Policy DM4 - Habitable Floorspace for New Developments

Minimum standards for affordable housing are essentially set by affordable housing providers, since achievement of such standards are a requirement of their funding. Such standards do vary from time to time, and therefore the logic of setting a policy in the Rochford DPD to specify these levels, when the requirement could easily change without any recourse to the Council, seems unwise. Furthermore, we do not consider that there is any justification (and particularly no justification specific or unique to Rochford District) to fetter the discretion or innovation of the house-building industry to respond to market requirements for different sizes of private residential properties. Unless there is a specific local justification for imposing floorspace sizes, Policy DM4 and its supporting text should be deleted.

The Notes to Table 4: Where it says "'Ev' is Vertical Illuminance in Lux and is measured flat on the glazing at the centre of the window." It should say "'Ev' is horizontal Illuminance in Lux and is measured flat on the glazing at the centre of the window." Presumably, the symbol used in the note and in the table should be Eh and not Ev. Windows are usually mounted vertically and so if you measure the illuminance flat on the glazing at the centre of the window you can only measure horizontal illuminance. Any vertical illuminance will not fall on the window.

Paragraph 2.33 - the requirement that 'All non-habitable rooms should be of an adequate size, height and shape, with sufficient natural lighting, and be ventilated directly by external air via a window.' is very prescriptive given the specified exclusions from the definition of habitable floorspace in Paragraph 2.25. The text should be amended such that only rooms in excess of 3 sq m should meet these requirements. This would ensure, for instance, that bathrooms had a window but a shower room or separate toilet facilities did not need to have a window.