Policy DHG 3 states that the Council adopts the Government's nationally described space standard, and that all new dwellings should provide adequate minimum internal space in line with the standard.

This policy is objected to, as there has not been an appropriate evidence base provided to properly set out why this is necessary. Planning Practice Guidance Paragraph: 020 Reference ID: 56-020-20150327 sets out what is required of a local authority in order to adopt internal space standards.

"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 DaSA and its associated evidence base have not provided sufficient evidence or justification in relation to the need for the adoption of these standards. The Space Standards Background Paper (October 2018) identifies the PPG paragraph set out above, but then does not appropriately consider any potential impact upon meeting demand for starter homes. The report also sets out clearly in paragraph 4.1 that "The Council does not collect and record data on internal floorspace as there has not previously been any adopted space standard within the District", and that in order to make an assessment of space standards an audit on 19 housing schemes within the "District was undertaken to identify the average unit sizes of new-build properties using Energy Performance Certificates (EPC)".

Based upon this methodology, the report states that "Overall compliance with the internal configuration within the Nationally Described Space Standards (NDSS) fares poorly" however paragraph 5.5 states that "Whilst the headline indicates that the overall compliance against the NDSS appears to be poor, Figure 5 shows that the average amount that non-compliant dwellings actually fail by is relatively small. Generally, compliance against the other requirements of the NDSS is 2 m or 2sq.m or less, meaning that minor internal changes to the layouts would likely result in compliance with the standards."

The evidence base therefore shows that in the very small survey sample taken, it is by only an extremely small amount that the space standards are not met, and that this can be addressed simply through internal reconfiguration. There is therefore no indication that houses are being constructed of a size that is fundamentally too small and a need for the implementation of the NDSS exists. Given that the 'research' takes no account of existing and historic compliance and does not provide a complete picture of the current situation across Rother, the adoption of the NDSS as policy is not sufficiently supported by the evidence base and is fundamentally flawed.

Therefore, until such time as a suitable and accurate evidence base has been researched and developed, the inclusion of the space standards as policy should not form part of the plan.

Please see attached full representation for further information.

Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171

Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172