Comment

Draft Black Country Plan

Representation ID: 43929

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

Representation Summary:

Policy CSP4 (achieving well-designed places)
3.18 The NPPF was updated in July 2021 with a much greater emphasis placed on the
delivery of high quality design. This saw significant amendments to chapter 12 of the
NPPF and was supplemented by the publication of the National Design Guide (2021)
and National Model Design Code (Parts 1 and 2) (2021). Together these documents
confirm the Government’s intent to guide the delivery of well-designed places and
demonstrating what ‘good design’ means in practice.
3.19 The NPPF now establishes a need for local planning authorities to ensure that visual
tools such as design codes and guides are used to inform development proposals to
provide maximum clarity about design expectations at an early stage to assist in
providing a framework for creating high-quality places, with a consistent and high-
quality standard of design to inform development proposals.
3.20 IM Land therefore consider that draft policy CSP4 should be updated to reflect this
change in national guidance and instead of establishing prescriptive design criteria
within a strategic policy, there is instead an opportunity for the principles identified
within draft policy CSP4 to inform the future development of Local Design Code for the
Black Country.
3.21 In any event, throughout the masterplanning undertaken to date, IM Land have sought
ensured that the illustrative masterplan is grounded through high quality urban design
and placemaking as evidenced through the Vision Document enclosed at Appendix 1.
IM Land will continue to develop and refine the illustrative masterplan in accordance
with best practice guidance.