Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14937
Received: 14/12/2020
Respondent: The Home Builders Federation Midland Region
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Nationally Described Space Standards (NDSS):
- Council should provide a local assessment evidencing case for Nationally Described Space Standards to accord with NPPF Para. 31, Para 127(f) & FN 46, and PPG.
- No such evidence supplied.
- Must be based on need not ‘nice to have’ basis, otherwise Government would have made mandatory in Building Regulations.
- Council should recognise customers have different budgets and aspirations; could lead to customers purchasing larger homes in floorspace, but less bedrooms to meet need. Could lead to overcrowding and reducing quality of living environment.
- Inflexible approach will impact on affordability and affect affordable home ownership products such as First Homes.
- Viability Assessment only test one average house type size, not all 16 NDSS compliant house typologies. Not robust approach.
- No assessment on impact on affordability. Council should assess potential adverse impacts on affordable home ownership products such as First Homes.
- Knock on effect to slow or reduce delivery rates.
- If NDSS carried forward, Council should put forward transitional arrangements.
In the absence of robust evidence justifying the requirement for NDSS and lack of viability testing, the Council should delete Bullet Point 5 from Policy P5.
If the proposed requirement for NDSS is carried forward, then the Council should put forward proposals for transitional arrangements. The land deals underpinning residential sites may have been secured prior to any proposed introduction of the NDSS. These sites should be allowed to move through the planning system before any proposed policy requirements are enforced. The NDSS should not be applied to any reserved matters applications or any outline or detailed approval prior to a specified date.
See attached letter