Response by the House Builders Federation to the Rother Development and Sites Allocations Local Plan

Thank you for consulting the Home Builders Federation (HBF) on the Development and Sites Allocations Local Plan. The HBF is the principal representative body of the housebuilding industry in England and Wales and our representations reflect the views of discussions with our membership of national and multinational corporations through to regional developers and small local housebuilders. Our members account for over 80% of all new housing built in England and Wales in any one year.
In writing our representation we have assumed that the plan will be examined against the latest National Planning Policy Framework and Planning Practice Guidance and consider that the latest policy framework should apply regardless of when the plan is submitted. The primary reason for the use of the transitionary period was to allow those authorities preparing plans on the basis of existing housing needs assessments to continue their progress. As the DaSA is not considered to be a strategic plan, as it neither amends a spatial strategy or proposes to increase its development requirements, it should be considered against the latest NPPF and PPG regardless of whether it is submitted prior to the end of the transitionary period.

Strategic policies affecting housing delivery

Other development management policies

DHG3: Internal Space Standards

The policy is unsound as it has not been justified.

Paragraph 56-020-20150327 of PPG sets what is required of a local authority in order to adopt internal space standards. This paragraph states:

"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."

Whilst the Council have tested the impact on viability arising from the introduction of space standards no evidence has been provided in relation to the needs for such homes and whether this could impact on the deliverability of starter homes. Small homes for first time buyers form an essential part of delivery that will improve the affordability of homes for younger people who, as the Council's evidence shows, are forming households far later than previous generations. It is important therefore important that any potential impacts in relation to needs is considered and without this evidence the Council cannot justify the inclusion of this policy.