Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/2228
Document Section Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION A - HOUSING External Space Standards Content View all on this section
Respondent Chimington Green Consortium (C… View all by this respondent
Agent Steve Mellor
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 Positively Prepared
  • Not Justified
  • Not Consistent with national policy
Do you consider the Document is Legally Compliant? Yes

HOU15 -

This policy is unsound because it is unjustified and unclear. It should be clear that flats have a provision of a 1.5 metre balcony or an area of private space or patio not both.

Paragraph 5.106A is completely unclear. It sets out the 10 metre long 'rule of thumb' approach to rear gardens but how can the first 5 metres from the rear of the house not be overlooked by surrounding properties. This distance is only achievable on the largest standard dwellings and this text should be removed or amended.

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.

What changes do you suggest to make the document legally compliant or sound? See Above
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.