Object

Representation ID: 44954

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Part 4

21.5 Taylor Wimpey objects to Part 4 of Policy ENV9 which requires all new residential development to meet the Nationally Described Space Standards [NDSS].

21.6 Taylor Wimpey notes that the Government’s decision to make these standards optional suggests that they do not expect all properties to be built in accordance with them. If the standards are to be applied, the Practice Guidance35 sets out a clear set of criteria local planning authorities should address in order to justify them, these being:

• need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed.
• 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 transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.

21.7 With regard these criteria, we firstly note that no need evidence is provided to justify the policy requirement. The justification text to the policy suggests that the standard is generally met in most new build housing across the Black Country but no further information on this matter is provided and it does not appear to have been covered in the evidence base, so there is nothing to ratify this. With regard to viability, the BCP Viability Study states that the NDSS has been applied within the appraisals as the minimum standard. However, it is not clear whether the impact upon affordability has been considered.

21.8 The BCA’s policy approach should recognise that customers have different budgets and aspirations. An inflexible policy approach to NDSS for all new dwellings will impact on affordability and effect customer choice. Well-designed dwellings below NDSS can provide a good, functional home.


21.10 If the Council is able to provide sufficient evidence to justify the policy, Taylor Wimpey considers that a transitional period should be applied. It is not clear whether a large proportion of new dwellings currently meet the standard, and the cost of such provision may not therefore be factored into current and past land acquisitions. A reasonable transitional period following adoption of a new policy would help enable developers to factor the cost of space standards into
future land acquisitions.