Comment

Draft Black Country Plan

Representation ID: 21354

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

Representation Summary:

POLICY ENV9 – DESIGN QUALITY
As an advocate of the importance of good design, WDH support the intention of Policy ENV9, with the policy requirements set out in the policy reflective of what WDH considers to be the principles of good urban design. WDH’s response to HOU1 sets out the manner in which the development of Bromwich Lane, Pedmore would adhere to those principles, and indeed would be in accordance with the plan as a whole.

With that said, it is noted that Policy ENV9 merely repeats the requirements of the Building Regulations in places. As such, it is not considered suitable to make reference to those requirements.

Furthermore, whilst WDH support the provision of high-quality, well-designed housing as an integral part of meeting the area’s identified housing needs, the inclusion of a requirement for all dwellings to demonstrate accordance with the Nationally Described Space Standards (NDSS) must be robustly justified; which currently is not the case. Moreover, the BCAs must consider the inevitable impact of that required on development capacity and viability to ensure that the plan is deliverable.