[This is our response to the Government’s consultation on a national space standard for dwellings. The Government is consulting on a number of issues including accessibility, security, water usage etc. This response only comments on the proposed national space standard. To see the Housing Standards Review Technical Consultation on Nationally Described Space Standard to which we are responding, click here for the Consultation paper and here for the Space Standard]
Question 7. Do you agree the Government’s proposals for a single level of requirements in the nationally described space standard?
First of all, we very much welcome the introduction of a national space standard. It is very important, long overdue and although we have some concerns, we are very pleased with the direction of travel.
Yes, we do agree that there should be a single level of requirements in the national space standard. As noted in previous consultation responses, the amount of space needed for people to use the rooms in their home, and move within them and between them does not vary geographically or by tenure. It therefore makes most sense to have one minimum standard that adequately reflects these needs.
In our view these standards should be incorporated into Building Regulations as soon as possible rather than being implemented through the planning system, both in the interests of simplicity and fairness to avoid adequate space in the home becoming a postcode lottery.
In addition to the points on bedroom size, ceiling height etc addressed in later questions, we would wish to highlight two concerns over the existing standard:
- The GIAs for houses are calculated on the assumption that staircases are compact with winders. We take this to mean winders at both the top and bottom of the staircase. Such stairs are a significantly greater falling hazard to occupants than conventional straight staircases, which is why housing associations (for example) moved away from staircases with winders approximately 25 years ago. In addition it is significantly harder (sometimes impossible) to install stair lifts on staircases with winders. We therefore think that the GIAs for houses should be re-calculated using the assumption of a straight staircase.
- Dining areas: we recommend that the standard incorporates a requirement that the dwelling layout should provide a dining area that will accommodate all of the designed-for occupants plus 2 visitors, and that this space should not be part of the living area. HCA quality audit data suggest a preference for households to be able to eat together, and for that activity to be separate from the living area. The family and social benefits arising from households having the opportunity to eat together are well documented, and should not be stymied by poor design. This requirement should not have an effect on the GIA.
Question 8. Do you agree with Governments proposals for internal storage?
No – the floor areas in the standard are adequate for internal general storage only, and 3 additional requirements need to be addressed:
- Tall storage for upright hoovers, ironing boards, brooms etc. This should be set at 0.5 m² floor area for up to 3-bed dwellings, and 1 m² floor area for larger dwellings.
- There should be additional storage provision for items associated with private external spaces:
- for flats without private gardens – 1 m²
- for dwellings with a private garden (up to 4 people) – 2.5 m²
- for dwellings with a private garden (5 people or more) – 3 m²
- Bicycle storage – similarly, such storage is likely to be internal for flats (and should therefore feature in this standard). For dwellings with gardens, it is likely to be external.
We recognise that the storage space for the dwellings with private gardens is likely to be provided externally (and may therefore be considered to be outside the remit of the standards). However, we wish to avoid losing sight of the issue. For flats, the storage space is likely to be located internally, even though it may be for items used externally, and should definitely be included in this standard.
We recommend that storage requirements that are likely to be external to the dwelling (for gardening equipment, outdoor chairs and tables etc and bicycles associated with houses, not flats) are referred to in the standard, perhaps as a footnote, even though they may not be incorporated into a set of standards designed to address only “inside the dwelling” issues. It is important that external storage is not overlooked.
Question 9. Do agree with the proposed requirements for bedrooms and bedroom sizes?
No – we consider them to be marginally too small, and that single bedrooms should be at least 8 m², and double/twin bedrooms at least 12 m², as set out in the London Housing Design Guide.
Question 10. Do you agree with the Government’s proposed approach to ceiling heights as set out in the proposed nationally described space standard?
Question 11. Would you agree that Government should continue to explore the potential role of building control bodies in providing plan checking and type approval of the nationally described space standard?
Yes – however please see our earlier comments that the standard should be incorporated into Building Regulations as soon as possible.
Question 12. How do you think on site compliance with space standards would best be checked?
We believe the best compliance process is for the building control body to check the construction against the approved planning drawings showing compliance with the space standard. We recognise that the Building Control Officer would be acting as agent for the Planning Officer, and could only report non-compliance back to the Planning Officer. S/he wouldn’t be able to take any enforcement action themselves – that would be for the planners. However the advantage of this approach is that Building Control Officers are on site in the normal course of their work and that non-compliance is therefore much more likely to be identified than is on-site checking has to be undertaken by planning department staff.
However, we also support the idea of requiring the sales particulars of any housing for sale to include the Gross Internal Areas for each dwelling. We strongly support initiatives to provide customers with as much information about what they are contemplating purchasing as possible.
Please note that the Property Misdescription Act was repealed last year and is no longer in force. Inaccurate information provided in sales particulars may therefore be actionable under the Consumer Protection from Unfair Trading Regulations 2008 and the Business Protection from Misleading Marketing Regulations 2008. We are concerned that the new regulations may offer less stringent control on misdescription of property particulars, but nevertheless strongly support the publication of Gross Internal Areas in property particulars.
Question 18. Do you agree with the Governments proposed approach as to how the use of optional requirements and nationally described space standard should be taken forward?
No – as previously noted we think that the nationally describe space standard should be incorporated into Building Regulations, and not be an optional planning policy.
However, even in terms of the current approach of using the planning system, we think there are flaws in the Governments current approach.
Local authorities will need to include the potential effect on site capacity of adopting the space standard just as they currently have to consider the effect of other policies that significantly affect site capacity such as density, car parking provision, separation distances between blocks, and open space requirements.
Designing in sufficient space to allow a home to function properly for the expected number of occupants is a basic functional requirement rather than a matter of amenity. In its nature, it is closer to ensuring that there are adequate services to / from the property, appropriate thermal insulation, weather protection etc. (Clearly, higher-than-necessary amounts of space are an amenity rather than a basic functional requirement, just as several ensuite bathrooms are. However, this feedback addresses the proposed nationally described space standard, which is set at a functional minimum level).
Therefore, this is not an issue where “local need” needs to be established prior to a policy being adopted. Adequate space to use the home is not a specialist need, that has to be identified and justified before being addressed. It is a universal need directly comparable to having adequate supply of water, electricity etc to meet the household likely needs.
Paragraphs 120 & 121 in the consultation document suggests that the Government considers adequate space in the home to be a specialist or “nice to have” amenity, that requires a robust justification for its inclusion in policy, perhaps more so than other policies. We consider this approach fundamentally flawed and instead suggest that local planning authorities are invited to adopt the nationally described space standard and to treat it as a higher priority than policies which only affect amenity, not basic functionality.
Question 19. – Do you agree the proposed approach will be sufficient to ensure local planning authorities and neighbourhood planning qualifying bodies in future only set policies requiring compliance with the optional requirements and nationally described space standard to address a clear and evidenced need? If not, please indicate why.
No – as noted above we do not think that the space standard should be discriminated against, and be made subject to more onerous justification requirements than other planning policies. Rather the reverse should be the case. For example, having enough space in the dwelling to be able to use the rooms conveniently and safely is more important than insisting on a separation distance between blocks of (say) 21 m instead of 20 m. Separation distance policies can have a much more dramatic effect on site capacity than the proposed nationally described space standard. Similarly, requiring 2 car parking spaces per dwelling instead of 1.5.
Meanwhile, there are many ludicrous examples of car parking problems on estates caused by the inability of residents to park their car in the garage, is it worth it because the garage contains the washing machine and dishwasher, because there is insufficient space in the dwelling to accommodate them. A lack of adequate internal space causes a car parking problem. Increasing car parking requirements on future projects is (obviously) the wrong policy response to such situations.
In summary, we strongly object to the entire tone of this question which apparently reflects a desire by Government to minimise the use of the nationally described space standard. This is completely the wrong approach. Until it is incorporated in Building Regulations, the Government should reverse their direction on this issue and facilitate – if not encourage – local planning authorities to use the space standard.