Comment

Representation ID: 46178

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

The policy should be clear about design expectations and how proposals will be tested against policy, having regard to national guidance and other material considerations. The BCA should prepare design guides and/or design codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences. If these are to follow as supplementary planning documents, then the draft development plan policy should be explicit in this regard.

The Policy should provide clarity over how the BCA intend to proportionately apply any assessment frameworks, such as Building for a Healthy Life (Footnote 6), in the context of high-quality design and placemaking being central to the ambitions of the LEP and the WMCA.

Whilst justified for the largest-scale, strategic development sites, in the context of the guidance provided by the Framework and the PPG, such processes can introduce unjustified additional costs and unnecessary delay in the decision making process for smaller scale developments. It is important when setting out broad policies relating to high quality design (of both places and buildings) that thresholds are introduced such that it is clear and unambiguous which developments are to be subject to which requirements. Paragraph 16 of the Framework is clear that development plans should contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.