Comment

Representation ID: 44919

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy CSP4 - Achieving well-designed places

4.1 The Framework [§127] requires plans to set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable. Whilst policy CSP4 is generally supported, it is considered that some of the wording is vague in places and fails to provide clarity of what would be expected of developers. For example, it states that:

4.2 “Building designs will be sought that are appropriate to the Black Country...”

4.3 However, no further information is provided on what “appropriate” design would be. It also states:
“All development will be required to demonstrate a clear understanding of the historic character and local distinctiveness of its location and show how proposals make a positive contribution to Black Country place-making and environmental improvement”.

4.4 Again, no clarification is provided as to what “Black Country place-making and environmental
improvement” would constitute.

4.5 The policy would therefore benefit from further clarification either within the policy text itself or the justification text. The policy as drafted conflicts with the Framework §16 (d) as it is not evident how a decision maker should react to development proposals. Given the focus in national policy on creating beautiful and distinctive places with a consistent and high quality standard of design, and in accordance with the Framework [§128], it may be worthwhile for a design guide to be prepared as part of the BCP which reflects local character and design preferences and would provide more specific guidance to developers on design requirements. The policy requirements should be set out in sufficient detail to determine a planning
application without relying on, other criteria or guidelines set out in a separate SPD.

4.6 If such a document is to be produced, it is essential that this is prepared as part of the BCP so that any cost implications can be properly viability tested in conjunction with other policy requirements.

4.7 It is also considered that the policy should be reviewed against the requirements of the latest version of the Framework (July 2021) to ensure that it reflects the most up to date national policy in relation to matters such as the creation well- designed and beautiful places, and the contribution of trees to the urban environment.

4.8 Paragraph 3.58 of the justification text to the policy suggest that a contribution towards public art with thresholds for eligible development and the value of contributions will be set out in Local Development Documents. As this may have an impact upon the viability of schemes alongside other contributions, Taylor Wimpey considers that any justification for this contribution and thresholds and requirements for a contribution should be set out in the BCP itself, so that they can be properly tested though the viability assessment work informing the
plan.