Policy HC12: Space about dwellings and internal space

Object

Representation ID: 4170

Received: 20/12/2022

Respondent: Miller Homes

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Internal Space Standards Topic Paper does not justify the requirement for use of space standards in Policy HC12 but identifies a series of matters relevant throughout the country. There is no evidence to suggest that the existing stock of housing is deficient against NDSS. Local Plans should not simply require all developments to provide NDSS housing. They should identify how many properties are required to be NDSS and the policies should seek to deliver this amount. The Council needs to recognise that if they require all properties to be NDSS compliant, it will have a direct impact on densities and affordability of new homes.

Policy HC12 should be revised. The requirement for internal space standards should be removed until a full and proper localised evidence is produced to demonstrate they are necessary. If the policy is to remain, it should make it clear that some flexibility to the policy may be applied depending on the individual merits of the development proposal. This flexibility is applied to the part of the policy on external space standards and the same principle should also apply to internal space standards.

Object

Representation ID: 4250

Received: 23/12/2022

Respondent: McCarthy Stone

Agent: Miss Natasha Styles

Legally compliant? No

Sound? No

Duty to co-operate? Yes

The council should note that the open space needs of older people are much less than that presented in the plan. For older people the quality of open space either on site or easily accessible for passive recreation is much more important than formal open space. The council should therefore acknowledge this within the policy and add amend policy HC12.

Object

Representation ID: 4276

Received: 22/12/2022

Respondent: Hampton Oak Developments

Agent: PlanIt

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Internal Space Standards Topic Paper does not justify the requirement for use of space standards in Policy HC12 but identifies a series of matters relevant throughout the country. There is no evidence to suggest that the existing stock of housing is deficient against NDSS. Local Plans should not simply require all developments to provide NDSS housing. They should identify how many properties are required to be NDSS and the policies should seek to deliver this amount. The Council needs to recognise that if they require all properties to be NDSS compliant, it will have a direct impact on densities and affordability of new homes.
Policy HC12 should be revised. The requirement for internal space standards should be removed until a full and proper localised evidence is produced to demonstrate they are necessary. If the policy is to remain, it should make it clear that some flexibility to the policy may be applied depending on the individual merits of the development proposal. This flexibility is applied to the part of the policy on external space standards and the same principle should also apply to internal space standards.

Object

Representation ID: 4402

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced.
See supporting representations for further details.

Object

Representation ID: 4493

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced.
See supporting representations for further details.

Object

Representation ID: 4523

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced.
See supporting representations for further details.

Object

Representation ID: 4549

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced.

Comment

Representation ID: 4589

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

Taylor Wimpey has limited comment in respect of the external space standards that reflect existing policy which are generally considered appropriate.
However, if bungalows are to be provided within a scheme, it would seem logical to relax garden sizes or allow for the provision of communal/shared gardens to ensure efficient use of land and to reflect any desire from the market for low-maintenance external amenity areas. This approach is also likely to align to any appropriate space about dwellings requirements which should reduce the necessary distance between principal facing windows for ground floor windows, where intervening boundary treatments would interrupt views.
Taylor Wimpey does currently adhere to the Nationally Described Space Standards (NDSS) through the design of current housetypes.

Object

Representation ID: 4606

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced.

Object

Representation ID: 4638

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Object to policy HC12, because it is not in accordance with national policy. Where a need for NDSS is identified, the PPG (Reference ID: 56-020-20150327) requires Councils to take account of the need for the standards, the potential impact on viability and the timing of introducing the standards.

The Internal Space Standards Topic Paper (November 2022) fails to recognise that those considering renting or home ownership have different budgets and aspirations. An inflexible policy approach to NDSS for all new dwellings will impact on affordability and affect choice in the market. In this regard, the Council should focus on good design and usable space to ensure that dwellings are fit for purpose.

Object

Representation ID: 4662

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced.

Object

Representation ID: 4702

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that the evidence does not currently support the imposition of the optional NDSS within South Staffordshire. To the contrary, the evidence highlights a number of potential risks if such a policy were to be introduced.

Comment

Representation ID: 4754

Received: 22/12/2022

Respondent: Tetlow King Planning

NDSS are not a building regulation and where dwellings are not meeting NDSS it does not necessarily mean that the dwellings being delivered are of poor quality. For affordable housing in particular there may be instances where achieving NDSS is impractical and unnecessary.

Object

Representation ID: 4766

Received: 19/12/2022

Respondent: Mrs Joanne Harding

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The PPG states that local planning authorities should provide justification for requiring internal space policies, showing evidence of need, viability and timing. If the Government had expected all properties to be built to NDSS that they would have made these standards mandatory not optional.

There is a direct relationship between unit size, cost per square metre (sqm), selling price per sqm and affordability. An inflexible policy approach imposing NDSS on all housing removes the most affordable homes and denies lower income households from being able to afford homeownership. The Council should focus on good design and usable space to ensure that dwellings are fit for purpose rather than focusing on NDSS.

Object

Representation ID: 4806

Received: 21/12/2022

Respondent: L&Q Estates Limited

Agent: Marrons Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There may be instances when greater flexibility is required in application of NDSS, The introduction of such standards is contrary to the Framework, which is clear that these standards should only be introduced where this will address an identified need for such properties.

Object

Representation ID: 4824

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The Internal Space Standards Report (2021) does not provide any evidence of the need for NDSS to apply in the district and the reasons why houses in the district need to be larger. There is also a risk that an inflexible approach to the application of NDSS could have unintended the consequence of impacting upon affordability and fails to recognise that well designed dwellings below the NDSS can provide good affordable home options. This element of the policy is unjustified and unsound and should be deleted.

Object

Representation ID: 4845

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

External space standards and amenity spaces should not be explicitly stated within the policy. Planning judgement on a case-by-case basis with reference to the distance/size criteria as guidance rather than policy would suffice to
achieve suitable quality residential environments.

Comment

Representation ID: 4889

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The requirement to meet the Nationally Described Space Standard is considered reasonable. External space standards and amenity spaces should not be explicitly
stated within the policy. Whilst there are caveats contained within which state an allowance for flexibility “depending upon the site orientation and the individual merits of the development proposal”, planning judgement on a case-by-case basis with reference to the distance/size criteria as guidance rather than policy would suffice to achieve suitable quality residential environments. It must be ensured that specific criteria do not result in ‘planning by numbers’ and an unintentional lack of flexibility in assessing future planning applications.

Object

Representation ID: 4924

Received: 22/12/2022

Respondent: Gladman

Agent: Gladman

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

If the Government had expected all properties to be built to NDSS then they would have made these standards mandatory not optional. Therefore, if the Council wishes to adopt this optional standard, it should be justified by meeting the criteria set out in the national policy, including need, viability and impact on affordability. An inflexible policy approach to NDSS for all new dwellings will impact on affordability and effect customer choice. Gladman do not consider that the requirement for all dwellings to be built to at least NDSS has been robustly justified by the Council at this stage.

Comment

Representation ID: 4928

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The requirement to meet the Nationally Described Space Standard is considered reasonable. External space standards and amenity spaces should not be explicitly
stated within the policy. Whilst there are caveats contained within which state an allowance for flexibility “depending upon the site orientation and the individual merits of the development proposal”, planning judgement on a case-by-case basis with reference to the distance/size criteria as guidance rather than policy would suffice to achieve suitable quality residential environments. It must be ensured that specific criteria do not result in ‘planning by numbers’ and an unintentional lack of flexibility in assessing future planning applications.

Object

Representation ID: 4968

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy requires all new dwellings to meet Nationally Described Space Standards. Where a need for internal space standards is identified, the PPG (Reference ID: 56-020-20150327) requires Councils to take account of the need for the standards, the potential impact on viability and the timing of introducing the standards. We objected to this policy in our Preferred Options representations as no evidence was provided to justify these standards. SSDC has now produced an Internal Space Standards Topic Paper (November 2022). We have no further comments on this requirement within the policy.

The policy also proposes very specific garden area and distance requirements. Although private amenity space and distances between dwellings are not addressed within the internal space standards guidance, there is a national requirement to make the most effective use of land (NPPF Chapter 11). We consider that the Council should have to justify the requirement for these specific standards and the potential impact of this policy on proposed housing yields.

Object

Representation ID: 4990

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy requires all new dwellings to meet Nationally Described Space Standards. Where a need for internal space standards is identified, the PPG (Reference ID: 56-020-20150327) requires Councils to take account of the need for the standards, the potential impact on viability and the timing of introducing the standards. We objected to this policy in our Preferred Options representations as no evidence was provided to justify these standards. SSDC has now produced an Internal Space Standards Topic Paper (November 2022). We have no further comments on this requirement within the policy.
The policy also proposes very specific garden area and distance requirements. Although private amenity space and distances between dwellings are not addressed within the internal space standards guidance, there is a national requirement to make the most effective use of land (NPPF Chapter 11). We consider that the Council should have to justify the requirement for these specific standards and the potential impact of this policy on proposed housing yields.

Object

Representation ID: 5015

Received: 21/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Taylor Wimpey supports, in principle, the direction of travel for draft Policy HC12 (Space about dwellings and internal space standards), particularly given that it is fairly consistent with the space standards set out in Appendix 6 of the adopted Core Strategy (2012).
However, whilst similar space standards are already adopted, Taylor Wimpey considers that it is important to acknowledge Footnote 49 of NPPF paragraph 130(f), which states that policies may “make use of the nationally described space standard, where the need for an internal space standard can be justified.” As set out under paragraph 31, all policies should be “underpinned by relevant and up-to-date evidence”, and “should be adequate, proportionate and focussed tightly on supporting and justifying the policies concerned.”
In addition, the PPG4 sets out:
“Where a need for internal space standards is identified, the authority should provide justification for requiring internal space policies. Local planning authorities should take account of [need, viability and timing”
On the basis of the above, Taylor Wimpey would advise the Council that, should a policy approach that requires the delivery of dwellings to the NDSS be adopted, the Council should provide a local assessment evidencing the case for the District in accordance with the NPPF and PPG. This would be essential evidence to underpinning the Council’s proposed policy approach and will be necessary to ensure the policy can be found sound.
In order to ensure a sound a robust policy, Taylor Wimpey recommends that the Council should provide a local assessment evidencing the case for the District in accordance with NPPF paragraph 31.

Object

Representation ID: 5093

Received: 19/12/2022

Respondent: Barberry

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We note that this policy mentions outlook and mentions a garden area ratio under ‘external space’. However, has this been tested against the proposed net densities of 35 dwellings per hectare and above?

We also feel that the suggested 21m distance between dwellings from principal elevations should be subject to further review because it could result in excessively wide streets which may affect developments achieving net density targets. Moreover, it would not accommodate the sorts of street hierarchies that would typically be advocated in larger developments with multiple character areas. Furthermore, such separation distances could result in wide carriageways appearing over-dominant, creating a poor environment with a lack of a sense of place.

We consider the policy, as worded, would be contrary to para 130 of the NPPF which states that 'Planning policies and decisions should ensure that developments … (d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;’

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.

Comment

Representation ID: 5132

Received: 13/12/2022

Respondent: Seven Homes

Agent: RCA Regeneration

We note that this policy mentions outlook and mentions a garden area ratio under ‘external space.’ However, has this been tested against the proposed net densities of 35 dwellings per hectare?

We also feel that the suggested 21m distance between dwellings from principal elevations should be subject to further review because it could result in excessively wide streets which may affect developments achieving net density targets. Moreover, it would not accommodate the sorts of street hierarchies that would typically be advocated in larger developments with multiple character areas. Furthermore, such separation distances could result in wide carriageways appearing over dominant throughout schemes.

Object

Representation ID: 5145

Received: 19/12/2022

Respondent: St Philips

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We note that this policy mentions outlook and mentions a garden area ratio under ‘external space’. However, has this been tested against the proposed net densities of 35 dwellings per hectare or more?

We also feel that the suggested 21m distance between dwellings from principal elevations should be subject to further review because it could result in excessively wide streets which may affect developments achieving net density targets. Moreover, it would not accommodate the sorts of street hierarchies that would typically be advocated in larger developments with multiple character areas. Furthermore, such separation distances could result in wide carriageways appearing over-dominant, creating a poor environment with a lack of a sense of place.

We consider the policy, as worded, would be contrary to para 130 of the NPPF which states that 'Planning policies and decisions should ensure that developments … (d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;’

Object

Representation ID: 5157

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

We note that this policy mentions outlook and mentions a garden area ratio under ‘external space’.However, has this been tested against the proposed net densities of 35 dwellings per hectare?

We also feel that the suggested 21m distance between dwellings from principal elevations should be subject to further review because it could result in excessively wide streets which may affect developments achieving net density targets. Moreover, it would not accommodate the sorts of street hierarchies that would typically be advocated in larger developments with multiple character areas. Furthermore, such separation distances could result in wide carriageways appearing over dominant throughout schemes.

We consider the policy, as worded, would be contrary to para 130 of the NPPF which states that 'Planning policies and decisions should ensure that developments … (d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;’

Object

Representation ID: 5179

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Certain house types, for example M4(2) dwellings should have smaller, more manageable gardens.

Introduce some flexibility into application of Nationally Described Space Standards (NDSS) as occasional non-compliance may be appropriate for sound urban design reasons.

Should Nationally Described Space Standards be pursued then the Council need to provide additional evidence to demonstrate the policy is sound. Taking account of the following issues:
-evidence should ensure that impacts of adopting space standards can be properly assessed e.g. impact on meeting demand for starter homes.
-viability impacts including on affordability
-timing of implementation to enable developers time to factor cost of standards into future land acquisitions.

The HMA does not provide any justification or evidence for requiring NDSS in the District.

Object

Representation ID: 5242

Received: 21/12/2022

Respondent: Richborough Estates

Agent: RCA Regeneration Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

We note that this policy mentions outlook and mentions a garden area ratio under ‘external space’. However, has this been tested against the proposed net densities of 35 dwellings per hectare?
We also feel that the suggested 21m distance between dwellings from principal elevations should be subject to further review because it could result in excessively wide streets which may affect developments achieving net density targets. Moreover, it would not accommodate the sorts of street hierarchies that would typically be advocated in larger developments with multiple
character areas. Furthermore, such separation distances could result in wide carriageways appearing over dominant throughout schemes.
We consider the policy, as worded, would be contrary to para 130 of the NPPF which states that 'Planning policies and decisions should ensure that developments … (d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;’