Policy HC12: Space about dwellings and internal space

Object

Representation ID: 5254

Received: 21/12/2022

Respondent: CCB Investments

Agent: RCA Regeneration

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: 5291

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

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: 5303

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy is neither justified nor consistent with national policy, and should be amended as suggested unless further evidence is provided.

it is our view that this policy should be more flexible on both internal and external standards to account for specific circumstances on sites that might support smaller units; and to acknowledge that well-designed dwellings below NDSS can still provide good, functional homes.

At this stage, the Council have not prepared the evidence base necessary to support the introduction of these standards. Indeed, the Council’s Viability Study 2022 only tests five average house type sizes, rather than testing the 16 NDSS compliant house typologies. There is no evidence to demonstrate that testing only a limited number of average sized dwellings would meet all the technical requirements of the NDSS.

For external space standards, We object to this prescriptive approach, which does not allow for flexibility in design on a site-by-site basis, where creative design solutions may be required to address other issues such as privacy, lighting etc, which fall short in achieving such prescriptive standards.the current approach to maintain prescriptive, top-down standards is not appropriate and at a minimum should include amendments to the wording noting ‘where possible’ and ‘where feasible’ should be added into the policy.

Object

Representation ID: 5340

Received: 19/12/2022

Respondent: St Philips

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The continuity of existing external space and dwellings standards is generally supported although there should be a recognition that certain house types, for example Part M4(2) dwellings, should have smaller, more manageable gardens.
The requirement that all dwellings should meet Nationally Described Space Standards (NDSS) is generally supported but some flexibility must be allowed in its application as occasionally non-compliance with NDSS may be appropriate for sound urban design reasons and the Policy should therefore build in some flexibility.
Notwithstanding, if the NDSS requirement is to be pursued then the Council need to provide additional evidence for the Local Plan Examination to demonstrate that the policy is sound. National Planning Guidance Housing: optional technical standards (paragraph
020) clearly states that “Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:
• Need – evidence should be provided in the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.
• Viability - the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.
• Timing - there may need to be a reasonable transition period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.”

It is clear that the introduction of the NDSS requires a Local Plan policy which has been fully evidenced, justified and viability tested. The South Staffordshire Housing Market Assessment Update 2022 (HMA) refers to the NDSS (paragraph 7.32) only in the context of
assessing the need for accessible and adaptable homes. The HMA does not provide any justification or evidence for requiring NDSS in the District.

Object

Representation ID: 5359

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The continuity of existing external space and dwellings standards is generally supported although there should be a recognition that certain house types, for example Part M4(2) dwellings, should have smaller, more manageable gardens.Cameron Homes do however object to the internal floorspace policy requirement for all
homes to meet the Nationally Described Space Standards (NDSS). In order to pursue the NDSS requirement, the Council need to provide additional evidence for the Local Plan Examination to demonstrate that the policy is sound. National Planning Guidance Housing: optional technical standards (paragraph 020) clearly states this.
It is clear that the introduction of the NDSS requires a Local Plan policy which has been fully evidenced, justified and viability tested. The South Staffordshire Housing Market Assessment Update 2022 (HMA) refers to the NDSS (paragraph 7.32) only in the context of assessing the need for accessible and adaptable homes. The HMA does not provide any justification or evidence for requiring NDSS in the District.

Object

Representation ID: 5380

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Policy requirement to comply with the implementation of the Nationally Described Space Standards (NDSS) is generally supported. However, some flexibility must be allowed in its application as occasionally a small minority of dwellings on larger sites may require non-compliance with NDSS for sound urban design reasons. This flexibility should be applied to limited exceptions that are thoroughly reasoned, the policy she be amended to reflect this.
The policy is considered unsound, as it is neither justified nor consistent with national policy for the reasons set out above.

Object

Representation ID: 5394

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy should be more flexible on internal and external standards, to reflect specific site circumstances and that well-designed below standard can provide good homes. No evidence provided by the council to support the introduction of these standards. Inflexible policy approach denies lower income households access to homeownership. The approach should be driven more by design than top down prescriptive standards.