Question 9 relates to the adoption of new optional technical housing standards issued by the Government. It also relates to RDC's proposal to require a % of dwellings for "older people".

National Space Standards - RDC is proposing to adopt the Governments minimum internal space standards. The National Planning Practice Guidance (PPG) is explicit that space standards should be 'justified', taking account of need, viability and timing. RDC has not provided sufficient justification that there is a need to apply the minimum standards, a key test of Soundness set out in the NPPF. Furthermore, RDC has not yet considered the viability implications of doing so, with the DaSa advising that the viability impact will be tested prior to the submission of the plan. A full Local Plan viability assessment is required, in line with Paragraph: 003 Reference ID: 56-003-20150327 of the Planning Practice Guidance.

From TWSE's experience to date, the additional building costs associated with dwellings that meet minimum standards are not necessarily recovered in sales values, as there is often a ceiling on the purchase price achievable for each type of dwelling on general development sites. This needs to be factored into any viability work undertaken by RDC going forward, and such an assessment must be published as part of the next stage of the DaSa.

Should the DaSa continue to propose the minimum space standards, it is considered that 'Flexibility' (an NPPF test of Soundness) needs to be provided within the policy wording. Notably, the policy should allow for a relaxation of the standards where the applicant can demonstrate that is not practicable or financially viable to deliver the standards.

RDC should also give further consideration as to how the space standards, in combination with other policy requirements it is proposing to introduce (eg minimum garden sizes etc) may impact on the deliverability of individual housing sites. Notably, the space standards and other minimum standards such
as garden sizes may increase the land take of each individual plot beyond that which would usually be assumed. This may reduce the overall number of units that can be achieved on housing sites, in turn impacting the RDC's ability to meet its Core Strategy housing requirement.