Policy CSP4 - Achieving well-designed places

Comment

Representation ID: 11570

Received: 06/10/2021

Respondent: David and Marilyn Goode

Secondly, this will considerably impact on people already living in the area. It will not only ruin the quality of life for residents living in these areas. It will increase pressure on schools, our shops and Doctors with over populating these areas.

Comment

Representation ID: 11709

Received: 08/10/2021

Respondent: Walsall MBC

We welcome the proposal to promote sustainable design and active travel, but more emphasis should be made of this in order to meet Climate change projections for 2041!

Support

Representation ID: 11827

Received: 09/10/2021

Respondent: Mr Richard Knight

I agree with the importance of well-designed places and buildings.

Object

Representation ID: 12176

Received: 11/10/2021

Respondent: Mr nicolas crombie

Effective quality standards for housing and quality of place have led to poor quality housing provision in the BCAs. The new BCA Plan must address the key factor of quality of place in addressing this syndrome using as a tool the engagement of local communities in determining the quality factors required for their neighbourhood

Comment

Representation ID: 12334

Received: 01/10/2021

Respondent: Mr & Mrs Barry and Joan Richards

Number of people: 2

Dear Sirs.
We as long residents of Aldridge appose this plan for dozens of reasons mainly the damage it will do to Aldridge village with overcrowding, fewer available parking places, increased crime. There are many more which you will hear from this research.

We once lived in a situation where such a development took place after we had bought the house and the crime rate went through the roof and the value of our properties suffered greatly and that will happen here and has probably started since your intension were made clear.

Comment

Representation ID: 12350

Received: 01/10/2021

Respondent: Christine Leahey

Document Ref. Strategic Allocation WSA3, Site WAH237/ WAH235


Your policy document states that one of the design principles is "improvements to local facilities to support residents & to enhance the sustainability of the existing area, in particular improved capacity at the primary schools and local health centre". The existing area will not be enhanced as there is no infrastructure for transport and schools are oversubscribed as well as the local health centre. Widening the local roads will have a significant negative impact to the local residents, increased traffic, air pollution, noise all of which are identified as factors that would not have an adverse affect on the local area.
There are no existing drainage amenities suitable for such an extensive development and any development will directly contradict your principles of delivering landscape, biodiversity and amenity benefits.
The development will directly and negatively impact your strategy for landscape and habitat creation that provides enhancement, retention and mitigation for established trees and hedges. Any development will have a significant adverse impact on visual amenity and character on aminal species.

All developments should be based on the "presumption in favour of sustainable development" and the above factors do not comply with this.
The proposals to allocate the site for housing directly contradict your Strategic Priority II which is to protect and enhance the natural biodiversity, wildlife corridors, geological resources, countryside and landscapes. The land is used for agriculture Grade 3a and is consistently producing crops each year. Any change will significantly affect the livlihood and economical well being of the people involved in this valuable food production system.
The proposal to allocate the site for housing directly contradict Strategic Priority 12 which is to protect, sustain and enhance the quality of the built and historic environment whilst ensuring the delivery of distinctive and attractive places. Our area is a very distinctive and attractive place which will be completely decimated and the landscape ruined with development. Visual amenity will be lost and economic detriment on house values for all the local residents.

Comment

Representation ID: 14838

Received: 10/10/2021

Respondent: Alison Wilkes

Policy CSP4
Comment: The policy should directly link to Policy ENV3 and it's statement that all development shall deliver the Local Nature Recovery Network Strategy.

Justification
Comment: The natural environment and green and blue infrastructure are key to achieving well-designed places and this should be acknowledged here, as should the value of ecosystem services.

Support

Representation ID: 15288

Received: 11/10/2021

Respondent: Natural England

Policy CSP4 - Achieving well-designed places

We welcome this policy direction, specifically in reference to development proposals employing methods to help achieve climate change mitigation and adaption, minimising carbon causes and non renewable resources, and securing integrated and well connected multifunctional open space networks.

Support

Representation ID: 17525

Received: 11/10/2021

Respondent: Sport England

Sport England supports the references within this policy to Active Design and Active Environments principles, which we define as creating places and spaces that encourage people to be physically active. In particular, we support: * In part 1) the emphasis on spaces and buildings being influenced by their context to respond positively to identified community needs; * In part 4) to developing a permeable street network that provides active travel choices * In part 5) to ensuring safe and secure environments including safe and accessible pedestrian and cycle infrastructure * In part 6) to ensuring an integrated and well-connected open space network, including through new developments for housing and employment uses, with reference to delivering opportunities for sport and recreation. Since the policy makes specific reference to these Active Design principles, it would be appropriate to reference Sport England's Active Design Guidance in the associated justification and evidence on pages 42-44. A link to Sport England's guidance is provided below: https://www.sportengland.org/how-we-can-help/facilities-and-planning/design-and-cost-guidance/active-design

Comment

Representation ID: 18324

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 3.19 " references made in criterion 2 to the
use of carbon based products being minimised. It is not understood why the use of renewable timber, for instance, would need to be minimised in the interests of sustainability, energy efficiency and minimising the use of non renewable resources. In addition, referencing is made in criterion 5 to the urban environment being designed in a way to encourage people to act in a ‘civil and responsible manner’. Again, it is difficult to perceive how a development proposal will deliver these specific requirements on the ground."

Support

Representation ID: 18325

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 3.19 "the general themes identified in CSP4 are supported."

Comment

Representation ID: 18525

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Comment: A point should be added to the policy that directly references the statement made in Policy ENV3 – Nature Recovery Network and Biodiversity Net Gain that all development shall deliver the Local Nature Recovery Network Strategy, and that these will take account of where in the Local Nature Recovery Network the development is located and deliver benefits appropriate to that zone.

Support

Representation ID: 18527

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

6
Support: WTBBC support the pursuance of an integrated and well-connected multifunctional open space network. This point links with Policy ENV8: strengthening (through extension, increased access and enhanced value) and providing components of a high quality, multifunctional green space and greenway network. WTBBC are of the view that to fully realise many of the BCP’s aspirations that mapping of the existing multifunctional green space and greenway network should be undertaken in parallel with the Local Nature Recovery Strategy. This will enable targeted investment in the network which maximises biodiversity, social and a range of other ecosystem services benefits.

7
Support: WTBBC support the recognition of the value of protecting and enhancing the Black Country canal network in achieving well-designed places.

Comment

Representation ID: 20978

Received: 11/10/2021

Respondent: Dr Baljit Bhandal

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 is not going to leave any meaningful space for the provision of public open space.

Comment

Representation ID: 22189

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

The general approach in Policy CSP4 is welcomed. Paragraph 127 of the Framework states that “Plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable. Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics.” We consider that the proposed policy is appropriate and provides sufficient clarity as to what will be expected and what would be acceptable.

Reference is made within the policy to achieving high levels of sustainability and use of sustainable modern technologies. The approach taken in the policy is welcomed in that it does not try and conflate the dual roles of the planning process with Building Regulations, as we consider that Building Regulations are a far more efficient and effective way of securing sustainable building design and energy reduction than the planning system is.

Support

Representation ID: 22231

Received: 11/10/2021

Respondent: Steve Crutchley

Policy CSP4 – Achieving Well-designed Places

The general approach in Policy CSP4 is welcomed. Paragraph 127 of the Framework states that “Plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable. Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics.” We consider that the proposed policy is appropriate and provides sufficient clarity as to what will be expected and what would be acceptable.

Reference is made within the policy to achieving high levels of sustainability and use of sustainable modern technologies. The approach taken in the policy is welcomed in that it does not try and conflate the dual roles of the planning process with Building Regulations, as we consider that Building Regulations are a far more efficient and effective way of securing sustainable building design and energy reduction than the planning system is.

Support

Representation ID: 22268

Received: 21/01/2022

Respondent: Miss Jodi Stokes

Placemaking – Achieving well-designed places

3.10 We note that high-quality design and place-making is central to the ambitions of the Local Enterprise Partnership (‘LEP’) and West Midlands Combined Authority (‘WMCA’). The key themes from the Black Country Garden City Prospectus (launched by the LEP in 2017) and West Midlands Design Charter (launched by the WMCA in 2020) are reflected in draft Policy CSP4 (Achieving well-designed places). We agree that draft Policy CSP4 reflects the requirements of Chapter 12 of the NPPF, and for development to reflect local design policies and government guidance on design including the National Design Guide and National Model Design Code (as per paragraph 134 of the revised NPPF).

Comment

Representation ID: 22347

Received: 11/10/2021

Respondent: Canal & River Trust

The Trust supports the design and placemaking aspirations of policy CSP4, in particular part 7, which deals specifically with the canal network. However, we would like to see the words 'wherever possible' completely from this part of the policy so that protection and enhancement of the canal network through design and layout and integration into the development is always an expectation for canalside sites. We suggest that this is consistent with the NPPF (chapters on design and historic environment) and the National Design Guide (on integrating nature and public spaces).

Comment

Representation ID: 22507

Received: 11/10/2021

Respondent: Environment Agency

Policy CSP4 - Achieving well-designed places

Paragraph 2 starts with the qualifier ‘Where Possible..’, which immediately leaves scope for any proposals to claim the requirements are ‘Not possible here’. We recommend that this is deleted or a more challenging approach is included in Paragraph 2, such as through some defined criteria for ‘Not Possible’, such as emergency works, or evidence required to demonstrate when not viable. By comparison, the wording in Paragraph 3 is more absolute. This Paragraph also overlooks the economic opportunity from maximising the use of recovered and recycled materials in construction, especially where locally-sourced, as a Circular Economy needs a ‘pull’ for resources to stimulate the recovery of waste. Sustainable modern technologies should seek to minimise the demand for ‘new’ raw materials as far as possible. In particular would be approaches to increase the recovery and recycling of plasterboard from the ‘skip waste’ stream, as this material can be problematic when landfilled, and plaster is heavily used in construction. Conversion of commercial properties into homes, or the formation of Houses of Multiple Occupation or student accommodation mean that the ‘refurbishment waste stream’ can be a significant factor, as rental properties tend to require more frequent maintenance than owner-occupied premises.

Paragraph 5 refers to encouraging civil and responsible behaviours, this can include reducing practices such as littering, flytipping, open burning of waste, and illegal dumping, processing or ‘warehousing’ of large volumes of waste. It would be very welcome to discuss interventions in this area, including how to tackle locations that seem derelict or ‘uncared for,’ and can attract a range of anti-social activities and crime. A plan to manage and if possible eliminate these locations could be considered, especially to avoid simply ‘moving the problem around’.

Comment

Representation ID: 22559

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

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.

Comment

Representation ID: 22614

Received: 29/09/2021

Respondent: Chief Constable of West Midlands Police (CCWMP)

Agent: Tyler-Parkes

The Tyler Parkes Partneship Ltd act for the Chief Constable of West Midlands Police (CCWMP).

This Comments Form TOGETHER WITH the accompanying letter dated 29th September 2021 comprise the CCWMP's representations on Policy CSP4.

The CCWMP welcomes the assertion at policy CSP4 paragraph 5 in the Draft Black country plan (BCP) that, ‘…The Black Country will be a safe and secure place to live and work in, through organising the urban environment in ways that encourage people to act in a civil and responsible manner. Development proposals will be required to provide active frontages, well-located, safe and accessible pedestrian and cycle infrastructure and an appropriate intensity of use in centres and elsewhere. Designs should promote natural surveillance and defensible spaces.’

He also welcomes the supporting justification explanation at paragraph 3.52 that, ‘The aim of the Black Country Plan is to create the conditions for economic and social growth, which will take place within a safe, attractive and accessible built and natural environment. The BCP also encourages and supports the growth of locations that encourage participation and community engagement. Successful placemaking in the Black Country will foster community stability and incorporate elements that create resilience to adverse economic and environmental impacts…’

However, the CCWMP objects to the omission of any reference to the ‘Secured By Design’ guide and the ‘Park Mark’ parking standards which would ensure a consistency in designing out crime standards. It is recommended that the following modification to the policy be included:
'…Designs should promote natural surveillance and defensible space. All new development should include consideration of crime prevention measures, Secured by Design, Park Mark principles, and the need for a maintenance plan to reduce crime, the fear of crime and anti-social behaviour.’

Support

Representation ID: 23186

Received: 11/10/2021

Respondent: Historic England

CSP4 – Achieving well designed places – includes some useful text for the historic environment and the benefit of responding to local heritage and cultural context which we support.
Clause 3 relates to heritage and would benefit from the addition of a line about protecting the significance of heritage as well as responding to historic character.
Clause 7 looks at protecting and enhancing the historic canal network which we support.

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.

Support

Representation ID: 23309

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

The general approach in Policy CSP4 is welcomed. Paragraph 127 of the Framework states that “Plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable. Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics.” We consider that the proposed policy is appropriate and provides sufficient clarity as to what will be expected and what would be acceptable.

Reference is made within the policy to achieving high levels of sustainability and use of sustainable modern technologies. The approach taken in the policy is welcomed in that it does not try and conflate the dual roles of the planning process with Building Regulations, as we consider that Building Regulations are a far more efficient and effective way of securing sustainable building design and energy reduction than the planning system is.

Support

Representation ID: 23414

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

4.13 With regard to achieving well-designed places, Draft Policy CSP4 states that the Black Country’s ongoing transformation will be supported by the development of places and buildings providing a range of functions, tenures, facilities, and services, intended to support the needs of diverse local communities. L&Q Estates are supportive of Draft Policy CPS4

Object

Representation ID: 43855

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

4.15 Policy CSP4 relates to delivering well designed places. Taylor Wimpey supports the intent of this policy to deliver well designed places, and in particular
enhance the attributes of the Black Country's character and heritage.
4.16 In terms of specific points in the policy, reference is made in criterion 2 to the use of carbon-based products being minimised. Whilst the intention of this statement is understood, it should be re-worded as it would otherwise restrict the use of products such as renewably sourced timber and other similar materials. In addition, reference is made in criterion 5 to the urban environment being designed in a way to encourage people to act in a ‘civil and responsible manner’. Again, it is difficult to perceive how a development proposal will deliver these specific requirements 'on the ground'.

Object

Representation ID: 43911

Received: 10/10/2021

Respondent: Barratt West Midlands

Agent: Turley Associates

3.17 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.
3.18 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.
3.19 Barratt therefore consider that 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 Codes for the Black Country.
3.20 In any event, throughout the masterplanning undertaken to date, Barratt has sought to ensure that the illustrative masterplan is grounded through high quality urban design and placemaking as evidenced through the Vision Document enclosed at Appendix 3.
3.21 The nature and distinctive qualities of the local landscape surrounding land at
Pennwood has been taken into account when developing the siting, scale, and design of new development. In addition, the masterplan has been informed by additional
technical work on heritage and ecology allowing the proposed layout to better accommodate landscape and visual screening but also deliver significant ecological benefits through the green infrastructure network.
Green Belt

Comment

Representation ID: 43929

Received: 11/10/2021

Respondent: IM Land

Agent: Turley Assocs

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.

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.

Comment

Representation ID: 44965

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

4.0 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.