Comment

Representation ID: 23221

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Policy CSP4 – Achieving Well-designed Places

We generally welcome the thrust of Policy CSP4 and agree that achieving well designed places that make a positive contribution to the local character of an area is a desirable policy objective. Furthermore, the thrust of national planning policy seeks to emphasise the role that good design can and should play in new development as evidenced by the recent updates to the Framework and the inclusion of specific new design policies in Chapter 12.

However, we need to be realistic about what this means for the amount of development that can be delivered on sites. We raised this in the workshop meetings held at the beginning of this year and the response was that good design can be achieved at higher densities. Whilst in principle this is true, the higher density schemes I have worked on the black country have been a result of the unique history or design response required for that site. In the most part, where the existing Design Guidance documents holds more weight, the guidance and standards invoked do not allow for high density housing schemes in favour of a more traditional layout. There is nothing wrong with this approach from a design/amenity perspective; however, if higher densities are going to be met than have previously been achieved, then what constitutes good design will need to be rethought. A clear commitment to this will be needed, because otherwise the practical reality is not going to meet the policy aspiration, and the development needs will not be met.

The amount of development that can be achieved on the site is also impacted by the net developable area. The sixth criteria in this policy relates to the delivery of a network of public open space within housing sites. We support the provision of public open space within residential developments, but it is not clear how this aspiration relates to the assumption that that net developable area on brownfield sites will be 80% of the site. When you consider the potential for single sided roads and the other inefficiencies that come with brownfield sites, this not going to leave any meaningful space for the provision of public open space.