirations from infilling.
The requirements of policy HC12 and should be properly factored into the Council’s density assumption calculations. They should also be fully explored in the Viability Appraisal. We are not aware of any evidence that this is the case.