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1
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Fix
that problem and my response will be more revealing
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2
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Villages should be
treated differently to urban areas like towns. The villages in this
area are being over developed and slowly losing their identity with
the countryside between them being swallowed up by inappropriate
developments which are not integrated into the communities where
they have been built.
Steventon is a classic example of this.
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3
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no
other comments
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4
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Insufficient
respect is given to the existing structure and context of the area,
eg height restrictions are not related to existing structures. Each
new house is higher than the last and each plot fuller than the
last.
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5
|
I
understand that you need to appear to be doing something but this
is just another guideline that can be completely ignored when it
suites the developer. Planning permission WILL eventually be given
and objections ignored. In my experience, the planning department
leaves it to the individual to fight with the developer and takes
no part in the process. Local government (County, District, and
Parish) has made itself irrelevant and is just an extra expense
that the beleaguered householder has to pay with no visible
benefit.
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6
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This
is a valuable, well presented document and the content is very
encouraging. Can the same scientific and aesthetic good sense be
applied to existing developments? Are you shutting the stable door
when the horse has bolted??!
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7
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As
families grow and their children get cars, every dwelling must be
built making parking space for that families potential car
ownership in yhe future.
Too many cars line the pavements due to lack of allocated
space.
We are currently making life safer on the roads for pedestrians
putting the onus on the drivers . What about the cars parked
outside their homes half on the pavement, this isnot making
pavements safer for pedestrians.
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8
|
The
designs look good on paper and are of the standard and quality
required by the law, of that there is no doubt. I would like to see
more detail and commitment relating to who will maintain the site
once completed, what guarantees are in place if the developer goes
bankrupt during or immediately after completion (often happens) and
what is being done to ensure there are recovery positions for the
council if things go awry.
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9
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I hope
this carries weight and is implemented as soon as
possible.
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10
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The
design of this "feedback" questionaire is focussed purely on
ticking a participation box, it fails entirely to ask the question
"what have we learned about the implementation of previous
guidelines?" and as such has 0% learning in it.
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11
|
All
new housing should be provided with solar electricity generation
and heating alternatives to gas/electric boilers. All new housing
should have off street parking including for visitors. All new
housing should have electric vehicle re-charging points.
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12
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I
think I have made my views clear
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13
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Many
of the trees on the roadsides of this county are dead or very old.
They all need attention and culling with new trees planted to
prevent trees and branches falling on cars and people in high
winds.
Good opportunity would be to hire teams of trained young people to
cut down and replant new trees to take us into the gfuture.
Governments will give grants for new trees so it would be very cost
effective to make safe our country roads.
many thanks
as a senior I have time and energy to get involved in planning
consultancy as I would like to see the character of architecture in
England move forwards into the 21st cent.
Mary Thomas
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14
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More
developments need to be monitored as the work progresses or things
will be added that cannot be undone once a build has
finished.
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15
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What a
load of puerile waffle!!
It's GCSE level archtecture/town planning stuff, so generic as to
be meaningless
Was this a job creation scheme?
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16
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I
would repeat my comment above about NDPs, Historic Parks and
Gardens and undesignated heritage assets. The guide is incomplete
without recognising their importance in the relevant
sections.
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17
|
My
comments have been recorded above. It is incomplete as it
stands.
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18
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Please
see comment for Questions 3 & 11.
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19
|
My
main point is to lobby government to get the building regulations
amended to force developers to do the right thing!
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20
|
concern that the
principles may be used by officers without an ability to discern
intuitive and skilful design innovation
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21
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car
parks could be used in a positive way to collect solar energy by
the use of photovoltaic cells on covered areas - please see
attached.
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22
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The
needs of disabled people, ie dropped kerbs clearly marked, easy
access to all areas, and good infrastructure, cannot emphasise both
issues enough.
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23
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This
whole exercise is secondary to the fundamental issue of
over-development, and there is a fear that it will be used as a
smokescreen.
The danger is that everybody will get buried in the minutiae of the
planning process. Innovative thinking about moving from the current
unsustainable development to passive designs which do not harm the
AONBs and Green Belt and minimise damage to the rest of the
environment are required.
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24
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Air
pollution and noise are considerations not covered.....cause stress
and health issues.
Traffic flow to dense new housing not thought out:
1) 38ton Quarry Trucks traffic massive upflow from Shellingford
Quarry blighting north wantage, damaging road surfaces
2) Massive uplift in Traffic flow in Mably Way serious issue which
will get worse as more houses built on Airfield and new relief road
around Challow links to it, soon provididing a rat-run to the north
from Ardington area.....a link road
Dont allow constant in-filling by developers...leave some green
areas/fields. Protect Elm Farm fields by A338...no Lidl...totally
inappropriate.
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25
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I am
not an architect or designer. More space on the "What makes a good
development" section would apply better to members of the public
who do not have design experience/training.
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26
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Only
that it is implemented quickly and that the major developers buy
into it.
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27
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far
too biased towards developers, create a simpler version for
householders
Make a commitment that if the design standards are met then the
plan will be approved, unless there are real objective concerns,
and not just an officers's bias based on an unwillingness to change
roof scapes, even where it is for the benefit overall
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28
|
Where
relevant please include reference to Oxfordshire Gardens Trust
which can be contacted about historic parks gardens and landscapes.
We have researched a number of sites which are not on the national
register, but which may come to be at some point, these include
Radley and Rycote, researched for the CB300 project.
On our OGT website there is online information about our research
on walled kitchen gardens in both districts, CB300 research and
recreational parks as well as links to the registered sites. If it
were possible to include an interactive link to our site this could
help those wishing to make changes impacting on these sites and
their settings find relevant information rapidly
In other cases we can be contacted directly at
Much of this information has been deposited with the
HER.
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29
|
As
hinted at above, I'd be inclined to think about the design of THE
PLANNING PROCESS as much as the layout of the design
guide.
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30
|
Accessible areas
need to be ensured and builders need to be supervised. Access alley
ways need not to have steps to aid wheelchairs and prams.
Through traffic should be able to have speed restriction if
children and the poorly sighted are to be provided for.
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31
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Would
like to see reference to Neighbourhood Plans
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32
|
All good, but with reservations expressed about EV charging in
section 11
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33
|
to
many house being build we need carparks and primark in didcot to
many cafes in didcot
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34
|
Sorry that I
haven't completed your survey correctly. However having recently
been the totally innocent victims of incredibly poor SODC Planning
Department decisions, none of this is relevant - as it just isn't
taken into account in reality.
The SODC Planning Department hides behind the General Permitted
Development rights ruling regardless of what the real local
situation is. In our case, a wealthy, selfish, arrogant couple with
no regard for local community and the rural habitat was allowed to
build a monstrous modern 'outbuilding' larger than their house
which now sits on what is agricultural land essentially at the end
of our garden...not affecting their outlook, no, but creating a
Berlin Wall of metal roof for us to look at as a reminder - every
day - and that creates the most hideous unbearable glare for us on
sunny days.
But despite going through the Enforcement Investigation route,
there is 'no breach' of planning law. No, legally maybe not. But
morally - absolutely it breaches all manner of things. Disaster for
the rural community as it has now set a precedent for awful modern
stark characterless buildings to be built in the midst of some real
rural heritage.
No, a Design Guide is not going to help. The first correction needs
to be the Planning Department that we pay our taxes towards
actually considering each situation in a much more real human
community-minded way - and not hide behind
Westminster.
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35
|
Sound;
the listening experience of the inhabitants of the developments has
not been considered. South Oxfordshire has many large, busy roads
eg A34, M40 which have a significant sounding impact on the
inhabitants and their internal and external domestic spaces. For
example I made a series of audio recordings in Drayton during the
initial stages of the pandemic (first lockdown) and at various
dates before the panedemic. The impact of the sound of the A34 on
quality of experience of those living with 500m of the road is
extreme. During the lockdown the soundscape was birdsong; the slow
creak of swings; the sound of football on the recreation ground.
The current daily soundscape consists entirey of the rattle of the
A34, the sound of tyres on asphalt, the clank of trucks as they
pass imperfections in the road surface.
Sound has a considerable impact on wellbeing and the success or
failure of any given development but is completely absent from this
Design Guide.
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36
|
I
understand that your guide wishes to be useful, but without legal
powers to enforce it, I regret to say that I expect developers to
continue to erect crowded facilities with minimal infrastructure.
This will always be the outcome whilst those in control are
motivated by making profit as large as they can get away with. You
are quite simply up against human nature.
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37
|
These
included in the various sections of the survey thank
you.
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38
|
Perhaps architects
could consider Poundbury as a way of introducing new build
properties near or into richly historic villages and county towns
and not uniform "boxes" which are reproducible from one boring set
of drawings from Lands End to John of Groats. Each county has its
own individual look: flint and render being prominent in
Oxfordshire - not red brick (rendered block better?).
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39
|
As an
individual with no connection with the building or associated
industries, my interest in responding to this consultation is
purely as 'an active village resident'. Most of my comments relate
to the guide's focus on issues only relevant to large scale
developments - and this might properly yield the greatest benefits.
However, I doubt that householders contemplating an extension or
constructing a single new dwelling would bother to seek out the
guide or apply it guidance.
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40
|
Thank
you for the opportunity, but at our age we are not looking to move
from our home of over 50 years to a new build. Except perhaps a
Care Home.
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41
|
As you
can see my main concern is nature conservation in the context of
development so please put more teeth in the requirements
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42
|
Neighbourhood
plans are not mentioned.
Discussion with local town/parish councils needed pre application-
to fully understand the local context, and local
initiatives.
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43
|
you
need to understand that we simply dont want all this development .
how about redesigning on existing sites and upgrading them, like
Blackbird leys and Cowley, Kidlington, instead of building on green
belt all the time. Appreciate you are aiming for better design, but
that's just a sinecure as we dont want more of your building in the
first place. this will end in tears, please stop the development or
intensify building in existing sites.
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44
|
There
could be a glossary in order to access the meaning of words such as
'fenestration' etc.
The Joint Design Guide needs to be checked for spelling mistakes
(there are several of these) and punctuation e.g. 's.
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45
|
Actually there is
one thing that I noticed - on one of the graphics I think in fig1,
Place and Setting - where you have in the lower left corner the
view toward site from AONB, it actually says ANOB but that's a
really nit picky detail so feel free to ignore!
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46
|
Dear
Sir/Madam,
Thank you for consulting Network Rail on the draft Joint Design
Guide. This email forms the basis of our response.
Network Rail is a statutory undertaker responsible for maintaining
and operating the country’s railway infrastructure and
associated estate. Network Rail owns, operates, maintains and
develops the main rail network. This includes the railway tracks,
stations, signalling systems, bridges, tunnels, level crossings and
viaducts. The preparation of development plan policy is important
in relation to the protection and enhancement of Network
Rail’s infrastructure.
The design guide acknowledges how access to public transport is key
in order to meet the access needs of a wide range of users and in
producing high quality development. Development should therefore
take into account existing nearby rail infrastructure such as
freight and passenger services in the area. The design of
development should also consider any noise/vibration mitigation
when building near the railway.
With this in mind, any planned future development (both residential
and employment) should take into account any adverse impact on
railway. It could be that the predicted growth, may increase future
demands at nearby stations which may, in turn, necessitate the need
for enhancements to existing facilities such as waiting rooms,
toilets and parking. Where there is an adverse impact on the
operation of the railway, Network Rail will require appropriate
mitigation measures to be delivered as part of the planning
application process and developer contributions when
necessary.
Level Crossings
Development proposals’ affecting the safety of level
crossings is an extremely important consideration for emerging
planning policy to address. The impact from development can result
in a significant increase in the vehicular and/or pedestrian
traffic utilising a crossing which in turn impacts upon safety and
service provision.
Any development which would result in a material increase or
significant change in the character of traffic using a rail
crossing should be refused unless, in consultation with Network
Rail, it can either be demonstrated that the safety will not be
compromised, or where safety is compromised serious mitigation
measures would be incorporated to prevent any increased safety risk
as a requirement of any permission.
In this regard, we would request that the potential impacts from
development affecting Network Rail’s level crossings, is
specifically addressed through planning policy as there have been
instances whereby Network Rail has not been consulted as statutory
undertaker where a proposal has impacted on a level crossing. We
request that a policy is provided confirming that:
• The Council have a statutory responsibility under planning
legislation to consult the statutory rail undertaker where a
proposal for development is likely to result in a material increase
in the volume or a material change in the character of traffic
using a level crossing over a railway:
o Schedule 5 (f)(ii) of the Town & Country Planning
(Development Management Procedure) order, 2010 requires that…
“Where any proposed development is likely to result in a
material increase in volume or a material change in the character
of traffic using a level crossing over a railway (public footpath,
public or private road) the Planning Authority’s Highway
Engineer must submit details to both Her Majesty’s Railway
Inspectorate and Network Rail for separate approval”.
§ Any planning
application which may increase the level of pedestrian and/or
vehicular usage at a level crossing should be supported by a full
Transport Assessment assessing such impact: and
§
The
developer is required to fund any required qualitative improvements
to the level crossing as a direct result of the development
proposed.
We trust these comments will be considered in your preparation of
the forthcoming Design Guide.
Yours Sincerely,
Grace Lewis
Town Planning Technician Wales and Western
Network Rail
Temple Point, Redcliffe Way, Bristol, BS1 6NL
www.networkrail.co.uk/property
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47
|
- no
reference found to the role of neighbourhood plans
- much more limited information on location and form of
conservation areas than current design guide
- much more limited information on local character assessments for
different parts of the district council's area than in the current
guide
- fewer usable examples (e.g. over reliance on drawings rather than
using photos as in current guide)
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48
|
See my
previous answer.
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49
|
see
comments made in earlier sections re Neighbourhood plans - their
policies will heavily influence the design at location
level
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50
|
It is
an impressive piece of work but sadly biased in favour of urban
situations.
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51
|
crime
is a major problem the elite are in denial make all estates ect
mugger no go zones
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52
|
Response manually
entered, submitted in an email format.
Please can you tell me why you bother to produce such guides when
the SODC planning committee do not recognise them, or even
acknowledge them, when making planning decisions-as we recently
found out to our cost.
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53
|
Response manually
entered, submitted in an email format.
Difficult to find anything to disagree with, as it is all
motherhood and apple pie. The proof is in implementation of limited
new building, compatible with the location. Adequate infrastructure
is also essential for new housing. That does not apply to the
appalling developments around Didcot. The planners should be
ashamed that they allowed them.
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54
|
Response manually
entered, submitted in an email format. The original response is
attached below for reference.
M&W officers have reviewed the consultation information and at
this time do not consider it likely that materially significant
mineral and waste impacts will emerge as a result of implementing
the consultation’s proposals. M&W officers have based
this response on potential impacts relating to: -
Gloucestershire’s mineral resources; the supply of minerals
from and / or into Gloucestershire; and the ability of the
county’s network of waste management facilities to operate at
its full permitted potential | M&W OFFICERS RAISE NO
OBJECTION
M&W officers have reviewed the consultation information and
have no further comments to make.
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|
55
|
Response submitted
in an email format and is attached below.
Admin note: please view attachment below for detailed
comments.
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|
56
|
Response manually
entered, submitted in an email format.
Having considered the consultation, I can confirm Buckinghamshire
Council has no comments in wishes to make.
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|
57
|
Response manually
entered, submitted in an email format.
Thank you for your email below regarding the Joint Design Guide
consultation.
The Coal Authority is a non-departmental public body sponsored by
the Department of Business, Energy & Industrial Strategy. As a
statutory consultee, the Coal Authority has a duty to respond to
planning applications and development plans in order to protect the
public and the environment in mining areas.
As you are aware, South Oxfordshire and Vale of White Horse
District Councils lie outside the defined coalfield and therefore
the Coal Authority has no specific comments to make on your Local
Plans / SPDs etc.
In the spirit of ensuring efficiency of resources and
proportionality, it will not be necessary for the Council to
provide the Coal Authority with any future drafts or updates to the
emerging Plans. This letter can be used as evidence for the legal
and procedural consultation requirements at examination, if
necessary.
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|
58
|
Response manually
entered, submitted in an email format.
Thank you for your message below, together with the link to your
“Joint Design Guide” web-site.
I can confirm that I have no comments to make.
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|
59
|
Sunningwell Parish
Council’s comments on the proposed Joint Design Guide 2022
are as follows;
The author of the new design guide is not referred to in the
document although it appears to have been written in a way that
makes it difficult to understand for anyone other than maybe a town
planner or possibly architect/designer; it is not user friendly for
Applicants, Councillors or those not directly involved in the
planning process.
Key design objectives uses words such as contextual analysis, green
and blue infrastructure, net gain biodiversity, clear and permeable
hierarchy, positive relationships between front and backs of
buildings, design complimentary to ‘grain’. Most people
won’t know what this means or how to apply it to a
design.
Design is required to ‘adapt to the changing requirements of
occupants’. Is that possible or is it an idealistic
view?
There will be no differentiation between open market and affordable
housing; if developers aren’t going to achieve the same value
for affordable as they might do for open market housing then it is
very unlikely they can build affordable housing to the same quality
and design. Has this point been discussed with housebuilders and
developers to get their view?
In the council’s opinion the document makes a number of
unnecessary assumptions, and statements without supporting examples
or evidence, such as ‘good design of hospitals helps people
recover quicker’, ’good design of schools improves
educational achievement’, ’good design of open space
affects people’s mental health’, and ‘good design
of a department store improves turnover’.
The section on ‘Built Form’ referring to extensions
being sensitive to character and appearance of original dwellings
and street scene and being aware of the impact of a proposal on
existing adjacent property [Neighbouring Amenity]. This is already
well documented in the existing design guide published in 2015 as
are most other issues mentioned in this latest draft
document;
In summary there doesn’t appear to be a great deal of
difference between the 2022 draft Design Guide and the existing one
which is more user friendly and straightforward; it therefore
should be questioned why it is deemed necessary to go to the cost
and time of producing a completely new design guide when the
existing one would suffice but with a simple Addendum to update the
2015 Design Guide on changes that have taken place between then and
now.
Sunningwell Parish Council 24 February 2022
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|
60
|
The
lack of any reference to the usefulness of adopted neighbourhood
plans is a serious omission. They could (and do!) play a very
useful role in guiding developers working in various locations in
SODC and the Vale, and should be supported through this
document.
|
|
61
|
N/A
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|
62
|
The
original email submission is attached below.
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|
63
|
Design
guides are most effective where they contain clear design
principles (which has been done) and are supported by examples. The
Council feel that more case studies and examples could be included
especially in terms of major housing developments which can have a
big impact when poorly designed.
It would also be helpful to have some indication of how this links
to National Design Guide and National Design Codes.
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|
64
|
Response manually
entered, submitted in an email format.
I would like to comment on Goals. In the third Paragraph, I would
like to see more emphasis put on Access for people who are
disabled. Hiding it away in the small print does not emphasise the
importance of access for people using mobility scooters, rollators
and mums with baby buggies. A watchful eye should be kept on
Developers who change their plans from ramps at the initial
planning stage to steps in retrospective planning.
Can I suggest something:
All routes should be open to access by people who are mobility
impaired and for those who need to use baby buggies.
Route surfaces should be carefully considered as gravel and bricked
surfaces are very uncomfortable for people in wheelchairs. Also,
there should be dropped kerbs at junctions and other relevant
points, eg to schools, shops or post boxes, etc.
If there are public footpaths across fields, etc giving shortcuts
to nearby facilities, it would be helpful if they are made
accessible to enable those using mobility scooters, wheelchairs and
pushing baby buggies to have equal access.
Developers appear to need more help in designing fully accessible
developments, so it would be very helpful if this website puts more
emphasis in supporting those who are disadvantaged.
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|
65
|
Response manually
entered, submitted in an email format. Original submission attached
below for reference.
1.0. Introduction.
The Chilterns Conservation Board (CCB) is grateful for the
opportunity to submit comments on the draft design guide and, at
the outset, would congratulate the Councils on their production of
a readily accessible, legible, and very well focused guide. We have
a few points to make, mostly dealing with appropriate
cross-reference to the Chilterns Buildings Design Guide and other
CCB documents that are germane. All the contributions made below
are submitted against this overall level of support.
2.0. Detailed Policy Submissions.
2.1. To assist, we set out the duties and responsibilities of the
CCB in Annex 1, at the end of these representations. For ease of
reference, we have tabulated our points, with additional text as
underlined or deleted text as ‘strikeout’ text.
The Chilterns AONB is nationally protected as one of the finest
areas of countryside in the UK. Public bodies and statutory
undertakers have a statutory duty of regard to the purpose of
conserving and enhancing the natural beauty of the AONB (Section 85
of CroW Act).
The Chilterns Conservation Board is a body that represents the
interests of all those people that live in and enjoy the Chilterns
AONB. It is made up of representatives nominated by the
organisations listed in Appendix 1.
Should you require any further information please do not hesitate
to contact me.
Appendix 1: About Us
The Chilterns Area of Outstanding Natural Beauty
The Chilterns AONB was designated in 1965 for the natural beauty of
its landscape and its natural and cultural heritage. In particular,
it was designated to protect its special qualities which include
the steep chalk escarpment with areas of flower-rich downland,
woodlands, commons, tranquil valleys, the network of ancient
routes, villages with their brick and flint houses, chalk streams
and a rich historic environment of hillforts and chalk
figures.
Chilterns Conservation Board
The Chilterns Conservation Board is a statutory independent
corporate body set up by Parliamentary Order in 2004 under the
provisions of Section 86 of the Countryside and Rights of Way
(CRoW) Act 2000.
The Board has two statutory purposes under section 87 of the CRoW
Act:
a) To conserve and enhance the natural beauty of the AONB;
and
b) To increase the understanding and enjoyment by the public of the
special qualities of the AONB.
In fulfilling these roles, if it appears that there is a conflict
between those purposes, Conservation Boards are to attach greater
weight to (a). The Board also has a duty to seek to foster the
economic and social well-being of local communities within the
AONB.
Like all public bodies, including ministers of the Crown, local
authorities and parish councils, the Chilterns Conservation Board
is subject to Section 85 of the CRoW Act which states under
“General duty of public bodies etc”
“(1) In exercising or performing any functions in relation
to, or so as to affect, land in an area of outstanding natural
beauty, a relevant authority shall have regard to the purpose of
conserving and enhancing the natural beauty of the area of
outstanding natural beauty.”
List of Organisations providing Nominees to the Chilterns AONB
Conservation Board
The Chilterns Conservation Board has 27 board members, all drawn
from local communities:
• Hertfordshire and Oxfordshire County Councils
• Central Bedfordshire and Luton Borough Councils (unitary
authorities)
• Buckinghamshire Council (formerly Aylesbury Vale, Chiltern
and South Buckinghamshire, and Wycombe District Council).
• Dacorum Borough Council, North Hertfordshire DC, Three
Rivers DC and South Oxfordshire DC.
• The Central Bedfordshire, Buckinghamshire, Hertfordshire
and Oxfordshire Parish Councils (6 elected in total), and
• DEFRA (8 in total).
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|
66
|
Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
Thank you for allowing Thames Water Utilities Ltd (Thames Water) to
comment on the above.
Thames Water is the statutory water and sewerage undertaker for the
South Oxfordshire and Vale of White Horse district councils and is
hence a “specific consultation body” in accordance with
the Town & Country Planning (Local Development) Regulations
2012. We have the following comments on the JDG:
Water Efficiency/Sustainable Design
The Environment Agency has designated the Thames Water region to be
“seriously water stressed” which reflects the extent to
which available water resources are used. Future pressures on water
resources will continue to increase and key factors are population
growth and climate change.
Water conservation and climate change is a vitally important issue
to the water industry. Not only is it expected to have an impact on
the availability of raw water for treatment but also the demand
from customers for potable (drinking) water. Therefore, Thames
Water support the mains water consumption target of 110 litres per
head per day (105 litres per head per day plus an allowance of 5
litres per head per day for gardens) as set out in the NPPG
(Paragraph: 014 Reference ID: 56-014-20150327) and support the
inclusion of this requirement in the Policy.
Thames Water promote water efficiency and have a number of water
efficiency campaigns which aim to encourage their customers to save
water at local levels. Further details are available on the our
website via the following link:
https://www.thameswater.co.uk/Be-water-smart
It is our understanding that the water efficiency standards of 105
litres per person per day is only applied through the building
regulations where there is a planning condition requiring this
standard (as set out at paragraph 2.8 of Part G2 of the Building
Regulations). As the Thames Water area is defined as water stressed
it is considered that such a condition should be attached as
standard to all planning approvals for new residential development
in order to help ensure that the standard is effectively delivered
through the building regulations.
Proposed policy text:
“Development must be designed to be water efficient and
reduce water consumption. Refurbishments and other non-domestic
development will be expected to meet BREEAM water-efficiency
credits. Residential development must not exceed a maximum water
use of 105 litres per head per day (excluding the allowance of up
to 5 litres for external water consumption). Planning conditions
will be applied to new residential development to ensure that the
water efficiency standards are met.”
Comments in Relation to Flood Risk and Sustainable Drainage
Systems
The National Planning Practice Guidance (NPPG) states that a
sequential approach should be used by local planning authorities in
areas known to be at risk from forms of flooding other than from
river and sea, which includes "Flooding from Sewers".
When reviewing development and flood risk it is important to
recognise that water and/or sewerage infrastructure may be required
to be developed in flood risk areas. By their very nature water and
sewage treatment works are located close or adjacent to rivers (to
abstract water for treatment and supply or to discharge treated
effluent). It is likely that these existing works will need to be
upgraded or extended to provide the increase in treatment capacity
required to service new development. Flood risk sustainability
objectives should therefore accept that water and sewerage
infrastructure development may be necessary in flood risk
areas.
Flood risk sustainability objectives and policies should also make
reference to ‘sewer flooding’ and an acceptance that
flooding can occur away from the flood plain as a result of
development where off site sewerage infrastructure and capacity is
not in place ahead of development.
With regard to surface water drainage it is the responsibility of
the developer to make proper provision for drainage to ground,
watercourses or surface water sewer. It is important to reduce the
quantity of surface water entering the sewerage system in order to
maximise the capacity for foul sewage to reduce the risk of sewer
flooding.
Limiting the opportunity for surface water entering the foul and
combined sewer networks is of critical importance to Thames Water.
Thames Water have advocated an approach to SuDS that limits as far
as possible the volume of and rate at which surface water enters
the public sewer system. By doing this, SuDS have the potential to
play an important role in helping to ensure the sewerage network
has the capacity to cater for population growth and the effects of
climate change.
SuDS not only help to mitigate flooding, they can also help to:
improve water quality; provide opportunities for water efficiency;
provide enhanced landscape and visual features; support wildlife;
and provide amenity and recreational benefits.
With regard to surface water drainage, Thames Water request that
the following paragraph should be included in the JDG: “It is
the responsibility of a developer to make proper provision for
surface water drainage to ground, water courses or surface water
sewer. It must not be allowed to drain to the foul sewer, as this
is the major contributor to sewer flooding.”
We trust the above is satisfactory, but please do not hesitate to
contact David Wilson on the number above if you have any
queries.
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67
|
Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
Please find below Horspath Parish Council’s response to the
draft Joint Design Guide.
1. SODC is to be congratulated of producing an innovative web-based
document with plentiful inter-active maps and illustrations.
2. However, it is probably untrue to state in the introduction that
earlier Design Guides had included too much detail, because unless
such detail is actually included in a Design Guide which will
become a Supplementary Planning Document, there will always be
scope for dispute about its interpretation in specific situations
where there is no detailed specific advice included in the new
Guide, and this will unnecessarily consume the time of Planning
Service staff and possibly involve seeking expensive legal
advice.
3. It is likely that more pre-Application advice will be needed to
ensure that a Planning Application will fulfil all the requirements
of this Design Guide.
4. While it is logical to provide both a web-based version of the
Design Guide and a hard copy version, it is difficult to see how
developers who use the hard copy version can follow through the
same checklist of tests on the sustainability of their proposed
development as can be carried out using the online web-based
version.
5. The bias and focus of the Design Guide is clearly more on urban
design rather than the design of places in rural areas, of which
there are many in South Oxfordshire.
6. In terms of obvious omissions in the scope of the guide, there
is insufficient importance given to ensuring that good design will
achieve SODC’s policy objectives to improve biodiversity in
the natural environment and to respond to the declared Climate
Emergency by setting standards for the mitigation of climate change
and the extremes of weather forecast to be associated with
it.
7. The maps need to be labelled or coded as
‘inter-active’ when they are inter-active, to be
distinguished from maps which have no ‘clickable’
access to further information.
8. The vertical line of buttons on the right side of the pages need
to be labelled, at least by number, to indicate that these are
buttons to click on to open the various sections of this
Guide.
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68
|
I
would like to see greater emphasis on responding to the
implications of climate change. For example, developers should be
required to install solar panels and ground or air source heat
pumps for each and every house built - as I travel around the
district I see row upon row of new build houses going up without a
solar panel in sight: this is surely utterly irresponsible with the
energy supply situation we now face and the urgent need to move to
renewable from carbon sources of energy.
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69
|
Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
Hallam Land Management Ltd (‘HLM’) is pleased to
respond to the consultation on the South and Vale Joint Design
Guide. Hallam has various land interests within South Oxfordshire
and Vale of White Horse, promoting and delivering development at
various scales and therefore has a vested interest in the future
growth ambitions of both authorities and how these are articulated
and supported as part of a new Joint Local Plan to 2041 for the
area and associated Supplementary Planning Documents.
HLM commends the draft Design Guide for being creatively presented
with an engaging and interactive format that is easily navigable,
with a logical structure.
As a general comment, HLM notes that the guide is intended to build
upon and replace previous local design guides and the statement
that it aligns with the National Design Guide (2019), however is
concerned that the SPD is seeking to prescribe specific design
outcomes and standards across a Joint Plan area at a point where
there are no joint development plan policies yet in place, due to
the Plan’s infancy, and therefore there has been no
consideration nor testing of the application of standards and
criteria sought, in the round, nor having regard to whole Plan
viability.
One approach to safeguard against this risk and ensure that the SPD
is appropriately guided by and aligned with local plan policy could
be to retain the document as a draft, until such time the
‘parent’ local plan policies (and supporting evidence)
are progressed to a point at which there is certainty around the
implications in respect to deliverability and viability of the
approach and standards sought. This approach would provide
flexibility for the draft SPD to be refined and adjusted alongside
the progression of the emerging joint plan.
Design Principles, not Prescription
HLM notes that one of the four aims of the Design Guide is to
“provide a simple set of design criteria that applications
should meet and are easy to follow” – first bullet. The
wording “should” is supported in this context; it
rightly recognises the need for design guidance to retain a degree
of flexibility to allow for a balance of conclusions to be reached,
specific to a scheme and its context. However, the Design Guide
then presents a set of detailed principles, referred to as
‘criteria’ which the document states “You need to
ensure your design meets” (How to use the guide).
HLM strongly maintain that an SPD should not include a level of
prescription that stymies proposals from reaching appropriate
master planning and design conclusions as to how best to achieve
sustainable development in the round, as advocated by the NPPF.
Whilst some principles will have relevance to many development
proposals, a number of principles are narrower in focus, and very
detailed (i.e., specific design treatment in relation to street
materials, private amenity space, open space and storage, services
and utilities) and will need to be considered insofar as their
desirability and relevance with regard to both characteristics and
context of each site and proposal; and critically, at the right
stage of the proposals.
HLM considers that the principles can be used as helpful guidance
against which to test and challenge proposals to seek improvements
in the quality of development, and not a set of strict criteria to
assess development proposals, so as to provide important
flexibility in application.
There are also a number of examples where the tone of the SPD seems
at odds with the NPPF. This response does not seek to quote all
cases; however, a more general observation is the continued use of
“must” throughout the draft SPD, which in effect
removes any opportunity for an iterative design process to be
achieved that is appropriate to the intrinsic characteristics of a
scheme. The NPPF uses “should”, which allows for due
consideration of an effective alternative.
Design Principles that are proportionate to the proposal
HLM supports the draft Design Guide in providing assistance in the
process of developing high quality development proposals. HLM
however, wish to raise that as currently drafted, the Guide appears
too narrowly focussed and detailed, in relation to planning
applications and fails to differentiate between the scope and
detail of the design requirements at the outline, full and/or
reserved matters planning application stages.
HLM considers that the document must reflect that in reality, the
design evolution differs in scale, scope and complexity from the
stages set out in the Design and Planning diagram. This is critical
to ensure support for a flexible approach to design particularly
where development proposals are at an outline stage. Relevant to
this point, is an opportunity for the guide to acknowledge wider
integration of locating development aligned with infrastructure
provision, and encouragement of a mix of uses, which support and
strengthen the quality of placemaking.
Avoiding repetition of National Policy in the NPPF, planning
practice guidance and additional guidance and frameworks
HLM welcomes the reference to national policy and guidance both at
national and district wide levels. In this context HLM considers
that there are parts of the Design Guide where guidance and
principles unnecessarily repeat those already provided in the wider
guidance and frameworks, for example Biodiversity Net Gain.
HLM suggests that the Design Guide has the potential to be focused
on the key design issues that are important and unique to South and
Vale – and not unduly repeat guidance and principles that are
well established at a national level, to ensure the guide is
focused and concise (an approach advocated at in the planning
Practice Guidance ID: 26-005-20191001), but also allows for and
supports variety of design applications. This proportionate and
flexible approach is amplified in NPPF paragraph 128, “Their
(design guides and codes) geographic coverage, level of detail and
degree of prescription should be tailored to the circumstances and
scale of change in each place and should allow a suitable degree of
variety.
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70
|
• Add bubble
to the second diagram saying – ‘is in keeping with the
character and nature of the environment of the receiving
area’
• Under Key Design objectives – add separate bullet
(rather just an add on to the bullet uses land efficiently whilst
respecting the existing landscape character and delivers a net gain
biodiversity) - something like as follows: Conserve and, where
possible, enhance the natural beauty and value of the landscape,
respecting policy requirements for the national (AONB to be renamed
perhaps as National landscape), and any district and parish
designations of valued landscapes
• Under Key Design objectives – Explain what is to be
included under ‘contextual analysis’ (landscape/built
form/habitats/historic/water catchment and so on?). this may have
to vary for a house extension up to a major development
Additional guides at beginning
Need to add Neighbourhood development plan if there is one for
area
AONB management plan – design guide if applicable
As this is mainly for developers, if large development, should
there be mention of consultation and communication with local
community
Would be helpful to have page number
I think the description of high quality is descriptive and not
informative
There is nothing about affordability in the initial part of the
guide
Key design guide – ensure the proposal –
Mainly relevant to urban or town development, in rural areas, there
may not be access to local services, and public transport
–
At beginning say want to use easily accessible language, then use
– high quality public realm - what does this mean
Design principle 4.11
Play space – MUGA need to be aware of floodlights and light
pollution
Light pollution only mentioned once – movement and
connectivity ? should be in other areas of the guide
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71
|
Response manually
entered, submitted in an email format. The original response is
attached below for reference.
Pegasus Group have been instructed on behalf of our clients,
Dorchester Residential Management (DRM) and Christ Church, Oxford
(ChCh) to provide a representation in response to the consultation
of the Draft Joint Design Guide, which closes on Tuesday 1st March
2022.
DRM and ChCh welcome the opportunity to engage with the Councils
and support the principles behind the preparation of the Joint
Design Guide, however, we do have some specific and detailed
comments which are set out below.
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72
|
Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
Thank you for your consultation.
We are the charity who look after and bring to life 2000 miles of
canals & rivers. Our waterways contribute to the health and
wellbeing of local communities and economies, creating attractive
and connected places to live, work, volunteer and spend leisure
time. These historic, natural and cultural assets form part of the
strategic and local green-blue infrastructure network, linking
urban and rural communities as well as habitats. By caring for our
waterways and promoting their use we believe we can improve the
wellbeing of our nation. The Trust is a statutory consultee in the
Development Management process.
Based on the information available our substantive response (as
required by the Town & Country Planning (Development Management
Procedure) (England) Order 2015 (as amended)) is that the Trust has
no comment to make on the proposal.
Please do not hesitate to contact me with any queries you may
have.
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73
|
Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
The Parish Council would also query if small scale developments
should be included as a separate item?
|
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74
|
Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
The Planning and Development Committee resolved to submit the
following comments on the draft Joint Design guide, at their
meeting on 23rd February 2022:
In general, the Planning and Development Committee feel the
document is clear and well-written. It is full of worthwhile
statements, and it would be good if the actions could be carried
through but in the current Planning climate, the Committee are not
confident of the Council’s ability to do this.
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75
|
I have
already filled in this consultation before but would like to add a
couple of points on Solar power. As solar power is likely to be the
best form of renewables in Oxfordshire, I would like to include the
use of solar panels on roof tops, such as all domestic houses and
huge buildings like warehouses and data centres, as well as in car
parks and children playgrounds. The last two areas also means there
is added shade and rain protection ....we are likely to need more
shade as our climate heats up.
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76
|
It
would be very helpful to incorporate some clear policies into the
Joint Design Guide, including a well-considered policy for the
installation of solar panels, both in existing buildings and also
in new developments and new stand-alone solar farms.
|
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77
|
Please
include design concepts to do with renewable energy in appropriate
places throughout the Design Guide. How should they be included in
individual houses? What about offices or manufacturing buildings,
and retail? And flatted developments?
This Design Guide is exceptional. Thank you.
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78
|
Response manually
entered, submitted in an email format.
Cllr Rankin, Chair of the Planning Committee, commented that he
likes the present guide. Cllr Kay feels that the Draft Joint Design
Guide has tidied up aspects of the previous guide. Cllr Dowie feels
that it is better for the end user than the previous version, it is
less vague. The links are easier to find. Cllr Rankin had to learn
to navigate the present version of the guide. Cllr Kay commented
that the Design principles are still there and links to other plans
but not to Neighbourhood Plans, he felt that the Neighbourhood
Plans - Vale of White Horse District Council (whitehorsedc.gov.uk)
link should be in the new design guide.
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79
|
The
Planning Team is of course a key player in the need to adapt our
lifestyles to the pressure of climate change in a National Planning
framework that is still focused on GDP driven growth, rather than
the preservation of our natural and social capital. On one hand
David Attenborough has told us that 'What we do now and in the next
few years will profoundly affect the next few thousand years'. On
the other hand the Planning system has to comply with the
controversial Oxfordshire Growth Needs Assessment imposed by
Central Government.
Please build a change mechanism into the guide so that it can
quickly reflect any changes in Government policy in this
area.
Thank you for all you are doing!
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80
|
Your Ref: South
Oxfordshire and Vale of White Horse District Council Joint Draft
Design Guide
DIO Ref: 10053938
It is understood that South Oxfordshire and Vale of White Horse
District Council are undertaking a Joint Draft Design Guide
consultation that will provide guidance on how new development can
be designed and constructed within the shared Authority
areas.
The Defence Infrastructure Organisation (DIO) Safeguarding Team
represents the Ministry of Defence (MOD) as a statutory consultee
in the UK planning system to ensure designated zones around key
operational defence sites such as aerodromes, explosives storage
sites, air weapon ranges, and technical sites are not adversely
affected by development outside the MOD estate.
This response relates to MOD Safeguarding concerns only and should
be read in conjunction with any other submissions that might be
provided by other MOD sites or departments.
Paragraph 97 of the National Planning Policy Framework 2021
requires that planning policies and decisions should take into
account defence requirements by ‘ensuring that operational
sites are not affected adversely by the impact of other development
proposed in the area.’ To this end MOD may be involved in the
planning system both as a statutory and non-statutory consultee.
Statutory consultation occurs as a result of the provisions of the
Town and Country Planning (Safeguarded aerodromes, technical sites
and military explosives storage areas) Direction 2002 (DfT/ODPM
Circular 01/2003) and the location data and criteria set out on
safeguarding maps issued by Department for Levelling Up, Housing
and Communities (DLUHC) in accordance with the provisions of that
Direction.
Copies of these plans, in both GIS shapefile and .pdf format, can
be provided on request through the email address above.
Having reviewed the current supporting documentation in respect of
South Oxfordshire and Vale of White Horse District Council Joint
Draft Design Guide, there are four areas of interest for the
MOD.
DIO safeguarding have an area of interest in RAF Benson and the
statutory Aerodrome Height, Birdstrike and Technical Safeguarding
Zones surrounding the aerodrome. Both South Oxfordshire and White
Horse District Councils have encompassing areas within the
statutory Aerodrome Height, Birdstrike, Technical and Explosive
Safeguarding Zones surrounding RAF Benson. Additionally, DIO
safeguarding have an area of interest in RAF Brize Norton and RAF
Fairford whom both have statutory Aerodrome Height and Birdstrike
Safeguarding Zones surrounding both aerodromes within the Vale of
White Horse District Council authority area.
The MOD’s secondary area of interest is a new technical asset
known as the Central WAM Network which contributes to aviation
safety by feeding into the air traffic management system in the
central areas of England. There is the potential for development to
impact on the operation and/or capability of this new technical
asset which consists of nodes and connecting pathways, each of
which have their own consultation criteria. Both South Oxfordshire
and White Horse District Councils have encompassing areas within
this network.
The aerodrome height and technical safeguarding zones serve to
protect the airspace above and around aerodromes to maintain an
assured, obstacle free environment for aircraft manoeuvre and
ensure that line of sight navigational aids and
transmitter/receivers are not impeded. This airspace needs to be
kept free of obstruction from tall structures to ensure that
aircraft transiting to and from or circuiting the aerodrome can do
so safely.
Additionally, within the statutory consultation areas associated
with aerodromes are zones that are designed to allow birdstrike
risk to be identified and mitigated. The creation of environments
attractive to those large and flocking bird species that pose a
hazard to aviation safety can have a significant effect. This can
include landscaping schemes associated with large developments,
such as green and/or brown roofs/roof gardens on flat roof
buildings, as well as the creation of new waterbodies. Sustainable
Drainage Systems (SUDS) additionally provide an opportunity for
habitats within and around a development. The incorporation of open
water, both permanent and temporary, and associated reedbeds,
wetlands ponds and ditches provide a range of habitats for
wildlife, including potentially increasing the creation of
attractant environments for large and flocking bird species
hazardous to aviation.
Explosive Safeguarding Zones define areas in the vicinity of
storage sites and armed aircraft stands in which land use and
building types are regulated to maintain explosives storage
licensing standards.
The safeguarding map associated with the Central WAM Network has
been submitted to DLUHC for issue. As is typical, the map provides
both the geographic extent of consultation zones and the criteria
associated with them. Within the statutory consultation areas
identified on the map are zones where the key concerns are the
presence and height of development, and where introduction of
sources of electro-magnetic fields (such as power lines) are of
particular concern. Wherever the criteria are triggered, the MOD
should be consulted in order that appropriate assessments can be
carried out and, where necessary, requests for required conditions
or objections be communicated.
In addition, where development falls outside designated
safeguarding zones the MOD may also have an interest, particularly
where the development is of a type likely to have an impact on
operational capability. Examples of this type of development are
the installation of renewable energy generation systems and their
associated infrastructure. The MOD has, in principle, no issue or
objection to renewable energy development though some methods of
renewable energy generation, for example wind turbine generators or
solar photo voltaic panels can, by virtue of their physical
dimensions and properties, impact upon military aviation
activities, cause obstruction to protected critical airspace
encompassing military aerodromes, and impede the operation of
safeguarded defence technical installations.
In summary, the MOD would wish to be consulted within the South
Oxfordshire and White Horse District Council Joint Local Plan, of
any potential development within the Aerodrome Height, Birdstrike,
Technical and Explosive safeguarding zones surrounding RAF Benson,
of any potential development within the Aerodrome Height and
Birdstrike safeguarding zones surrounding RAF Brize Norton and RAF
Fairford which consists of structures or buildings exceeding
statutory safeguarding technical zones. In addition, the MOD
request that developers are made aware, through policy provisions,
that development which might result in the creation of attractant
environments for large and flocking bird species hazardous to
aviation will be subject to scrutiny, and that those schemes where
risk cannot be removed or mitigated will be refused The MOD should
also be consulted on any applications for development within the
safeguarding zones designated to ensure the operation and
capability of the Central WAM Network that trigger the criteria set
out on the statutory safeguarding plan for that asset.
I trust this clearly explains our position on this consultation.
Please do not hesitate to contact me should you wish to consider
these points further.
Yours sincerely
It is understood that South Oxfordshire and Vale of White Horse
District Council are undertaking a Joint Draft Design Guide
consultation that will provide guidance on how new development can
be designed and constructed within the shared Authority
areas.
The Defence Infrastructure Organisation (DIO) Safeguarding Team
represents the Ministry of Defence (MOD) as a statutory consultee
in the UK planning system to ensure designated zones around key
operational defence sites such as aerodromes, explosives storage
sites, air weapon ranges, and technical sites are not adversely
affected by development outside the MOD estate.
This response relates to MOD Safeguarding concerns only and should
be read in conjunction with any other submissions that might be
provided by other MOD sites or departments.
Paragraph 97 of the National Planning Policy Framework 2021
requires that planning policies and decisions should take into
account defence requirements by ‘ensuring that operational
sites are not affected adversely by the impact of other development
proposed in the area.’ To this end MOD may be involved in the
planning system both as a statutory and non-statutory consultee.
Statutory consultation occurs as a result of the provisions of the
Town and Country Planning (Safeguarded aerodromes, technical sites
and military explosives storage areas) Direction 2002 (DfT/ODPM
Circular 01/2003) and the location data and criteria set out on
safeguarding maps issued by Department for Levelling Up, Housing
and Communities (DLUHC) in accordance with the provisions of that
Direction.
Copies of these plans, in both GIS shapefile and .pdf format, can
be provided on request through the email address above.
Having reviewed the current supporting documentation in respect of
South Oxfordshire and Vale of White Horse District Council Joint
Draft Design Guide, there are four areas of interest for the
MOD.
DIO safeguarding have an area of interest in RAF Benson and the
statutory Aerodrome Height, Birdstrike and Technical Safeguarding
Zones surrounding the aerodrome. Both South Oxfordshire and White
Horse District Councils have encompassing areas within the
statutory Aerodrome Height, Birdstrike, Technical and Explosive
Safeguarding Zones surrounding RAF Benson. Additionally, DIO
safeguarding have an area of interest in RAF Brize Norton and RAF
Fairford whom both have statutory Aerodrome Height and Birdstrike
Safeguarding Zones surrounding both aerodromes within the Vale of
White Horse District Council authority area.
The MOD’s secondary area of interest is a new technical asset
known as the Central WAM Network which contributes to aviation
safety by feeding into the air traffic management system in the
central areas of England. There is the potential for development to
impact on the operation and/or capability of this new technical
asset which consists of nodes and connecting pathways, each of
which have their own consultation criteria. Both South Oxfordshire
and White Horse District Councils have encompassing areas within
this network.
The aerodrome height and technical safeguarding zones serve to
protect the airspace above and around aerodromes to maintain an
assured, obstacle free environment for aircraft manoeuvre and
ensure that line of sight navigational aids and
transmitter/receivers are not impeded. This airspace needs to be
kept free of obstruction from tall structures to ensure that
aircraft transiting to and from or circuiting the aerodrome can do
so safely.
Additionally, within the statutory consultation areas associated
with aerodromes are zones that are designed to allow birdstrike
risk to be identified and mitigated. The creation of environments
attractive to those large and flocking bird species that pose a
hazard to aviation safety can have a significant effect. This can
include landscaping schemes associated with large developments,
such as green and/or brown roofs/roof gardens on flat roof
buildings, as well as the creation of new waterbodies. Sustainable
Drainage Systems (SUDS) additionally provide an opportunity for
habitats within and around a development. The incorporation of open
water, both permanent and temporary, and associated reedbeds,
wetlands ponds and ditches provide a range of habitats for
wildlife, including potentially increasing the creation of
attractant environments for large and flocking bird species
hazardous to aviation.
Explosive Safeguarding Zones define areas in the vicinity of
storage sites and armed aircraft stands in which land use and
building types are regulated to maintain explosives storage
licensing standards.
The safeguarding map associated with the Central WAM Network has
been submitted to DLUHC for issue. As is typical, the map provides
both the geographic extent of consultation zones and the criteria
associated with them. Within the statutory consultation areas
identified on the map are zones where the key concerns are the
presence and height of development, and where introduction of
sources of electro-magnetic fields (such as power lines) are of
particular concern. Wherever the criteria are triggered, the MOD
should be consulted in order that appropriate assessments can be
carried out and, where necessary, requests for required conditions
or objections be communicated.
In addition, where development falls outside designated
safeguarding zones the MOD may also have an interest, particularly
where the development is of a type likely to have an impact on
operational capability. Examples of this type of development are
the installation of renewable energy generation systems and their
associated infrastructure. The MOD has, in principle, no issue or
objection to renewable energy development though some methods of
renewable energy generation, for example wind turbine generators or
solar photo voltaic panels can, by virtue of their physical
dimensions and properties, impact upon military aviation
activities, cause obstruction to protected critical airspace
encompassing military aerodromes, and impede the operation of
safeguarded defence technical installations.
In summary, the MOD would wish to be consulted within the South
Oxfordshire and White Horse District Council Joint Local Plan, of
any potential development within the Aerodrome Height, Birdstrike,
Technical and Explosive safeguarding zones surrounding RAF Benson,
of any potential development within the Aerodrome Height and
Birdstrike safeguarding zones surrounding RAF Brize Norton and RAF
Fairford which consists of structures or buildings exceeding
statutory safeguarding technical zones. In addition, the MOD
request that developers are made aware, through policy provisions,
that development which might result in the creation of attractant
environments for large and flocking bird species hazardous to
aviation will be subject to scrutiny, and that those schemes where
risk cannot be removed or mitigated will be refused The MOD should
also be consulted on any applications for development within the
safeguarding zones designated to ensure the operation and
capability of the Central WAM Network that trigger the criteria set
out on the statutory safeguarding plan for that asset.
I trust this clearly explains our position on this consultation.
Please do not hesitate to contact me should you wish to consider
these points further.
Yours sincerely
|
|
81
|
The
design guide would be more helpful if it tried less to maintain the
"in-keeping" design approach but rather focussed on design that is
necessary to meet net zero targets. The authors should have
referred to the LETI design guide or even the UK Ecotown PPS
instead of coming up with something failing far short of what is
actually required.
How will developers be encouraged to create new developments with
an integrated sustainability approach as opposed to a tick box
exercise?
How will developers/communities establish new "Hockerton" style
developments using this guide?
How will new developments be created to include urban/rural
agriculture at varying scales?
How will this guide lead to improved biodiversity within the region
especially on-site?
How will this guide lead to the required level of new innovative
technology being implemented in future developments in the
region?
How will developers be prevented from building buildings with the
lowest possible energy performance and biodiversity standards that
they can get away with?
How will car-free developments built to Passivhaus standards using
local low embodied energy materials, serviced with renewable energy
district heating systems be prioritised via this design
guide?
How will more self-build be promoted by this design
guide?
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CONTENTS PAGE
-
Officers asked for a separate clearer contents page, to ease
navigation. The three lines in the top right corner were not
clear/obvious enough. A contents page needs to link directly to the
location of the ‘Principles’ boxes, which are used for
assessment.
LABELLING OF CHAPTERS/ REFERENCE POINTS NEEDED -
Officers commented that there needed to be a point of reference of
chapters, rather than just the paragraph numbers. The design guide
is often referred to in delegated reports, emails with agents,
appeal statements. It is easier to do this the current design guide
at the moment (e.g. Chapter 10 – Householder Development >
Principles DG103/104/105). Could this be incorporated into the JDG.
(e.g. Chapter 5 – Built Form > DG5A – General Built
Form, DG5B – Apartments etc.)? Officers queried the text
alignment in some of the ‘Principles’ boxes and
questioned whether the paragraph points could be labelled 5.01,
5.02, 5.10 etc. rather than 5.1, 5.2 etc).
LAYOUT OF SECTIONS: PRINCPLE BOXES FIRST
In our opinion the principles are the most important part of each
section. Could the principles boxes be relocated to the top of each
section so that they appear under the relevant chapter/section
titles, for quick and easy reference. The Goals/Objectives Text and
supporting diagrams can then expand on the principles.
PAGES & PRINTABLE LAYOUT –
Officers commented that the formatting, over two columns in
widescreen, without any separation between sections was more
difficult to read. Officers raised that there would need to be
clearer separation for reference, and the JDG would need to be in a
format that would be more easily printable. Without page numbers,
it is difficult to navigate the document, or refer people to
specific areas of the guide. For example, appeal Questionnaires
often ask for the Title Page, Contents Page etc. to be submitted
separately. Officers were mindful that Planning Inspectors do not
like web links.
WEBSITE LAYOUT: SCROLLING / NAVIGATION
Linked to this, Officers asked whether more distinct colours could
be used for each section/chapter. Officers also commented that the
small navigation circles on the right hand side were not easy to
use. The website felt like a continuous scroll to reach the
information needed. A clear navigation panel on the side which set
out the different chapters, sections, subsections and principles
should be incorporated.
Lines are needed to demarcate the sections or alternatively,
separate web pages could be created to break it up more. This could
the address the point above about having printable web/pages which
could then be used as supporting documents for e.g. Appeals.
AUDIENCE –
Officers commented that the wording of the design guide seemed
aimed at planning professionals who know what they would be looking
for and what guidance would be applicable to the scale of the
development proposed. It may not come across as well to a citizen
who is completely new to planning. Officers noted that some of the
wording/planning jargon used did not have a link to a glossary
definition for someone who is new to planning. For example,
‘green / blue infrastructure’.
DIFFERENTIATION BETWEEN SCALE OF DEVELOPMENT -
Officers note that an all-inclusive approach has been taken for
design principles. From an Officers perspective - we can
differentiate between principles relevant to Majors, and principles
relevant to Householders but this may not be immediately obvious to
those who are new to planning. For example, Officers expressed
preference for how the current Vale Design Guide had a separate
Householder Extensions Chapter. For example, making it clear for
Mrs Bloggs who is visiting the website because she would like to
know more about guidance around Householder Extensions. In this
instance a lot of the Majors design guidance wouldn’t apply,
but this isn’t immediately obvious.
GUIDANCE ON CONTEMPORARY DESIGN
This may still be in development, but please basic design
guidance/principles/best practice be provided on how to
successfully incorporate contemporary design into a scheme –
particularly surrounding fusing contemporary design with existing
buildings (e.g. scale, the design cues that should be taken,
materials etc.). Please see example ref. P20/V2106/HH. This would
be helpful for Officers assessing a scheme, particularly also for
Listed Buildings. We are seeing many more of these types of
application, so to achieve consistently high quality schemes, a
section on this to advise people on how to approach them would be
extremely useful, in replacement of architect’s panel.
GLOSSARY
Please could the formatting of this section be looked at. It is not
user friendly. It might be worth expanding the glossary to include
more jargon like ‘green/blue infrastructure’, and in
the first instance listing the words, and then having it set out so
that when a user clicks on the word, the definition expands out
underneath. This would reduce the amount of text and should make it
easier to use.
ADOPTION:
Officers asked;
(1) when this JDG is due to be adopted, and
(2) how often the JDG will be reviewed?
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83
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It is
a very good Design Guide, but it needs to be clear that it can be
applied in rural as well as urban areas.
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84
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No
other comments.
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85
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An
explanation on how to use this guide for small developments and
extensions as well as strategic sites. A bit thrown in at the deep
end when someone might want to paddle.
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86
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I
consider it would be useful to developers and support the delivery
of renewable energy schemes if guidance was added on the siting and
design of stand-alone renewable energy generation schemes, such as
solar farms.
I also consider it important to add guidance on the siting and
design of domestic-scale renewable technologies to ensure these do
not detract from the quality of a development and that the
residential amenity of neighbouring property is
protected.
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87
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Would
be helpful to release word versions with check boxes that can be
ticked. Marking the survey questionnaire available in a variety of
formats would be really helpful to organisations like Town Councils
when they respond so the answers can be easily shared and agreed
prior to submission.
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88
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We are
sceptical how committed the District is to implementing the Design
Guide in practice when it comes to agreeing detailed planning
applications. There should be training, awareness raising,
workshops and other events to involve officers and the private
sector in understanding and implementing the content.
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89
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I
think the Joint Design Guide should include something specific on
solar farms. In particular, I think they should be located near to
appropriate sub-stations where they can be connected to grid
without disrupting roads or SSSIs. The perimeter fencing should be
in keeping with the surroundings or screened from view by hedges.
Consideration should be given to distributing panels in a way that
reduces the visual impact i.e. not facing all the same way. This
can help level the output. Consideration should be given to
compatibility with existing wildlife and the management of the land
beneath the panels should be defined so that it maximises
biodiversity.
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90
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Response manually
entered, submitted in an email format.
Thank you for producing this draft guide and I look forward to
seeing the final version.
Acknowledgment of different groups’ needs is noted in a
couple of places but the guide could take this further to outline
more clearer the ‘how’. Local Authority guidance has an
important role in clearly setting out the standard and level of
ambition expected in new development and the role that the design
of the built environment can play in tackling inequalities.
It is sometimes assumed that developers (who I assume are one of
the target audiences of this guide) should know how to make places
accessible for different groups, and there can be a tendency to
support ‘freedom of interpretation’, but in practice
developers do not always keep abreast of latest research or they
can add in token elements (with little evidence of their
effectiveness) that are later value-engineered out. Therefore
having a comprehensive, people-focussed and evidenced-led Local
Authority Design Guide is very valuable.
Play space and youth provision as well as children and young
people’s mobility can often act as an indicator of the
quality of the built environment. I would highly recommend Tim
Gill’s book, Urban Playground: How Child Friendly Planning
and Design can Save Cities (2021) which expands on this point well.
Numerous accompanying webinar recordings introducing the book can
also be found on YouTube. Another useful guide is NACTOs Designing
Streets for Kids (2020) which is a resource that can be downloaded
free from NACTOs website. Another recommended text, covering the
topic of inclusive design and providing guidance on ‘putting
mental health, wellness and quality of life at the forefront of
city planning and urban design’, is Jenny Roe & Layla
McCay’s book Restorative Cities: Urban Design for Mental
Health and Wellbeing (2021).
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91
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Response manually
entered, submitted in an email format.
Thank you for consulting the Environment Agency on this draft Joint
Design guide which is a Supplementary Planning Document (SPD), and
will be ‘material consideration in determining planning
applications submitted to the Council.
The draft Joint Design guide is said to be relevant for all scales
of development and we support the fact that the Key design
objectives (especially these three listed below), should be
considered at the outset and throughout the design process for all
development types in delivering high quality sustainable
development.
• uses land efficiently whilst respecting the existing
landscape character and delivers a net gain biodiversity
• incorporates and/or link to a well-defined network of green
and blue infrastructure;
• is sustainable and resilient to climate change, minimises
carbon emissions and mitigates water run-off and flood risk;
In that regard we have no further comments. If you have any queries
do not hesitate to contact us.
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92
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The
original email submission is attached below.
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93
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THE
DESIGN GUIDE
Additional guidance and frameworks beyond our guide – should
include Chilterns Conservation Board design guide, & similar
for North Wessex Downs AONB.
Key design objectives need to include, ensure light pollution from
light spill into the environment is kept to a minimum. Picture
windows that go from ground level to apex, or floor to Apex should
be discouraged as they cause unnecessary light spillage, and heat
is wasted when such glazing accompanies vaulted ceilings.
Roofs on new dwellings, should be at the optimum angle (30 to 40
degrees) to allow for the installation of solar panels at
construction or fitted afterwards.
For large developments, discussions must be held with all utility
providers at a very early stage. It is appalling that developments
built in the 1970s to today (this includes very recent
developments) where there are no overhead lines are now blighted
with telegraph poles & overhead wires (Airband UK). Surely
these overhead wires will conflict with government & local
policies for tree planting, as the trees will require much more
maintenance to protect the communication wires. It is also
unsatisfactory that developments built in the past few years as
well as having new telegraph poles & overhead wires are now
having their pavements dug up to provide new fibre communications
(Switch Fibre).
ABOUT SOUTH & VALE
There seems to be confusion about Landscape Character, Landscape
Type in the document.
The Landscape Character map seems to show landscape type. Landscape
Character is better described in Design Principles – Place
& Setting and the Natural Environment section, where the links
to the appropriate documents can be found.
In the 2016 guide the South Oxfordshire Landscape Assessment (pg
19) includes a map showing broad landscape character areas, and
includes a table of Character Areas (pg 20) detailing the
correlating landform and landscape & associated settlement
patterns for each of these Character Areas, which gives a broader
overview of each area. The landscape assessment seems to now be
covered in the section Natural Environment but not in as much
detail and no associated landform & landscape or settlement
patterns as in the 2016 document.
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94
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Response manually
entered, submitted in an email format.
I also have a question about how you envisage people referring to
the guide in their applications and us in our responses? Do you
think we will just refer to sections of the guide rather than
section numbers as we used to? Maybe this will be in your
training?
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95
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Will
the SODC Planning Officers use it? Previous Design Guides appear to
have been ignored and not used by SODC itself.
It is developed for medium to large developments and not individual
"fill in" houses or extensions which our PC normally deals
with
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96
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Response manually
entered, submitted in an email format.
There are currently over 40 made Neighbourhood Development Plans
(NDPs) across South Oxfordshire and the Vale of White Horse
District Councils. Once a NDP is successful at referendum, it
becomes part of the development plan, sitting alongside the Local
Plan. Therefore, planning applications will be determined in
accordance with them, unless material considerations indicate
otherwise.
Paragraph 127 of the NPPF states:
‘Neighbourhood planning groups can play an important role in
identifying the special qualities of each area and explaining how
this should be reflected in development, both through their own
plans and by engaging in the production of design policy, guidance
and codes by local planning authorities and
developers.’
National policy encourages communities to engage in achieving
well-designed places through neighbourhood planning. A number of
adopted NDPs across the districts already include either design
planning policies, detailed character assessments and/or separate
design guides. An increasing number of NDPs are including detailed
design codes and/or design guidance. The Government also currently
offers technical support to groups looking to include design codes
in their plan, therefore we foresee this uptake across the
districts continuing.
Currently the Joint Design Guide does not make any reference to
NDPs and the potential for these to include locally distinctive
design policies, design codes and guidance. For the above reasons
we see a benefit in the Joint Design Guide recognising the role
NDPs can play in influencing good design. Within the Joint Design
Guide there is a section titled ‘Additional guidance and
frameworks beyond our guide:’, and we recommend that
reference to the potential of locally bespoke design guidance in
NDPs is inserted here, linking through to the South Oxfordshire and
the Vale of White Horse Neighbourhood Planning webpages
respectively.
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97
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Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
We write on behalf of our client, CEG, in response to the
consultation on the draft Joint Design Guide for South Oxfordshire
and Vale of White Horse District Councils.
CEG create spaces and places that positively contribute to the
lives of those who live and work within them. As a long-term
investor, they maintain an enduring commitment to the future of
their developments and surrounding communities, and are determined
to deliver future-proofed designs of the highest quality.
With these objectives in mind, CEG support the principle of
preparing a Joint Design Guide Supplementary Planning Document
(SPD) to support the implementation of Local Plan policy, but we do
have some comments on the scope and content of the draft document,
which we believe need to be addressed prior to adoption of the
SPD.
Overall, CEG welcome the proposed Joint Design Guide, but do have
some concerns that in places the Guide steps beyond its role as a
Supplementary Planning Document. It is also considered that
interaction between the Joint Design Guide, national design
guidance and development plan policy could be made clearer, which
would be of benefit to both applicants and Council Officers.
We would like to be kept informed of progress with the Joint Design
Guide.
Please do get in touch if you require any clarification in relation
to this consultation response.
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98
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Response manually
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Having got to https://data.southoxon.gov.uk/JDG/Menu.html
I have been searching for something about gardens.
I realise that we cannot be too prescriptive about gardens since as
soon as someone moves into a property they can more or less do what
they like with the garden.
But many won't.
And developers want to provide something which will look moderately
attractive for passive occupiers.
Is there a section on gardens which I just haven't found yet?
If there is one there are 3 issues I'd like to see addressed:
• People have expressed their concerns to me about plastic
backed turf. I gather that producers like to plant grass on this
plastic mesh backing as it grows more quickly and/or it is easier
to pick up and move? But it is very bad for the environment and
wildlife, in particular for creatures which can get caught up in
the mesh. I have been asked if we can ban the use of this turf with
plastic mesh backing?
• If trees are to be planted in gardens, from a
sustainability point of view I'd like to see fruit or nut trees
provided where possible.
• For boundaries between properties where there is room, and
certainly at the edges of sites, hedges would be better from a
nature and environment point of view than fences or walls although
I appreciate a strong wall may be needed in some places.
So I await the next iteration of the Joint Design Guide with
interest and wish you all well with its production. I should say
that I would be happy to read through the next version if someone
can send it to me as a file(s) - my husband is very good at proof
reading!
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99
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Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
This letter is submitted in response to the current consultation
held by South Oxfordshire and Vale of White Horse district councils
on the Joint Design Guide. Whilst at this stage Gladman have only a
few specific comments to make on the draft Design Guide, we request
to be kept updated on its
progress moving forwards and be notified of any further
consultations regarding the guide.
Purpose of Supplementary Planning Documents
SPDs are not subject to the same degree of consultation and
examination as policies contained in Local Plans and should only be
prepared, therefore, to provide additional guidance to those
bringing forward development proposals across the district. The
National Planning Policy Framework (NPPF
2021) confirms this in Annex 2: Glossary where it defines SPDs
as:
“Documents which add further detail to the policies in the
development plan. They can be used to provide further guidance for
development on specific sites, or on particular issues, such as
design. Supplementary planning documents are capable of being a
material consideration in planning
decisions but are not part of the development plan.”
The role of the SPD should therefore seek to provide guidance on
existing planning policy contained in the adopted Development Plan.
It is important to note that this does not present an opportunity
to reinvent existing planning policies contained in the adopted
Local Plan.
Scope of the draft Joint Design Guide SPD
Gladman welcome the preparation of the SPD as it provides
additional clarity beyond the policy wording contained within the
adopted Local Plan. Nonetheless, having reviewed the contents of
the draft SPD, Gladman feel that there are elements of the document
which may require further refinement.
Conclusion
Gladman welcome the opportunity to comment on the draft Joint
Design Guide SPD and would like to be kept informed as the document
is progressed.
Gladman reserve the right to provide further comments on the SPD at
any later stage of public consultations.
I hope you have found these representations useful and please do
not hesitate to contact me should you wish to discuss any of the
points raised within this representation.
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100
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Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
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101
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Please
see submitted letter for full comments.
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102
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There
is an early reference to pre-app advice. ONPA is concerned that
such advice, when offered to applicants, sometimes fails to take
into account the policies of neighbourhood plans (NPs), whether on
design or other matters. We would like to see more emphasis given
in the guide to the need for applicants to check for NP policies
that might impact on their proposals, at an early stage.
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103
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In
omitting any reference to Public Rights of Way in the Movement and
connectivity section, the Guide disregards an entire section of the
local Highway network. This must be addressed, with PROW clearly
identified as part of the Active Travel network for both commuting
and recreation within and around the development. Within this there
should be further information about existing and potential use of
both the PROW and road network by vulnerable road users, to ensure
that designs will include elements to safeguard and improve safe
off- and on-road access for walkers, cyclists, equestrians and
people with limited mobility.
The British Horse Society has a comprehensive range of guidance on
the design and layout of shared-use, off-road paths, covering
topics such as Surfaces, Widths, Signage, Structures and Road
Crossings. These can all be found on the Society's website at
www.bhs.org.uk/accessadvice.
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104
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This
is great.
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105
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Should
include guides on applications which claim to be addressing the
climate emergency - such as wind/solar power, the installation of
industrial scale batteries - but which are often the rsult of
speculative applications (aka landbanking by housing developers) in
ordfer to garner tax credits, green subsidies and to provide
'geenwashing' for entities claiming to be 'net zero'
If in planning terms 'net zero' means a polluter can offload an
environmental disbenefit on one locality (eg solar power stations
on farmland) in order to be able to claim carbon offsets and/or
green credentials when in fact none of the environmental benefits
are accrued locally then we have a major problem: urban landowners
and consequent investment will seek to place their greenwashing
entities in the cheapest location which, as with housing developers
who eschew brownfield sites, will often be (greenbelt) farmland
which is ever more needed to enable a reduction in food miles and
an increse in the UK's food security.
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106
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How
this fits in to the planning process is not at all clear - see
notes at start of survey.
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107
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Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
Please find attached a few comments made by our Members in response
to your recent Joint Design Guide consultation. Concern was
expressed about the ability of the District / Vale Councils to
encourage (and even enforce) better development given the resource
levels that exist between the two authorities. The document itself
was, however, largely well-received.
Plain English
• We note the aim to break the mould and avoid a lengthy
document that is “full of complex design phrases and
terms”. Yet the document does use architectural and
placemaking terminology. While we recognise it is difficult to
avoid terminology in these very specialist field, we would hope
each term / word is identified and pop-up / hyperlinks used to
explain them. Given the structured form of the Guide, it may be
appropriate to provide such guidance at each occurrence within the
document.
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108
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Response manually
entered, submitted in an email format.
Thank you for including the Marine Management Organisation (MMO) in
your recent consultation submission. The MMO will review your
document and respond to you directly should a bespoke response be
required. If you do not receive a bespoke response from us within
your deadline, please consider the following information as the
MMO’s formal response.
Marine Management Organisation Functions
The MMO is a non-departmental public body responsible for the
management of England’s marine area on behalf of the UK
government. The MMO’s delivery functions are: marine
planning, marine licensing, wildlife licensing and enforcement,
marine protected area management, marine emergencies, fisheries
management and issuing grants.
Marine Planning and Local Plan development
Under delegation from the Secretary of State for Environment, Food
and Rural Affairs (the marine planning authority), the MMO is
responsible for preparing marine plans for English inshore and
offshore waters. At its landward extent, a marine plan will apply
up to the Mean High Water Springs (MHWS) mark, which includes the
tidal extent of any rivers. As marine plan boundaries extend up to
the level of MHWS, there will be an overlap with terrestrial plans,
which generally extend to the Mean Low Water Springs (MLWS) mark.
To work together in this overlap, the Department of Environment,
Food and Rural Affairs (Defra) created the Coastal Concordat. This
is a framework enabling decision-makers to co-ordinate processes
for coastal development consents. It is designed to streamline the
process where multiple consents are required from numerous
decision-makers, thereby saving time and resources. Defra encourage
coastal authorities to sign up as it provides a road map to
simplify the process of consenting a development, which may require
both a terrestrial planning consent and a marine licence.
Furthermore, marine plans inform and guide decision-makers on
development in marine and coastal areas.
Under Section 58(3) of Marine and Coastal Access Act (MCAA) 2009
all public authorities making decisions capable of affecting the UK
marine area (but which are not for authorisation or enforcement)
must have regard to the relevant marine plan and the UK Marine
Policy Statement. This includes local authorities developing
planning documents for areas with a coastal influence. We advise
that all marine plan objectives and policies are taken into
consideration by local planning authorities when plan-making. It is
important to note that individual marine plan policies do not work
in isolation, and decision-makers should consider a whole-plan
approach. Local authorities may also wish to refer to our online
guidance and the Planning Advisory Service: soundness
self-assessment checklist. We have also produced a guidance note
aimed at local authorities who wish to consider how local plans
could have regard to marine plans. For any other information please
contact your local marine planning officer. You can find their
details on our gov.uk page.
See this map on our website to locate the marine plan areas in
England. For further information on how to apply the marine plans
and the subsequent policies, please visit our Explore Marine Plans
online digital service.
The adoption of the North East, North West, South East, and South
West Marine Plans in 2021 follows the adoption of the East Marine
Plans in 2014 and the South Marine Plans in 2018. All marine plans
for English waters are a material consideration for public
authorities with decision-making functions and provide a framework
for integrated plan-led management.
Marine Licensing and consultation requests below MHWS
Activities taking place below MHWS (which includes the tidal
influence/limit of any river or estuary) may require a marine
licence in accordance with the MCAA. Such activities include the
construction, alteration or improvement of any works, dredging, or
a deposit or removal of a substance or object. Activities between
MHWS and MLWS may also require a local authority planning
permission. Such permissions would need to be in accordance with
the relevant marine plan under section 58(1) of the MCAA. Local
authorities may wish to refer to our marine licensing guide for
local planning authorities for more detailed information. We have
produced a guidance note (worked example) on the decision-making
process under S58(1) of MCAA, which decision-makers may find
useful. The licensing team can be contacted at:
marine.consents@marinemanagement.org.uk.
Consultation requests for development above MHWS
If you are requesting a consultee response from the MMO on a
planning application, which your authority considers will affect
the UK marine area, please consider the following points:
• The UK Marine Policy Statement and relevant marine plan are
material considerations for decision-making, but Local Plans may be
a more relevant consideration in certain circumstances. This is
because a marine plan is not a ‘development plan’ under
the Planning and Compulsory Purchase Act 2004. Local planning
authorities will wish to consider this when determining whether a
planning application above MHWS should be referred to the MMO for a
consultee response.
• It is for the relevant decision-maker to ensure s58 of MCAA
has been considered as part of the decision-making process. If a
public authority takes a decision under s58(1) of MCAA that is not
in accordance with a marine plan, then the authority must state its
reasons under s58(2) of the same Act.
• If the MMO does not respond to specific consultation
requests then please use the above guidance to assist in making a
determination on any planning application.
Minerals and Waste Local Plans and Local Aggregate
Assessments
If you are consulting on a minerals and waste local plan or local
aggregate assessment, the MMO recommends reference to marine
aggregates, and to the documents below, to be included:
• The Marine Policy Statement (MPS), Section 3.5 which
highlights the importance of marine aggregates and its supply to
England’s (and the UK’s) construction industry.
• The National Planning Policy Framework (NPPF), which sets
out policies for national (England) construction mineral
supply.
• The minerals planning practice guidance which includes
specific references to the role of marine aggregates in the wider
portfolio of supply.
• The national and regional guidelines for aggregates
provision in England 2005-2020 predict likely aggregate demand over
this period, including marine supply.
The minerals planning practice guidance requires local mineral
planning authorities to prepare Local Aggregate Assessments. These
assessments must consider the opportunities and constraints of all
mineral supplies into their planning regions – including
marine sources. This means that even land-locked counties may have
to consider the role that marine-sourced supplies (delivered by
rail or river) have – particularly where land-based resources
are becoming increasingly constrained.
If you wish to contact the MMO regarding our response, please email
us at consultations@marinemanagement.org.uk or telephone us on 0208
0265 325.
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109
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Response manually
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Thanks for notice & invite for comments
For any lengthy consideration of planning matters I always prefer
to peruse and consider
local printed copies at Wallingford Library
PS This may be far too late for the 1000 plus Wallingford Housing
developments already approved
and for the local Crowmarsh housing area "planning" to swamp the
village with 600 new houses over 4 sites.
local Crowmarsh developments of some 600 houses
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110
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Response manually
entered, submitted in an email format.
Thank you for providing us with the email below asking for comments
on the S&V design guide. The links don’t seem to be
working…thought I would let you know …
If you can let me know when they are up and running, I’d be
grateful.
It is working well now, and the Design Guide is looking
good….
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111
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Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
Please find attached the collated responses from the planning
policy team on the Joint Design Guide - we hope these
comments/recommendations are useful. These include comments from
our Transport Officer, and other offices focusing on Local Plan
workstreams that relate directly to elements of the Design Guide,
but have all been collated together for ease and divided by
section. I have also reviewed the guide in terms of healthy
placeshaping and have added recommendations throughout.
If you have any questions or comments on anything in the attached
please do not hesitate to get in touch.
It’s a great guide, and we are looking forward to its
implementation
General Comments
• Font size – this feels too small, it is difficult to
read and not very inviting
• Navigation needs to be clearer – it is not obvious to
the user that once completing the first page you need to click on
the next circle set down the right-hand side of the page. Could a
prompt be added to encourage people to go through the rest of the
document? This could be explained in the ‘about the design
guide section’ which explains how to interact with the pop-up
graphics.
• Interactive format looks good but again makes it more
difficult to navigate. Suggest a PDF version is produced when the
final version is published (if this isn’t already planned).
This will also mean it can be easily shared with PINS in an appeal
or local plan examination.
• It lacks the ability to word search the whole document
– is there a way of adding this function?
• The Design Principles in the strongly coloured boxes
don’t look as readable or enticing as the emptier white box
text. Some of us found ourselves skipping reading these principles
boxes and looking at the pictures and spacious text instead. We
suggest changing the hierarchy in the page design, so the
principles are bigger font/ less text crowded/ more
prominent.
• All references to the National Design Guide should be
updated to have (2021) in brackets rather than (2019) to reflect
the most recent updates.
There is currently references to both.
Typos
• ‘Landscape Charters’ (is this supposed to be
‘Character’?)
• Landscape Character Map: ‘Fromer Airfield/MOD
sites’
• In Climate and Sustainability supporting text ‘South
Oxfordshire’ has a typo twice in the two links
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The
original submission is attached below.
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Response manually
entered, submitted in an email format.
These representations have been prepared by Thakeham Homes Ltd
(hereafter referred to as Thakeham) in relation to the South and
Vale Draft Joint Design Guide consultation (“the draft Design
Guide”) as a local stakeholder. Thakeham is a housebuilder
with offices in Sussex and the Thames Valley that has a track
record for delivering high quality, sustainable developments.
About Thakeham
Thakeham prides itself in being an infrastructure-led sustainable
placemaker and is committed to creating new, extraordinary places,
where the highest attention to detail makes a positive
difference.
Thakeham builds for the future, for communities and individuals.
Our approach sets us apart from our competitors. Thakeham deliver
schemes with a focus on sustainable development, looking ahead of
current housing standards. From 2025, all Thakeham Homes will be
carbon neutral in production and zero carbon in lifetime use.
Each development is different and tailored to its locality with
careful consideration of the area’s character, as well as the
environment. The delivery of homes facilitates the delivery of
physical, social and green/blue infrastructure which benefits the
wider surrounding area, as well as the new residents, and ensures
that Thakeham creates sustainable places to live and work.
Thakeham is passionate about having a positive impact on
people’s wellbeing, constantly striving to deliver against
our four key focus areas:
Building local communities via excellent placemaking that creates
interconnected communities that challenge issues of loneliness and
promoting healthy living, and via our long-term charity
partnerships.
Building future generations via our school engagement programmes,
including our industry leading holistic ecology programme
‘Eddie and Ellie’s Wild Adventures’ for primary
age pupils, and providing inspiring careers support to secondary
age pupils through our Cornerstone Employer status with The Careers
Enterprise Company.
Building a stronger industry with our support of small and medium
size enterprises and upskilling for local workers, supporting
apprenticeships, and actively contributing to the diversification
and upskilling of the construction sector.
Building sustainable places by tackling issues of climate change,
biodiversity loss and societal disconnects via our ambitious
Sustainability Strategy.
As one of 12 members of the NHS Healthy New Towns network, Thakeham
is a committed advocate of developing healthy places in line with
the Healthy New Town principles. However, over time, Thakeham has
realised that these principles are just the starting blocks, and,
as a founder member of the HBF (Home Builders Federation) Future
Homes Task Force, Thakeham is committed to delivering sustainable,
zero carbon communities. Our approach sets us apart from our
competitors. Thakeham deliver schemes with a focus on
infrastructure-led sustainable development.
Thakeham’s Approach to Sustainability
Thakeham would like to take this opportunity to outline the
measures implemented on its developments to minimise environmental
impacts as a direct and indirect result of development as Thakeham
consider this will have a direct bearing on the sustainability of
our Site and our proposals in the context of the
Consultation:
• From 2025, all Thakeham homes will be net-zero carbon in
lifetime use.
• From 2025, all Thakeham homes will be carbon neutral in
production. Our off-site panellised system will make construction
more efficient, faster, enhancing quality and reducing construction
traffic.
• Thakeham is committed to offsetting the embodied impact
from the production of new houses, as well as development houses
that are zero carbon in lifetime operation.
• Thakeham supports the Wildlife Trust’s guidance on
Homes for People and Wildlife. Our commitment is to achieve 20%
biodiversity net gain (double the target set out in the recent
Environment Act 2021) on all our developments post-2025, with
attractive and functional green and blue infrastructure throughout
all our developments.
• Through placemaking and the implementation of sustainable
travel plans, Thakeham prioritises walking and cycling over car
travel, helping people make more sustainable choices, as well as
highlighting innovative car-sharing online platforms such as
LiftShare to reduce single-occupancy car use.
• Thakeham provides electric car charging points at all of
our homes both market and affordable alike, reducing barriers to
customers purchasing emission-free vehicles.
• Thakeham is keen to champion low carbon transport in the
local area, encouraging local transport services such as buses to
electrify their fleets.
• Mechanical Ventilation with Heat Recovery (MHVR) is
installed in our homes, which has a filter built-in to capture
incoming pollution to provide fresh filtered air.
• Thakeham works with its supply chain with an aim that all
mechanical plant on site is less than 18 months old, which means it
is less polluting and more fuel efficient.
Response to the draft Design Guide consultation
These representations are structured to accord with the individual
sections within the draft Design Guide, for ease of
reference.
Generally, Thakeham is supportive of the proposals set out in the
draft Design Guide and particularly welcomes the digital approach
taken, as well as its conciseness. Thakeham therefore supports the
aim and overall approach of the draft Design Guide, where it
provides additional clarity to design policies within the
respective Local Plans.
General comments
Whilst the representations above follow each section of the draft
Design Guide, there are some themes which flow throughout which
Thakeham would specifically highlight. For example, it is notable
that there is an absence of development scale attributed to some
requirements and Thakeham are of the view that a graduation of
these requirements, relevant to site size and capacity, would be
fundamental to their interpretation and would avoid protracted
dialogue at the application stage. When considering South
Oxfordshire’s proposed CIL (Community Infrastructure Levy)
increases (currently the subject of a separate consultation), the
draft Design Guide must be clear that the requirements are
proportionate and viable to the scale of development
proposed.
The draft Design Guide must also be consistent in its approach to
the requirements, particularly where these might be covered in
multiple sections. Thakeham has highlighted a few areas where there
are contradictions or different levels of detail in relation to the
same requirement, and consider it is imperative that the draft
Design Guide is clear to understand.
Conclusion
As noted, Thakeham support the approach taken in relation to the
draft Design Guide and in general are supportive of its contents.
Thakeham has however highlighted several areas where Thakeham
suggest statements need to be qualified, better explained, or
amended. Thakeham has also raised the issue throughout that the
requirements do not appear to be applicable to all scales of
development.
Thakeham would be pleased to discuss any elements of these
representations further if that would be helpful. Should you
therefore have any queries please do not hesitate to contact
me.
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No
further comments.
Admin note, the original submission is attached below for
reference, alongside the submitted supporting document.
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Response manually
entered, submitted in an email format. The original submission is
attached below for reference.
Carter Jonas is instructed by CEG to respond to the draft Joint
Design Guide (JDG) produced by South Oxfordshire and Vale of White
Horse district councils (“the Councils”).
CEG is a landowner and promoter which operates across both South
Oxfordshire and the Vale of White Horse, and is specifically the
promoter of Culham Science Village (“CSV”); the land
allocated in the South Oxfordshire Local Plan for development under
strategic policy STRAT9: Land adjacent to Culham Science
Centre.
It is understood that the intention is for the Councils to adopt
the JDG as a Supplementary Planning Document (SPD).
CEG is pleased to have the opportunity to comment on the JDG, and
generally supports the guidance contained therein. In general, the
JDG provides credible and well-established good practice principles
that will result in high quality placemaking.
There are some areas, however, where CEG would like to make
comments and observations, and the areas that are questioned are
broadly around numeric standards and those relating to the design
process.
Role of SPD
Before turning to the technical areas of the design guide, CEG
considers that the role of the SPD is not made clear in the JDG.
SPDs provide a role in explaining and amplifying adopted policy of
the development plan, and they are capable of being material
considerations in planning decisions. Whilst the latter point is
made clear in the supporting material to the JDG, the policy
framework within which the JDG sits is less clear.
The adopted policies upon which the SPD is built should be clearly
set out in the JDG, and this is especially important where it is a
shared document between two Councils. There is a suite of
‘design’ related policies in the Vale of White Horse
Local Plan and similarly there are several “DES”
polices in the South Oxfordshire Local Plan. Many of these policies
are complimentary, or even say the same things, but others are not.
Chief amongst the policy differences in South and Vale is the
existence of policies that are explicitly directed towards carbon
neutrality in South, which are less explicit in the Vale. Moreover,
there are a range of Neighbourhood Plans in both authority areas
– made and emerging – which include design guidance,
and so a clear policy framework which shows where and how the JDG
will work should be included at an early part of the document (or
interactive web pages).
Conclusion
In conclusion, CEG supports the principles set out in the Joint
Design Guide, however, as set out above, there are some details
that should be considered, and matters clarified, before the JDG is
adopted by the Councils.
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The
original submission is attached below.
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Response manually
entered, submitted in an email format. The original submission is
attached below for reference, alongside photos for the Design
Guide.
General points:
The document is very long and wordy in places despite the
introduction advising that this document is not.
Our main point is that everything that will be required by a
development proposal should be covered in the design principles
boxes and these should be numbered so that reference can be made to
them in reports, and appeals. Some information / guidance set out
elsewhere in the text or interactive menus was not included in the
principles, or perhaps did not translate into a detailed design
principle as a “requirement” that officers could
communicate to applicants. This would make it tricky for officers
to defend a particular position when faced with challenge by
applicants or appellants. Having it all together in principles
would also assist making a speedier decisions.
An enhanced glossary would be also be useful in that respect. This
should also be available from the circles to the right hand side in
addition to the main menu.
There was no contents page, or page numbers, as such it will be
hard to reference the design guide in reports and statements etc.
(evident below as we have not referred to para numbers)
The interactive links are perhaps engaging, but they are not
immediately obvious, and it seemed many of them once opened did not
relate to the headline. The spot headings at the side were not
immediately obvious. A pdf document will be necessary as some may
not be able to use interactive function. Control F does not work on
the current interactive webpage document.
Could all relevant umbrella (adopted local plan) policies be
highlighted, it is appreciated that the Councils do not always have
the same policies so perhaps it is better to include these at the
beginning of each section rather than in relation to specific
points?
Photos: Some of the locations / photos are not correct or do not
really represent the point, e.g Prezzo is not in Walilngford (it is
in Thame), the Thame paving looks like a wall, and bricks are
covered in scaffolding. We have included some hopefully useful
photos that our team has gathered to assist.
We think the tick / red X approach on good and bad examples gives
an immediate message and is useful.
We have some comments on specific matters, but these are not
comprehensive due to time constraints.
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Response manually
entered, submitted in an email format.
There are two things I take from the draft guide:
1. is there an easy search facility? That is, can you just search
for, for example, "lighting" or "materials" or "heat pump" and be
taken to the appropriate policy/words?
2. I can't see anything at all about dark skies, the desirability
of reducing light pollution and light spill etc.
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The
original submissions is attached below for reference.
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The
original submission is attached below for reference.
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121
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Response manually
entered, submitted in an email format.
The Council fears that, in the effort to cover all design issues,
the guide is unduly long and complex and, clearly, is written for
professional users (architects, developers, planning consultants
etc). The Council would prefer a guide which starts with a menu of
"what sort of building do you want to design?" and then directs you
to the appropriate section where there would be detailed
instructions with worked examples.
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Response manually
entered, submitted in an email format.
I thought the guide was absolutely brilliant.
One thing I thought of this morning, actually (a silly point) is
that I was a couple of sections in before I realised that I needed
to scroll down to get the full info on each section.
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The
guide provides a series of design principles that will be
considered when deciding on all future planning applications
– whether it’s a resident looking to build an extension
or a developer building a large housing site.
