DHG1: Residential Internal Space Standards

The comments below are made in relation to Policy DHG1, which proposes the adoption of the Nationally Described Space Standards (NDSS).

Planning Policy Guidance sets out clear criteria which Councils must satisfy in order to adopt optional NDSSs over and above the requirements of Building Regulations.
"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 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, 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 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."

The guidance effectively sets out three stages which must be overcome to ensure the NDSSs are only applied where needed and impacts are fully considered. We have considered Policy DHG1 below with these policy hurdles firmly in mind:

Need
A local authority must demonstrate clearly evidenced need to require the NDSSs. Paragraph 8.21 of the DaSA references an 'Access to Housing and Housing Standards' background paper. However, this hasn't been provided as part of the background evidence and we have not therefore had the opportunity to review. Without sight of the background evidence it is not possible to determine whether the Council has presented sufficient evidence to demonstrate need for the
optional enhanced housing standard above what is established as nationally suitable in Building Regulations. PHSE therefore reserves the right to comment further once the background evidence is available. It is worth noting that discussion during the Housing Standards Review led to the conclusion that the enhanced space standard should not be applied across the board and should only be adopted where needed locally.

All new housing must comply with Building Regulations which allows flexibility in terms of footprint, room size, circulation space etc. This can be considered carefully by the housing market in determining product choice to meet the needs and demands of customers. This in turn allows for build refinement in relation to internal fit out. Finally, this results in a whole range of supply chain and construction efficiencies which are crucial to reducing cost, driving affordability and reducing build time to increase production. It is not clear whether any of this has been considered by the Council.

The house building industry is of the view that current sales rates confirm that current product range is fully suitable for those wanting to buy properties. The industry knows its customers and what they want - firms would not sell homes below the enhanced standard size if they did not appeal to the market. Sales rates in the South East are strong and some of the greatest demand is for first time buyer products. If customers were not happy with the market offer then they would
have the option to purchase from the second hand market - however demand remains high indicating customer satisfaction. By means of a national measure, the House Builders Federation (HBF) annual customer satisfaction survey of 'new home' buyers identified that 92% of respondents were happy with the internal layout.

Viability

Paragraph 8.25 of the DaSA states "In terms of viability, the Government's own impact assessment details the likely cost impacts to development in adopting the optional standards. These are relatively low and, also considering the consequential impact on sale values, should not detract from the overall viability of developments. This will be further tested prior to the submission version of the Plan alongside other planning-related costs."

Adoption of the NDSS on 100% of housing will have a significant impact on sites which were previously considered to be borderline viable. This increased cost is transferred onto the landowner, therefore adoption of the NDSS will further compound challenges in meeting minimum benchmark land values. Increased housing sizes will also result in less efficient use of land and thus a relative increase in infrastructure burden per plot.

Timing

PHSE note that the plan-making process will provide time to prepare for the imposition of NDSSs. It should also provide the Council time to release its evidence and further test the impact of NDSSs on viability, a process in which the house building industry should be involved. The Council should also be minded to consider including a transitional period in the policy which would allow developers to factor in the additional cost associated with this policy into future land deals.

The policy is also vague as to how regard will be given to the standard when allocating housing sites, as is stated in the Policy Option Tests. PSHE would like clarification as to how the potential requirement for NDSSs will be considered against allocations carried forward from the previous plan, such as Preston Hall Farm.

Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28092