Brighton and Hove City Plan Submission
Representations by Hove Civic Society
Hove Civic Society wishes to make a number of representations in respect of the Submission version of the Brighton and Hove City Plan.
We wish to support a wide range of policies in the plan. In particular we support the overall housing targets and allocation policies and the proposals for the development and special areas in the City.
We wish to challenge the soundness of the plan in two respects:
§ We believe the plan should include space standards for new housing developments to prevent housing to be built in the City that is not fit for purpose. We believe this requires an addition to an existing policy and a commitment to produce minimum dwelling standards for new housing in the city; we believe such standards should closely follow the standards now set by the Mayor for London in the London Plan as adopted in July 2011 and in the Mayor’s Housing supplementary planning guidance as adopted in November 2012.
§ Whilst we welcome the references in almost all policies related to the Development areas to decentralised district heating, we believe such reference should also be made in respect of policy for area DA8 specifically referring to the substantial contribution that Shoreham power station could make to district heating for the city.
Support for policies in the Brighton and Hove City Plan submission:
Hove Civic Society wishes to record our support for the overall structure of the city plan, the distribution of development areas and the targets set for housing development and employment generating uses. We welcome the first step of setting dwelling standards by requiring new developments to meet the Lifetime Homes Standard. We also welcome many of the policies and suggestions including the ambition for a transport link along the seafront, the recognition that park and ride could be managed by using unused car parking space throughout the city and in particular at railway stations during weekends and the recognition of shopping facilities in Hove and Portslade. We welcome the announcement of guidance for car free developments. In particular we wish to record our support for the insertion in a range of development area policies of various references to decentralised energy and heat networks. We believe that the development and expansion of district heating for the city has a major potential of making the city much more energy efficient and hence sustainable.
We are broadly content with the plan and its policies and we would be most concerned if there were significant changes to key policies. We would like to be offered the opportunity to be heard if this should be the case.
We would like to express our appreciation to the Council for the way many of our comments at the consultation stage have been taken onboard.
Objection to lack of policy on dwelling standards:
We object on the grounds of soundness to the omission from the plan of a requirement for all new housing to meet minimum dwelling standards. We believe this is a key strategic measure that secures quality, sustainability and the health of occupants.
Hove Civic Society have long held the view that many new dwellings in the city are too small to provide a minimum of comfort for future occupants. The size of dwellings can be such that standard furniture is difficult to accommodate and storage is at extreme premium. The Society is bemused by the fact that the Council has adopted standards for affordable homes, which are about the level of standards developed elsewhere in the UK, and which are meant to provide a minimum basic standard of accommodation, but that these standards do not apply to private sector developments. Indeed private sector developments often contain substantially smaller dwellings, providing what others such as the Mayor of London have called Hobbit homes. It is often said that the private sector knows best what to provide. However in a situation such as in the South East, where demand exceeds supply even substandard dwellings will be snapped up, because of a lack of choice. Hove Civic considers reasonable dwelling space, including adequate storage to be a key quality, health and sustainability issue. We believe that the demand for high quality homes and the requirement to identify size, type and tenure and range of housing in the NPPF also embraces this issue and that it is therefore a legitimate planning issue to consider.(ref para 50, NPPF, doc reference 10)
The case for dwelling standards has been admirably made by the Greater London Authority and these are now enshrined in the Greater London Plan (adopted July 2011) and repeated in the London Mayor’s Housing supplementary planning guidance (adopted November 2012). We believe that there are several good reasons for Brighton and Hove to adopt the same standards:
§ The housing situation in terms of population pressure and demand is not dissimilar in Brighton and Hove;
§ There is a tendency towards higher densities especially in all the development areas identified in the plan, which makes good quality design and higher space standards imperative;
§ It makes good sense to introduce an identical standard across the region as this will provide clarity and assist market operators;
Our case therefore mirrors that prepared for the Greater London Plan. We paraphrase here the key arguments made by the GLA. Our Appendix 4 includes the space standards for different type of dwellings and Appendix 5 provides references / hyperlinks, where possible, to the documents referred to.
We draw upon the Evidence provided to the Examination in Public of the draft replacement London Plan on Housing Design Standards, dated July 2010. (Doc reference 8) The evidence is supported by a formidable bibliography. Many of the titles reflect in an anecdotal way the key concerns with new housing development such as:
§ ‘No more hobbit homes’ Bowie D, Planning in London, Issue 71, October-December 2009;
§ No More Toxic Assets: Fresh thinking on housing quality, CABE 2009;
§ Room to Swing a Cat? The amount and use of space in new dwellings in London and the South East, HATC, 2010;
§ No homework space for the MySpace generation, Housing Corporation, News Release, 16 October 2006;
In the run up to preparing their policy the GLA had commissioned research in 2006 by HATC limited which provided much of the basic arguments for better dwelling standards (document reference 3). In brief the argument provided in evidence by the GLA is as follows:
There is dissatisfaction with new housing development – in an 2004 audit only 18% of new housing developments achieved a score of ‘good’ or ‘better’ (para 1.4)
The tendency towards higher density requires higher standards of space, amenity and management or there is a risk of recreating the cramped and poor housing environments of the past.(para 1.4)
New dwellings ‘should be built not only for short-term market demands or current occupant needs, but to provide long term flexibility with homes that will meet the changing needs of occupants and tenures over time..’(para 1.6)
Whereas design standards including dwelling size are common in other countries England is notable in the examples provided for its lack of certain design controls particularly in regards to the size of homes (para 1.8)
Research and case studies show that the benefits of higher quality housing include reduced crime rates, contribution to the mitigation of health inequalities, better welfare and reduced costs to society, and higher residual values for developers. (para 1.9)
‘Various research studies and consumer surveys show a considerable degree of consistency not only in the preferences expressed regarding the importance of space in the home, but also in levels of dissatisfaction with inadequate space a frequent issue raised amongst residents. In looking at what is currently being provided in actual development schemes, there is a general trend towards decreasing space with more rooms being ‘crammed’ into dwellings, leading to smaller habitable rooms and significant reductions in storage space.’ (para 1.10)
‘Research shows that the average one-bed flat in London has shrunk by 13% since 2002. Another recent study found that 60% of the one-bedroom dwellings in London analysed within the study had no storage space… The same study found that two-bedroom dwellings in particular fell well below the benchmarks proposed by the Homes and Communities Agency (HCA) by some 10 sqm (roughly the size of a small double bedroom), and that some of the two-bedroom dwellings being marketed in London were the same size as the proposed Draft Replacement London Plan (DRLP) standards for a one-bedroom dwelling.’ (para 1.11)
There is a growing demand for space irrespective of household size. ‘Consumer research shows that space is high on the list of priorities of the increasing number of one-person households, and that criticism about lack of space is expressed ‘by all groups of home buyers with singles just as vociferous as families’ (para 1.12)
Space standards are used by a number of authorities. ‘Historically, guidance on space standards has varied, but has been broadly consistent within a range of about +/- 10% since the Second World War, and the Parker Morris standards of 1961 are still a commonly cited benchmark for space standards in the UK.’ (para 1.14)
‘The draft London Plan space standards have therefore been set at a level which allows the property to cater for a reasonably wide variety of diverse household needs over the lifetime of the property, and do not appear to be overly onerous when compared to other existing space standards.’ (para 1.15)
The standards set (and replicated in our Appendix 4) are evidence based. The approach taken was ‘to calculate the minimum space required for each room (based on occupancy) to meet the Lifetime Homes standard and to accommodate a basic inventory of furniture that is commonly required in particular rooms relative to occupancy, as well as allowing adequate access and activity space. Additional circulation space needed in dwellings above one storey has also been taken into account.’ (para 4.5.2)
The methodology to achieve this calculation is set out in great detail in paras 4.5.3 – 4.5.13.
A comparison of various standards is set out in a table para 4.6.7, which demonstrates the similarity of the standards set.
In para 5.3 and 5.4 the evidence argues coherently that standards are now capable of being considered a “material planning consideration” and a component of “sustainable development” and the success of the GLA in incorporating a requirement for new developments to be built to the Lifetime Home standard as an enforceable policy further supports the view that residential space standards could be set in and enforced through the planning system.
We believe we can apply this formidable array of successful arguments, which has resulted in the space standards as proposed now being incorporated in the statutory London Plan and also a formally adopted SPG, to the Brighton and Hove City Plan Submission:
§ The housing conditions and housing demands by a growing population in Brighton and Hove do not differ significantly from those that can be found in London;
§ The increase in anticipated density especially in the identified development areas require that special attention is paid to dwelling sizes and space standards to avoid creating the slums of the future;
§ Our own research demonstrates that there are many examples of dwellings with far too little internal space that are submitted for approval (our Appendix 1). Equally there are proposals submitted with space standards which exceed the standards set in Brighton and Hove for affordable homes (such as the PortZed proposal). We therefore believe that given the will local developers can produce good quality decent sized dwellings locally and still conduct a successful business.
§ The current policy vacuum on dwelling sizes makes the local planning authority reluctant to argue the case for dwelling sizes and there is a track record of lost appeals on the matter. It is therefore essential to anchor dwelling size in policy.
§ The Brighton and Hove City Plan submission now includes firmly as policy the requirement for new developments to meet Lifetime homes standards (policy SA6, A8). We welcome this as a first step in setting dwelling standards and would like to remind the Council that the GLA dwelling standards take their evidence base from Lifetime homes standards and develop these. (Lifetime homes standards criteria shown as our Appendix 3)
§ We believe that it would only be a small step for the Council to adopt dwelling size standards derived from Lifetime homes standards and it is arguable that the council should be able to simply adopt the London Plan standards, with its well developed methodology. It seems to us unnecessary to repeat the expensive, exhaustive and time consuming process of defining standards, especially bearing in mind the similarities between London and Brighton and Hove and the need for some regional consistency.
We therefore proposed that the following changes are made to the submitted plan:
The Plan should make quite clear that the size of new dwellings is a key consideration which determines the quality and sustainability of new housing and can have a beneficial impact on the health on future occupants.
This point can be made in the context of policy SA6, A8 and also policy CP19a as follows:
Add in policy SA6 A8, after the words ‘lifetime homes standard’ the words ‘and minimum dwelling standards’