Draft Policy DM4 - Habitable Floorspace for New Developments

We have severe reservations about the necessity of the policy and, if it were retained, the absolute nature of the policy requirement to maintain minimum internal floorspace requirements. The housing market has successfully brought forward good quality housing without these standards and there is no evidence that the housing stock is sub standard or that there is no demand for the housing that has been built to date. On this basis, we do not agree that this policy is necessary. The standardisation of house sizes would not be an appropriate way in which to guide development.

The policy wording would result in an inflexible policy and a policy which could prevent good quality smaller homes from being built. The wording of the policy may render a scheme unacceptable where minor undershooting of the standards occurs. The minimum floor to ceiling heights are also too absolute at 2.5m (see paragraph 2.31). Where schemes are proposed which marginally undershoot this standard, planning permission would be refused despite the scheme providing good quality accommodation.

Such absolute standards are also likely to have an effect on the densiy of schemes as greater land is required to meet these internal floor area standards. There is no evidence to suggest that smaller dwellings are unacceptable as living areas and these standards are based on non Rochford specific averages from English Partnership developments and research by CLG. No case has been made to apply this to the Rochford scenario and neither are we aware of any other District applying such rigid policy frameworks.

There is a danger that the viability of redeveloping brownfield sites is adversely affected where lower densities are insisted upon just to secure particular internal space standards. or, if it is to be retained, that it is sufficiently flexible.

By prescribing minimum sizes, properties will become more expensive and unaffordable. Room sizes should be left to market forces.

The minimum ceiling height of 2.5m is excessive and will add to the overall height and bulk of new dwellings.

Agree that new dwellings should form part of well planned developments and that the rooms are of a good size and layout to afford future occupiers a good standard of amenity, suitability for modern living.

The imposition of minimum space standards, including a minimum floor to ceiling height, is overly prescriptive, and could impact on scheme viability, housing choice, and the efficient use of land. It is not clear why the standards relate more closely to the higher EP requirements rather than those of the HCA. Although it is accepted that planning should seek to ensure that dwellings are well laid out and offer satisfactory levels of amenity, the precise size of private dwellings should principally be a matter for the market. No existing problem has been identified; there is no justification for this policy.