Nationally Described Space Standards We agree with the Council's conclusion based on the evidence within the SHMA that, at present, there isn't sufficient evidence within South Somerset to justify the application of the Nationally Described Space Standards for market housing. We recognise it will apply to affordable dwellings but, in our experience, this is frequently a pre-requisite in any event for RSLs.

To support the introduction of the nationally described space standards in South Somerset the Council will need to use up to date evidence of need, and of the policy being viable. Its introduction should not disadvantage the delivery of affordable housing; applying the standard without robust testing may give rise to more viability testing on individual applications, regardless of the NPPF's indication that this should only take place at the plan-making stage. As such the Council should ensure t

5.11 It is noted that the Plan makes reference to the SHMA (paragraph 9.34) which concluded that there was a case for adopting the standards for affordable housing, but not for the market sector. The Council conclude that based upon the evidence currently available in the SHMA, the nationally described space standards will be applied to affordable housing. However as referred to elsewhere in these representations, the SHMA is considered to be out of date.

Policy HG3 proposes to introduce the requirement for the Nationally Described Space Standard (NDSS) for all affordable housing. The adoption of the NDSS should be in accordance with 2019 NPPF (para 127f & Footnote 46) and the latest NPPG. The 2019 NPPF states that "policies may also make use of the NDSS where the need for an internal space standard can be justified". As set out in the 2019 NPPF policies should be underpinned by relevant and up to date evidence which should be adequate, proportio

POLICY HG3 - AFFORDABLE HOUSING - INTERNAL SPACE STANDARDS We note that at para 9.34 the council proposes to apply space standards only to affordable homes. We feel this is a mistake, and that the reasoning given is weak. The fact that homeowners may choose to use a bedroom for other purposes is not relevant as to whether bedrooms should be of a minimum size. A home marketed as 4 bedroom should have four bedrooms of the minimum size (single or double) specified in government standards. Rooms sm

Policy HG3 sets internal space standards for affordable housing which align with the Government's nationally described space standards. However, given the nationally described space standards are not compulsory, it is requested that this policy is re-worded to ensure the requirements are flexible, to allow each application to be considered on a case by case basis. In addition, it is considered that to demonstrate compliance with the space standards, developers are likely to need to provide more

National Described Space Standards 4.11 It is noted that the Plan makes reference to the SHMA (paragraph 9.34) which concluded that there was a case for adopting the standards for affordable housing, but not for the market sector. The Council conclude that based upon the evidence currently available in the SHMA, the nationally described space standards will be applied to affordable housing. 4.12 Policy HG3 proposes to introduce the requirement for the Nationally Described Space Standard (NDSS

The Council should fully evidence the need, and design expectations, for the delivery of electric vehicle charging points and the other elements of this policy, and robustly viability test this policy requirement to ensure that it will not cumulatively affect the delivery of affordable housing. It would be useful to understand how the Council has considered the design implications of part f. of this policy alongside Policies HG3 and HG5; how does this fit with the expectation for achieving the

5.12 Policy HG3 proposes to introduce the requirement for the Nationally Described Space Standard (NDSS) for all affordable housing. The adoption of the NDSS should be in accordance with 2019 NPPF (paragraph 127f and Footnote 46) and the latest PPG. The 2019 NPPF states that "policies may also make use of the NDSS where the need for an internal space standard can be justified". As referred to above and set out in the 2019 NPPF policies should be underpinned by relevant and up to date evidence wh

The final comment we wish to make at this stage concerns a cluster of policies which include a level of precision which needs to be carefully considered or tempered with the scope for some flexibility. The policies seek to fix the percentage and type of affordable housing to be provided (HG2); the space standards to be applied to affordable housing (HG3) and the mix of market housing to be delivered (in terms of size measured by the number of bedrooms) (HG4). These matters or details would be be