Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/1916
Document Section Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION A - HOUSING External Space Standards Content View all on this section
Respondent Home Builders Federation Ltd (… View all by this respondent
Response Date 10 Aug 2016
Do you consider this part of the document is Sound? No
On which grounds do you consider the document unsound? (if applicable)
  • Not Justified
Do you consider the Document is Legally Compliant? Yes

The policy is unsound because it is unjustified.


The Council needs to provide evidence to justify this local policy. The Government is anxious to reduce the burdens imposed on developers, as articulated by its Productivity Plan (Fixing the Foundations, HM Treasury, July 2015). The Government’s work on streamlining construction standards relates primarily to the “construction, internal layout and performance of new dwellings” (Written Ministerial Statement, 25 March 2015). It is unclear, therefore, whether external space standards falls into the area covered by the review. Nevertheless, it is our view that such a policy is not necessarily in the spirit of the Government’s agenda to streamline the system and reduce burdens on developers.

If the Council considers that such a policy is necessary then it needs to justify it better, demonstrating how recent residential development has provided very poor levels of private external open space. We have been unable to detect an assessment in the supporting evidence base. It can be difficult to judge what might represent an appropriate amount of external space, since there are no official guidelines on this question. As with the internal space standards, the Council may wish to consider the land supply implications of such a policy.

What changes do you suggest to make the document legally compliant or sound?
Do you consider it necessary to participate at the oral part of the examination? Yes
Does your representation relate to an omission site (a site that has not been included). For example a site for Housing, Employment, Travellers, or Local Green Spaces. No
Please supply details of the omission site.