Comment

Draft Black Country Plan

Representation ID: 22559

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

Representation Summary:

Policy CSP4 – Achieving well-designed places

We are supportive of the policy as a strategic policy for the Black Country. Building design is a very subject matter; what may be seen as high quality and good design may not be by others. The Governments direction on design with the introduction and need for Design Codes to help make the decision-making process clearer, less subjective and more consistent is clearly seeking to ensure that polices are left to personal/individual interpretation which can often restrict the delivery of all types of development.

However, this process is going to take time and development cannot be put on hold until Design Codes or their equivalent are introduced. The policy is a general one which mirrors the current policy in the adopted BCCS. The Black Country whilst a region which shares a number of physical and social characteristics, it is made up of a number of cities/towns which have their own unique identity. Building designs suitable to their location is a suitable option but cannot be one which is applied without taking into account the typography and shape of the land and the impact these major physical constraints can have on the design and viability of development.
High quality design will have impacts on the deliverability and viability of development. This needs to be balanced very carefully by the Black Country and their individual authorities when looking at efficient design, high quality materials and impacts on the historic environment.