Policy CSP4 - Achieving well-designed places

Comment

Representation ID: 45883

Received: 11/10/2021

Respondent: Transport for West Midlands

The way streets and places are designed and ultimately managed (i.e traffic regulations or the physical designs of our streets) are vitally important to help manage the overall levels of traffic, dominance of vehicles and how comfortable people feel using sustainable and active travel modes. Unfortunately, certain groups do not always feel safe (including women, transgender groups and disabled groups as examples), and so measures need to be implemented to tackle any barriers which exist in new developments, including appropriate safety measures. This point should therefore be set out more strongly in this policy section.

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.

Comment

Representation ID: 47033

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

As identified at paragraphs 3.14-17 and 3.75, the draft BCP has identified exceptional circumstances for the removal of land from the Black Country Green Belt. The Council summarise their exceptional circumstances case further at paragraph 4.7 of the Urban Capacity Review Update (May 2021).

Following national planning policy, the authorities are therefore justified in proposing to amend the Green Belt boundary through the associated policies map. Indeed further land will be necessary to be released from the Green Belt if the Councils are to deliver the scale of supply proposed in the plan, let alone reducing the overall shortfall being exported to neighbouring authorities (as we discuss further in response to draft policy HOU1 below).

The policy however could do with refinement. As currently drafted part 2 applies to sites to be removed from the Green Belt (so at the point the plan is adopted will no longer be in the Green Belt), and the balance of the policy is to be applied to land remaining in the Green Belt. The policy would benefit from part 2 being deleted to provide greater clarity. Part 2)a. (the need for a defensible Green Belt boundary) is covered in draft policy CSP3, it may be that policy should also include reference to part 2)b. and the need for compensatory measures. Another solution could be making Part2)b. part of any site specific allocation for sites removed from the Green Belt.

In evolving the next version of the plan the Councils should provide further information in a single document (perhaps as a topic paper) summarising the Green Belt compensatory measures on a Black Country wide basis to ensure there is clarity on how NPPF paragraph 142 is satisfied.

NPPF paragraphs 140 and 143 are clear that Green Belt boundaries should be permanent and endure beyond the plan period. Where necessary safeguarded land should be identified when defining Green Belt boundaries in order to meet longer term needs. Despite this the draft BCP makes no attempt to safeguard land for its needs beyond 2039. This is particularly relevant for authorities such as Sandwell, safeguarded land can also contribute to maintaining the area’s housing land supply. Indeed Sandwell has consistently not been able to demonstrate a five year housing land supply2 in recent years given under delivery on brownfield land, a strategy it proposes to continue through the BCP. The plan should therefore identify safeguarded land to satisfy national planning policy.