Object

Representation ID: 22293

Received: 11/10/2021

Respondent: Investin PLC

Agent: Lichfields

3.24 Draft Policy ENV9 states that all new residential development “will be required to meet the Nationally Described Space Standards (NDSS), except where it can be clearly evidenced that the implementation of the NDSS would cause harm to the significance of a heritage asset. The space standards will apply to all tenures.”
3.25 If the Council wishes to apply the optional NDSS to all dwellings, then this should only be done in accordance with NPPF paragraph 130(f) and footnote 49. Footnote 49 states that “policies may also make use of the NDSS where the need for an internal space standard can be justified”.
3.26 As set out in the NPPF, all policies should be underpinned by relevant and up to date evidence, which should be adequate, proportionate and focussed tightly on supporting and justifying the policies concerned (paragraph 31). The PPG28 sets out that “where a need for internal space standards is identified, the authority should provide justification for requiring internal space policies. Authorities should take account of the following areas need, viability and timing”. The BCA should provide a local assessment evidencing its case; however, no evidence has been presented to justify the policy requirement.
3.27 Draft Policy ENV9 is unsound because it fails the four tests of soundness as per NPPF paragraph 35 as it is not positively prepared, justified, effective and consistent with national policy.