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Comments
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Council’s
response
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1
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Too
many words.
Too many pages.
Too many concepts.
Too much everything.
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·
Noted.
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2
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The
information is clear but the information itself is crazy. Is the
Council seriously suggesting that all applicants undertake a Design
Compeitition? Does the Council understand the costs that are
associated with such a contest?
Why would a consultancy that provides planning and architectural
advice ever consider a contest against its own in-house architect?
Why would a regular average householder care to run a competition
for an architect to provide a rear extension and a porch, in fact,
what architect would even bother to submit an application?
Again, the same can be said for public consultation. No householder
application requires a public consultation aside from an informal
chat with the neighbours. Even a small scale development such as a
replacement dwelling or an infill plot would likely need to more
discussion outside of the immediate neighbours and the parish
council. The design guide fails to acknowledge the nuance of
different applications and this needs to be made clearer.
In any case, the flow chart suggests to applicants that if a design
review occurs and results in an improved design then planning
permission would be forthcoming. Such a suggestion is obviously
wrong and even the most beautiful development would be
innapropraite in the wrong location. This again needs to be
clearer.
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Noted,
we will explain and clarify when this flow chart needs to be
followed.
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3
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This
has no purpose. As a resident I should not have to be asked about
the design of promo material.
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This
is not promotional material but a Supplementary Planning
Document
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4
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The
flow chart makes it appear that Planning Permission is inevitable.
You just need to go through the loop enough times and you'll get
it.
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Noted,
we will explain and clarify when this flow chart needs to be
followed.
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5
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Clear
to understand
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·
Acknowledged
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6
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No
major issues with this
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Acknowledged
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7
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Please
add a search engine so that the document can be searched for key
words.
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Noted and in review
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8
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Not
clear that responses to this survey will be acted upon.
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A
consultation report will summarise the responses received and
appendix of raw data will be attached. A section within the
consultation report will explain how we have dealt with the main
issues raised prior to the guide being adopted.
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9
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The
existing Vale design guide is very clear, and yet in Faringdon we
see multiple large developments being approved which skip the
guidance . A cursory look at multiple exits and entry suggestions,
space for growing food, movement framework, etc. shows there is
little point in making new guides, if the implementation of
existing guides is so poor. If the same people and processes are at
work in the approval process, there is no point in investing in new
guidelines.
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Noted.
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10
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I
have not read the guide in detail as I wish to make some specific
comments which I hope will find space in the next pages.
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Noted.
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11
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I
haven’t got to section yet so how can I ascertain if easy to
use . Stupid question
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Noted.
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12
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I
found the whole package very easy to access and
understand.
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Acknowledged
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13
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will
you be having a display in council offices ao that many members of
the public , who do not have access to internet can also get
involved ?
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Copies
of the guide were accessible in all the main ombatme across both
districts. A pdf copy of the guide was distributed to those that
requested within the consultation period.
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14
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This
guide is well written, and clear without being prescriptive. As an
individual who lives in a small village, I can easily relate to all
the sections and I particularly like the built environment section.
You have done a good job on behalf of people like me. I hope that
individuals, architects, builders and larger developers take good
note and use the spirit of the guide when building the much-needed
houses for young people and those with modest incomes.
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Acknowledged
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15
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There
is still a tendency to use professional jargon which is not easily
understood by most of us, e.g.”” permeable hierarchy of
streets”” and “” inclusive
design”” .
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We
have tried to avoid technical language wherever possible. A
glossary of terms can be found on the website which define such
concepts.
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16
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Very
clear If I added points might be to strengthen as far as possible
need to meet the guidline criteria firmer than “”good
if you do”” and that priority to go to developments
that consider likely transport needs /CO2 emissions of
occupiers
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·
Noted.
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17
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The
document has very little to do with the planning process. It could
be used to support any planning decision; somebody decides to build
a couple of 18 storey block of flats opposite Didcot station (which
are out of kilter with the 2 and 3 storey environment – but
makes a lot of money for the developers – and creates a
dangerous fire risk and criminal hotspot). The Joint Design Guide
would green light it. If developers wanted a link road every 200
metres down the Didcot – Milton/A34 instead of one links road
from Milton Island (McDonalds) to Didcot – Harwell road (zig
zagging?), then 10 link roads snarling up road communications would
be green lighted even though this 2 mile piece of road is also the
first part of the proposed Didcot – Clifton Hampdon (& on
to M40?) link road. Therefore the Guide does not at present take
account of the wider environment. The Guide is fine for reviewing
the building a Church with crypt in one of the villages, but is not
‘fit for purpose’ for million pound projects. I suggest
the inclusion of two or more of the following: PESTLE analysis,
risk analysis, SWOT. PROVE. P.S. When I was asked to input into the
discussion about the 18 storey block of flats opposite the station
was a major fire risk and crime hotspot, the fire brigade wrote to
me to say that I was mistaken, and the Police rep said I was also
mistaken even though I gave examples. Perhaps Grenville Flats
changes his/mind? And regarding the crime hotspot perhaps somebody
could ask why multi story flats were build in Cowley and Blackburn
Leys and not Headington and North Oxford; and compare the crime
levels using Gov.uk?Thames Valley statistics?
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The
design principles outlined in the design guide are applicable to
all scales of development. Will review.
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18
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it
makes it seems as though is you can resolve the design you will get
pp. that is very far from the case. It also suggests everyone needs
a design review. The flow chart is just wrong. By failing to use
numbered points the introduction is useless. On a web page how on
earth can it be referenced?
design guides are really very rarely ‘full of complex phrases
and terms’ literally everything is in plain ombat in older
design guides. This one refers to ‘blue infrastructure’
quite early on which is so plainly unexplained jargon it is
ombatment. This guide is not doing what it sets out to do.
the introduction cites a ‘well designed hospital helps
patients recover quicker’. That is lovely but it is of almost
no consequence whatsoever for the rest of the design guide which is
heavily biased towards residential development. It is like the
authors don’t even understand why they are writing this guide
and who they want to influence by its. It is off beam.
the spider diagram (that i cannto reference of course)
doesn’t even cite health as an issue for design.
this is a mess of ideas rather than true clarity of vision
the landscape character links don’t work? Are they supposed
to? Who knows? How can one comment when it doesn’t seem to do
what one expects?
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The
design principles are numbered but the remaining text was limited
and adding a numbering system to it would affect the overall
formatting and appearance of the website. The section on value of
good design has been updated. Further reference to health and
placemaking has been made throughout the guide. Will review
landscape character links.
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19
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Does
not seem to take into account the need for a good infrastructure,
water, gas, electric supplies, medical needs, drainage etc. Or to
take into account the needs of parents with children in buggies,
people with mobility issues, good access to all areas, ie dropped
kerbs, and pathways not ateps.
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Some
of the issues need to be considered at the outset of the design
process and with the relevant authorities (County
Council).
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20
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In
design brief says Garages will be built to dimensions of 3m x 6m
for single and 6m x 6m for Double.
Its about time local planning took control to update these
dimensions for the modern word and vehicles.
(I have a 1998 built detached house with garage these internal
dimensions and its completely useless apart from storing tools an
junk. With the doorside facias taking up c35cm of door
entrance-width further….cant even get a small car in it or
get out of one once inside garage.)
Modern cars espec 4 x 4 ‘s and even new Evs are around 2.02m
wide and a shade over 5.0m long if you research.
IF THE VALE STIPULATED MANDATORY MINIMUM WIDTH AND LENGTH WHICH
WERE PRACTICAL TO PUT A CAR IN AND WIDE ENOUGH SO YOU CAN OPEN A
DOOR then a number of substantial benefits:
1. New Owners of Garages would be lot happier
2. Whole Community would welcome the reduction in the number of
cars outside peoples houses in streets and on drives
3. Second Cars formerly ‘on drive’ would be put in
garages probably reducing thoughtless useage as have to be
‘got out’
4. Planning could better use community space around
dwellings…wider verges/trees and no parking bays specially
built on roads.
5. Environment benefits in less-cluttered appearance and more space
as less parking-courts made, less tarmac areas.
6. Eyesore of Wheeliebins reduces as can put in
garage….(especially if planners force house-builders to
ombatm houses have internal-door access into these
garages).
7. Less cars on streets means better access for Emergency Services
and Waste Disposal rounds etc.
8. Less road-surfaces needed mean savings on maintenance, drainage,
more space in community devoted to open community use near homes eg
play and walking spaces, bike paths.
Serious issue and simple to sort now. Will provide a better future
in design aimed at a drive to improve peoples’ surroundings
rather than let builders build what they want as long as they pay
‘community/infrastructure planning charges’.
Please consider as standard for the areas builds..
thank you.
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The
design guide follows guidance set out by County Council regarding
garages. Some of these matters are beyond the remit of the design
guide. Other aspects will be reviewed.
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21
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There
is a need to prioritise the brief. The aspirations are laudable,
but I doubt whether they will be realized. Many of the aspirations
will be vacuous unless and until Climate Change is both
successfully arrested (both in this country and globally) and
protected against. The latter may require very high investment
infrastructure (including drainage for especially high run-off
drainage, hurricane protect and land slides).
It is not enough to publicise improved design guidelines.
Successful sustained developments call for a partnership between
Local Government and Developers. Along with the upgraded Guide
there should be a public Charter which commits Local Government to
provide the essentially well designed and sustainable
infrastructure and services required by all users of the proposed
development. Infrastructural provisions should be made in tandem
with the building and landscape development rather than
subsequently. The need for priority to be given to the creation of
successful and sustainable COMMUNITIES needs to be highlighted as a
development priority.
It should be emphasised that Developments should either directly
provide or be linked to green energy generation/conservation and
re-cycling; in situ or nearby. Measures for combatting the impacts
of prolonged heat-waves should be required, covering both buildings
and the surrounding landscapes.
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·
Noted.
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22
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I
like the clear use of headings/subheadings and introductory
sentences that can give meaning without having to read the full
detail – different levels of information are good.
A minor formatting point: bullets under the heading
‘Additional guidance and frameworks beyond our guide’
are in a slightly different font because they are links – I
think a consistent font would look better.
Generally the look and feel of this section and throughout is
really user friendly and attractive.
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Acknowledged
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23
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the
structure of the document as a whole was extremely clear and
excellent overall, i enjoyed reading it. The introduction was the
only part I felt somewhat confused – particularly the
measures of quality which did not link to or reflect the goals
within the document. I am also not sure what is meant by
“”landscaping””
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Noted.
The introduction section will be reviewed to reflect the overall
goals of the guide. A definition of ‘landscaping’ has
been added to the glossary of terms.
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24
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They
are all fine in principle. Providing a less prescriptive approach
might result in better outcomes for all, and in teh case of small
developments like house extensions that’s fine. But once a
commercial supplier becomes involved there is a danger that with
their well-resourced legal departments they will run rings around
the guide and exploit ambiguity to build more of the same crowded
developments with nowhere to put the bins, nowhere to park, and
basically as many homes as possible in as small a space as they can
get away with.
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·
Noted.
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25
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I
need to see the following pages before I am able to answer
this.
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·
Noted.
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26
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Sorry,
perhaps I’m very slow, but I had no idea I was expected to
click on a chain of coloured dots to find the detailed
content.
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Noted and in review
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27
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I
found the sections clearly labelled, and the main text was clear
and easy to understand. The use of graphics helped
enormously.
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Acknowledged
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28
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While
the introduction sections declare that the guide is for all, they
do not make it clear that the the first sections are for major
developments and that it is only the Built Environment and Climate
Change sections that are truly directed at small scale and infill
development, extensions or conversions. As the major developers
should all be employing specialist consultants familiar with the
main urban design themes, and it is the smaller-scale designers who
will be most in need of help, I suggest this is an omission. By the
time readers have found out by trying to work their way through the
guide they could be forgiven for losing patience.
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·
Acknowledged
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29
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Too
long winded – interest runs out before reaching end of
document.
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Noted and in review
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30
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While
coverage is intended to apply to large scale developers and
individual householders, the impression comes across as focussing
on major developments
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Noted and in review
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31
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The
language is still technical or formal. Is it meant for am
architect, a builder or someone who wants a house built? To a
householder like me it sounds too idealised; too a cynic like me it
sounds like an impossible dream, When I look at the development in
our area, though, it should have been available a good while
ago.
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·
Noted and in review
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32
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Ref:-
The introduction section website page is very clear and concise in
its content. The only comment I would like to make is the following
point:
1. To put a ‘date notification’ as to when the website
page has been updated e.g this Web page last modified on 1/03/22
etc…. This will enable the viewer to be informed on accurate
and up to date Planning information
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Noted and in review
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33
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There
needs to be a key/ labelling of the coloured dots that are
hyperlinks with the main body of information. It is easy to miss
these.
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Noted and in review
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34
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This
JDG is composed in such a way that it is accessible for the average
member of the public; as it states, it is written to break the
mould of the typical design guide which are often too long,
detailed and strict and full of complex design terminology- I would
definitely agree that it breaks that mould.
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·
Acknowledged
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35
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too
much information
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·
Noted.
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36
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The
Menu option at the top right of the web page needs to be made much
clearer. It took me a while to work out how to access the
information in the guide. I liked the Translate option – but
it’s hidden at the bottom.
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Acknowledged
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37
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Not
really applicable for a small rural Parish Council. It is useful as
guideline for Planning.
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Noted.
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38
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1.
the text appears in 2 (un-numbered) columns.It’s not clear
whether you should read down the page (i.e.the left-hand column)
until you reach the bottom of the page, and then go back up to the
top of the right-hand column. Paragraph numbering would remove this
confusion.
2. The diagram in the “”About the guide””
section is confusing. It’s not a flow-chart since some
“”legs”” to not link back to other
“”Activities”” and it’s not an
“”Inputs”” diagram since the direction
arrows do not always point from the inout to the process. Basically
it’s a mess.
3. in the paragraph where readers are advised to
“”please contact us or visit our website here South or
Vale”” the link word South and Vale are not highlighted
and thus do not stand out as being
“”click-on”” points.
4. Some paragraphs are verbose and not necessarily correct i.e.
where you say sustainable development is:
””Development that meets the needs of the present
without compromising the ability of future generations to meet
their own needs.””
Since the particular requirements of future generations is not
known, how can you say when a given development is compromising or
not?
The document then goes on to say: “”Simply stated, the
principle recognises the importance of ensuring that all people
should be able to satisfy their basic needs and enjoy a better
quality of life, both now and in the future””. Well, if
the principle can be simple stated why bother with less-simple
explanation in the first half of the paragraph? You then go on to
give an even simpler, one sentence, definition which is better and
is really all that is needed.
5. It is verging on a tautology to say “”A
well-designed hospital will help patients recover
quicker;”” since it implies that a hospital where
patients don’t “”recover quicker”” is
by definition “”not well designed”” which
is obviously not the case. It would be more correct to say
“”Should”” rather the “”will
help””. Ditto for the other example of
“”will”” in that section.
6. Some of the propositions stated are not valid. i.e. that
“”A well-designed residential development ..will ..
enhance the existing character and appearance of the area,
resulting in a win-win situation for both existing and future
residents and developers.”” There are plenty of
instances where “”green field”” vistas
around small villages are being spoiled by red-brick developments,
be they ever so well-designed, to the regret of the occupants.
Another case where “”Will”” should be
“”Should””.
My general feeling is that the opening section, down to
“”How to use this guide””, is unnecessarily
vebose with the same thing being repeated in various
ways.
It could be made more simple (i.e concise and to the point) and
less idealistic more pragmatic with some stringent
editing.
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·
Noted and in review
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39
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The
Guide is clear and concise
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·
Acknowledged
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40
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The
definition of ‘high quality’ is vague
(“”beautiful places where people want to live, work and
visit””), and there is still quite a lot of use of
jargon (e.g. “”a well-defined network of green and blue
infrastructure”” – I had no idea what that
referred to until later on in the guide, and “”creating
a positive relationship between fronts and backs of
buildings”” is an example of constant uses of phrases
that designers might use but other people will struggle to
interpret).
It also seemed odd to me that the page started with a diagram of
the process described as the one “”that we would
strongly encourage all applicants to follow”” and yet
the process didn’t seem to involve using the guide at all. I
couldn’t see a stage in which the guide was actually supposed
to fit (and I was initially expecting the process to be an outline
of the guide itself, so that this guide took people through the
process recommended).
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·
Noted and will review
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41
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Response
manually entered, submitted in an email format.
I have only read the “easy to use website” so far but
in relation the that wish to make three points.
(1) it uses admirably plain language – excellent!
(2) there are some solecisms in the “key design
objectives” section: 3rd bullet incorporates
and/or linkS; 9th bullet ombatment mixed uses;
10th bullet complementS the scale.
(3) “• is sustainable” Earlier you define this as
“without compromising the ability of future generations to
meet their own needs.” How can you possibly square this with
the fact that, by using vast areas of agricultural land you are, as
a fact, doing the exact opposite! By converting this land to built
uses you are depriving future generations of the ability to grow
crops on that land. With an ever-increasing population and
dwindling proportion of UK-produced food this results in increased
imports, all requiring energy to be transported here from their
places of origin (and incidentally reducing food security in an
increasingly insecure world). You are also removing some of the
many benefits of land being in agricultural use – carbon
storage of grassland soils, hedges for wildlife and attractive
landscapes, footpaths through green uses that promote mental
health…... I know that you have to “tow the government
line” on what “sustainability” actually means but
it would be nice to see some honesty occasionally!
I hope to make some substantive comments on the Guide itself in due
course.
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·
Acknowledged
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42
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We
are pleased that good quality design is important to the Council
and welcome the publication of the draft Design Guide for South
Oxfordshire and Vale of White Horse. However, we do have some
concerns over the content and design of the document.
Whilst it is encouraging that the guide is interactive and
digitally accessible, it is difficult to navigate and the menu is
hard to find. The guide would benefit from a contents page at the
beginning of the document with sign posting and links used
throughout the document.
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·
Noted and will review
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43
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Response
manually entered, submitted in an email format. For reporting
purposes additional text is marked as
‘’xxx’’ and deleted text as *xxx*. The
original submission is attached to this comment form for
reference.
South Oxfordshire and Vale of White Horse (South and Vale) are
exceptionally beautiful districts, rich in architecture of
different periods, styles and materials and rich in landscape
quality with a large proportion of the districts being designated
as an Area of Outstanding Natural Beauty (AONB). As well as
respecting and enhancing the existing natural and built environment
of South and Vale, the Councils expect the design of new
development to be similarly outstanding for the benefit of local
residents, visitors and future generations. ‘’In the
AONB’s any proposed development must demonstrate that it
conserves and enhances the special qualities of that
AONB.’’
Justification: To reflect the AONB’s status.
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·
Noted and will review
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44
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Response
manually entered, submitted in an email format.
I have had a look at the Design Guide and having no experience of
planning so it all sounds wonderfully idealistic.
It states – Research and national guidance have all
demonstrated the link between good design and improved quality of
life, equality of opportunity and economic growth. It suggests that
a well designed hospital or school will contribute to the wellbeing
of those who use the facilities they provide. However there is no
mention of the importance of good design in the houses/homes that
are built. Good design in houses has been demonstrated to be
important to the mental health and wellbeing of its inhabitants. I
imagine your remit does not extend to minimum space standards for
dwelling places but it should. However beautiful and well designed
the external features of a development if the rooms inside are
cramped and poorly designed then that building is not fit for
purpose.
People buying or renting homes deserve flexible space to cook, to
entertain, to be private, to store ’stuff’, to have
room for bikes and wellingtons as well as high tech. Such homes
require imaginative design and surely this should be a vital part
of new developments.
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·
Noted and will review
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45
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Response
manually entered, submitted in an email format.
About South and Vale
1. To be properly navigable the map of ‘Settlements &
designations map for South and Vale’ needs to have some more
place names inserted.
2. The Oxford Green Belt is referred to incorrectly as
‘Greenbelt’ (which is the name of a place in Maryland
USA), and, particularly in the post-Covid era, the enormous value
of easy access to it for city dwellers, as well as for the many
village communities located within it, for the improvement of their
mental and physical health, has not been emphasised sufficiently.
Reference to the NPPF (July 2021) could usefully be
added.
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·
Noted and will review
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46
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Response
manually entered, submitted in an email format.
9. Reference should be made to Neighbourhood Plans and taking them
into account, so that they can influence the design process at an
early stage. It is often too late to take local wishes into account
once planning applications are fully developed, and then found to
be in conflict with a Neighbourhood Plan. Early recognition of a
Neighbourhood Plan should prevent a planning officer having to
raise queries with a developer. Development should not take place
where it is found to be in conflict with a Neighbourhood
Plan.
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·
Noted and will review
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47
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Response
manually entered, submitted in an email format.
About South and Vale
•The Councils “expect the design of new development to
be similarly outstanding for the benefit of local residents”.
The Committee do not currently see much evidence of this approach
here in Didcot.
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·
Noted.
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48
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If
the website is to exist for awhile (and not solely for the duration
of the consultation) there are some grammar problems that could be
fixed.
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·
Noted and will review
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49
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The
Design Guide
The Guide is very clear but it fails to acknowledge up front the
impact of the SODC and Vale carbon reduction targets on all
developments.
Its Purpose
Please add text after ‘To improve the standard of design in
all developments in South and Vale and ensure that only
developments of the highest quality and sustainability are
delivered.’ – South and Vale are also both signed up to
the carbon reduction targets of the Oxfordshire Energy Strategy,
which committed to a 50% reduction in carbon emissions by 2030. To
achieve this, the imperatives of climate change will be addressed
throughout the Guide. The development of smaller homes is
encouraged, both to address the local shortage of affordable homes
and to build dwellings with a smaller carbon footprint.
Inform you design:
Add after ‘For example, surveys that assess the quality of
trees, landscape, or geology, identify the presence of a particular
habitat or species or identify transport and movement
information’ – alongside technical studies to show how
the carbon footprint is minimized during construction and use, how
to encourage local production of food and living walls be
incorporated to absorb CO2, check that flood risk is mitigated and
that adequate drainage is available.
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·
Noted and will review
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50
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Landscape
Character map could be interactive – very difficult to match
up with key.
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·
Noted and will review
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51
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There
is so much detail that it’s easy for fundamental principles
to get lost – e.g. “”can’t see the wood for
the trees””. Consultations need to be very well
publicised, easily accessible with a good distribution of venues
where proposals can be viewed and explained , and stretching over a
period of several weeks in order to elicit good responses. There
should be a set minimum percentage of responses from the population
which, if not achieved, should lead to an investigation into how
the consultation was advertised, and with an extended period of
consultation publicly and clearly announced.
|
Noted,
the consultation stretches over a period of 8 weeks. Those who
requested to be informed were put on a database and got made aware
of the consultation via email or letter. Document was available at
main libraries to view for those who did not have access to the
internet. Surveys were also made available. Pdf of the document
were provided to those who requested one.
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52
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The
comment “”well designed developments led to lower crime
and higher property values”” isn’t true in
practice. Just take Upton in Northampton as an example. Very well
designed with all the great and the good with “”secure
by design”” strategies but has a reputation for being a
place of high crime rates. Better to state a whole range of KPIs
e.g. low energy consumption, high rates of cycling/walking, onsite
renewable energy generation, high life expectancy, good air
quality, improved on-site biodiversity and local food production
from allotments etc etc.
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·
Noted and will review
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53
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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 be interactive and
link directly to the location of the ‘Principles’
boxes, which are used for assessment. Linked to this Officers
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.
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 with 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 also 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).
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’.
NO DIFFERENTIATION BETWEEN SCALE OF DEVELOPMENT -
Officers note that an all-inclusive approach has been taken for the
design objectives/principles. From an Officers perspective –
we can differentiate between principles relevant to Majors, Minors
and Householders/Others 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 clearer for
Mrs Bloggs (who is visiting the website because she would like to
know more about guidance on Householder Extensions). In this
instance a lot of the Majors design guidance wouldn’t apply,
but this isn’t immediately obvious.
NEIGHBOURHOOD PLANS –
Under “Additional guidance and frameworks beyond our
guide” – Officers recommended having some wording
encouraging people to check whether their local area has a
Neighbourhood Development Plan. Perhaps a link could be provided to
the relevant section on our website with a list of all the
made/adopted neighbourhood plans, as we have to give these weight
in decision making: https://www.whitehorsedc.gov.uk/wp-content/uploads/sites/3/2022/02/Feb-2022-Neighbourhood-Planning-VALE-hyperlinks-Master.pdf
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Noted and will review
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54
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The
whole section is easy to follow and well set out.
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Acknowledged
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55
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Please
refer to Bloor Homes’ comments in response to Questions 9 to
13 below, which raise specific comments in relation to each section
of the Design Guide SPD.
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Noted.
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56
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The
ombatme of the Plan structure of NPPF tp LP etc isn’t clear
and there is no mention of adopted Neighbourhood plans.
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Noted and will review
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57
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The
guide, we understand, is intended to cover design principles for
any planning application. From a sizable estate of new houses at
one extreme to a small alteration to an existing dwelling. However,
the introduction focuses almost entirely on issues relating to
sizable developments most of which have no bearing on minor
applications. We feel that for such applications, applicants are
likely to be confused or overwhelmed. It may be appropriate to
clarify and simplify the guide for smaller applications.
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Noted and will review
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58
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Response
manually entered, submitted in an email format
Design and Planning
The diagram indicates there is public consultation after a design
review, but this is usually only locally publicised. Full public
consultation comes after the submission of the planning
application.
Amendment needed: The box that follows on from Design Review should
say – local public consultation.
Why is design important?
The aim of the guide includes the intent to ‘provide a simple
set of design criteria that applications should meet and are easy
to follow’.
1. The document is not easy to navigate and lacks page numbers and
paragraph numbers for easy reference and location of
guidance.
2. The interactive document lacks the ability to search, for
example, guidance on light pollution or other common aims that
appear in more than one section of the guide.
3. The guide needs an index.
Amendments needed: The document needs to be a single searchable,
downloadable version of the guide. It needs an index with page
& paragraph numbers.
Delivering high quality, sustainable & beautiful
development
The guide treats sustainable and beautiful development as being of
equal importance. Sustainability is required to counter an
existential threat, a lack of beauty is undesirable but does not
pose the same threat to health and well-being that climate change
does. Amendments needed: This section should emphasise that
sustainability takes precedence and should not be sacrificed or
traded off against beauty – a subjective judgement.
Key Design Objectives – For all developments
This section lists 19 key objectives. Although each singly has
value as a set it is far too many. Amendments suggested. Objectives
should be grouped under headings which might include, for example,
enhancing the natural environment, layout and access, heritage and
safety.
What does the key objective ‘creates healthier places by
providing opportunities to transform lifestyles for the
better’ mean and how will it be assessed?
The key objective ‘has access to local services and
facilities and, where needed, incorporate mixed uses, facilities
and co-located services as appropriate with good access to public
transport; should provide a wide range of house types and
tenures’ is two objectives. Amendment needed. The objective
should be split into
i. has access to local services and facilities and, where needed,
incorporate mixed uses, facilities and co-located services as
appropriate with good access to public transport;
ii. Should provide a wide range of house types and tenures;
About South and Vale
Settlement & designations map
In The Oxford Green Belt the pop-out link to Oxford City Council
for more information on the Oxford Green Belt needs replacing as it
is out of date.
Replace the pop-out link with: https://www.cpre.org.uk/wp-content/uploads/2019/11/Oxford_factsheet_2018.pdf
Landscape Charters
Should this be Landscape Characters not Charters?
Landscape character map
The key & map do not appear to be interactive. Referring to the
South Oxon Landscape Character Assessment 2017, this map seems to
show Landscape Types rather than character.
Amendments suggested:
-An interactive map which highlights the associated area linked to
each landscape type, when a specific landscape type in the key is
clicked on.
- A line separating the two districts would be useful, as would an
interactive link on the white areas to confirm which settlement
they are.
- This section needs to link with Section 4, Natural Environment,
Natural features & resources
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Noted and will review
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59
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Response
manually entered, submitted in an email format.
I was going through the design guide and I didn’t realise it
didn’t just continuously scroll any more. So I couldn’t
work out where to find the technical bits at first. I was wondering
if you’re able to put one introductory paragraph saying you
can move through the guide using the buttons on the left or go
directly to specific sections via the menu option at the top or
something? That might be obvious to anyone who didn’t see an
earlier draft maybe but I wasn’t aware at first how to find
the other parts or that I could skip specifically to building
conversions for example.
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Noted and will review
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60
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The
navigation is cumbersome. There should be a contents list after the
introduction so people know where they are, not on a separate page.
The layout requires a large, wide screen to read it and one section
is not clearly defined from another.
It is difficult to know where you are. The Additional guidance and
frameworks beyond our guide: is missing Neighbourhood Plans which
gives local people some say in developments and which the
volunteers involved work very hard on.
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Noted and will review
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61
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Response
manually entered, submitted in an email format.
Section 1 – About the Guide
The introductory section explains the background to the guide, and
how applicants should use the guide, but it does not explain
precisely how the guide will be applied by the District Councils.
Section 1 does note that the Joint Design Guide SPD will be an
important material consideration once it has been
adopted by the Councils, and later on in Section 1, there is
reference to the Council using the ‘criteria’ in the
design guide to assess schemes.
Will all schemes be assessed by the Councils against all of the
criteria relevant to a particular development, using some form of
checklist? How will the Councils apply those criteria that are more
aspirational, as opposed to being Local Plan policy
requirements?
The next version of the Joint Design Guide should be clearer in
terms of how, precisely, the Councils propose to use the Guide when
assessing planning applications.
The introductory section refers briefly to the National Design
Guide (2019) and National Design Code (2021), under the heading
‘Additional guidance and frameworks beyond our guide.’
There ought to be reference here also to Building for a Healthy
Life (2020). Indeed, given the myriad of different design
guidance available to applicants, it would be very helpful if the
Joint Design Guide could be clearer in relation to the overlap
between the guidance set out in the Joint Design Guide, and other
guidance and frameworks referenced. So for example, will proper use
of the Joint Design Guide ensure that the ten characteristics of
well-designed places, as set out in the National Design Guide, are
achieved?
Finally in relation to Section 1, the flow diagram could be
misinterpreted (and should therefore be amended), as it suggests
that if you follow the stages outlined, you secure ‘Planning
Permission!’. That may be a more likely outcome, but of
course there will be many other factors at play. The flow diagram
should also be amended (or a footnote introduced) to clarify that
not all schemes will need to be subject to Design Review.
Section 2 – About the South and Vale
The interactive map showing settlements and designations has a
clickable button for the Oxford Green Belt. The first paragraph of
the text that sits behind the clickable button states:
“In common with all other Green Belts, the primary planning
purpose of the Oxford Green Belt is to prevent urban sprawl into
the countryside and the coalescence of settlements. It is also
intended to protect the setting of the historic City and to
encourage the re-use of derelict land (brownfield sites)
within it. It also serves as an opportunity for City dwellers to
have ready access to the countryside, particularly obviously where
the Green Belt to the South of Grenoble Road benefits residents of
The Leys to the North. (The five purposes of Green Belts are set
out in section 1.5 of Planning
Policy Guidance 2: Green Belts)”
Planning Policy Guidance 2: Green Belts, has of course long since
been superseded by the NPPF, and there have been some subtle
changes to the defined purposes of the Green Belt. The quoted
paragraph above should be updated to reference the NPPF (2021),
paragraph 138 (not to PPG2: Green Belts), and the defined purposes
of the Green Belt updated as necessary.
The text in relation to the Oxford Green Belt could also helpfully
refer to the more recent changes to the Planning Practice Guidance
(PPG), which make reference to the concepts off-setting and
compensation, where an authority propose releasing land from the
Green Belt for development.
In relation to the landscape character map for South and the Vale,
this is quite difficult to follow, as there is no base mapping
behind the colours, and some of the colours are quite similar. It
would be very helpful if the landscape character map could be made
interactive.
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Noted and will review points individually
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62
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Response
manually entered, submitted in an email format.
This evening I had another go at the Joint Design Guide
consultation.
Starting from the SODC website it is straight forward to get
to https://data.southoxon.gov.uk/JDG/Guide.html
by putting Joint Design Guide consultation in the search
box.
However, having read this section numerous times I sometimes
struggle to find the actual content.
Then I remember that Anne Marie told me to look for the 3 bars in
the top right!
I gather that 3 bars in the top right means Menu.
Do you think that all those wishing to access the Guide know
this?
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Noted and will review
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63
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There
needs to be clear language, and distinction (where necessary)
between, for example, design principles and criteria (see
‘Design Principles’ blue box in the draft guide) and
design objectives (listed later in the guide). There is no
commentary on different requirements for different scale of
developments, nothing about non-residential design; no commentary
on differing requirements for outline or detailed, or conservation
area / AONB / listed buildings. However we note the caveat that
‘not all criteria are relevant to all proposals’ which
needs to remain, with the addition that the level of detail
required will also vary depending on the nature of the proposals.
The Guide would benefit from more detail in line with the
principles of the National Design Guide (NDG), while providing more
detailed guidance relevant to the local area which is reflective of
adopted policy.
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Noted and will review
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64
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Please
see submitted letter for full comments.
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Noted
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65
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Clear
– yes; likely to deliver the goals – no. The authors
wish to “”break the mould”” of design
guides, but have in our opinion aimed it at householders who might
not choose to use professional designers. However, these applicants
are not the main problem with the quality of development.
It’s generally the large-scale developers, who won’t
read this new Guide, who are lowering the standards. They know all
too well what is hoped for, but choose for mainly financial reasons
not to follow the acres of guidance that are already out there.
This new guidance seems to be aimed at the ordinary person, aiming
to simplify what are often quite difficult and technical issues,
but it ends up in some areas being rather patronising.
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Acknowledged
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66
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Additional
guidance and frameworks section should include:
- Defra Rights of Way Circular (1/09) https://www.gov.uk/government/publications/rights-of-way-circular-1-09
(specifically section 7. Planning permission and public rights of
way)
- Oxfordshire Rights of Way Management Plan
- emerging Oxfordshire Local Transport and Connectivity Plan (LTCP)
5
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Noted and will review
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67
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Sustainable
Development should go much further than the original definition.
Any development should be zero carbon and should enhance
nature.
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Noted and will review
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68
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1.
While the aims of the Design Guide appear reasonable for larger,
new developments, the introduction is almost guaranteed to frighten
the ‘house extension’ applicants. The standard of
English is poor (sloppy) and the text is full of jargon terms that
are not defined, despite what the introduction states. Many of the
phrases or terms used will not be clear – they will either
not mean anything relevant to the experience of an average
householder or will have a wealth of meaning to a design specialist
only. The document needs a thorough proof reading to put errors
right.
2. I am supportive of the aim to ‘break the mould’ but
do not see the mass of jargon in the document as the way to do it.
The Draft Design Guide (DDG) is not short and concise. It does not
define the meaning of relevant design phrases and terms adequately
and I assume that the Local Plans (including any Neighbourhood
plans) are those that “”must be read in conjunction
with other statutory plans””. If they ‘must be
read in conjunction …’ then they must be defined in a
list that is a complete list that should appear in this document
– otherwise you are creating uncertainty rather than clarity.
You must state that the Local Plan policies have to be followed as
the primary requirement – they have supremacy over the DDG
and act as the starting point in the planning application
process.
3. The document seems to be less ‘breaking the mould’
and more ‘changing one mould for another’ – in
this case producing the BHL version of the mould as the
standard.
4. Do you intend to re-structure the Planning Dept to create a
large team of pre-application designers to advise applicants? The
Design Process flowchart starts with ‘appoint your design
team’. Is this appropriate and proportionate for the majority
of small, simple house extensions?
5. How many/what proportion of applications are for relatively
simple and small house extensions? Do you expect (as the document
suggests) that an applicant for a small extension should do a
‘contextual analysis’ of the area, or
‘incorporates and/or link to a well-defined network of green
and blue infrastructure’ or ‘creates healthier places
by providing opportunities to transform lifestyles for the
better’ etc etc? The section that explains (a little) about
‘Householder extensions and outbuildings’ is buried in
the Built Form section towards the end of the Guide. I suggest this
is referenced near, or in, the Introduction sections and possibly
put in a seperate section if the proportion or numerical number of
applications is highest in this category.
6. The flowchart follows through pre-application, design review to
a public consultation. What is this public consultation? What
‘public’ will be consulted – there will have been
no knowledge of the pre-application as far as the local public are
concerned (unless they have been involved in a Placecheck exercise,
which may only have been notified to a limited number of people).
Will the planning process now inform local residents and other
bodies (statutory or otherwise) about all pre-application
requests?
7. Who will ensure that a design review takes account of all the
comments and decides which feedback will result in what changes to
the initial design?
8. I am amazed that there are no references to artificial lighting
guidance and standards in the document, both external lighting
schemes and internal lighting within buildings that may have an
adverse effect on the external local environment.
This is particularly important across the whole range of
developments from town centres, through housing developments (large
and small) and commercial and employment hubs to suburban and rural
areas – especially in AONBs (and potential dark sky zones).
Street, service area and road lighting is also important to be
integrated into any development design.
The potential adverse effects of artificial lighting on humans and
wildlife, flora and fauna is a major field of design consideration
that MUST be considered accurately and effectively. It applies to
each and all of the sections in the design guide. Why is there no
mention, let alone references, at all in any of the sections to
either the requirements for the design process or to the wealth of
guidance (national – ILP, AONB, design professionals,
research organisations etc) available?
I suggest that the references that should be included in all
categories should be :
- Institution of Lighting Professionals Guidance Note GN01 (2021)
THE REDUCTION OF OBTRUSIVE LIGHT;
- Dark Skies of the North Wessex Downs AONB – A Guide to Good
External Lighting (2021);
- Institution of Lighting Professionals Guidance Note GN08 (2018)
Bats and artificial lighting in the UK.
It is possible that the GN08 document reference could be included
in the Biodiversity section (Support your design) only.
Even the section 2 (Natural Environment) starts with a ref to LVIAs
but makes no mention of the requirement to present design documents
that consider both the daytime analysis of the various factors to
be considered AND ALSO THE EFFECTS OF THE LIT ENIVIRONMENT. For at
least half the year (Autumn-Winter-Spring) the lit environment is
critical to creating places and areas that people will occupy (live
in), work in and travel through during their daily activities.
There are also significant adverse effects of too much of the wrong
sort of light on a range of wildlife activity, breeding, migration
and feeding habits (resulting in a serious decline in a whole range
of species, not just bats).
The impact of poorly designed lighting is severely detrimental to
the natural, human wellbeing and energy-concious environment and
must be considered properly. Too often in the past, lighting has
not been considered in planning applications at all or only to a
minimal degree. This results in some appalling errors and adverse
results for local residents. It is clear that officers in the
planning department do not have a clue about many aspects of
lighting and its effects. Too often, planning applicants (and their
advisors, including development designers) also have little idea of
the negative impacts of external lighting schemes, particularly in
AONB areas. They frequently err on the side of providing far too
much light (to be on the ‘safe’ side) or feel that
‘you can’t have too much light’.
I will be happy to help you put forward some additional
content/headings/references if you are ombatm to listen.
9. Overall, the DDG contains a wealth of design guidance, but does
not meet the stated purpose.
10. The purposes of the design guide include the term
‘bespoke’ – what does this mean?
11. The ‘we aspire to’ list includes
“”provide a quicker and easier process that all
applicants can follow”” – the DDG adds a
pre-application step and a public consultation, so I fail to see
how it will be quicker. The initial documentation includes
“”A contextual analysis, an opportunities and
constraints plan with a clear key, a concept plan with a clear key,
a regulating framework plan and associated technical””
– this does not look to be an easier process since the format
of these documents is neither indicated or specified.
12. Who will decide whether the ‘design’ is acceptable,
good or bad – a design specialist or the planning
officer?
13. What voice will local residents have and how will their views
be considered?
14. Who will decide what additional documentation is required (if
any) and in what format? How does the documentation in point 11
above fit in with existing documentation requirements (EIA, D&A
Statements, LVIAs etc etc)?
15. How do you intend to persuade applicants who do not want to
‘communicate’ their design aims/constraints/goals to
follow this process? How do you get the level of detail or
sufficient information to fully define the development – what
standards will be applicable?
16. What role does the Enforcement section undertake if what is put
in the design is changed or not provided? What if a re-design is
needed or a change in design is not notified?
17. The intro states that you want to deliver high quality,
sustainable and beautiful development – who decides what is
‘beautiful’. I am sure that the more people you ask,
the more different answers you will get. So who will
decide?
18. I ask that in your Key design objectives, you include something
on lighting eg for people, communities, wildlife and ecology get
external lighting right – The right amount of light, where
wanted, when wanted, controlled by the right system.
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Noted and will review
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69
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Response
manually entered, submitted in an email format.
I am just starting to look through this and found a spelling
mistake on the first page with a diagram using script
writing…Could you just check the word response…I think
you have written responce. Otherwise, what I have looked at is
looking great so far! Well done.
The spelling mistake is right at the beginning of the document on
the page with About this Guide and Design and Planning and is part
of the diagram in script writing…it says’ Refine your
design in responce to feedback’
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Acknowledged
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70
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Response
manually entered, submitted in an email format.
Introduction Sections
Additional guidance and frameworks beyond our guide
• Reword ‘Local Plans for South Oxfordshire’ and
‘Local Plans for Vale of White Horse’ to ‘Local
and Neighbourhood Plans for South Oxfordshire’ Local and
Neighbourhood Plans for Vale of White Horse’, to reflect role
of Neighbourhood Plans.
Key design objectives
• These could be missed (given their location at the bottom
of this section) but are a fundamental part of the guide – we
would suggest either placing them in their own chapter or visually
increasing their importance, for example by placing them in a
box.
• ‘ensures a sufficient level of well-integrated and
imaginative solutions for car and bicycle parking and external
storage including bins.’ – Bins and cycle storage can
be an afterthought in developing proposals, which results in poor
design. In order to create attractive facilities for cycling
(relevant for decarbonisation and promoting healthy active
lifestyles), ideally bins would be located separately from cycle
storage and cycles should be equally or more accessible than car
parking spaces.
About South and Vale
• Good infographics – informative and simple
Settlements and designations map
• Crowmarsh is in the wrong place. It needs to be further
west adjacent to Wallingford, and probably better to refer to it as
‘Crowmarsh Gifford’. Also is it worth putting the
district boundaries on the map?
Landscape Charters Graphic
• This may benefit from an explanation of what the graphic is
based on, i.e., the character assessments. Maybe these could be
explained a little and/or linked? And/or links to recommendations
for Open Dipslope etc.
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Noted and will review
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71
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Response
manually entered, submitted in an email format.
””The Parish Council supports the principle of updated
design guidance for the district.
LACK OF CONTEXT
It is noted that the guide refers to additional guidance and
frameworks: (i.e. The National Planning Policy Framework (NPPF,
2021) Local Plans for South Oxfordshire, Local Plans for Vale of
White Horse, National Design Guide (2019), National Design Code
Part 1: The Coding Process (2021), National Design Code Part 2:
Guidance Notes (2021) ).
However the Parish Council is concerned that it does not explain
the specific role of these documents and whether they have
influenced the guidance in the document and whether they should
also be consulted by those using the guide to develop development
proposals.
In addition the guide does not refer to the role of Neighbourhood
Plans (NDPs), whether existing or in preparation, where these
provide local design guidance or design codes for their
neighbourhood.
Eye and Dunsden Parish Council are currently preparing an NDP and
this includes a character appraisal of the parish with accompanying
design guidance. The draft NDP is expected to be published for
consultation later this year 2022. This guidance will form an
integral part of the suite of relevant planning documents in force
in our parish as it will provide specific local guidance in design
matters.
ERROR IN AONB MAPPING
It is noted that the geographical boundary of the Chilterns AONB
within the Parish as shown on a plan in the design guide is
inaccurate. It does not currently extend across the entirety of the
southern parishes. Our parish is part of a consortium pressing
Government for AONB enlargement to include the area you have shown,
and together with the AONB board, we are looking to SODC for
support in this matter.””
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Noted and will review
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72
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Response
manually entered, submitted in an email format.
‘About the Design Guide’
The draft Design Guide is purportedly “…relevant for
all scales of development…”, however, Thakeham would
note that the requirements throughout appear to have been drafted
with strategic-scale development in mind and Thakeham would
question whether they are transferable to smaller-scale sites,
given it would not be accurate to suggest that there is a
‘one size fits all approach’ to design. To save
protracted discussions at the application stage, Thakeham suggest
that it is important to be clear on the application of the
requirements set out in the draft Design Guide, particularly where
there may be, or indeed should be, a graduation in relation to the
scale of a site/development.
‘About South and Vale’
The draft Design Guide notes that “As well as respecting and
enhancing the existing natural and built environment of South and
Vale, the Councils expect the design of new development to be
similarly outstanding for the benefit of local residents”
(our emphasis). The term ‘outstanding’ is considered
subjective and imperatively is noted within the National Planning
Policy Framework 2021 (“NPPF”) at paragraph 80 –
referring to design ‘of exceptional quality’ regarding
the acceptance of isolated homes in the countryside, and paragraph
134 – referring to the weight to be applied to
‘outstanding or innovative designs’. Thakeham would
therefore suggest that the councils should be clear on the
definition of ‘outstanding’ within the draft Design
Guide or justify why they ‘expect’ development to be
designed to a level which the NPPF describes as
‘exceptional’.
The draft Design Guide submits that “In Planning terms the
quality and nature of the land within a Green Belt is
irrelevant”. Thakeham would note that often the quality and
nature of the Green Belt plays a key role in assessing whether land
should be included in, or removed from the Green Belt. Such
considerations may include agricultural land value, previously
developed land, biodiversity opportunities and defensible
boundaries. Whilst the NPPF defines the five purposes of the Green
Belt, Thakeham is of the view that it is incorrect to state that
the quality and nature of current or proposed Green Belt land is
‘irrelevant’ within planning considerations and suggest
this is reworded. For example, Thakeham would suggest the following
is more accurate:
‘In planning terms, the quality and nature of land proposed
to be included in or removed from the Green Belt can play an
important role in assessing its suitability. In terms of the
ongoing functionality of land included within the Green Belt, it is
the five purposes contained within the National Planning Policy
Framework (NPPF) that Green Belt land is tested
against’.
Notwithstanding the quoted text above, in the following paragraphs
the draft Design Guide suggests that the Oxford Green Belt is
“…almost entirely of high environmental value”.
Moreover, it suggests that “Agriculture is an important
aspect of this Green Belt, with a relatively high proportion being
‘Best and Most Versatile’ (Grade 1 or 2) quality
land”. Having consulted the Natural England Agricultural Land
Classification map for the Oxford region1, there are only two areas
of Grade 1 (‘Excellent’) agricultural land within the
Green Belt: at the far eastern edge near Great Milton and at the
far southern edge near Berinsfield. Whilst there is a presence of
Grade 2 (‘Very Good’) agricultural land elsewhere
within the Green Belt, it is overwhelmingly dominated by Grade 3
(‘Good to Moderate’), Grade 4 (‘Poor’)
agricultural land and land classified as ‘other land
primarily in non-agricultural use’, particularly around
Oxford and other key settlements. Thakeham therefore consider the
draft Design Guide is misleading with this assertion and suggest
that this statement is either amended or qualified with evidence
i.e., with regard to the Natural England Agricultural Land
Classification map for the Oxford region1.
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Noted and will review points individually
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73
|
There
needs to be clear language, and distinction (where necessary)
between, for example, design principles and criteria (see
‘Design Principles’ blue box in the draft guide) and
design objectives (listed later in the guide).
We note the caveat that ‘not all criteria are relevant to all
proposals’ which needs to remain, with the addition that the
level of detail required will also vary depending on the nature of
the proposals. It would be helpful if the SPD confirms that there
will be different requirements for different scale of developments
(and what those requirements are likely to be). There is no
commentary on differing requirements for outline or detailed
proposals, or conservation area / AONB / listed buildings guidance;
and it is unclear what might be required in relation to reserved
matters applications. There is only a very short section of
specific guidance for non-residential design.
|
·
Noted and will review points individually
|
74
|
Response
manually entered, submitted in an email format.
As shown in the key flowchart diagram CEG notes the inclusion of
Design Review and whilst the exact form of Design Review is
undefined, CEG does question the need for this on every
proposal.
|
·
Noted and will review points individually
|
75
|
Response
manually entered, submitted in an email format.
Presentation
The online, interactive presentation has benefits offers some
benefits over a simple printed document but can be difficult to
navigate, in particular to find relevant material. An index would
be useful.
The landscape character map adds very little to the document
– it has too many colours that are difficult to relate to the
index – it would have been helpful if it was interactive
– with the ability to click on or hover over a colour to
produce a pop-up identifying the character. It is also difficult to
relate the map to locations – the option for an overlay of
the main towns and villages would be helpful.
Scope of the design guide
Despite recognising that most of each district is rural in nature
and largely covered by two areas of outstanding natural beauty
(AONB), the design guide is focused mainly on urban development.
There is no mention of the specific issues relating to development
within an AONB. Whilst issues such as tree planting and
biodiversity are covered, these have a particular significance in
the context of an AONB, where National Policy and Policies in local
plans require development to conserve and enhance the AONB. Despite
the statement that South has four towns and Vale has only three,
almost every diagram shows large developments in or on the edge of
a town, eg the diagram showing the benefit of tree planting shows 3
and 4 storey buildings in what is clearly a town environment. Much
of the terminology relates to urban areas – street scenes,
town squares, tree lined streets, etc. The first mention of a
village development is in section six on space and layout. The
guide claims to cover all development from house extensions to
large scale developments but is biased toward larger scale
development. There is a modest section on extensions and no mention
of small developments of, say, 3 or 4 houses or infill development.
Many of the design requirements for open spaces, movement are not
relevant to smaller developments or are difficult to
implement.
|
·
Noted and will review points individually
|
|
Comment
|
Council’s
response
|
1
|
Too
many words.
Too many pages.
Too many concepts.
Too much everything.
|
·
Noted.
|
2
|
As
before, the guide is clear in the points that it is making but
totally useless when it comes to acknowledging the nuance between a
householder/small scale application and a large scale development.
No householder application requires consideration of a large number
of the objectives yet the wording of the design guide suggests it
does.
- There is no need to include the objective relating to heritage
assets as this is covered by other legislation. This should be
removed to avoid duplication.
- The section “”respects the local context working with
and complementing the scale, height, density, grain, massing, type,
details of the surrounding area;”” is unclear, what is
‘type’ and ‘details’ in this context? It
dosn't make sense, there is no such thing as a local type or local
detail. The type and detail is the cumulation the scale, density,
massing etc.
|
·
Noted and will review
|
3
|
The
Guide omits a key objective. Oxford Council is supposed to
represent the Public Interest. The Guide ignores that.
|
·
Noted.
|
4
|
Too
jargon-based.
What does “”well-defined network of green and blue
infrastructure”” even mean?
and the:
“”respects the local context working with and
complementing the scale””
It reads as if the author is trying to impress rather than be
clear.
|
·
Noted and will review
|
5
|
Easy
to understand
|
·
Acknowledged
|
6
|
The
objectives are clear and adequate as long as the actual is the same
as the proposal and not diminished in any way because of financial
constraints driven by the developer
|
·
Noted.
|
7
|
It’s
a lot to take in.
|
·
Noted and will review
|
8
|
The
existing Vale design guide is very clear, and yet in Faringdon we
see multiple large developments being approved which skip the
guidance . A cursory look at multiple exits and entry suggestions,
space for growing food, movement framework, etc. shows there is
little point in making new guides, if the implementation of
existing guides is so poor. If the same people and processes are at
work in the approval process, there is no point in investing in new
guidelines.
|
·
Noted.
|
9
|
See
above
|
·
Noted.
|
10
|
Ditto
|
·
Noted.
|
11
|
key
objectives should be sustainability and access. At present neither
Wantage or Didcot have road access to support any more development.
All day Saturday it is impossible to get through Didcot as the
bottleneck at the rail bridge is chaos.+
All of the old buildings ned to be levelled on the lower Broadway,
this is the best opportunity to clear this area and improve
transport.
The best site to access another Harwell village development at
Milton interchange where there is a vast un development area to
start for some large food supermarkets. .Not tesco or sainsburies
as there are plenty of these in the area.
|
·
Noted.
|
12
|
The
design message seems to me to be one of ‘fitting in’
and I find that is what I want.
|
·
Acknowledged
|
13
|
Might
include the desirability of designs which allow de commissioning
and resource reuse at end of anticipated life
expectancy.
|
·
Noted.
|
14
|
See
previous comments and suggestions.
|
·
Noted.
|
15
|
this
is far from clear and will om lead to better designs or better
DASs.
it really needs to be clearer about what proportnality you expect.
It seems as though all thus guff is needed for all levels of
development when it isn’t.
this needs a much clearer route map to follow for the scale of
development one is putting forward.
i work in planning every day
the place and setting section is not helpful at all.
experienced practitoners know more ombatm infomation than this is
seeking to draw out. I don’t see what help it is
|
·
Noted.
|
16
|
Very
general…more specifics needed on materials….must retain
Medieval Market Town appeal of Wantage…or it turns into
concrete Didcot.
|
·
Noted.
|
17
|
I am
not convinced that within the existing frameworks, public-private
partnerships are capable of (a) either agreeing on key design
objectives or delivering them. It just isn’t possible to
please everyone all of the time. Realism needs to caveat high
idealistic objectives, in order to gain public respect and
support.
|
·
Noted.
|
18
|
They
are all simple statements and not too many to be
overwhelming.
|
·
Acknowledged
|
19
|
The
design standards are contradictory. You say you want
sustainability, but say nothing about increasing the square feet
used per existing footprints. And yet surely this is more
sustainable than new developments. Or if not why not?
You do not seem to encourage residents to get solar panels when
having extensions built. The positive environmental aspects of
extensions are not explained
|
·
Noted and will review
|
20
|
OGT
would like to see reference to registered parks and gardens in
‘conserves and wherever possible enhances….historic
parks and gardens especially registered sites in the key design
objectives
|
·
Noted and will review
|
21
|
the
quality element i thought was the weakest part of the whole
document – as the measures of quality did not reflect the
goals.
|
·
Noted.
|
22
|
Great
in principle. But how are you going to demonstrate to someone whose
job is to work around the rules, that vague principles have or have
not been met?
|
·
Noted.
|
23
|
no
comment
|
·
Noted.
|
24
|
There
is no mention in the key design objectives of the preservation of
sound heritage or the creation of a positive sound environment to
support ecological sustainability alongside supportive and positive
living conditions.
|
·
Noted.
|
25
|
These
are highlighted, making them stand out on the page. Each objective
is short and precise.
|
·
Noted.
|
26
|
On
the grounds of looking at what builders & developers do rather
than what they say, I strongly object to the use of the word
“”sustainable”” in your guide. To date,
around Wantage, Grove and surrounding areas, the provision of
thousands of new houses over the past 10 years has been accompanied
by a reduction in public transport and the absence of
infrastructure development (roads, medical care provision,
schools). Your guide, if it is intended to be truthful, should
replace the offending word with
“”unsustainable””.
|
·
Noted.
|
27
|
Lots
of rather subjective terminology very open to
interpretation
|
·
Noted.
|
28
|
Easy
access to the site plan before any written report would be more
useful to more people.
|
·
Noted.
|
29
|
No
problem here, but again focus seems to be on major developments.
Will individual householders or single dwelling builders even
consult the guide, let alone pay any attention to it.
|
·
Noted and will review
|
30
|
The
language and the length need attention.
|
·
Noted and will review
|
31
|
Good
in terms of principles, but seem subjective when evaluation whether
achieved
|
·
Noted.
|
32
|
I
don’t think this section could have been made any clearer if
I’m honest!
|
·
Acknowledged
|
33
|
The
comment on landscape character and biodiversity is clear
‘uses land efficiently whilst respecting the existing
landscape character and delivers a net gain biodiversity’
– however, I feel this should also include a reference to
ensuring that any important protected areas, such as ancient
woodland, remain intact and are not impacted by the
development.
|
·
Noted and will review
|
34
|
Talk
about “”contextual analysis”” and
“”respecting the local context”” for
example are unclear and overly technical. Also
“”complementing the scale, height, density, grain,
massing”” uses terminology which isn’t accessible
to a lay person e.g. what is grain? What is massing? And how does a
building or structure (which is inanimate) complement anything? In
short if the object is to have written in plain simple language
then I consider that the guide has failed.
|
·
Noted and will review
|
35
|
What
is missing form the Design guide is any reference to Neighbourhood
Plans – these should be drawn from when any pre application
advice is sought as well as during the whole of the planning
process, especially for any new development build.
The points around the “”High Quality Sustainable
Development”” vary; “”Variety of
choice”” would only apply to developments of more than
one dwelling and is already a well-established practice,
“”Well-connected and walkable””,
“”Low carbon””, “”Available to
all users”” and “”attractive outdoor
spaces”” are fairly measurable while
“”Beautiful architecture””,
“”Character and identity”” are subjective
and “”Can adapt well”” seems to me to be
completely impossible to quantify or even to aim for.
Under the bullet points for “”Key Design
Objectives”” headings are satisfactorily detailed,
adaptable for all types of applications, but
“”understands and addresses the needs of all potential
users to ensure inclusive design”” is subjective (see
above comments for “”Can adapt
well””).
|
·
Noted and will review
|
36
|
Not
really applicable for a small rural Parish Council. It is useful as
guideline for Planning.
|
·
Noted.
|
37
|
Clear
and easy to understand? You must be joking!
1 Take the line “”is informed by a contextual analysis
of the area”” which, put more simply means
“”Includes a outline of the essential features of the
area in which the development is to be situated.
2 Consider “”and delivers a net gain
biodiversity’. In simple-speak this would be
“”increases biodiversity””
3 Consider “”link to a well-defined network of green
and blue infrastructure;”” I think
“”well-Defined”” adds nothing and should be
replaced by “”supporting””. I have not yet
come across any reference to what “”green and Blue
infrastructure”” might be!
4 Take “”provides a clear and permeable hierarchy of
streets, routes and spaces to create safe and convenient ease of
movement by all users;””
permeable means porous so what is a “”porous
hierarchy””? You might have a hierarchy of permeable
streets but a route is “”a course taken””
(presumably over permeable streets and/or rights of way) and so is
superfluous in this context.
5 Oh, this one’s a corker! “”has streets and
spaces that are well overlooked creating a positive relationship
between fronts and backs of buildings;”” . I suspect
what is meant is “”has streets and spaces where the
fronts and backs of the buildings that overlook them have a common
architectural theme.””
I haven’t got the time nor the inclination to go through this
section of the document detailing, line by line, the corrections
which I think are required to clarify what it is attempting to set
out. However I will ombat with:
6 “”ensures a sufficient level of well-integrated and
imaginative solutions for car and bicycle parking and external
storage including bins.”” Which I think means
“”includes ombatm parking facilities for cars and
bicycles and external storage including
bins.””
|
·
Noted.
|
38
|
if
you wish to say something it is always best to keep it simple and
highlight the most important points.and don’t make a song and
dance of something that can be.said simply
|
·
Noted.
|
39
|
Many
Planning applications do not even include a Design and Access
Statement .Even if they do include a D&A statement that does
not address the criteria in the Design Guide should Parish/Town
Councillors object to the application as a result?
Though this may sound harsh for a small development such as an
extension if design information is not included then an application
cannot be adequately assessed.
|
·
Noted.
|
40
|
As
commented on already, the language here is not lay-person friendly.
‘contextual analysis’, ‘permeable hierarchy of
streets’ as well as the ones I’ve already mentioned are
all examples of phrases designed to ‘sound nice’ to
those in the know, but for this kind of guide, a clearer language
would be much more helpful. For example ‘ensure the proposal
is informed by a contextual analysis of the area’ presumably
means ‘ensure that the new structures you are proposing fit
in with the area appropriately – which means you need to show
that you have thought about both the natural and man-made features
of the surroundings’.
|
·
Noted.
|
41
|
Response
manually entered, submitted in an email format. For reporting
purposes additional text is marked as ‘xxx’ and deleted
text as *xxx*. The original submission is attached to this comment
form for reference.
CCB points in support and justification of these amendments and/or
additional details:
uses land efficiently whilst respecting the existing landscape
character, ‘’which enjoys nationally protected status
in the AONBs’’ and delivers a net gain biodiversity.
Justification: To reflect the AONB’s status.
|
·
Noted and will review
|
42
|
Response
manually entered, submitted in an email format.
In general, the Key Design Objectives are supported. However, it is
recommended that an additional bullet point is added to the list of
objectives, in order to emphasise that, firstly, the movement of
pedestrians and cycles is supported, favoured and prioritised over
vehicles movements. As a secondary point, the Key Design Objective
should favour public transport over vehicle movements.
Therefore, it is suggested that the following wording is added to
the Key Design Objectives:
“Prioritises movement on foot and bicycle first, and then by
public transport, with movement by private car being given the
lowest priority.”
In addition to this, it is recommended that the following Key
Design Objective is edited as follows:
“Ensures (add ‘an appropriate’) (remove
‘sufficient’) level of well-integrated and imaginative
solutions for car and bicycle parking and external storage
including bins”
|
·
Noted.
|
43
|
Please
change ‘is sustainable and resilient to climate change,
minimises carbon emissions and mitigates water run-off and flood
risks;’- to: is sustainable and resilient to climate change,
minimises carbon emissions from materials, construction and use and
mitigates water run-off and flood risks.
|
·
Noted and will review
|
44
|
Planning
is a very complex topic and it is challenging for a layman to
understand and factor all aspects of the design objectives into a
project. The website does well in explaining each aspect but
sometimes the explanations are convoluted and still long-winded. It
is difficult to see how a layman would factor in all aspects when
planning a project.
|
·
Noted and will review
|
45
|
The
terms “”Sustainable development”” &
“”high quality design”” needs to be
explained in a little more detail and be less vague.
|
·
Noted and will review
|
46
|
NO
DIFFERENTIATION BETWEEN DIFFERENT SCALE OF DEVELOPMENT
“For all developments” – The listed design
objectives, seem geared towards major developments. This is clear
for people who understand planning. But for someone new to planning
there’s no differentiation for different applications, as it
is quite generalised. Use of jargon which may not be understood by
some. If jargon is used, a link should be provided to the glossary
for easier use.
|
·
Noted and will review
|
47
|
Whilst
the key design objectives are clearly written, it is important that
the Councils ensure that they are written in compliance with the
National Planning Policy Framework (NPPF), and as such it is
recommended that each key design objective is reviewed in that
regard. For example, the draft ‘key design objectives’
seek to ensure that a proposal “conserves and where possible,
enhances the significance of heritage assets, e.g. listed
buildings, archaeological remains and historic features, spaces,
routes and views.” That does not, however, reflect the policy
tests set out within the NPPF; particularly paragraphs 199 to 202.
Thus, this key design objective should be updated to require a
proposal to “consider its impact on the significance of
heritage assets (e.g. listed buildings, archaeological remains and
historic features, spaces, routes and views) in accordance with the
NPPF.”
Moreover, the SPD should clearly set out how each of those
overarching key design objectives would be applied in the
determination of planning applications. Within that, it should make
clear that the role of the SPD, and thus those key design
objectives, are as guidance, rather than planning
policy.
|
·
Noted and will review
|
48
|
I
hope the definitions of public and private space are defined in a
pop up.
|
·
Noted and will review
|
49
|
It
would be good to see more emphasis on the visual aspects of
development. For larger developments the ambition to avoid
excessive uniformity of construction materials and design. Also the
need to consider the vernacular aspect, especially in rural areas
and conservation areas by using appropriate materials which blend
with the existing building landscape
We think that places that are high quality are beautiful places
where people want to live, work and visit. They allow us to carry
out daily activities with ease and offer us choice as how to do
them. In short, high-quality places enhance our lives and
wellbeing.
|
·
Noted and will review
|
50
|
The
relative legibility is very clear. However, as noted in the
submitted representations, we consider that some design principles
(including 2.1 and 4.41) should be re-worded. For example, we
consider that the wording of design principle 2.1 is amended to be
more specific than simply referring to ‘adverse
effects’. Accordingly, we consider the wording “without
adversely affecting them” is replaced with “without
acceptable adverse effects”.
In addition, design principle 4.41 seeks to ensure open space/s is
integrated as part of the natural landscape features of the scheme
and located so that residents can access them easily and directly
to provide instant ‘maturity’ as well as creating
windbreaks, visual screening and shelter. However, we consider that
there is an error in the wording of this principle and thus we
propose that design principle 4.41 should instead be worded as
follows:
‘Integrate the existing natural landscape features as part of
the scheme so that residents can access them easily and directly;
this will provide instant ‘maturity’ as well as
creating windbreaks, visual screening and
shelter.’
|
·
Noted and will review
|
51
|
But
do we agree with them? You don’t ask. Missing from the list
is being in keeping with surroundings. This is extremely important
and consultations for our Neighbourhood Plan have shown that houses
out of keeping with surrounding are extremely unpopular, but seem
to be promoted by SODC Planning Officers.
|
·
Noted and will review
|
52
|
The
key design objectives are clear, but they are an incomplete
replication of the National Design Guide (NDG), and not completely
in accordance with the NDG. The SPD should ensure that National
Design Guidance is not replicated, but that the SPD adds a layer of
relevant local detail that does not conflict with the NDG and is
reflective of adopted policy.
The key design objectives replicate the National Design Guide (NDG)
to some extent, but are not completely in accordance with the NDG.
The SPD should ensure that National Design Guidance is not
replicated, but that the SPD adds a layer of relevant local detail
reflective of adopted policy.
The key design objectives replicate the National Design Guide (NDG)
to some extent, but are not completely in accordance with the NDG.
The SPD should ensure that National Design Guidance is not
replicated, but that the SPD adds a layer of relevant local
detail.
|
·
Noted and will review
|
53
|
Please
see submitted letter for full comments.
|
·
Noted.
|
54
|
These
seem to be a fair and comprehensive set of general
principles.
|
·
Acknowledged
|
55
|
The
sustainability angle is not clear. Mitigation of climate change
means reducing greenhouse gases. Resilience is about adaptation.
Mitigation requires development to be zero carbon in construction
and Passivhaus in operation. Resilience means safe from hot summers
(70,000 died in a few days in 2003 across Europe) through shade,
exceptional insulation, and usable ventilation. It means safe from
flood which means nowhere near a floodplain or where surface runoff
could happen. Safe from extreme storms means in a sheltered
place.
There should be consideration of the future-world of non-private
ownership of cars, with access to world-class public transport, and
shared car clubs. Walking and cycling should take precedence over
motorised transport and be completely safe. EV chargers should be
available for the shared cars.
|
·
Noted and will review
|
56
|
The
design guide is understandably oriented towards the mist common
types of planning applications. But given the toidal wave of
(screening) applications for solar power stations, often on good
quality agricultural and and/or green belt Council ombatm the dsign
guide should also address applications of this type, including
their cumulative effects
|
·
Noted and will review
|
57
|
Get
external lighting right – the right light, in the right
place, at the right time, for the purpose required.
|
·
Noted.
|
58
|
Response
manually entered, submitted in an email format.
o Example: The section on key design objectives starts with noting
the requirement for a contextual analysis of an area. It goes on to
include references to green and blue infrastructure, permeably
hierarchies of streets, uses terms such as density, grain, massing,
etc. All of these terms are meaningless to most of the public and
new Councillors.
|
Noted.
Terms will be added to glossary of terms as necessary. We have
tried to move away from jargon and make the guide accessible and
easy to understand for all audiences.
|
59
|
The
key design objectives are clear, but they are an incomplete
replication of the National Design Guide (NDG), and not completely
in accordance with the NDG. The SPD should ensure that National
Design Guidance is not replicated, but that the SPD adds a layer of
relevant local detail that does not conflict with the NDG (or Local
Plan policy requirements).
|
Noted
and will review. The Design Guide is aligned with the National
Design Guide. Further detail and design principles that go beyond
the National Design Guide can be found throughout the sections of
the Design Guide.
|
|
Comments
|
Council’s
response
|
1
|
Couldn’t
access them on my ipad!
|
·
Noted and will review
|
|
2
|
Too
many pictures, graphics and interactive maps
|
·
Noted
|
|
3
|
Interactive
maps are useful for those who do not have the suitable IT access.
Aside from this, helpful.
|
·
Noted and will review
|
|
4
|
Really
rather childish. Be clear with your descriptions and gimmicky
little pictures and interactive graphics should not be
necessary.
|
·
Noted
|
|
5
|
It
would be nice not to have spelling mistakes in your
presentation!
|
·
Noted and will review
|
|
6
|
It
highlights important areas if you want more information
|
·
Acknowledged
|
|
7
|
Give
a good understanding of what is meant to happen
|
·
Noted and will review
|
|
8
|
It’s
much better designed and presented than most of the developments
around here.
|
·
Acknowledged
|
|
9
|
The
existing Vale design guide is very clear, and yet in Faringdon we
see multiple large developments being approved which skip the
guidance . A cursory look at multiple exits and entry suggestions,
space for growing food, movement framework, etc. shows there is
little point in making new guides, if the implementation of
existing guides is so poor. If the same people and processes are at
work in the approval process, there is no point in investing in new
guidelines.
|
·
Noted
|
|
10
|
Your
graphics are amateur they remind me of small child writing z
Christmas list no chance of achieving any but wrote down
regardless
|
·
Noted
|
|
11
|
none
of the above replace a static design with models and for the public
to view
|
·
Acknowledged
|
|
12
|
I
found the use of pictures from outside our two districts
disappointing and unnecessary. There were at least a dozen, mainly
in the built environment sections, of which 4 were from the same
village in Northampton!
|
·
Noted
|
|
13
|
No
comment.
|
·
NA
|
|
14
|
the
interactive maps don’t work though so i am only really
guessing here that if fully functional then they will be
helpful.
i don’t know why the maps don’t then also also links to
conservation area apprasials and neighborhood plans
if they don’t this is only half the point isn’t
it.
thoroughness is ombatme isn’t this supposed to be a one stop
shop?
|
·
Noted and will review
|
|
15
|
some
of the layouts show cars having to reverse out of drives –
contrary to the highway code -
The air source heat pump picture next to figure 58 is appualling
design.
A lot of the pictures showing timber cladding show the buildings
after recent construction – there is a need to maintain
timber cladding which doesn’t really happen causing the
building to look tired very quickly two good examples is the Law
school building Durham university – when built looked great
– it now looks tired and uncared for. The same for the Queen
Alexandra College of the Blind sports hall – now looks
unkempt due to the lack of maintenance of the timber cladding. NB
you need to clean the cladding with high pressure water (and
chemicals) not very eco friendly.
The pictures on the whole give a white middle class
feel.
|
·
Noted and will review
|
|
16
|
The
first map of the area was far roo small, could not see it at
all
|
·
Noted and will review
|
|
17
|
Dont
work on tablets that well
|
·
Noted and will review
|
|
18
|
Thank
You
|
·
Acknowledged
|
|
19
|
Really
like the look and functionality of the graphics.
|
·
Acknowledged
|
|
20
|
The
basic drawings aid nothing on the extensions, they give far too
much leeway for planning officers to reject based on their own
bias. There should be more photos of architectural aspects that
will be treated more favourably/ unfavourably. There should be more
detailed advice so that decisions are objective and not
subjective
|
·
Noted and will review
|
|
21
|
Overall
design, layout and structure – excellent
|
·
Acknowledged
|
|
22
|
Where
is the draft design guide?
|
·
NA
|
|
23
|
Too
much text is overwhelming, and difficult to understand.
The use of graphics helps show things in a simple, clear way. I
appreciate them , and think they are essential.
|
·
Acknowledged
|
|
24
|
Working
through the guide was not clear – the buttons on the side
were not obvious.
|
·
Noted and will review
|
|
25
|
The
little logos and symbols that occur every now and then are frankly
irritating – they don’t yet tie in with any of the
arguments or provide any key. If clearer, explained, and used as a
key to help identify strands of argument, they would be more
useful. The maps are very good, as in the old SODC guide, but the
interactive labels don’t always make a particularly useful
point. The captioned photos are helpful – would it be
possible to keep to examples within the districts so as to maximise
relevance?
|
·
Acknowledged
|
|
26
|
keep
them clear and simple not complex; they don’t need to be
‘arty ‘; font size 14 or 16 so they can be
read!!
|
·
Noted and will review
|
|
27
|
Haven’t
found them yet – Didn’t open when requested,
|
·
Noted and will review
|
|
28
|
The
images provided a useful context to associated sections of the
document, and provided some interesting relief to what would
otherwise be a purely textual presentation.
|
·
Acknowledged
|
|
29
|
Certainly
worth including.
|
·
Acknowledged
|
|
30
|
Comments
put forward for consideration.
To trial and test the pracalities on the new drawing design
elevations and the interactive mapping process:-
1. How does it work when submitting planning applications? Is there
a step by step guide for applicants to follow?
2. Do applicants simply forward on their drawing elevations (
normal format followed as in previous in years) to the Vale’s
Planning Team. The team will converts the static drawings plans
received into an interactive format? Or will it be the
responsibility of the applicant/applicant’s agent before
proposed plans are to be submitted to the Vale Planning
Team?
|
The
Design guide itself is an interactive guide, with drawings and
diagrams that can be interacted with to provide additional
information.
This is a feature of the design guide
website.
We are not suggesting applicants submit interactive drawings or
content as part of a planning application.
|
|
31
|
It’s
really beneficial to be able to see not only the maps of South and
Vale to identify all of the different settlements, designations and
landscape charters, but also what that might look like within the
context of a town (e.g. figure 1, place and setting). The
definitions of, for example, flood zones and conservation areas on
the interactive parts of the maps would certainly be beneficial to
anyone looking into where to develop.
|
·
Acknowledged
|
|
32
|
Some
of the pictures and drawing need some text to explain the icons
used – its not always clear what they mean
|
·
Noted and will review
|
|
33
|
There
are some good bits but much of the material is
pedestrian.
|
·
Noted
|
|
34
|
The
diagrams, pictures using captions would be a good way to present if
they included the right things
|
·
Noted and will review
|
|
35
|
Subject
to their relevancy. There are different dynamics in rural
areas.
|
·
Acknowledged
|
|
36
|
Some
of the diagrams need rationalising.
The pictures are nice but help much to the understanding of the
document.
|
·
Noted and will review
|
|
37
|
I
have missed them but all that stuff helps
|
·
Noted
|
|
38
|
A
picture is worth 1000 words!
|
·
Acknowledged
|
|
39
|
A joy
to use, in spite of some hiccups here and there….will be
ironed out eventually
|
·
Acknowledged
|
|
40
|
Even
after reading the instructions I forgot I could click on crosses on
the interactive maps. I think maybe the icon needs to be red? Also
a ‘X’ to close them would be more intuitive than a Back
arrow.
|
·
Acknowledged
|
|
41
|
For
those of us not contributing as build and design professionals a
caption is worth a great deal.
|
·
Noted and will review
|
|
42
|
I
think you are in danger of making it a bit over simplistic. There
is a fine balance to be attained in what is fundamentally a topic
that requires some expert knowledge.
|
·
Noted and will review
|
|
43
|
The
navigation isn’t intuitive. I thought it ended at one page.
Now I see the coloured dots on the right help me navigate. Now that
I see the whole thing, very impressive.
|
·
Acknowledged
|
|
44
|
1. A
map is required of the likely flooding area from a weather event in
the Thames Valley similar to that experienced in 2021 in North
Germany.
2. Diagrams of living walls should be included alongside diagrams
of trees.
|
·
Noted and will review
|
|
45
|
All
plans need to show not only the particular site of the proposal but
also its impact on surrounding areas….and developments not
yet included but which will be consequent on the proposal. Pretty
pictures of shrubberies lining walkways rarely give realistic
impressions of how tawdry such places can become. The presentation
of development and design proposals has become a skilled art, into
which large sums of money are invested with PR companies. These
plans and displays can be as misleading as they are helpful, and so
Local Authorities should establish clear codes as to how these must
be composed.
|
·
Noted
|
|
46
|
Some
photos were excellent e.g. Swales at Upton that demonstrate how
SuDs can contribute towards biodiversity gain in larger
developments. However, some of the drawings and diagrams although
clear were in fact contrary to sustainable development e.g.
diagrams showing dormers that apparently enhance the building
ascetics but have a devastating impact on building energy
efficiency and ability to install solar panels on roofs.
|
·
Noted and will review
|
|
47
|
-
Diagrams are helpful to cut and paste to applicants and agents as
examples
- Officers liked the red, amber, green diagrams – but the key
needs to be underneath or more clearly outlined so it cannot be
missed
- Photos are helpful, but it would be good to have more examples
from across both Districts. Officers felt that the photographs
provided were very South-heavy
- Photos of more contemporary design would be helpful (like Photo 3
under BUILT FORM)
- Some of the infographics (for example under ‘About South
& Vale’) seem to take up a lot of space. Is there a
different way to present these?
|
·
Acknowledged
|
|
48
|
This
is a much clearer way of setting out the guidance than using a
printed report. It is easy to focus in on the key issues that apply
to a development.
|
·
Acknowledged
|
|
49
|
Whilst
the interactive maps are helpful, it should be made clear where
interactive maps represent guidance, and where they are
demonstrating how the design principles could be applied within a
live development scheme.
Using Figure 3 within the ‘Natural Environment’ section
as an example, it is not clear whether Figure 3 is seeking to
highlight how a potential applicant could respond to a site’s
constraints and the design principles, or whether the responses
highlighted (i.e. “retain characteristic hedgerows where
possible and Important Hedgerows”) should be taken as
guidance in itself. Whilst it would appear in relation to Figure 3
that those annotations are seeking to demonstrate how the guidance
could be applied when analysing opportunities and constraints
within a site, that should be made clearer within the captions to
each figure. If it is the case that the annotations are guidance,
however, then they should be included within the main body of the
text, rather than within the interactive graphics where they may be
overlooked.
|
·
Noted and will review
|
|
50
|
The
pop up texts should be accurate and concise.
|
·
Noted and will review
|
|
51
|
It
was not entirely clear that much of the information provided in the
maps, drawings etc were really relevant to someone wishing to
understand the Design Guide in order to try to comply with
it.
|
·
Noted and will review
|
|
52
|
We
consider that some of the maps could be more interactive. For
example, we consider the landscape character map for South and Vale
would be clearer/easier to understand if it were to include the key
settlement locations on the map.
The graphics within the document are generally clear and show good
examples of what developers and consultants should be aiming
for.
|
·
Noted and will review
|
|
53
|
Need
to use local examples of high density developments. So many
developments are for individual householders, but most pictures
shown are for large scale developments.
|
·
Noted and will review
|
|
54
|
The
pictures, drawing and diagrams could be helpful if better
explanation were given on what they are supposed to represent and
what we are supposed to glean from them. There is not enough
explanation.
Interactive maps, are not very interactive. Again could be greatly
improved and more useful.
|
·
Acknowledged
|
|
55
|
It
should be made clear when the interactive elements are providing
guidance (or referencing national guidance), or are referring to
adopted policy.
|
·
Acknowledged
|
|
56
|
Please
see submitted letter for full comments.
|
·
Review supporting document
|
|
57
|
When
one can locate these, they are very helpful! However, there need to
be titles against the bullets on the righthand side of the
front/header page of the Guide (one has to hover the cursor over
them before realising they actually ARE links, and not simply a
graphic embellishment of the page!) The link titles should be
clearly visible at all times, not just when the cursor is over the
bullet.
|
·
Noted and will review
|
|
58
|
should
have more pictures of good design rather than the current emphasis
on interactive ombatmentnal drawings
|
·
Noted and will review
|
|
59
|
It
should be made clear when the interactive elements are providing
guidance (or referencing national guidance), or are referring to
adopted policy. The comments are potentially confusing as some seem
to introduce new policy, whereas others provide guidance (see
below).
|
·
Noted and will review. The text provided within the interactive
plans are only providing further clarification or information on
what needs to be considered as part of a development proposal. We
will clarify this in the introduction.
|
|
|
|
|
|
|
|
|
Comment
|
Council’s
response
|
|
|
|
1
|
Too
many words.
Too many pages.
Too many concepts.
Too much everything.
You get the idea.
The guide is too elaborate and lengthy.
Nice concept.
Poorly implemented.
|
·
Noted.
|
2
|
The
vast majority of applications do not require an opportunities and
constraints plan, nor a concept plan nor a regulating framekwork
plan. The design guide should reduce the workload of officers by
ensuring that applications are acceptable when submitted, not
increasing their workload by forcing them to review more useless
information. Further, this has nothing to do with small scale
development such as householder/minor applications and this is not
made clear within the design guide.
|
Noted.
We believe good design no matter the scale requires an
understanding of the context. A constraints and opportunities plan
gives the applicant to consider all of the issues before developing
a design rationale.
|
3
|
The
context should be viewed as the limited natural environment that
surrounds the city of Oxford; the heavy pollution generated by the
desire to build new homes; the waste and damage to nearby locations
and villages during construction; the provision of adequate local
infrastructure and the dame to local roads from heavy
lorries…the list is endless. Your document addresses none of
this. None of this is new development should be undertaken on Green
Belt; the views of local people are being ignored.
|
·
Noted.
|
4
|
Although
setting and context are mentioned, there is no mention of
proximity, effect on the neighbours and neighbourhood, or
overcrowding and over development,
|
·
Noted.
|
5
|
Yes,
here’s the problem with ALL your efforts when trying to
provide a plan. There is no clear way to identify what one is
looking at. Overlay a street map and it might be
meaningful.
|
Noted.
The plans provided are an example and not specific to a
location.
|
6
|
Very
clear and thorough
|
·
Acknowledged
|
7
|
These
are all well and good on paper but it is the longer term
infrastructure of the site that really needs consideration. The
potential changes to existing and surrounding housing stock is just
as important as the development – ie building on flood plain
or not giving due consideration to future matters is not something
you will see on any place and setting design principles.
|
Noted.
The Design Guide cannot go beyond the framework of the Local
Plans.
|
8
|
One
factor often overlooked is the impact of pets on the local
environment. Where developments are near SSSIs measures should be
imposed to limit this impact.
|
Noted.
This is beyond the remit of our design guide.
|
9
|
The
existing Vale design guide is very clear, and yet in Faringdon we
see multiple large developments being approved which skip the
guidance . A cursory look at multiple exits and entry suggestions,
space for growing food, movement framework, etc. shows there is
little point in making new guides, if the implementation of
existing guides is so poor. If the same people and processes are at
work in the approval process, there is no point in investing in new
guidelines.
|
·
Noted.
|
10
|
I
like the ideas that you are promoting but know that developers will
find all the loopholes and mercilessly exploit them to maximise
their financial return. Don’t be discouraged.
|
·
Noted.
|
11
|
we
are still building red brick homes that look like “”an
army camp”” The rest of the world have moved away from
bricks and old designs. We need homes to reuse rain water , have
solar panels and perhaps community orchards and allotments for
people to grow produce.
when a group home for the elderly is built , please make sure there
is a ombatm outlook for them to see outside their windows. Not
shops schools and busy traffic interchange as GWP Didcot
|
·
Noted.
|
12
|
There
is no reference to guidance contained in Neighbourhood Development
Plans or the importance of Registered Historic Parks and Gardens or
Undesignated Heritage Assets. These are all important elements of
place and setting and should be integrated with the
text.
|
·
Noted and will review
|
13
|
Many
villages and towns have local and neighbourhood plans. These should
surely be the basic reference point for developers. I looked in
vain through this document for any references to them.
|
·
Noted and will review
|
14
|
Please
see previous comments.
|
·
Noted
|
15
|
To
keep devopments in keeping with other local houses
|
Noted.
Understanding the context and drawing from the local vernacular is
an important part of this section.
|
16
|
it
needs breaking down to the scale of the development.
if you are buldiong single house this section is really not
helpful
it needs more clarity of direction of the sections to use dependent
upon the proposal
it is far too one size fits all. One size fits none at all in terms
of this section.
|
·
Noted.
|
17
|
concern
that the principles may be used by officers without an ability to
discern intuitive and skilful design innovation
|
Noted.
Officers will receive training once the Design Guide is
adopted.
|
18
|
I
think it would be good to include sport England’s Active
Design Guidance in this document: https://www.sportengland.org/how-we-can-help/facilities-and-planning/design-and-cost-guidance/active-design
Active Design is a combination of 10 principles that promote
activity, health and stronger communities through the way we design
and build our towns and cities.
That’s why we, in partnership with Public Health England,
have produced the Active Design Guidance which works as a
step-by-step guide to implementing an active environment.
This guidance builds on the original objectives of improving
accessibility, enhancing amenity and increasing awareness, and sets
out the 10 principles of Active Design.
|
·
Noted and will review
|
19
|
Ensure
any development preserves the natural environment as much as
possible
|
·
Noted.
|
20
|
New
developments should not spoil views.
|
Noted.
Both place and setting and natural environment sections of the
guide have regard to views beyond the red line plan.
|
21
|
Seems
to be slightly negative attitude to hedgerows….’worthy
of retaining’ and ‘low quality ombatme’ marked.
Should attitude be ‘save all hedgerows where possible’
and ‘hedgerows to make premium by planting to provide
wildlife bird/bat corridors’.
Hedges should be kept on estates between house not just bulldozed
before estates built like Vale developers being allowed to
do.
|
·
Noted and will review
|
22
|
The
Guidelines are good, concerning how to go about he identification
of visual/physical assets and detractors. They should help
developers to progress their proposals on how to enhance those
assets where possible and to diminish/possibly eradicate the
constraints/detractors (some are not possible, e.g. existing
pylons!). Again the search of perfection can be the enemy of the
‘good’ or even the ‘better’ this
time.
|
·
Acknowledged
|
23
|
Seem
comprehensive.
|
·
Acknowledged
|
24
|
Biased
towards developers, create a summarised version for
householders
|
·
Noted.
|
25
|
please
add in under For All Developments reference to registered parks and
gardens and their settings
Second para Developing a Design Rationale please add in in
reference to registered parks and gardens
|
·
Noted.
|
26
|
Excellent
– really clear and easy access to relevant
documents
|
·
Acknowledged
|
27
|
The
design principles indicated should; enhance appearance of the area.
Provide an attractive place for the inhabitants to live inside the
buildings and in the area around. Provide opportunities for folk to
exercise and enjoy the outside. Adequate parking and play
space.p
|
·
Noted.
|
28
|
Would
like to see reference to Neighbourhood Plans
|
·
Noted and will review
|
29
|
well
i think to houses being build we need primark in didcot more
carparks
|
·
Noted.
|
30
|
There
is no mention of the sounding environment; how sound heritage can
be preserved; how sound pollution and noise is experienced in the
settings. More experiential data is required.
|
·
Noted and will review
|
31
|
I am
fully in agreement of characterizing the local area before making a
definitive plan for new developments.
Everything in the guide makes sense and should help to ensure
developments are appropriate for the location and enhance the area
rather than being detrimental to existing communities.
|
·
Acknowledged
|
32
|
Vital
– a good example of importance is how the new development in
Benson completely fails – too many similar design that
don’t enhance the village. Creating a very separate an
unintegrated community.
|
·
Noted.
|
33
|
Not
naming roads or area doesn’t help identify areas intended for
greening or development.
|
·
NA.
|
34
|
Overwhelmingly
directed towards major greenfield development.
|
·
Noted.
|
35
|
Excellent
|
·
Acknowledged
|
36
|
fine
|
·
Noted.
|
37
|
The
new Barton estate off the northern by pass certainly does not come
anywhere near design principals. The whole development is an insult
to the historic city of Oxford.
|
N/A.
Barton Park sits outside our districts.
|
38
|
People
will need garages close to there house to be able to charge
electric cars in the future.
|
·
Noted.
|
39
|
It is
important to consider whether previous designs, such as a bypass
should continue in order to e.g. prevent congestion or pollution
within an existing built community. It is important to consider
whether removal of this aspect will be detrimental to the
community.
It is important to recognise the unique aspects of a rural
community; it should be treated differently from that of towns and
cities. The unique character of a rural community should not be
changed.
It might be preferable to write the principles in bullet points
and/ or emphasise key words in bold or italics.
|
·
Noted.
|
40
|
These
design principles are signposted and set out clearly- it packs in
very nicely what must be considered for a contextual
analysis.
|
·
Acknowledged
|
41
|
It is
good to see that the guide mentions protecting important views and
landscape character, avoiding building in prominent places or
ridge-lines and emphasises that development must fit in with the
local area.
|
·
Acknowledged
|
42
|
no
reference found to the role of neighbourhood plans in place and
setting
|
·
Noted and will review
|
43
|
“”The
density of a development must reflect the character of the
surrounding area. Densities should vary across the site, with lower
densities towards the countryside edge. This can help to provide a
transition between existing built-up area and the open
countryside.”” I think this is in this section although
since the document which cannot easily be searched, I’m
struggling to relate my comments to the appropriate parts of the
document. The above sounds sensible but where a relatively low
density has been provided for this reason, that lower density
should be protected. I cannot find anything in this policy which
makes this point clear.
|
·
Noted.
|
44
|
We
agree that emphasis should be on local rather than national. Plus
to take account of the fact that South and Vale are predominantly
rural in nature which has to take precedence over the National
Design Principles.
|
·
Noted.
|
45
|
Probably
appropriate for a large-scale housing development (ombatm
it’s still overly complex and wordy – more suited to
drawing uo an outline of auturistic science-fiction novel) but not
very applicale to an application for an extension.
|
Noted.
Note that all principles in the design guide are applicable to all
scales of development.
|
46
|
I do
not go much on rowen atkinsons .the comedian/mr bean. Place near
ipsden.to me a traditional Manor House would be a much better
building for the country side.the Italians have buildings that are
as old as the hills with all new tech inside.thats what you
need
|
·
Noted.
|
47
|
The
design should enhance the character of its setting.
|
·
Noted.
|
48
|
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
|
·
Noted.
|
49
|
All
very laudable and it would be good to see this
implemented.
|
·
Noted.
|
50
|
My
only comment is that there was one map….interactive
conservation area map…. which when I clicked on Drayton it
came up with an old map. Eg. It missed out certain buildings, like
garages or extensions, and included land in some gardens which are
inaccurate.
|
·
Noted and will review
|
51
|
At
the bottom of this section it suggests using various documents to
‘support your design’, including conservation area
appraisals. There is no mention of neighbourhood development plans,
where these are adopted (and there are many throughout the Vale and
SODC). These NDPs have already done much of the specific work that
the design guide is asking for, so should definitely be mentioned
as a source of information.
|
·
Noted and will review
|
52
|
We
have no specific comments to raise in this section which follow
well established principles of good design.
|
·
Noted.
|
53
|
Again,
some of the language is too ‘high’. What does
‘move away from notional character areas.’ Mean? It
doesn’t mean anything to me! ‘ Create a narrative
around place-identity’ sounds to me like you are encouraging
people to make up fanciful types of justification for their designs
rather than actually understand the history of a site.
‘Narrative’ is, I think, the dangerous word in this
sentence as it implies storytelling as opposed to true
use/incorporation of historical or important local features. I
would say you probably need to get someone who is used to writing
for the lay public to sit down and help put this into more useful
language for the site as at the moment I think it’s in danger
of encouraging the kind of faux marketing that you probably want to
discourage as much as everyone else hates it (where things get
called ‘the old dairy’ etc even when it never was a
dairy!)
|
·
Noted.
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54
|
Response
manually entered, submitted in an email format. For reporting
purposes additional text is marked as ‘xxx’ and deleted
text as *xxx*. The original submission is attached to this comment
form for reference.
In the table we recommend the addition of the
‘’Chilterns Buildings Design Guide’’
‘’Fig 1 ‘typo’ ‘’ views towards
the site from the ‘’AONB.’’
Any statutory designations such as National Nature Reserves, AONBs,
Green Belt, and SSSIs amongst others, and non-statutory
designations such as Ancient Woodland, Dark Skies
‘’valued landscapes’’ and Registered
Battlefields, amongst others;
Justification: landscape as mentioned in the NPPF and new guidance
produced by the Landscape Institute (2021).
|
·
Noted and will review
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55
|
Response
manually entered, submitted in an email format.
Space and Layout
Plots and Amenity
A number of amenity parameters are set out in the Draft Joint
Design Guide, including proposed back-to-back distances of 21m,
distances of 12m for back to side distances, and 10m front to front
distances. Such specific requirements are very restrictive and
could preclude the delivery of higher density, well designed
developments.
In some cases, it may be necessary to reduce the distance between
front-to-front distances down from 10m, for example. This would
assist in creating high quality and attractive environments for
pedestrians and cyclists. In such circumstances, consideration
would of course have to be given to the distances between the
windows of habitable rooms for privacy and amenity
reasons.
In addition to this, it is noted that 21m offset distances from
back-to-back of dwellings is excessive, as often residential
gardens do not exceed 10m in length in a typical medium density
development.
Accordingly, our views are that the inclusion of back-to-back, back
to side and front to front offset distances between dwellings in
the Draft Joint Design Guide is too prescriptive. Such requirements
are likely to limit the delivery of higher density areas within a
development and would also limit the ability to deliver innovative
and high-quality designs. The offset distances should be removed,
so that a more flexible approach can be adopted enabling ,
applicants to put forward high quality and innovative designs,
which should be considered on a site-by-site basis.
Design Principles – Private Amenity
Concerns are raised about the prescriptiveness of the standards
outlined, but also the fact that there does not appear to be a
logical increase in the minimum garden space based on the increase
in the size of the dwellings.
Consequently, it is recommended that the following amendments are
made:
• For detached, semi-detached and terraced dwellings, it is
recommended that the standard should be amended for gardens to be a
minimum of 50% of Gross Internal Area (GIA).
• For apartment buildings, it is unclear as to whether the
40sqm proposed is per apartment. It is recommended that this is
amended to be a total of 10% of the GIA per apartment, which can be
provided either through balconies or through a mixture of balconies
and communal spaces where necessary. It is important to retain
flexibility to enable and promote a high-quality design
approach.
Parking Strategy and Solutions
It is acknowledged that Oxfordshire County Council are considering
parking standards for new developments, particularly for the edge
of Oxford sites. The proposals contained within the Draft Joint
Design Guide need to be assessed against and prepared in
conjunction with emerging standards. This is necessary to ensure
that the Draft Joint Design Guide moves towards lower car usage and
ownership, in accordance with emerging policy.
Storage, Servicing and Utilities
Whilst the Draft Joint Design Guide refers to the need for cycle
and bin storage for dwellings, it does not provide any
clarification on the standards required (size of storage,
specification), or the desired location of such storage
arrangements for various types of dwellings. This section would
benefit from providing additional clarification and advice to
assist applicants when preparing future planning
applications.
|
·
We are seeking to update the images to ensure they are
relevant.
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56
|
Response
manually entered, submitted in an email format.
4. The Guide should allow local features such as the vernacular to
be included.
7. The Guide should recognise the impact of flooding
including:
- need for water absorption to reduce fast run-off (eg reducing
tarmac area; water butts; individual house rain soakaways)
- need to retain existing waterways and flood areas to continue to
serve built development.
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Select:
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57
|
This
is very important to preserve the character of the local area,
especially as we live is arguably one of the most beautiful areas
in the country. Any design and planning principles should ensure we
preserve while also making it possible to develop and plan for the
future. This is a very general section and is an excellent starting
point, however it would be really useful to have more detail on the
areas that are really critical and important to the local area.
Please see comment on next section around the installation of solar
panels in homes or large scale solar farms.
|
·
Noted and will review
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58
|
I’m
unsure where to place my overall comment. It’s about design
and therefore setting of renewable energy facilities, such as solar
farms, eg can they be sited in Green Belt land? If we could include
that subject in the appropriate sections of the design guide, it
will help in the medium to long term, but also immediately as
applications for solar panel sites are coming forward.
Heritage)
|
·
Noted and will review
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59
|
Place
and setting: Inform your design:
Please change: ‘Technical studies including (but not limited
to) surveys on landform, watercourses, trees, habitats, species,
flood risk mitigation and drainage.’ – to: Technical
studies including (but not limited to) surveys on landform,
watercourses, trees, habitats, species, production of food, natural
carbon sequestering, flood risk mitigation and drainage.
Design principles -
Please change the following:
1.0 Existing networks of natural features, including land used for
agriculture, watercourses, trees, woodland, hedgerows, green
spaces, field patterns, habitats and public rights of way
(footpaths, bridleways, etc.);
1.4 Any statutory designations such as National Nature Reserves,
AONBs, Green Belt, and SSSIs amongst others, and non-statutory
designations such as Community Led Plans, Ancient Woodland, Dark
Skies and Registered Battlefields, amongst others;
1.5 Potential barriers to development such as railway lines, major
roads, utilities, pipelines, noise, pollution, land contamination,
flooding, lack of drainage capacity etc., and any resulting
easements including those specified in the Local
Plan(s);
|
·
Noted and will review
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60
|
Whilst
generally comprehensive, there does not appear to be any specific
mention of the significance of the wider landscape setting of the
City of Oxford, which extends into both the Vale of White Horse and
South Oxfordshire District Councils. Key views into the city, and
from the city out into its wider surrounding green setting are
available to both the south and west, including the western hills
including Harcourt Hill and Boars Hill. To the south, the wider
setting on Nuneham Park provides views into the City from the
South. Due to its high sensitivity, the wider green setting should
be specifically mentioned to ensure it is identified and
highlighted as an area of significance and extra
protection.
Reference should also be made to undesignated heritage assets, as
these can also be important buildings that could positively
influence the setting of new development.
|
·
Noted and will review
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61
|
As
the Guide says, the contextual analysis is essential, both within
the site and beyond its boundary. It must be sensitive to history,
but also honest about possible future implications. Designs must
clearly indicate further expected developments which would impact
the wider neighbourhood, which are probably consequent on
permission being obtained although not yet included specifically
within the permission sought. These may be their own development
plans, but also plans being promoted by other
developers.
|
·
Noted.
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62
|
Most
of this section is To date, planners have favoured attempts to
proposals being “”in-keeping”” with the
architectural character of the surrounding settlements/buildings.
All this means in the Chilterns, is that flint stone material is
predominantly imported from France which demonstrates how visual
design over-rides both common sense and environmental impacts.
Materials that were used hundreds of years ago might not
necessarily be the best material to use today and this needs to be
reflected in the design guide. Why not favour new materials or new
biophilic design that promote both biodiversity and/or low embodied
energy and/or zero cars? Where are the photos etc that provide
examples of this more environmentally orientated approach to
development? If developers are having to create all their new
developments so that they vaguely resemble the historic surrounding
architecture with fake chimneys etc, how will this help the region
have new developments that actually address climate change and lost
of biodiversity? This won’t be achieved with fake chimneys
made from fibreglass!
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·
Noted and will review
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63
|
FORMATTING:
Needs a chapter number for reference. Could an interactive mini
contents list be included under each chapter title/heading for
easier navigation? Principles should really be first, and then
follow up with explanation text, diagrams and helpful links
below.
DIFFERENTIATION: Would be good to highlight that principles are
perhaps more appropriate for Majors & Minors applications,
rather than householder development?
|
·
Noted and will review
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64
|
Very
clearly explained.
We agree that the emphasis should be on local rather than national
design issues. It is essential that the rural nature of the
Chilterns and its setting are fully taken into account in planning
decisions.
|
·
Noted.
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65
|
No
comments.
|
·
Noted.
|
66
|
No
mention of Neighbourhood plans where place and setting information
will be in much greater detail. Topography might have to be
explained in a pop up.
|
·
Noted and will review
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67
|
We
felt this section captured very well the ambitions for Place
making
|
·
Acknowledged
|
68
|
Please
refer to submitted representations.
|
·
Noted
|
69
|
No
comments
|
·
Noted.
|
70
|
It
would be useful to have a form for the Character Assessment, so all
the relevant aspects can be properly considered and included. The
City of Oxford has a proforma for this with scores. This is very
helpful and should be included in the guide.
Much more emphasis must be placed on the character of other
houses/buildings nearby so it can be in keeping and sympathy and
not an eye sore that clashes.
|
·
Noted and will review
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71
|
Response
manually entered, submitted in an email format.
The approach to place and setting is logically presented, and
outlines the main matters to be considered as part of any
contextual analysis. We do note that this section is not as
detailed as corresponding guidance in the National Design Guide,
and as highlighted above, it would be helpful to understand how the
Councils propose to use the Joint Design Guide (and potentially
other national design guidance) when assessing schemes.
|
·
Noted and will review
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72
|
The
Place and setting chapter is better in that it does take note of
existing green areas within and around a site. It also makes
reference to Extended footpath links through the development and
integrating pedestrian and cycle links although there is no mention
of how these routes might connect with the wider world. This comes
in the Movement and connectivity chapter. (One of the main faults
with the preliminary Chalgrove strategic site designs I saw which
had cycle and pedestrian routes within the site but no provision
for cycling to anywhere else useful.) So I am really pleased to see
these points:
1. Provides direct pedestrian and cycle links to local services and
facilities that follow natural desire lines and uses the features
identified in the opportunities plan to create visually interesting
and attractive routes;
2. Maintains priority for pedestrians and cyclists, designing
people-friendly spaces;
3. Locates facilities and services within a short walking distance
of homes (800 m) and provides easy access for existing and new
residents;
4. Provides bus stops within a five-minute walk (400m) of homes, is
preferably 600m from a primary school and 1500m from a secondary
school, and where possible, close to local services and
facilities;
Actually most of the points highlighted in this chapter look pretty
good to me so it will be interesting to hear what others say about
them! I would just add one more point, 3.32, from a sustainability
point of view to the section on
1. Ensure that public art commissioned in any new
development:
2.
3.
And that is to make sure there is a maintenance programme in place
for whatever is put in. I have noted the sorry state of some pieces
of public art (eg pieces on the Phoenix Trail and those in the
Sculpture park in Cowleaze Wood) whose installation I can remember
in the 1990s.
|
·
Noted and will review
|
73
|
Response
manually entered, submitted in an email format.
Place and Setting (Design Principles – (Place and
Setting)
This section of the Design Guide requests that a document setting
out the contextual analysis is prepared to identify the local
character and wider context of the application site which considers
the settlement, landscape, biodiversity, streets etc.
Gladman do not object to the principle of this document, or the
steps proposed. However, it is considered that this information is
often included in other application documents including
‘Design and Access Statements’. Therefore, it may be
prudent to provide further flexibility within this guidance to also
allow for the contextual analysis to be delivered and undertaken
through other documents which support an application.
|
·
Noted and will review points individually
|
74
|
As
this is a SPD and not policy (and should therefore clarify the
policy, rather than adding further policies) the document should
state that development schemes which seek to follow the principles
set out will be supported, rather than stating that applicants
should “ensure” that a scheme adheres to specific
principles.
GOAL: Identify the site’s features and its context
The text is helpful in identifying some of the issues that might be
relevant in assessing a site’s features and its context. It
is helpfully made clear that the assessment will vary depending on
the site and the proposals, except for one sentence. ‘This
should consider the structure and history of the settlement and
landscape within which it is located or relates to, the character
of the landscape, biodiversity, the streets and spaces and the
built form (all of these elements constitute local
character)’. This sentence should be moved towards the end of
the third paragraphed and re-phrased to say ‘The contextual
analysis is likely (amongst other issues) to consider the structure
… local character)’. GOAL: Use the site’s
features and context to shape your design
This section provides clear advice. The sentence ‘Do not
tightly define character area boundaries but make sure to have a
gradual transition between them. Focus on the character of the
streets/area as a way of creating attractive and defined
space’ should be removed as this is unnecessarily
prescriptive.
STEPS: Communicate your design
A sentence should be added to at the start to indicate that
requirements will vary depending on the proposals. We suggest
‘the communication of your design will depend on the extent
of your proposals, but is likely to include the need for:
-
An opportunities and constraints plan;
A concept plan
An illustrative layout
Other drawings might include (for example) cross sections or a
regulating framework plan for larger proposals. A clear Key is
required for each drawing.’
|
·
Noted
|
75
|
Please
see submitted letter for full comments.
|
·
Noted and will review
|
76
|
This
section fails to mention the existence of neighbourhood plans, many
of which have policies – often quite detailed – on
design of new developments. We think it is a serious omission that
applicants are not asked to look carefully at what their local
community has adopted as policy on design. Can you please add
something to the final draft?
|
·
Noted and will review
|
77
|
Additional
references for ‘Support your design’:
- Oxfordshire Definitive Map and Statement (the legal record of
public rights of way)
- Oxfordshire County Council (OCC) Rights of Way Management
Plan
- OCC Local Transport & Connectivity Plan
The DESIGN PRINCIPLES – PLACE AND SETTING section 1.6 should
read:
“”1.6 The settlement structure of the site and
surrounding area: this includes studying the historical development
of the settlement, its townscape; structure and hierarchy of
streets, spaces, facilities, existing connections (including public
rights of way and cycle routes), gateways, nodes, density, plot and
block sizes. Figure ground diagrams can help explain a settlement
structure;””
This is because the principle should apply to ALL FOUR categories
of PROW (i.e. bridleways, restricted byways and byways open to all
traffic, in addition to footpaths)
|
Noted.
|
78
|
On
Site B in Wallingford, the ancient groundscape was torn apart. It
had historical value in its makeup. Fields should not be
restructured as this was. This guide seems to say that that would
not happen in the future. Thank you.
Not sure why this part does not speak more of connectivity into
existing settlements and the ‘15min city’
concept?
|
·
Noted. We refer to 20 minute neighbourhood in the movement and
connectivity section and define it in the glossary.
|
79
|
Good
design rspects place and setting. Poor design often claims all
sorts of benefits for place and setting without actually achieving
either
|
·
Noted.
|
80
|
Agree
with most of them although jargon in places is not defined.
Needs statement on external lighting (including ILP GN01 and AONB
guidance).
|
·
Noted and will review
|
81
|
Response
manually entered, submitted in an email format.
Understanding the site’s features and its setting &
developing a design rationale
• It would be good to mention what an opportunities and
constraints plan is in this body text as this is an important
requirement of South Local Plan Policy DES3
|
·
Noted and will review points individually
|
82
|
Response
manually entered, submitted in an email format.
The draft Design Guide states within Figure 2 (Development access)
that “Successful development depends on good access and
connections. Make sure to provide more than one access point to
provide one way in and one way out. This would result in an overall
well connected development”. Thakeham agree that good access
and connections are vital to a successful and sustainable
development, however, two vehicular access points are neither
required, suitable or achievable on all developments; particularly
when taking into consideration the scale of development proposed.
Thakeham would suggest therefore that the councils are clear on the
access requirements they expect and from what scale of development;
ideally supported by technical guidance. It is imperative that this
is clear and not left to interpretation at the application stage,
to ensure consistency.
Furthermore, within Figure 2 (Future links) it is suggested that
future links should be provided “…to neighbouring land
that could be developed in the future…”. Thakeham
support the need for a holistic approach to masterplanning, however
it would be unreasonable for a proposed development to make
allowances for future connections without a level of certainty that
neighbouring land will come forward. This would also require the
engagement of neighbouring landowners/developers/promoters, which
has the potential to stall or delay an application. Thakeham
therefore consider that the councils should be clearer in the
application of this requirement and would suggest that only if
neighbouring land parcels are part of an allocation, or there is an
equivalent degree of certainty that both parcels will be developed,
should connection allowances be required.
The draft Design Guide suggests that to inform the design
developers should “Agree the scope of a landscape and visual
impact assessment/appraisal with the local authority”.
Thakeham suggest that further clarity on this should be included,
in relation to whether it will therefore be possible to engage with
landscape officers ahead of a Pre-Application submission, so any
landscape assessments produced at the earliest stage are based on
an agreed scope.
|
·
Noted and will review points individually
|
83
|
As
this is a SPD and not policy (and should therefore clarify the
policy, rather than adding further policies) the document should
state that development schemes which seek to follow the principles
set out will be supported, rather than stating that applicants
should ‘ensure’ that a scheme adheres to specific
principles. The SPD provides guidance and not policy – that
should be made clear in the document / online guide.
GOAL: Identify the site’s features and its context
The text is helpful in identifying some of the issues that might be
relevant in assessing a site’s features and its context. It
is helpfully made clear that the assessment will vary depending on
the site and the proposals, except for one sentence. ‘This
should consider the structure and history of the settlement and
landscape within which it is located or relates to, the character
of the landscape, biodiversity, the streets and spaces and the
built form (all of these elements constitute local
character)’. This sentence should be moved towards the end of
the third paragraph and re-phrased to say ‘The contextual
analysis is likely (amongst other issues) to consider the structure
… local character)’.
The second and third paragraphs related to this goal would
therefore read: -
A contextual analysis identifies the context within which the
application site is set. (*remove text*) *This should consider the
structure and history of the settlement and landscape within which
it is located or relates to, the character of the landscape,
biodiversity, the streets and spaces and the built form (all of
these elements constitute local character).* The level of detail in
the analysis should be proportionate to the scale and complexity of
the development proposals.
Every site feature identified provides an opportunity to shape your
design, even where they may initially appear to limit what you are
able to achieve. Imaginative solutions to incorporate off-site and
on-site features can give developments a unique character and form
the basis of your design rationale. You need to identify and take
account of the off-site and on-site features at the outset of the
design process as they are very rarely successfully retrofitted
into a design at a later stage. There should be a clear drawing
trail showing how the design of the development has
evolved.
The contextual analysis is likely (amongst other issues) to
consider the structure and history of the settlement and landscape
within which it is located or relates to, the character of the
landscape, biodiversity, the streets and spaces and the built
form.
GOAL: Use the site’s features and context to shape your
design
The sentence ‘Do not tightly define character area boundaries
but make sure to have a gradual transition between them. Focus on
the character of the streets/area as a way of creating attractive
and defined space’ should be removed as this is unnecessarily
prescriptive.
STEPS: Communicate your design
A sentence should be added to at the start to indicate that
requirements will vary depending on the proposals. We suggest
‘the communication of your design will depend on the extent
of your proposals, but is likely to include the need for:
-
An opportunities and constraints plan;
A concept plan
An illustrative layout
Other drawings might include (for example) cross sections or a
regulating framework plan for larger proposals. A clear Key is
required for each drawing.’
|
·
Noted and will review points individually
|
84
|
Response
manually entered, submitted in an email format.
The JDG identifies that a key goal in developing a design rationale
is to “use the site’s features and context to shape
your design”. Whilst CEG agrees that an understanding of
context should be an embedded component of any design rationale,
the vision of what is sought to be created should also be a key
driver that shapes the approach or rationale to a design approach.
This is particularly relevant for larger developments where, for
example, the vision may be to create a connected, forward-thinking
development that promotes sustainable living.
|
Noted.
|
|
Comment
|
Council’s
response
|
1
|
Too
many words.
Too many pages.
Too many concepts.
Too much everything.
You get the idea.
The guide is too elaborate and lengthy.
Nice concept.
Poorly implemented.
|
·
Noted.
|
2
|
Show
where natural environment will be lost.
|
·
Noted.
|
3
|
Again
the vast ombatm of applications do not require a landscape
strategy.
Section 2.0 states that a LVIA is required for every single
application? This is ridiculous and totally over-the-top, the
design guide needs to be clear as to when this is, and is not
required. Not just state something that would be helpful. This
totally defeats the point of the guide. This is repeated again at
section 2.9 where the design guide simply states numerous documents
should be provided ‘where applicable’. The design guide
should state when these are required and applicable not leave it up
to the judgement of the applicant, that is the entire purpose of
the design guide.
Section 2.8 has nothing to do with the natural environment and
relates entirely to pollution, this should be dealt with in another
section.
The requirement to provide a biodiversity net gain under the
environment act 2021 dosnt come in for another 2 years. This should
be referenced.
Nothing within this section references TPO’s or conservation
area protection for trees?
|
·
Noted and will review
|
4
|
Natural
environment should be given priority over new
development.
|
·
Noted.
|
5
|
The
result of overdevelopment is the removal of trees, hedges and
natural barriers, therefore the elimination of wildlife corridors
so vital to the environment and quality of life.
|
·
Noted.
|
6
|
See
above
|
·
Noted
|
7
|
Could
building not just accommodate and allow for but positively
integrate trees and other planting, so that each space is unique
and not just a bland copy of another off the peg
development?
|
·
Noted.
|
8
|
As
with the above. Design on a plan is fantastic (no one is going to
do a poor design) but having full consideration of the natural
environment and the impact on existing stock and infrastructure is
vital to ensure good living and good quality of life.
|
·
Noted.
|
9
|
See
answer to 8
|
·
Noted
|
10
|
The
existing Vale design guide is very clear, and yet in Faringdon we
see multiple large developments being approved which skip the
guidance . A cursory look at multiple exits and entry suggestions,
space for growing food, movement framework, etc. shows there is
little point in making new guides, if the implementation of
existing guides is so poor. If the same people and processes are at
work in the approval process, there is no point in investing in new
guidelines.
|
·
Noted.
|
11
|
find
suitable areas for joggers and dog walkers. Many people today use
dog walking as their form of exercise and if people live alone they
rely on a dog for company. Conversely there should be a limit on
too many dogs in social housing. If people cannot afford to work
and pay for home then to have several dogs which need finance is
not acceptable
|
·
Noted.
|
12
|
I
think that it is brilliant that you place so much emphasis on this.
And on the importance of trees and increasing biodiversity.
However, I imagine there will be a large gap between your ambition
and the actual result. Is it possible to help planners by
mentioning here things like incorporating bat bricks, swift,
swallow and martin boxes and hedgehog highways at the build stage?
It is so much easier to add them then. We are very lucky in our
area to have swifts, even though they are declining nationally. I
like your emphasis on hedgerows. Brick garden walls should not be
allowed; not only do they cut up the land into unconnected parcels
inaccessible for hedgehogs and other wildlife, they also do not let
the sun in for the unfortunate humans who will use the
gardens.
|
·
Noted and will review
|
13
|
Connective nature
corridors should be ombatment into plan including crossing hard
features such as raods via bridge or tunnel
|
·
Noted.
|
14
|
better
than place and setting
still no numbering to allow ease of navigation or explanation
also it is just as bad as the NPPF which is really brief and then
requires people to look through umpteen different documents, ombat
knowing their relevance and doesn’t even refer to existing
SPD like CAAs or NPs.
|
·
Noted and will review
|
15
|
concern that the
principles may be used by officers without an ability to discern
intuitive and skilful design innovation
|
Noted.
Officers will receive training following the adoption of the Design
Guide.
|
16
|
see
above
|
·
Noted
|
17
|
Any
larger scale development should be tied to the need to make spaces
for nature – developers should have to pay a tax towards
creation of new nature reserves
|
·
Noted.
|
18
|
Landscape features
should be preserved. Development in Areas of Outstanding Natural
Beauty and Green Belt must not be allowed.
|
·
Noted.
|
19
|
Noise
impact on wildlife never considered. 20 yrs ago ols used to hunt
around Mably Way all the time but in last 10 years never hear as
driven out by car noise to seek ombat areas.
|
·
Noted
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20
|
They
are good in general. However, I don’t see any thought being
given to public participation in either the design, establishment
or long-term management phases. Thought needs to be given to ensure
continuity of ‘green cover and visual features’ in
perpetuity. That requires sufficient space to permit age diversity
, eg. Double or treble avenues planted with species of different
ages, compatible characteristics etc. Rotational management to
sustain age diversity calls for Management Plans that span several
decades, if not hundreds of years. That calls for constant
education of – and communication with and between –
successive generations of residents/users. The choices of climax
species of trees for any one area will be vitally
important.
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·
Noted.
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21
|
Good
to see emphasis on trees and biodiversity.
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·
Acknowledged
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22
|
Biased
towards developers, create a summarised version for
householders
|
·
Noted.
|
23
|
In the
box Support your Design, please add in
Oxfordshire Gardens Trust website www.ogt.org.uk
There is much useful information about registered sites and sites
of local interest as well as records of research projects on walled
kitchen gardens, recreational parks, tercentenary of Capability
Brown (CB300) research applicable to both council areas
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·
Noted and will review
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24
|
Excellent format.
General comments – new planting should consider existing
planting, particularly if native species are present.
Landscaping is a very incongruous term (often used to describe
titivating around buildings with some green bits – a bit like
a garnish of parsley on a substantial meal. Hopefully those days of
thinking /use of greenery are long gone.
The term landscape proposals provides more clarity.
Maintenance / management- could provide more information. How is
quality to be determined at this stage (the longest stage).
Time is the 4th dimension to design. Landscapes are not
static but change & evolve with time – more so than the
built environment.
Perhaps consider short, medium and long term management
considerations for all aspects of the natural
environment.
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·
Noted and will review
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25
|
Very
important to consider the impact of the natural
environment.
|
·
Noted.
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26
|
Respect for the
local environment and indigenous flora and fauna. Enhancing the
local area’s appearance and allowing walks or ombatme to
local facilities.
|
·
Noted.
|
27
|
Would
like to see reference to Neighbourhood Plans
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·
Noted and will review
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28
|
There
is no mention of the natural environment as a sound-making and
receiving entity. The focus is entirely on spatial and visual
aspects of the ombatment. Not enough experiential data
referenced.
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·
Noted and will review
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29
|
I
fully commend taking account of natural features – too often
these have been bull dozed in the past with little consideration to
natural features. It will be good to see development that enhances
the natural environment.
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·
Acknowledged
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30
|
We are
the custodians of the very rare chalk streams in our area –
it would be amazing to see plans that that do not disturb these.
Ditto respect for the current patterns of local flooding eg
Chalgrove
|
·
Noted.
|
31
|
Nature
does not grow in straight lines – the delopment should
reflect this
|
·
Noted.
|
32
|
Trees
planted in pedestrian walking and seating areas – market
squares, children’s play/activity grounds and wide roads : if
correct type of tree can be kept at a reduced height (for
maintenance) which will provide thick shadow in high summer –
as in squares and public places in Continental Europe where they
have been using this form of public shading for
centuries.
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·
Noted and will review
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33
|
Again,
of little relevance to minor householder developments.
|
Noted.
Applies to all scales of development.
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34
|
The
term ‘ecological interest’ is used whereas I would
suggest’ ecological impacts’. The term
‘interest’ implies interesting to a particular group or
subjective interest or rarity whereas ecological impact is the
necessarily wider picture. For example something might not be rare
and therefore not be ‘of interest’ and unremarked but
if four or five developments all take place impacting the same type
of ecology at similar times it could become quite rare
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·
Noted and will review
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35
|
In
general, despite the fine words, the natural environment is
undervalued. Once destroyed in the interests of
“”development””, it is very seldom
restored. I would like to see greater relative value placed on the
natural environment and nature conservation. I think this
contributes substantially to quality of life.
|
·
Noted.
|
36
|
Could
you specifically add a reference to creating hedgehog highways to
allow movement
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·
Noted and will review
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37
|
Net
gain in biodiversity- should be seeking a substantial improvement.(
to ombat Climate Change)
|
·
Noted.
|
38
|
The
new estate off Fogwell Road in Botley does not meet the principals,
the ugly flats can be seen for miles, the plans may look alright
when you look at a flat architects drawing, but when viewed from
the normal street scene the buildings look a right jumbled mess.
There is not a single tree or flower anywhere. It already looks
like an instant slum.
|
·
Noted.
|
39
|
It
might be preferable to write the principles in bullet points and/
or emphasise key words in bold or italics.
|
·
Noted and will review
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40
|
All
good here, sets out clearly what needs to be considered for a
scheme.
|
·
Noted and will review
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41
|
Excellent to see
the Natural Environment and biodiversity receiving centre
stage
|
·
Acknowledged
|
42
|
no
reference found to the role of neighbourhood plans in natural
environment
|
·
Noted and will review
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43
|
You
say that “”Developments that result in net losses of
biodiversity are not acceptable.”” In reality much of
the development in the District (South Oxfordshire in my case) DOES
reduce biodiversity. For example NE Didcot has seen hedges removed,
which reduces the population of nesting birds and which has
eliminated a local murmuration of starlings. If you are serious
about not reducing biodiversity you need to sharpen up your act.
The aim is ok but honouring it in the breach sends out the wrong
signal.
|
·
Noted.
|
44
|
As far
as we can tell, the Draft Design Guide should take more note of the
rural characteristics of South and Vale as in our view the entire
Design Guide has a distinct urban bias.
|
·
Urban design is a discipline that relates to the design of our
cities, towns and villages. It is a collaborative and
multi-disciplinary process of shaping the physical setting of where
we live, work and socialise. It is the art of making places no
matter the context. Therefore the word ‘urban’ is not
be taken literally but rather as a way of describing a
discipline.
|
45
|
See
comment in the section above.
|
·
Noted
|
46
|
yes
this is good the Italians would agree
|
·
Acknowledged
|
47
|
very
informative.
|
·
Acknowledged
|
48
|
This
section suggests preparing a landscape strategy using various LPA
and nationally-approved landscape character assessments. Why not
refer developers/applicants to the landscape character assessments
ALREADY commissioned by every area with an adopted neighbourhood
development plan? This seems to be a glaring omission.
|
·
Noted.
|
49
|
We
have no specific comments to raise in this section which follow
well established principles of good design.
|
·
Acknowledged
|
50
|
I was
surprised not to see a link to the MAGIC maps (https://magic.defra.gov.uk)
which allow people to see habitat designations, including priority
habitats. I was glad to see it specifically stated that
irreplaceable habitats cannot be ‘offset’.
I think it’s a shame not to give a few more examples of the
types of biodiversity improvements that can easily be included into
designs, such as swift bricks, bat boxes and bird boxes for
appropriate species (e.g. sparrow and starling as well as the more
common blue tit and robin boxes, and sometimes a barn owl box might
be appropriate too). Many people are unaware of some of these
features and just mentioning them could help encourage their uptake
(as they are very low cost – although they need to be used in
the right circumstances – e.g. at the right heights and with
appropriate surrounding habitat)
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·
Noted and will review
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51
|
Response manually
entered, submitted in an email format.
Admin note: The original email submission is attached for reference
at the end of this comment form.
Thank you for your consultation request on the above dated and
received by Natural England on 18th January
2022.
Natural England is a non-departmental public body. Our statutory
purpose is to ensure that the natural environment is conserved,
enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable
development.
Our remit includes protected sites and landscapes, biodiversity,
geodiversity, soils, protected species, landscape character, green
infrastructure and access to and enjoyment of nature.
While we welcome this opportunity to give our views, the topic this
Supplementary Planning Document covers is unlikely to have major
effects on the natural environment, but may nonetheless have some
effects. We therefore do not wish to provide specific comments, but
advise you to consider the following issues:
Green Infrastructure
This SPD could consider making provision for Green Infrastructure
(GI) within development. This should be in line with any GI
strategy covering your area. The National Planning Policy Framework
states that local planning authorities should ‘take a
strategic approach to maintaining and enhancing networks of
habitats and green infrastructure’. The Planning Practice
Guidance on Green Infrastructure provides more detail on
this.
Urban green space provides multi-functional benefits. It
contributes to coherent and resilient ecological networks, allowing
species to move around within, and between, towns and the
countryside with even small patches of habitat benefitting
movement. Urban GI is also recognised
as one of the most effective tools available to us in managing
environmental risks such as flooding and heat waves. Greener
neighbourhoods and improved access to nature can also improve
public health and quality of life and reduce environmental
inequalities.
There may be significant opportunities to retrofit green
infrastructure in urban environments. These can be realised
through:
• green roof systems and roof gardens;
• green walls to provide insulation or shading and
cooling;
• new tree planting or altering the management of land (e.g.
management of verges to
enhance biodiversity).
You could also consider issues relating to the protection of
natural resources, including air quality, ground and surface water
and soils within urban design plans. Further information on GI is
include within The Town and Country Planning Association’s
“”Design Guide for Sustainable
Communities”” and their more recent “”Good
Practice Guidance for Green Infrastructure and
Biodiversity””.
Biodiversity enhancement
This SPD could consider incorporating features which are beneficial
to wildlife within development, in line with paragraph 118 of the
National Planning Policy Framework. You may wish to consider
providing guidance on, for example, the level of bat roost or bird
box provision within the built structure, or other measures to
enhance biodiversity in the urban environment. An example of good
practice includes the Exeter Residential Design Guide SPD, which
advises (amongst other matters) a ratio of one nest/roost box per
residential unit.
Landscape enhancement
The SPD may provide opportunities to enhance the character and
local distinctiveness of the surrounding natural and built
environment; use natural resources more sustainably; and bring
benefits for the local community, for example through green
infrastructure provision and access to and contact with nature.
Landscape characterisation and townscape assessments, and
associated sensitivity and capacity assessments provide tools for
planners and developers to consider how new development might makes
a positive contribution to the character and functions of the
landscape through sensitive siting and good design and avoid
unacceptable impacts. For example, it may be appropriate to seek
that, where viable, trees should be of a species capable of growth
to exceed building height and managed so to do, and where mature
trees are retained on site, provision is made for succession
planting so that new trees will be well established by the time
mature trees die.
Other design considerations
The NPPF includes a number of design principles which could be
considered, including the impacts of lighting on landscape and
biodiversity (para 180).
Strategic Environmental Assessment/Habitats Regulations
Assessment
A SPD requires a Strategic Environmental Assessment only in
exceptional circumstances as set out in the Planning Practice
Guidance here. While SPDs are unlikely to give rise to likely
significant effects on European Sites, they should be considered as
a plan under the Habitats Regulations in the same way as any other
plan or project. If your SPD requires a Strategic Environmental
Assessment or Habitats Regulation Assessment, you are required to
consult us at certain stages as set out in the Planning Practice
Guidance.
Should the plan be amended in a way which significantly affects its
impact on the natural environment, then, please consult Natural
England again.
Please send all planning consultations electronically to the
consultation hub at consultations@naturalengland.org.uk
|
·
Noted and will review
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52
|
Response manually
entered, submitted in an email format. For reporting purposes
additional text is marked as ‘xxx’ and deleted text as
*xxx*. The original submission is attached to this comment form for
reference.
The site layout should respect its physical features and those of
its adjacent land including its ‘’landscape
character’’, topography, orientation, landform,
geology, drainage patterns, field patterns/boundaries and
vegetation cover, for example.
Justification: links to Local Plan evidence base, for example the
LEPUS study for SODC.
The North Wessex Downs and the Chilterns Areas of Outstanding
Natural Beauty (AONB) cover large areas of land within the
districts. Their Management Plans and associated documents should
be ‘’applied to any proposals’’ *referenced
for sites* within the AONB or their setting.
Justification- ‘‘sites’’ might be
misconstrued here and design within the AONB covers refreshment,
renovation and not just new build proposals, which will be limited
in any event.
We recommend the addition of the ‘’Chilterns Buildings
Design Guide and Supplementary Technical Notes on Materials,
Roofing and Flint.’’
|
·
Noted and will review
|
53
|
Response manually
entered, submitted in an email format.
1. There are two significant omissions from consideration in this
section: wildlife corridors and agricultural land for local food
production, including allotments
2. In the “Support your design” box there could
usefully be a reference to the Oxfordshire Nature Recovery Network,
Defra’s 25-year Plan, and the Oxfordshire Local Nature
Partnership.
|
·
Noted and will review
|
54
|
Response manually
entered, submitted in an email format.
Natural Environment
• “Retain characteristic hedgerow pattern where
possible” – this has frequently not happened in the
past.
• Design principle 2.2 “ensure the scheme….does
not negatively impact on the benefits enjoyed by neighbouring
properties and spaces”. In a built-up area everything impacts
on neighbouring properties.
• The Committee agrees with the Biodiversity Net Gain
proposals.
|
·
Noted.
|
55
|
This
is again a good start, but again quite general. I would be keen to
see something included on the installation of solar panels –
be this in existing or new develoments, and in particular with
respect to any large scale solar farms on agricultural land which
will have a huge impact on the character of the environment. There
will also be a huge impact on the ecosystem which should be taken
into account.
|
·
Noted and will review
|
56
|
How
can we best maintain the beauty and openness of the natural
environment and also allow renewable energy sites? How they can
gently co-exist? Is there potentially a use of flood zones for
elevated solar panels?
|
·
Noted and will review
|
57
|
Goal:
Last paragraph. Please change “”proposed features such
as public open spaces, community orchards, structural planting, and
Sustainable Drainage Systems (SuDS)..’ –to:
‘proposed features such as public open spaces, allotments,
living walls, community orchards, structural planting, and
Sustainable Drainage Systems (SuDS).
Inform your Design
Please change Technical studies….. to ‘Technical
studies will show you whether there are any elements that need
protecting, as well as physical features – this should
include views, local production of food including the preservation
of existing farmland, carbon sequestering vegetation, water
features, existing vegetation, ecological interest, heritage value
and setting.’
Support your design:
Include Campaign for the Protection of Rural England
Oxfordshire
Design Principles:
Please change the following:
2.2 is designed to maximise the benefits of natural resources
(utilising landform, orientation, geology, natural carbon
sequestering vegetation and natural drainage patterns) and does not
negatively impact on the benefits enjoyed by neighbouring
properties and spaces;
2.5 has a joined-up network of gardens, living walls, open spaces
and allotments which form an integral part of the development and
are located where existing and new residents can access them
easily, not just located on the edge of the development (or where
there is left over space) and must be useable;
Main Heading – Please change ‘The value of trees within
the built environment ‘ – to: The value of trees and
living walls within the built environment.
Add an explanation of Living Walls: Examples of living walls have
been shown to remove CO2 equivalent to 275 trees in 1% of the
space. Relatively small ‘benches’ in urban areas have
been shown to remove 240 tons of CO2 from the atmosphere per year
and 250 grams of particulate matter per day. The inclusion of
living walls within a development can make a significant positive
impact on the carbon footprint of the development. For more detail
on living walls, go to ideal homes living walls: https://www.idealhome.co.uk/garden/garden-ideas/living-wall-ideas-280720
Throughout this section please change ‘Trees’ –
to Trees and Living Walls. Please include diagrams and pictures of
living walls.
|
·
Noted and will review
|
58
|
Again,
the wider setting of Oxford should be included within this section,
whilst this is generally Green Belt areas, it is significant due to
the role it plays in long term views and should be given a high
level of protection.
A number of Oxford View Cones are also located within the area
covered by the Joint Design Guide and these should be identified as
areas of high sensitivity to any proposed change. The Oxford View
Cones Study (Assessment of the Oxford View Cones) 2015 jointly
produced by Oxford Preservation Trust and Historic England should
be included within the list of ‘support your design’
documents.
|
·
Noted and will review
|
59
|
Fig 5
– “”Trees can provide an attractive noise
buffer”” – we have previously been told that
trees do not act as a buffer so would question this.
Bug hotels – these do not count towards the habitat
calculation (Defra metric) however there could be scope to
recognise more biodiversity enhancements that are not part of the
Defra metric (bug hotels, bat boxes, bird boxes) before
biodiversity offsetting is applied.
|
·
Noted and will review
|
60
|
I want
to emphasise as strongly as possible the undesirability of any
building intruding into the Green Belt – and any reduction in
the Green Belt. Whatever may have seemed bearable ten years ago,
has been overtaken by the escalation of climate change and the
erosion of so much natural life and biodiversity with many species
(animals, birds, insects, flora) moving to the brink of extinction.
There is so much interdependence in nature that damage to one
aspect now very quickly impacts others. The Prime Minister has
repeatedly assured questioners in the House of Commons that all
necessary housing can be built on brownfield sites.
Biodiversity proposals to compensate for unavoidable impacts (2.15)
must not be perfunctory.
There is no equivalence between the destruction of ancient
woodlands and hedgerow, with long-established wildlife corridors,
by planting new copses somewhere unrelated to that. It takes many
years for trees to grow and for all the associated wild growth to
take place which invites forms of natural life to make their
habitats and pathways there. A few scattered trees and some shrubs
are no replacement whatever. Nature requires as much diversity as
possible.
Token shrubberies, with manicured lawns, bordering concrete
expanses from which many will drive cars or to which delivery
vehicles will come, are no substitute for proper wildness of
countryside.
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Select:
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61
|
This
section could have had more photographic examples of best practice
with green walls/roofs and wildflower (Chalk) meadows in order to
promote a greater impact within the actual development site rather
than developers paying for biodiversity off-setting somewhere else.
The diagrams showing tree planting are probably too generic to be
that useful. There should be a greater emphasis on planting
indigenous trees like oak and using other indigenous plants with
the landscape.
The 20% limit on tree species may not be appropriate since it would
be better for developers to plant more expensive but slower growing
oaks than to plant a wide range of cheap fast growing exotic plant
species.
The design guide should place more emphasis on the long term
quality of the natural environment rather than on pointless
tick-box survey requirements that are normally promoted for
compliance rather than creating improvements. We must move away
from developers being allowed to chuck up a few bird and bat
boxes.
|
Select:
|
62
|
FORMATTING: Needs
a chapter number for reference. Could an interactive mini contents
list be included under each chapter title/heading for easier
navigation, to avoid scrolling? Principles should really be first,
and then follow up with explanation text, diagrams and helpful
links below.
DIFFERENTIATION: Would be good to highlight where principles are
perhaps more appropriate for Majors or Minors applications, and
where they may be more appropriate for householder development.
Diagrams all refer to major sites, but no examples of smaller minor
scheme provided. If the principles are genuinely meant for smaller
development, these examples are needed of how to implement the
principles at smaller scale, including for single
dwellings.
INFOLINKS: Where the information links are provided for
“Support Your Design” – could a link be provided
to Nature Space and information about Great Crested Newts? This is
dealt with a lot. Would it be useful to have a link to help
citizens identify protected species (for example;
amphibians).
PHOTOGRAPHS: Officers commented that the pictures are lovely!
– but weren’t sure if they added anything to the
section. Officers queried whether it would be more helpful to have
photographs of some protected species, but more of e.g. bat boxes,
bird boxes, hedgehog holes, which are often asked for on
applications as part of biodiversity mitigation.
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Select:
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63
|
The
only additions that could be made would be an increased emphasis on
the setting of the Chilterns AONB (in accordance with the 2021
NPPF) and a specific refence to the Chilterns AONB Management Plan
and Chilterns Building Design Guide to provide more specific
guidance for the AONB.
The Design Guide must be able to deal with design in rural areas as
well as focussing on the needs of the urban areas.
|
Select:
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64
|
The
Role of an SPD:
Whilst BHL recognises the majority of the ‘natural
environment’ design principles as being appropriate and
clearly written, it is important that the Design Guide
Supplementary Planning Document (SPD) does not seek to introduce
new requirements for developments that have not already been
established within the Councils’ adopted planning policy.
Indeed, the introduction of new development requirements falls
outside of the remit of an SPD.
That has been established within the National Planning Policy
Framework (NPPF), the Government’s Planning Practice Guidance
(PPG), and recent case law. The NPPF clearly sets out that the role
of SPDs is to “add further detail to the policies in the
development plan” by providing further guidance on particular
issues. Thus, the appropriate role for an SPD of this kind is to
provide additional guidance that was not included in policies
within the NPPF and PPG themselves, adopted local plan(s), or the
National Design Guide. It should, therefore, not seek to repeat
those documents, and instead should only provide guidance that adds
to their content.
However, the Government’s PPG has reiterated that SPDs should
not go beyond that by seeking to introduce new development
requirements that have not yet been set out in adopted policy. That
PPG states that, as SPDs “do not form part of the development
plan, they cannot introduce new planning policies into the
development plan” and that “they should not add
unnecessarily to the financial burdens on development” (PPG
Reference ID: 61-008-20190315).
That is particularly important where SPDs seek to introduce new
development requirements that would have a financial implication on
a development scheme. That matter has been considered in recent
High Court judgements (such as William Davis Ltd & Ors v
Charnwood Borough Council [2017] EHWC 3006 (Admin) (23 November
2017)), that have highlighted that the introduction of specific
development requirements that have financial implications does not
fall into the scope of an SPD, and that this should be considered
in local plan reviews where the full impact on viability can be
considered.
In general, therefore, it is suggested that the wording used in the
‘design principles’ sections is softened to reflect the
nature of an SPD as a guidance document, rather than planning
policy. For example, rather than stating that applicants should
“ensure” that a scheme adheres to specific principles,
the document should instead state that development schemes which
seek to follow the principles set out will be supported.
Moreover, a review of each individual design principle should be
carried out with reference to the relevant adopted development
plan(s), as well as the NPPF; to ensure that the SPD does not
introduce new requirements and is consistent with the NPPF’s
provisions. For example, the origin of the reference to providing
“a mix of [tree] species with no more than 20% of any genus
and no more than 10% of a particular species on the site” is
unclear, and does not appear to be derived from any existing policy
contained within extant plans. Moreover, setting specific targets
for each tree species is unduly restrictive and does not allow for
sites to flexibly respond to their setting, and also could limit
the ability of sites to achieve an efficient use of land. That
design principle should be amended accordingly or
removed.
Biodiversity Net Gain:
The above guidance is particularly relevant to the proposed
approach that is being taken to Biodiversity Net Gain (BNG).
Indeed, paragraph 2.13 of the draft SPD states that schemes should
ensure that they “deliver at least 10%” BNG, citing the
2020 Environment Bill.
However, such a requirement for a 10% BNG is not yet a policy
requirement that is included in national planning policy or the
adopted local plans of either authority, nor is the secondary
legislation in place to support the Environment Bill. Rather, the
adopted plans of both authorities require developments to deliver a
net gain (i.e. any net gain, not 10%). As such, it is outside of
the remit of the SPD to refer to any requirement of this kind, as
there is not a policy basis on which to base any guidance. Rather,
a more suitable mechanism through which to introduce any specific
BNG percentage requirement would be the emerging Joint Local Plan
that is currently under preparation; and in any event that would
only be appropriate once the necessary secondary legislation is in
place to support the Environment Bill.
Paragraph 2.13 of the emerging Design SPD should, therefore,
reflect the adopted policy position of both authorities by
supporting developments that “aim to deliver a Biodiversity
Net Gain in accordance with the relevant local planning
policy.” It would also be prudent to clearly specify that net
gains should be delivered on-site where possible, but that off-site
mitigation / compensation would also be acceptable where that is
not achievable. That has been recognised as being an appropriate
approach in the January 2022 ‘Consultation on Biodiversity
Net Gain Regulations and Implementation’ that was carried out
by the Government’s Department for Environment Food and Rural
Affairs (DEFRA). Moreover, the Councils should ensure that
mechanisms are in place to allow for off-site mitigation /
compensation (such as specific compensation schemes), and the
Design Guide SPD should clearly set those out.
Figure 3:
It is also noted that comments have been made in response to
Question 7 in relation to Figure 3. Those comments note that, as
currently drafted, it is not clear whether some interactive figures
(including Figure 3) represent guidance or whether they are
demonstrating how the design principles could be applied in a live
scheme. That should be clarified in relation to Figure
3.
|
Select:
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65
|
Good
coverage
|
·
Acknowledged
|
66
|
Again
for larger developments this section – especially the Design
Principles – capture well the key issues. It may have been
improved by particular reference to Community Orchards and Tiny
Forests
|
·
Noted.
|
67
|
Please
refer to submitted representations.
|
·
Noted
|
68
|
Response manually
entered, submitted in an email format
Design principles – Natural Environment, Ensure the
scheme
2.0 Greater emphasis should be placed on the weight attached to
complying with the design guides of the AONBs in the
district
2.1 Strongly support the requirement to ‘retain and create
views out of the sites’ and recommend that great weight be
placed on this in the AONBs.
New development should look at landform, landscape & associated
settlement patterns
Design principles – Planting in a development
proposal
This section focuses on trees. In the Chilterns hedgerows are a
strong, characteristic feature and the design guide should
emphasise the retention of existing hedgerows.
Planting in a development proposal
Goal: Use planting to help a development integrate into the
landscape with its own character and sense of place
The text under this goal says that ‘It is essential that all
landscaping is designed in coordination with all of the above and
below ground utilities infrastructure including lighting’.
Given the increasing prevalence of, and dependence on,
telecommunications, designs would be improved by placing all
telecommunications cabling underground. Developers should work with
district & county councils, and utility companies to find out
what future infrastructure plans are proposed so that there is no
need for the installation of telegraph poles at a later date. This
will also aid resilience as the climate becomes less
stable.
Design principles – Biodiversity
Strongly support but with greater emphasis on avoidance of
loss
|
Select:
|
69
|
Again
would be useful to have a form where each feature can be
considered.
|
Select:
|
70
|
Response manually
entered, submitted in an email format.
The Design Principles in relation to biodiversity (paragraph 2.13)
state that applicants should ensure their schemes aim to deliver at
least 10% Biodiversity Net Gain (BNG). We do not believe there is
any robust basis for this ‘requirement’ at this
time.
The Joint Design Guide references the Environment Bill, which is of
course now the Environment Act, but the mandatory requirement for
biodiversity net gain is not anticipated to come into force until
2023.
The relevant Local Plan policies are ENV3: Biodiversity (in the
South Oxfordshire Local Plan) and Core Policy 45: Green
Infrastructure (in the Vale of White Horse Local Plan). Both of
these policies seek a net gain in biodiversity, but not a 10% gain
in biodiversity.
The Joint Design Guide should be amended to reflect the Local Plan
policies that the SPD sits under (i.e. schemes should ensure a net
gain in biodiversity). The SPD cannot introduce new policies into
the development plan, and it cannot amend existing development plan
policies.
|
Select:
|
71
|
Response manually
entered, submitted in an email format.
Natural Environment (Design Principles –
Biodiversity)
The SPD sets out how new development schemes should aim to deliver
at least a 10% net gain in Biodiversity.
At present the Councils’ Local Plans do not contain policies
which seek to deliver a minimum 10% net gain in Biodiversity. In
line with guidance set out in the NPPF, the Councils should not be
using the SPD as a means to rewrite Local Plan policies but rather
to provide further guidance to existing policies.
In this regard, it may be more appropriate for the Council’s
to not include specific reference to ensuring new development
schemes deliver at least a 10% net gain in Biodiversity and leave
the requirement mechanism to be delivered through the Environment
Bill.
|
Select:
|
72
|
GOAL
Working with and enhancing the natural features and resources of
the site
In relation to Woodland buffers, the goal specifies a minimum
offset of 15m for ancient woodland. This kind of information is
helpful, but needs to be rationalised (see previous comments). The
Design Policies in South and Vale, and the SPD, need to be clear
what is guidance and what is policy, and the SPD should add further
clarification to policy.
Paragraph 2.2 expects that any scheme will not negatively impact on
the benefits enjoyed by neighbouring properties and spaces. This
wording should be softened to ‘… minimises any negative
impacts on the benefits enjoyed by neighbouring properties and
spaces’. Design often requires that small compromises are
needed for the greater benefit of a wider area: the design process
is in fact one of balancing impacts to ensure that benefits are
optimised.
Paragraph 2.5 refers to the need to deliver open spaces for
existing and new residents. This may be clearer just stating
‘residents’. GOAL Planting in a development
proposal
Paragraph 2.11 does not seem to be derived from a policy nor may it
be appropriate in all situations. The references to the mix of
species should be phrased as a suggested mix not a requirement.
Alternatively, the policy could be framed to advise that schemes
that identify such a mix will be supported.
GOAL Working with and enhancing biodiversity for future
generation
Paragraph 2.13 of the draft SPD states that schemes should ensure
that they “deliver at least 10%” BNG, citing the 2020
Environment Bill. However, such a requirement for a 10% BNG is not
yet a policy requirement that is included in national planning
policy or the adopted local plans of either authority, nor is the
secondary legislation in place to support the Environment Bill.
Rather, the adopted plans of both authorities require developments
to deliver a net gain (i.e. any net gain, not 10%).
It is therefore outside the remit of the SPD to refer to any
requirement of this kind, as there is not a policy basis on which
to base any guidance. Rather, a more suitable mechanism through
which to introduce any specific BNG percentage requirement would be
the emerging Joint Local Plan that is currently under preparation;
and in any event that would only be appropriate once the necessary
secondary legislation is in place to support the Environment
Bill.
Paragraph 2.13 of the emerging Design SPD should, therefore,
reflect the adopted policy position of both authorities by
supporting developments that “aim to deliver a Biodiversity
Net Gain in accordance with the relevant local planning
policy.” It would also be prudent to clearly specify that net
gains should be delivered on-site where possible, but that off-site
mitigation / compensation would also be acceptable where that is
not achievable. That has been recognised as being an appropriate
approach in the January 2022 ‘Consultation on Biodiversity
Net Gain Regulations and Implementation’ that was carried out
by the Government’s Department for Environment Food and Rural
Affairs (DEFRA).
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Select:
|
73
|
The
public rights of way network is an important part of the heritage
and landscape of this part of the county, therefore the
‘Support your design’ section here should also
include
- Oxfordshire Definitive Map and Statement (the legal record of
public rights of way)
- Oxfordshire County Council (OCC) Rights of Way Management
Plan
|
Select:
|
74
|
This
is really great!
It could be clearer on allowing large belts of landscape and
waterscape passing through the development for wildlife to move
unhindered. This might mean introducing new wildlife belts rather
than just relying on what was. The Environment Act demands 10%
biodiversity net gain. This should be emphasised, with a suggestion
that a much higher net gain would be desirable.
How can we get people to keep their gardens permeable to wildlife?
Could there be insistence on hedges and no fences between
gardens?
SuDs have failed in parts of Wallingford (bone dry during
flood-periods). Is this the place to insist that a management
scheme goes in to ensure SuDs works and will be maintained into the
future?
Thank you for the tree section. Could it be bolder on keeping as
many mature trees as possible? It takes so long for them to grow
back! Thank you for emphasising maintenance of trees. It is
something that has failed within a year in two Wallingford
developments. Please ask too for trees to be varied and of a native
species. Orchards are nice for the community too.
Please make mention of plants other than trees. Wildflower patches
and boggy parts add to the interest and help provide the continuous
corridors that wildlife needs.
Perhaps too you could bring in reducing the OPPOSITE of natural
areas: reducing areas of hard paving. Flood control is far better
achieved by absorbent surfaces.
|
·
Noted and will review
|
75
|
As the
global climate emergency demonstrates the natural environment needs
to be protected and enhanced. But all too often in planning claims
of protection and enhancement are hollow – the words being
used to mimic those of the LPA rather than actually describing what
the applicant really wants to achive
|
·
Noted.
|
76
|
Needs
additional lighting guidance – ILP GN01 and
GN08/18.
|
·
Noted and will review
|
77
|
Response manually
entered, submitted in an email format.
Design Principles
• Identify the character of new spaces, such as
‘parks’, ‘woodland’,
‘allotments’, ‘wildflower meadows’ rather
than ‘P.O.S.’. Be more specific about the function and
character of public open spaces
• Strong levels of natural surveillance with well-overlooked
public open spaces
Natural features and resources
• This section covers many different issues, this could be
confusing/overwhelming for some. Some of the issues also link to
other sections of the design guide, for example there is a clear
link to the Space and Layout section on open space design –
should this link be recognised/signposted in someway?
• Para 3 focuses delivering benefits for future occupiers,
but wondered whether opportunities to deliver benefits for
nature/wider environmental gains should also be
highlighted?
• Para 4 says about contributing to green infrastructure, but
should this be a bit clearer about multifunctionality/multiple
benefits and networks/connectivity?
Biodiversity
• The diagram highlights that habitats don’t start and
finish at the site boundary, but this doesn’t really come
across in the main text. Should there be something in the main text
about connectivity/corridors, with a thought to ensuring longer
term resilience?
General
• The intro says that this guidance is relevant for all
scales of development, however whilst this is true for some of the
guidance, there are parts that would only apply to larger scale
developments.
• Could there be more images/diagrams in this section that
show the principles applied to different scales of development? For
example, provide an example of what SuDS might look like on a
householder development?
• Noticed quite a few grammar issues/typos– for example
“agricultural barn are common nesting sites” and
“working with and enhancing biodiversity for future
generation”. There are also some typos in the diagrams for
example Figure 7 – “dont” instead of
“don’t”. There is also inconsistent use of
‘water courses’ and ‘watercourses’ in this
section.
• There a few phrases that could be a bit unclear, for
example what is a ‘meaningful green space’?
|
·
Noted and will review
|
78
|
Response manually
entered, submitted in an email format.
At paragraph 2.5 the draft Design Guide requires open spaces to be
part of a ‘joined-up network which form an integral part of
the development’. Thakeham would note that the open space
requirements for a site are driven by good masterplanning, having
consideration of the wider opportunities and constraints of each
site. Thakeham suggest that it is too prescriptive to suggest every
site should have open space within its centre and all open spaces
should be joined-up. This may not be suitable, appropriate or
achievable on all sites, therefore Thakeham suggest some
flexibility should be added to this requirement.
The draft Design Guide also notes that “Development proposals
should provide a net increase in tree canopy cover where this is
possible, having regard to other considerations…”.
Thakeham appreciate that there is flexibility within this wording
however Thakeham do not consider tree canopy increases should be
the baseline. It is important to ensure that any site enhancements
are mutually beneficial, and Thakeham therefore suggest the
councils consider whether this wording is appropriate.
At paragraph 2.11 the draft Design Guide states, regarding trees
and the proposed layout of a development, that “A mix of
species is required with no more than 20% of any genus and no more
than 10% of a particular species on the site”. Thakeham would
note that this is an unusual requirement, and our priority is to
focus on Biodiversity Net Gain as the main metric. Therefore,
Thakeham suggest that some flexibility is needed in relation to
this requirement, to allow for site-specific considerations.
Additionally, Thakeham suggest that the councils also consider
whether it is appropriate to introduce non-native trees into a
local area. This could have unforeseen negative consequences on
existing biodiversity; therefore, a high percentage of native trees
is often favoured.
|
Noted.
Will review.
|
79
|
GOAL
Working with and enhancing the natural features and resources of
the site
Paragraph 2.2 expects that any scheme will not negatively impact on
the benefits enjoyed by neighbouring properties and spaces. This
wording should be softened to ‘2.2 is designed to maximise
the benefits of natural resources (utilising landform, orientation,
geology, and natural drainage patterns) and (*remove text*) *does
not negatively impact* minimises any negative impacts on the
benefits enjoyed by neighbouring properties and spaces’.
Design often requires that small compromises are needed for the
greater benefit of a wider area: the design process is in fact one
of balancing impacts to ensure that benefits are
optimised.
GOAL Working with and enhancing biodiversity for future
generation
Paragraph 2.13 of the emerging Design SPD refers to policies at a
national level that are not yet in place (although they soon will
be). The Local Plans for the Districts will incorporate these
requirements as they are updated. The SPD should, therefore,
reflect the adopted policy position of government or the
authorities by supporting developments that ‘aim to deliver a
Biodiversity Net Gain in accordance with the relevant statutory
requirements.’
|
Noted.
Will review.
|
80
|
Response manually
entered, submitted in an email format.
Cala Homes (Midlands) have reviewed the draft guide and have the
following comments:
1. While the value of trees expressed in the Natural Environment
section is supported, house builders are often restricted in their
ability to place trees within residential developments by the
approach taken by Oxfordshire County Council, which essentially
sterilises the 10m radius around street lights within the adopted
highway.
2. Clause 2.11 in the Natural Environment section of the draft
proposes maximum numerical restrictions on the genus and species of
trees. While a good variety of trees is supported, it is considered
that the provision of trees on a site should be considered on a
site by site basis. It is considered that it would be restrictive
to require compliance with a notional requirement, where there may
be reasons to provide a range of trees of the same genus and/or
species. If a maximum percentage must be included in the condition,
it should be a recommendation or aspirational range, which can be
varied where it can be demonstrated appropriate to do
so.
|
Noted.
Will review.
|
|
Comments
|
Council’s
response
|
1
|
I
agree with the principles. It's vital to minimise any interaction
between vehicles and pedestrians / cyclists, by ensuring that main
routes DO NOT run through new developments, but bypass them.
Additionally, there must be dedicated facilities for cyclists and
pedestrians connecting directly to cycle networks.
It's vital that developments are located as close as possible to
the national rail network or bus routes with direct links to the to
main urban centres. important
|
·
Noted.
|
2
|
Too
many words.
Too many pages.
Too many concepts.
Too much everything.
YOu get the idea.
The guide is too elaborate and lengthy.
Nice concept.
Poorly implemented.
|
·
Noted.
|
3
|
Show
realistic conjestion and places that are more than 2 k from a bus
stop / route etc
|
·
Noted.
|
4
|
Again
- the vast majority of applications do not require a transport plan
or transport statement.
Public art has nothing to do with movement and connectivity. To be
honest, this is so tone deaf to the realities of development. I
cannot even name a single development anywhere in the south east
that has included public art commisions. Come on..
|
·
Noted.
|
5
|
Intensive
development curtails wildlife connectivity and changes the quality
of life in rural and small town areas.
|
·
Noted.
|
6
|
Too
much use of jargon. This is meaningful to town planners but quite
difficult for the rest of us.
|
·
We have used Plain English language as far as possible. Any
technical concepts are defined in the glossary.
|
7
|
With
the houses on Dunmore road for example - access to Southbound A34
is not being completed at Lodge Hill. This will cause untold
congestion in both Abingdon town centre (for traffic heading in
Newbury direction) as well as further congestion and traffic in
local villages such as Wooton for traffic trying to fight its way
into Oxford. Having this type of connectivity is vital. We have
excellent bus services to Oxford but most people have cars (whether
electric or not )
|
·
Noted.
|
8
|
People
will take shortcuts if they can which may degrade the environment.
Needs to be taken into consideration.
|
·
Noted.
|
9
|
The
existing Vale design guide is very clear, and yet in Faringdon we
see multiple large developments being approved which skip the
guidance . A cursory look at multiple exits and entry suggestions,
space for growing food, movement framework, etc. shows there is
little point in making new guides, if the implementation of
existing guides is so poor. If the same people and processes are at
work in the approval process, there is no point in investing in new
guidelines.
|
·
Noted.
|
10
|
Developers
of new housing should provide funds to extend public transport
between their developments and town centre, transport hubs (railway
and bus stations etc)
|
Select:
|
11
|
Too
much on-street parking. The taxpayer pays for roads, not places for
people to store their personal possessions.
|
·
Noted.
|
12
|
I
like the emphasis on active travel!
|
·
Acknowledged
|
13
|
Please
see previous comments, Question 3.
|
·
Noted
|
14
|
i
don't actually think this is very helpful. it is exceptionally
vague and yet is really only copying parts out of other documents.
why not just refer to them?
from this i have no idea at all what the Council's preference will
be for a given situation
|
·
Noted.
|
15
|
concern
that the principles may be used by officers without an ability to
discern intuitive and skilful design innovation
|
Noted.
Training will be offered to officers once the design guide is
adopted.
|
16
|
See
above
|
·
Noted
|
17
|
Include
footpaths and cycle routes
|
Noted.
We believe we already mention this in this section.
|
18
|
For
these design principles there must be local services and
facilities, and frequent cheap local transport. These are never
supplied at the beginning of a development and sometimes not at
all. Developers must be required to provide the agreed
infrastructure, services and facilities at the start of a
development.
|
·
Noted.
|
19
|
Design
brief says dont do Cul-de-sacs on estates as confuses and
inefficient use of space...and not to restrict road traffic by
putting unecessary expensive road-traffic restricting
constuctions!!
Just built both in Grove.....cul-de-sacs losing delivery drivers in
Grove Airfield and ridiculously dangerous road speed chicanes next
to Grove Rugby field just built! So does anybody read what you
write in design briefs?!
|
·
Noted.
|
20
|
Good
|
·
Acknowledged
|
21
|
Like
last section very good use of graphics.
|
·
Acknowledged
|
22
|
Biased
towards developers, create a summarised version for
householders
More should be done to ensure traffic calming for existing roads.
If new roads have 20mph, but more residents drive through exiting
roads at speed, it won't make local councils popular
|
·
Noted.
|
23
|
Really
good thinking about movement and development within the development
- but to make development sustainable it needs to connect to and be
part of the existing context -where are existing bus stops train
stations cycle routes ! How does the development connect to these
?
I think this section could be strengthened by asking developers to
consider existing networks and showing how the development plugs
into those.
|
·
Noted.
|
24
|
All
great in principle. But how you going to GUARANTEE that we don't
end up with more of the current cycle-paths-no-nowhere-with
cars-parked-on-them? Just get on a bicycle and cycle around the
south end of Grove where teh new junction has been put in. Imagine
being a schoolchild emerging from the new school exit road. What
were you thinking about?
|
·
Noted.
|
25
|
It is
vital that we move away from the car dependency. I think some
developments could be designed so that the discourage car use. It
seems absurd that it is assumed that all houses need a certain
number of parking spaces even when the development is in a 15
minute neighbourhood like all of our market towns. People are lazy
and reach for car keys even to go 1 mile down the road.
Quality paths need to be intrinsic in the design and routes should
be well signposted.
|
·
Noted.
|
26
|
If a
development is not near to essential facilities-i.e. shops and
schools doctor's surgeries, public transport would be needed to
prevent families being car-dependant.
|
·
Noted.
|
27
|
Would
like to see reference to Neighbourhood Plans
|
·
Noted.
|
28
|
How
do transport networks impact the sounding environment? idling
buses; tyres on asphalt; the drone of passing aircraft; proximity
to RAF or other heavy sound-making devices eg helicopters (Benson
etc). How are road and pavement surfaces designed to change the
sounding environment? How can a development be designed to sound
healthy and create auditory health alongside visual and spatial
health?
|
·
Noted and will review
|
29
|
Adding
cycle ways to existing routes doesn't make for the best solution.
Ensuring all types of transport (wheeled or by foot) is considered
at the beginning of a development will ensuring long term
sustainable solutions to movement of people and traffic.
|
·
Noted.
|
30
|
The
statement looks good, but in practice it doesn't seem to be
followed. For example, there is no provision for improved traffic
flow resulting from the Bayswater Brook development. Bayswater Road
is already overloaded during rush hour. These statements are
worthless if they are not followed through in practice
|
·
Noted.
|
31
|
Yes -
safe walking and cycling routes paramount. Access to transport is
such a big issue for villages where there is none, and unlikely to
be any unless subsidised.
|
·
Acknowledged
|
32
|
As
above nature and the natural environment does not grow, develop in
straight lines - man made developments to reflect this.
|
·
Noted.
|
33
|
Nothing
related to Wallingford - a County Town - or its satellite
villages
|
Noted.
This guide and its principles cover both South Oxfordshire and Vale
of White Hourse District Councils
|
34
|
And
again, only relevant to major, probably greenfield,
developments.
|
Noted.
Principles in this section are relevant to all scales of
development.
|
35
|
These
are good but ruling out cul de sacs may not be as beneficial as a
cul de sac for cars to reduce 'rat runs' but with through ways for
pedestrians and cyclists to encourage use of non vehicular
transport
|
·
Noted.
|
36
|
fine
|
·
Noted.
|
37
|
Walking
and cycling to be priority. Connection to existing residentail and
business areas
|
·
Noted.
|
38
|
if
you can provide a safe pathway for pedestrians and pram pushers
this would be good. Essentially not shared with bicycles and E
scooters.
|
·
Noted.
|
39
|
It
might be preferable to write the principles in bullet points and/
or emphasise key words in bold or italics.
|
·
Noted.
|
40
|
Same
as above, clear and concise.
|
·
Acknowledged
|
41
|
no
reference found to the role of neighbourhood plans in movement and
connectivity
|
·
Acknowledged
|
42
|
You
say of secondary routes that ""As these streets will be lightly
used by vehicular traffic pedestrians should feel comfortable
moving freely across the street. In some instances, the use of
shared surface treatments may be appropriate. The design of the
street should limit vehicular speeds to 20 mph, without the need
for excessive traffic calming measures."" This is too permissive
about shared use surfaces, which are a fad which rarely works. They
frequently do not prioritise walking and cycling (e.g.The Avenue,
Great Western Park, Didcot, which strongly favours motorists and
encourages them to drive too fast.) If you said that they may
occasionally be appropriate but include a warning about the hazards
they can cause, it would be better.
|
·
Noted.
|
43
|
As a
rural Parish we have no streets but only footpaths. Pedestrian and
cycle routes do not apply. This is symptomatic of this urban bias
in a predominantly rural county. eg: Provision of public transport
is immeasurably more important than designing a network of paths
and streets. We note the absence of a rural network. We need public
transport.
|
·
Noted.
|
44
|
A
briefer section - and all the better for it. But it still states
the obvious and is more verbose than it needs to be.
|
·
Noted.
|
45
|
this
is not so good this is public school hippy bull.all of this sounds
good if your not dealing with working class villains I AM WORKING
CLASS people like security.cul-de-sacs provide Security allies
ect.do not .new ally with lights wonderful.ten years later lights
smashed a muggers paradise.we are not living in belgravia.security
is peace of mind . peace of mind is paradise
|
·
Noted.
|
46
|
As a
rural parish where for safety the vast majority of residents have
to rely on cars to move around this has limited impact.
|
·
Noted.
|
47
|
This
section could also benefit from a reference to neighbourhood
development plan (NDP) village character area appraisals. Every
area with an adopted NDP will have one of these, and any
developer/applicant should show that they have read these documents
and demonstrated how their development responds to historic lanes
etc
|
·
Noted.
|
48
|
We
have no specific comments to raise in this section which follow
well established principles of good design.
|
·
Acknowledged
|
49
|
This
seems better written than most sections, for the lay reader
(although there are some exceptions, like the image title ""Swale
frontages as part of a street (Upton)"" which doesn't help the
uninitiated understand what a Swale frontage is). Also all those
pictures under 'street design' highlight horrible-looking
developments, to my mind! All I could think was that at least the
trees might grow to cover up the terrible buildings... I don't know
where 'Tadpole Garden Village' is but by the photos in this guide
it looks like the worst bit of design for a rural area that I've
perhaps ever seen in my life.
Is the image labelled ""Public seating in open space, benches
(Chinnor)"" really of seating? It looks pretty weird
seating!
|
·
Noted.
|
50
|
Response
manually entered, submitted in an email format.
1. Although the creation of routes for walking are emphasised,
there is no specific reference of the need to actually provide
footways or pavements of adequate width for pedestrians, pushchair
and wheelchair users, if necessary within the road frontage of new
buildings if the roadway is too narrow to include these safe routes
for active transport.
|
Noted.
We do mention with all users in mind which includes pedestrians,
prams and wheelchairs.
|
51
|
Response
manually entered, submitted in an email format.
Creating a Network
It appears that the "Creating a Network" section, is inconsistent
with the overarching principles of low car neighbourhoods which are
being promoted in Oxford.
Whilst we agree with the commentary on cul-de-sacs in general, the
layout of a proposed development needs to avoid residential streets
becoming car dominated. The layout of a proposed development should
not create too much car permeability, as this is likely to
encourage car usage, particularly for short trips. It is
recommended that the emphasis here should be amended to focus on
permeability by non-car modes.
If you could confirm safe receipt of this representation, it would
be appreciated.
Should you have any questions, please do not hesitate to contact
me.
|
·
Noted.
|
52
|
Response
manually entered, submitted in an email format.
3. The Guide should recognise that private travel by vehicle will
still be needed even if the County Council’s Transport Plan
reduces the volume.
5. The Design Guide should recognise increased working from home
and an increase of commuting perhaps only on several days a week
rather than every day
|
·
Noted and will review
|
53
|
Response
manually entered, submitted in an email format.
Movement and Connectivity
• Tertiary streets need to allow for on-street parking as
there is never enough provided on-site.
• Tertiary and secondary streets should have road surfaces
designed to show a clear way out for visitors.
• The Committee endorse avoiding cul-de-sacs.
|
·
Noted.
|
54
|
Some
good points are made in this section. The other key point to
highlight will be to provide better and more public transport.
Currently there is very little incentive for most people to use the
park and ride facilities as its just as cheap to drive into town
and park in the many parkign facilities in town. The appraoch
should be to make the public transport - ie buses - free to use so
it provided an incentive.
|
·
This comment raises issues that fall outside the scope of the
design guide.
|
55
|
As
our land becomes more crowded, it seems more and more important to
allow for non-car movement in our settings. Pavements are being
taken over by parked cars, so alternative placement of pavements
relative to roads might be innovative. I also think larger
developments might have car parks located in various places, with
pleasant walking paths to get to the individual houses. (Although,
how would we unload shopping and then how would deliveries take
place?) Could places with public rights of way be used for solar
panel farms? I'd think there would be room for landscaped trails
that also held solar panels. Could we use the extant road networks
in any way to also generate renewable energy?
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·
Noted.
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56
|
Please
include living walls in street diagrams.
Please add to principle 3. 9: --The Layout and hierarchy of streets
and provision of cycle and pedestrian routes needs to ensure that
cyclists and pedestrians have the shortest possible journeys to
access facilities, employment, shops and buses, inside and outside
the site. It is preferable and acceptable to have fewer direct
primary car routes to achieve direct safe routes for cyclists and
pedestrians.
Please change principle 3.10 to: includes trees, living walls and
soft landscaping that create character and distinction between
street types.
Please add new Street Design principle: include living walls in
areas of high emission from vehicles in order to improve air
quality.
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·
Noted and will review
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57
|
The
majority of the suggestions of natural traffic calming are not
supported through the Section 38 process, which would mean that
roads cannot be adopted. It is very important that the financial
burden to future homeowners of private roads is avoided.
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·
Noted and will review
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58
|
Building
true community, to embrace all ages, requires irregularity and not
too many straight lines. It must be accepted that many will
continue to drive, however many walkways and cyclepaths are
provided. Therefore to avoid congestion and traffic fumes, there
need to be multiple exits and entrances from estates, rather than
subsidiary roads all channelling into one. People will go on
needing their cars to get as close to their homes as possible, for
various purposes - particularly the elderly and frail and families
with young children. What looks clean and tidy on plans can quickly
become a soul-less wasteland. Large green areas are essential, but
stocked with a wide variety of shrubbery and plants, serving
different species, not long regimented rows of the same plant.
Shops and spaces where communities interact are needed at frequent
and readily-accessed intervals.
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·
Noted.
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59
|
The
design guide doesn't go far enough in encouraging walking and
cycling. With the possible trend of more people working from home
and less commuting , residents will probably need to be more
reliant on walking and cycling in the future. Most towns and cities
in Germany are now car-free and are serviced with networks of cycle
highways. This design guide doesn't promote this required level of
change of emphasis that will be required in the future. Why is the
guide still encouraging developers to start with a street plan
designed for cars? Why are there no examples of centralised car
parking areas with car-free streets?
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·
Noted.
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60
|
FORMATTING:
Needs a chapter number for reference. Could an interactive mini
contents list be included under each chapter title/heading for
easier navigation, to avoid scrolling? Principles should really be
first, and then follow up with explanation text, diagrams and
helpful links below.
[3.0-3.31] OCC STREET DESIGN GUIDE: Officers raised concern that
OCC are planning to adopt a Street Design Guide soon and queried
how much overlap there would be between the Districts Design Guides
and the County’s Design Guide.
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Noted and will review
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61
|
Clearly
set out.
The Guide needs to address issues of public transport in rural
areas, both for residents to move about and for visitors to key
'honeypot' areas like the Chilterns.
|
Noted.
This issue falls outside the remit of the Guide.
|
62
|
Movement
and Connectivity Design Principles
Whilst the intention and general scope of the ‘Movement and
Connectivity’ section of the draft Design Guide SPD is
recognised, some of the draft design principles should be amended
or removed to ensure compliance with national and local planning
policy, and to appropriately reflect the purpose and role of an
SPD.
Indeed, that general matter was discussed in Bloor Homes’
response to Question 9, which highlights the position of the NPPF,
PPG and recent case law that SPDs should not seek to introduce new
development requirements or have any additional cost implication,
and instead that their scope is to provide additional guidance in
relation to existing policies in adopted documents. Therefore, to
reflect the scope of SPDs, the SPD should not state that applicants
should "ensure" that a scheme adheres to specific principles, but
instead should state that development schemes which seek to follow
the principles set out will be supported.
Moreover, each design principles should itself be considered in
line with the NPPF to ensure that they are consistent with national
policy. For example, paragraph 3.0 states that schemes should have
"a network of streets, paths and integrated cycleways that connect
with each other and create an attractive network of routes for all
users and all modes of transport", referring to the principles of a
20-minute neighbourhood in that regard. Whilst the underlying
principles of 20-minute neighbourhoods are recognised in terms of
promoting sustainable development and connectivity, that is not a
requirement that is set out in the adopted plans of each authority.
Moreover, those principles are not always achievable in all
circumstances. However, sustainable development should nonetheless
be realised in suitable locations, and should not be prohibited as
a result of the application of those principles. Indeed, that is
recognised by the NPPF, which states that "opportunities to
maximise sustainable transport solutions will vary between urban
and rural areas" (paragraph 105) but that, despite that, rural
development should be pursued to enhance and maintain the vitality
of rural communities and support their services and facilities
(paragraph 79). Seeking to implement 20-minute neighbourhood
principles would not only be introducing a new policy, therefore,
but would also overlook the importance of supporting sustainable
development in rural areas. Thus, design principle 3.0 should be
removed.
That is similarly the case in relation to design principles 3.6 and
3.7, which seek to ensure that new homes are located within 800m of
facilities and services, 400m of a bus stop, and preferably within
600m of a primary school and 1500m of a secondary school. Again,
those design principles do not appear to have been predicated on
the basis of an existing policy in an adopted plan, and could
effectively negate any development in otherwise sustainable rural
areas. Again, that does not reflect that both Districts are largely
rural in nature, as is recognised in the SPD. As such, design
principles 3.6 and 3.7 should also be removed.
Street Hierarchies
Bloor Homes welcomes the inclusion of illustrative street
hierarchies that include design principles relating to street
widths, boundary treatments, street planting, pathway / cycleway
design and arrangement, surface treatments, etc.; all of which are
considered to be appropriate. With that said, however, the Design
Guide SPD should allow for flexibility within that, allowing for
schemes to incorporate departures from those principles to reflect
site-specific characteristics or where it can be demonstrated that
an alternative design is more appropriate.
Figure 8
As set out in Bloor Homes’ response to Question 7, it is not
clear whether some interactive figures are included as guidance in
themselves or whether they are demonstrating how the design
principles could be applied in a live scheme. The position and
status of Figure 8 should be clarified in that regard.
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·
Noted and will review points individually
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63
|
Perhaps
segrated cycle, pedestrian and vehicle routes if
possible.
|
·
Noted.
|
64
|
We
liked this section. Perhaps improved further by emphasising
opportunities for vehicle free areas especially close to community
and retail. Also provision of cycle racks. Not sure that Public Art
fits neatly into this section on Movement and
Connectivity.
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·
Noted and will review
|
65
|
Please
refer to submitted representations.
|
·
Noted
|
66
|
Response
manually entered, submitted in an email format
Creating a network
We recommend that when developments are proposed on greenfield
sites which may incorporate a public right of way, developers
consider the increase in the status of a public footpath to allow
cyclists, or if it links bridleways or provides a safe route for
equestrians, then an increase in status from public footpath to
bridleways, with a suitable multi-user surface.
There is a need to reference vulnerable road users, such as
equestrians where there is access to public bridleways.
Design principles - Movement and connectivity
No reference is made to car parking. New developments should
incorporate adequate parking to remove the need for cars to park on
the road.
Design principles - Street design
3.22 ensure the amount of street furniture is kept to a minimum
–
We strongly suggest the provision of telecoms services via
underground links – improve the street scene by removing
telegraph poles and improve resilience in the face of climate
change.
Public realm, lighting, art & furniture
3.25 this section rightly requires the design to ensure that
lighting avoids causing light pollution in rural/darker
areas.
However, this misses the point that the majority of light pollution
in rural and darker areas comes from light reflected and scattered
from the towns.
In addition, no mention is made of the light pollution from large
windows in new homes. Reference should be made to ensuring that
light pollution from within buildings is reduced by appropriate
shielding and the use of window material that reduces light
pollution.
We recommend the inclusion of a reference to the Institute of
Lighting Professionals (ILP) documents for good lighting and the
adoption of their recommendation for only downward outside lights
on dwellings, and the use of shields on low- and high-level
lighting to reduce light spillage onto hedges, trees, bedrooms
etc.
A diagram showing the types of light pollution must be included,
together with links to:
the ILP - https://theilp.org.uk/resources/ and The Commission for
Dark Skies - https://britastro.org/dark-skies/ ;
and examples of good lighting design to help both householders and
developers reduce the acknowledged damage from light pollution
particularly in a district with substantial areas of
AONB.
Resources
The Oxfordshire County Council Street Design Guide, must be
included as a resource.
https://www.oxfordshire.gov.uk/residents/roads-and-transport/transport-policies-and-plans/transport-new-developments/transport-development-control
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·
Noted and will review points individually
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67
|
Need
to look at local traffic flow numbers and whether there is
congestion and do a transport infrastructure model
|
·
Noted
|
68
|
Response
manually entered, submitted in an email format.
The design principles in relation to movement and connectivity are
generally supported, and will assist in encouraging more
sustainable modes of travel.
In relation to paragraph 3.7, whilst we support the aspiration of
locating new homes within 400m of bus stops, this
‘requirement’ should be presented as a target, in a
similar way to the target for being within 600m of a primary school
and 1,500m from a secondary school.
The design principles for streets and spaces are quite detailed.
CEG feel it is essential that principles such as these are worked
up in close consultation with Oxfordshire County Council as
highways authority, to ensure that the views of the District and
County Council are aligned, and that applicant’s don’t
work up schemes on the basis of the principles set out in the Joint
Design Guide, only to find that the County Council has a different
design view.
Subject to when the next version of the Joint Design Guide is
prepared, and depending upon the final publication date of the new
Manual for Streets, the Councils should ensure that the Joint
Design Guide reflects the latest guidance in Manual for Streets
(and that the new Manual for Streets is referenced in
the Joint Design Guide).
Finally in relation to this section, it is surprising that there is
no parking advice or reference to parking standards. It would
assist if, at the very least, the section on movement and
connectivity included a cross reference to the relevant parking
standards that the Councils will apply.
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·
Noted and will review points individually
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69
|
Response
manually entered, submitted in an email format.
Movement and Connectivity
In the ‘steps’ to creating a network a number of
documents are highlighted to support the applicant’s design,
including Manual for Streets 1. This document provides guidance on
‘Walkable Neighbourhoods’ stating:
"Walkable neighbourhoods are typically characterised by having a
range of facilities within 10 minutes’ (up to about 800 m)
walking distance of residential areas which residents may access
comfortably on foot. However, this is not an upper limit and PPS13
states that walking offers the greatest potential to replace short
car trips, particularly those under 2 km"
Meanwhile The Institute for Highways and Transport (IHT) have also
published guidance which offers suggested acceptable walking
distances to various locations. Table 3.2 in the IHT’s
Providing for Journeys on Foot document proposes distances which
are greater than those proposed by the SPD in the Movement and
Connectivity design principles.
It is proposed that the Councils’ SPD should align with
advice set out in the Manual For Streets document and provide
further flexibilities within the guidance.
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·
Noted and will review points individually
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70
|
GOAL:
`A place that is easy to get to and move through for all
users
The SPD refers to various cycling and parking requirements. In a
short SPD of this format, it is not possible to do justice to the
multiple variations of cycling and parking that could be
appropriate in a scheme. These sections of the guide should be
removed as they do not add any further clarity to the National
Design Guide, Local Plan Policies or the documents (such as LTN
1/20) referenced in the SPD.
Design principles 3.6 and 3.7 seek to ensure that new homes are
located within 800m of facilities and services, 400m of a bus stop,
and preferably within 600m of a primary school and 1500m of a
secondary school. These design principles do not appear to have
been predicated on the basis of an existing policy in an adopted
plan, and could effectively negate development in otherwise
sustainable rural areas. These paragraphs do not reflect the fact
that both Districts are largely rural in nature. Design principles
3.6 and 3.7 should be removed.
To reflect the status of the SPD, it should not state that
applicants should ‘ensure’ that a scheme adheres to
specific principles, but instead should state that development
schemes which seek to follow the principles set out will be
supported.
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·
Noted and will review points individually
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71
|
Please
see submitted letter for full comments.
|
·
Noted
|
72
|
This
is very much centred on roads at present and the lack of reference
to Public Rights of Way (PROW) is a significant omission. PROW are
public highways, and it is important to identify (a) the likely
impact of the development on existing PROW and (b) the
opportunities for improvement of the local PROW network as part of
the development proposal - not least because PROW form a valuable
part of the local Active Travel network.
Oxfordshire has a high population of horses (nearly 22,000
registered to addresses in the county, representing a
conservatively-estimated value to the local (and predominantly
rural) economy of over £121 million/year), but the network of
off-road equestrian routes is fragmented, making it necessary for
riders and carriage drivers to use roads as links between
PROW.
The safety of equestrians on Oxfordshire's roads is a significant
and growing concern as traffic speed and volume has increased in
recent years. Horse riders and carriage drivers are legal road
users ranked alongside cyclists and immediately below pedestrians
in the new Highway Code hierarchy of vulnerability. They have to
use roads (though they would much rather not) and to cross them in
order to gain access to off-road routes. The BHS keeps a record of
road incidents involving horses. In Oxfordshire from November 2010
to December 2021 there were:
• 110 road incidents reported
• 7 horse fatalities
• 15 horses injured
• 2 human fatalities
• 20 humans injured
Research indicates that only around 10% of incidents are reported
to the BHS.
In 2021 ALONE, in Oxfordshire there were: • 55 road incidents
reported • 2 horse fatalities • 2 horses injured
• 3 humans injured.
In the interests of improving road safety, there should therefore
be a default principle that horse riders at least have access to
all Active Travel routes that are available to other vulnerable
road users, unless there are well-evidenced and clearly-stated
reasons why they should be excluded. Horse-riders already share
PROW (excluding footpaths) and roads with pedestrians and cyclists,
and horses are routinely ridden and driven through villages and
other residential areas, often specifically because they are areas
where the traffic is slower and less frequent.
Design principle - Movement and connectivity 3.0 should therefore
read
""...has a network of streets paths and integrated cycleways that
connect with each other and create an attractive choice of routes
for all users and all modes of transport (20-minute neighbourhood);
prioritising the needs of ALL vulnerable road users - including
pedestrians, people with disabilities, cyclists, public transport
users and equestrians over the needs of motorists within the
network;""
This will support
1) development of a well-connected, maintained and clearly signed
Active Travel network for walkers, horse riders and
cyclists
2) mitigation for the adverse effects on vulnerable road users
(walkers, cyclists and equestrians) of increased traffic flow on
local roads as a result of the development
Key references should include:
Oxfordshire Definitive Map and Statement (the legal record of
Public Rights of Way)
OCC Rights of Way Management Plan 2015-25
(https://www.oxfordshire.gov.uk/residents/environment-and-planning/countryside/countryside-access/rights-way-management-plan)
OCC emerging Local Transport and Connectivity Plan 5
(https://letstalk.oxfordshire.gov.uk/ltcp)
Defra Rights of Way Circular 1/09
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Noted and will review points individually
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73
|
I'd
suggest cycleways should be wide enough to take mobility scooters.
These in themselves could become rainproof mini-electric vehicles
for non-disabled folk. I imagine little pods like these taking over
from use of the car for short journeys.
You mention street-lighting in this. Oxfordshire County Council is
working on a dark skies principle for street lighting. Can we
manage without lighting at all? Some say this is (surprisingly)
safer. Otherwise lights might be such that they come on only on
motion-detect. There are street lights in Richmond, London, that
can differentiate (and photograph) bats and not turn the lights on
(according to OCC officers, if I understood them
correctly).
Pedestrianised settlements should be required, with the cars on the
outside (or car clubs rather). This works fine in Pontevedra in
Spain
(https://www.theguardian.com/cities/2018/sep/18/paradise-life-spanish-city-banned-cars-pontevedra).
And for those areas that do go near to homes, surely 20mph if fast?
Shouldn't it be 10mph? (NB I like the home zones - but safer still
to ban cars).
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·
Noted and will review points individually
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74
|
Needs
some principles for lighting since for half the year places will
become lit environment for half the 24 hr period
possibly.
|
·
Noted
|
75
|
Response
manually entered, submitted in an email format.
• The document is sound and does pick out best practice.
However, there is little to suggest the document has been authored
across either the South Oxfordshire or Vale area. Visual examples
of best practice are presumably available from within SODC/Vale but
it seems no attempt has been made to identify and use them. For
example, Figures 9, 10 and 11 could use examples of poor and best
practice picked from the any town or village from one of the
Districts. This would enable Councillors and NDP groups to use
their knowledge of areas / visit real-world examples which may help
them understand better development forms – perhaps even
through "Google Earth".
• SODC Local Plan 2035 Policy DES10 appears to provide the
only direct policy link between the Guide and either of the Local
Plans. Have other opportunities to better link the guide to the
local planning environment been missed?
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·
Noted and will review
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76
|
General
comments
• A little confused about how the ‘streets as
spaces’ and ‘street design’ sections are
different. As to me, both concern the design of the street, and it
isn’t too clear how the principles differ.
• Reference the Oxfordshire County Council Street Design
Guide
https://www.oxfordshire.gov.uk/sites/default/files/file/roads-and-transport-policies-and-plans/DesignGuidePublication.pdf
• The highway authority will not adopt car parking which is
perpendicular to the highway
• Note there are a number of detailed design consideration
points on cycle and car parking in OCC’s DG which are not set
out in the JDG - It may be worth our JDG referring to this detail
as well as the Oxfordshire Cycling Design Standards and Oxfordshire
County Council Residential Parking Standards (and emerging new
standards) or providing replicated / district specific detailed
design guidelines
https://www.oxfordshire.gov.uk/sites/default/files/file/roads-and-transport-policies-and-plans/DesignGuidePublication.pdf
see part 3 - pages 33-44
Creating a network
• ‘This includes people with disabilities, parents,
carers, pregnant women, children and older people’ –
not sure how differently pregnant women travel than other
users?
• ‘Think about different users’ experience as
they travel through the site (e.g. blank façades in the public
realm do not provide an attractive experience from a pedestrian
point of view).’ - It might be suitable to elaborate on this
point of blank facades, including the consideration of 20-minute
neighbourhoods and healthy streets, with local services and
mixed-use developments provided so that residents do not have to
travel – so instead of a bank façade there could be a
local service to engage the community - a feature or service (book
exchange, a place to stop an rest, outdoor gym for example).
Consideration of place making.
Communicate your design
• It is worth referring to the criteria (scale of
development) as to when a Transport Statement or Transport
Assessment are needed? This is included in OCC’s "Transport
for New Developments, Transport Assessments and Travel Plans"
document Appendix 1 Page 27 of 66.
Support your design
• Add ‘Healthy Streets’ Design Check
guidance
• Add ‘Inclusive Mobility (Department for Transport,
2005)’
• Reword ‘Local Transport Note 1/20 Cycle
infrastructure design (Department for Transport, 2020)’
instead of ‘Department for Transport’s Local Transport
Notes guidance (1/20, 2/08 [superseded by 1/20], 1/12[superseded by
1/20])’
Design Principles – Movement and connectivity
• 3.0 – ‘Has a network of streets paths’
– should state ‘or paths'
• 3.0 - Other modes should be at least as attractive, if not
more, than using the car
• 3.0 Define 20-minute neighbourhoods – potentially
differentiate between urban and rural environments (particularly
relevant to the districts), although this will need agreement with
policy officers as would affect local plan policy.
Definition/Explanation in LTCP Draft is as follows:
‘20 minute neighbourhoods is a new expression for a design
concept that plans for essential facilities within 20
minutes’ walk from home. A 20 minute walk will get most
people around 1.5 km or a mile. The concept is that all essential
everyday facilities should be within that distance so it is easy
for people to base their lives on walking rather than using a car.
Facilities should include shops, recreational opportunities, parks,
community facilities, access to public transport (mostly bus stops)
and such like. The concept fits in with the goals of low traffic
neighbourhoods (LTNs) which minimise traffic within the
neighbourhood.
Another popular new concept is the 20 minute town based on a 20
minute cycle ride where a wider range of facilities is within 20
minute cycle ride, which at very moderate pace is around 3 miles or
5 km. A 20 minute town should for instance include access to public
transport for interurban travel (train or coach stations),
employment and comparison as well as convenience
shopping.’
• 3.2 after the word ‘safe’ examples could be
provided as is in the LTCP draft, ‘safe (consider
surveillance, sight lines, lighting)’.
• 3.2 – suggest adding ‘cycle and walking
paths’ instead of just ‘paths’. Add commas -
‘...and, where applicable, avoid...’
• 3.4 – could potentially add here about how these
routes should be convenient i.e., minimising the need to stop and
divert
• 3.6/7 - Where does the 800m come from? (this doesn’t
fit into the 20 minute neighbourhood approach [80m/minute means
that this is 1,600m]) I’m not advocating this to be changed
to 1,600m but want to be clear on where this value comes from.
Similarly, where have the other distance preferences come
from?
• Could we add an encouragement to include accessible
wayfinding/signposting to be installed to promote movement on
foot/bike/active travel
Streets as spaces
• LTCP has the following requirement which may be useful to
also add to reflect inclusive design ‘designed to provide an
inclusive street environment that meets the needs of people from
early to later life.’.
• 3.15 recommend adding about gradients, in reflection of
those less able (disabled/old) ‘gradients should also be
considered’.
• Recommend adding about need for shade and shelter, under
3.17 (Healthy Streets Approach)
• Figures 16 & 17, where arrows point, don’t see
much value added from preceding drawing: (drawing is included in
the original submission attached at the end of this comment
form)
• Image with description ‘Enclosed streets provide good
definition of space’ – should have a location added for
consistency with other images.
• 3.11 – add ‘including relevant funding
sources’
• 3.15 – add ‘To allow passing, minimum of 2m
width’ (Manual for Streets 2007)
Street Design
• Supporting text states ‘If you design for the elderly
and disabled, you are designing for all. This is inclusive
design.’ – what about children, women or parents etc?
This is quite a sweeping statement. Inclusive design also covers
age, ability, gender, race or income, this should be reflected
here.
• Add after ‘The quality of our streets and spaces can
be undermined by overly engineered traffic calming measures such as
speed humps’, ‘and featureless build-outs such as
chicanes’.
• Add after ‘...varying the alignment of the vehicular
route and use of tight junction radii’, ‘, while
considering access for emergency services and refuse
vehicles’.
• Image of ‘Swale frontages as part of a street
(Upton)’ – presume the area of planting is for
sustainable drainage, if so this could be explicitly
stated.
• The box of design principles states ‘Ensure the
scheme’, but then this doesn’t connect to the sentences
below – suggest ‘the scheme’ is deleted so it
makes sense.
• 3.22 - Maybe change street furniture to a minimum, change
to say something about how street furniture should not be
cluttered, only high quality designed street furniture should be
incorporated, maybe examples of some. As street furniture is
important for rest and social interaction, so we worry that in
saying it should be minimised, applicants may not provide
any.
• 3.23- Expand on ‘inclusive design’ –Could
have examples in brackets i.e. the need for shade and shelter,
seating for rest, consideration of gradients, include wayfinding
and signage installations, natural surveillance etc.
• We would consider landscape/green infastructure to be an
important element of street design however it is not mentioned
here. It is included in the picture examples but not added as a
design principle. Recommend that this is added and that we
potentially also add something about delivering landscape features
that provide sensory richness, i.e. visual, scent and sound to the
street. Planting can also be used to diffuse street lighting or
noise in residential areas, these sort of things could be mentioned
as well.
• LTCP includes the ‘Healthy Streets Approach’,
could add the following requirement as set out in LTCP ‘New
streets should be designed in accordance with the Healthy Streets
Approach’. Alternatively, this could be added to the
documents list.
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·
Noted and will review points individually
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77
|
Response
manually entered, submitted in an email format.
The draft Design Guide comments that cul-de-sacs are "...land
inefficient and causes confusion and frustration". Thakeham do not
agree with this generalisation and whilst cul-de-sacs for strategic
scale sites may not be appropriate, on smaller sites this type of
layout may better reflect the sites context and surrounding
character. Thakeham therefore suggest the councils are clear on the
application of the requirement and provide clarity on how this is
designed to apply to sites of different scales. Moreover, linking
primary streets to tertiary streets could result in rat-running,
which would increase traffic in more residential areas and raise
safety considerations. Thakeham therefore suggest that the councils
also carefully consider the potential negative impacts of this
requirement.
Figure 8 of the draft Design Guide discusses the requirement for
main streets to be ‘lined with building frontage’.
Thakeham would suggest that a ‘strong building
frontage’ requirement is more appropriate, as a continuous
frontage within a development may not always be appropriate and is
subject to site-specific considerations such as scale and local
context.
Thakeham would note that Figures 9 and 10 are too generic and more
importantly has been included as a guide for strategic scale sites
with an extensive internal road network. Thakeham therefore do not
consider that these principles are applicable to smaller scale
sites and suggest the councils are clear in the application of
these principles in relation to site size. In addition, Thakeham
would also repeat the above concerns that linking primary streets
with tertiary street could lead to rat-running.
Paragraph 3.2 suggests that developments should "...where
applicable avoid single point of access (particularly for large
developments)". Thakeham are encouraged by the flexibility that
appears to have been introduced, however Thakeham note that the
draft Design Guide comments at length about the desire for multiple
accesses – see comments in relation to the ‘Place and
setting’ section above. Thakeham suggest that the councils
are explicit on what they deem small- and large-scale development
to be, and how they intend to apply access requirements
accordingly. As currently written, it is considered too vague and
different sections of the draft Design Guide appear to provide
different levels of clarity on the same topic.
Paragraph 3.3 states that developments should provide "...links to
neighbouring allocated land that could be developed in the
future...". Comments above in relation to Figure 2 within the
‘Place and setting section’ of the draft Design Guide
note that a level of certainty is required in relation to the
development of neighbouring land. Here, the councils allude to
‘allocated land’ which goes further but Thakeham still
do not consider it is appropriate to plan for a neighbouring site
that may or may not come forward, unless the councils are able to
facilitate discussions. Moreover, Thakeham suggest that the draft
Design Guide should be clear in each section – if
‘allocated land’ is the benchmark the councils intend
to use, then this should be repeated throughout when discussing
‘future connections’ to provide clarity.
Paragraph 3.4 of the draft Design Guide states that developments
should provide "...direct pedestrian and cycle links to local
services and facilities...". Thakeham is committed to providing
good connections to existing services and facilities, however this
is often also based on factors beyond our control where connections
go beyond our site boundary, such as the suitability of the
existing network. Whilst Thakeham would always aim to work with the
councils, the draft Design Guide should account for this within the
wording of this requirement.
At paragraph 3.14 the draft Design Guide requires schemes to avoid
tarmac and use ‘porous materials for non-adopted roads and
pavements’. Thakeham consider this is too prescriptive and
any surfacing materials should be site and location
specific.
Paragraph 3.15 suggests developments provide "...continuous and
generous footpaths to meet the needs of all users...". Thakeham
suggest that the term ‘generous’ is subjective and
either this should be clearly defined, or more appropriately linked
to relevant guidance.
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·
Noted and will review points individually
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78
|
GOAL:
A place that is easy to get to and move through for all
users
The SPD refers to various cycling and parking requirements, but in
effect is unable to provide the comprehensive advice that is given
in the documents referenced in the SPD (such as LTN1/20), and that
will soon be supplemented by the updated Manual for Streets. These
sections of the guide should therefore be removed as they do not
add any further clarity to the National Design Guide, Local Plan
Policies or the referenced documents that already provide
comprehensive guidance.
Design principles 3.6 and 3.7 seek to ensure that new homes are
located within 800m of facilities and services, 400m of a bus stop,
and preferably within 600m of a primary school and 1500m of a
secondary school. These design principles do not reflect policy,
and should be proposed as targets rather than requirements. There
may for example be circumstances where it is preferable to separate
bus stops by further than 400m (for example to avoid delaying fast
services).
To reflect the status of the SPD, it should not state that
applicants should ‘ensure’ that a scheme adheres to
specific principles, but instead should state that development
schemes which seek to follow the principles set out will be
supported.
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·
Noted and will review points individually
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79
|
Response
manually entered, submitted in an email format.
Design Principles
The reference to creating a 20-min Neighbourhoods (Para 3.0) would
benefit from definition and whilst desirable is not always
achievable due to a number of factors including site
constraints/shape.
The reference to locating ’services and facilities’
within 800m of homes (Para. 3.6) requires some clarity in terms of
the types of services and facilities and also recognition that 800m
will not always be achieved due to site
constraints/shape.
Streets as Spaces
The street typologies identified at Figures 14-17 would benefit
from being outlined in the context of addressing OCC parking
standards as part of the design of any street typology.
Design Principles - Street Design
The reference to the use of tree planting as opposed to street
bollards (Para. 3.24) should be recognised in relation to other
competing street demands (e.g. utilities, street lighting,
visibility splays).
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·
Noted and will review points individually
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80
|
Parking
The guidance on parking, particularly on-street parking and
encouragement of cycling, car pools, etc is clearly biased toward
town and city dwelling and inappropriate for rural locations where
there is inevitably greater dependence on cars.
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|
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Comment
|
Council’s
response
|
1
|
Too
many words.
Too many pages.
Too many concepts.
Too much everything.
YOu get the idea.
The guide is too elaborate and lengthy.
Nice concept.
Poorly implemented.
|
·
Noted.
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2
|
This
section provides minimum amenity space requierments and property to
property distances which is brilliant. But there is no reference to
minum floor space requirements inline with National Space
Standards? It's essential this is included to ensure good design.
That said, it makes no logical sense that an apartment building
requires 40sqm of amenity space but a 1 bed requires 36sqm.
Further, the wording is poor and suggests that an entire apartment
building can be served by a single 40sqm amenity area, it should be
made clear this is multiplied per unit within the building.
It also makes no sense that terraced housing should have reduced
requirements from non-terraced housing.
The design guide should provide advice on the design and location
of garaging and parking.
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·
Noted and will review
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3
|
Space
for trees is disregarded yet is the essential of a wildlife
friendly site.
|
Noted.
The natural environment section does cover minimum space that
should be allowed for trees
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4
|
Meaningless
|
·
Noted.
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5
|
I am
not sure why gardens need to be rectilinear. Historically gardens
may well not have been so, and this adds character and
individuality to properties, avoiding the mass produced look of a
development leads to good design.
|
·
Noted and will review
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6
|
As
previous, looks great but the proof will be in the finished product
and how it is maintained. Will these spaces be managed by the
council or will residents have to pay for a management company to
maintain the grass verges etc and what guarantee will be in place
to prevent price hikes
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·
Acknowledged
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7
|
Most
new developments in this region seem to maximise the use of land
resulting in high density. Creating easily accessible and
preferably integrated high quality space is undervalued. For
example, placing a recreational space in one corner of a
development is not necessarily the best way of providing space
accessible to everyone.
|
·
Noted.
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8
|
The
existing Vale design guide is very clear, and yet in Faringdon we
see multiple large developments being approved which skip the
guidance . A cursory look at multiple exits and entry suggestions,
space for growing food, movement framework, etc. shows there is
little point in making new guides, if the implementation of
existing guides is so poor. If the same people and processes are at
work in the approval process, there is no point in investing in new
guidelines.
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·
Noted.
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9
|
with
much new land it is time to connect all the transport sources and
make it cheaper to travel by train or bus.
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·
Noted.
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10
|
Everything
is about ""parking"". Nothing is said about the storage of mobility
scooters or bicycles. Must say more about provision of secure
storage for mobility scooters & bicycles. Lumping the storage
of mobility scooters & bicycles alongside bins as something
that unsightly is simply wrong. It should be a design principle
that an equal number of ""Sheffield Stand"" style bike racks be
provided to the number of car parking spaces. ""Developers should
consider the promotion of car clubs/ rural car clubs"" this should
be supported by a design principle to require the provision of
parking spaces only for ""car club"" cars.
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·
Noted.
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11
|
Over
the past 10 year the new housing develops in Didcot have been
designed to pack as many houses into a hectare to maximise profit
per unit. The developers suggest that is to make the houses
affordable (but unit prices remain high possibly because many
buyers are subsidised by the Government). At the same time green
spaces are reduced or removed. On Western Park some of the houses
are so close that you can touch your neighbours if you lean out of
the first floor windows. If some of the development are 3 storey,
e.g. over shops (but not 4 floor or more), and some green space is
incorporated; this gives a better sustainable environment, and
keeps the buy in prices reasonable.
|
·
Noted.
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12
|
Include
employment zones, retail and leisure to cut down the need for
travel
|
·
Noted.
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13
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Amneity
parameters is the best bit of the whole doucment so far
|
·
Noted.
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14
|
concern
that the principles may be used by officers without an ability to
discern intuitive and skilful design innovation
|
·
Noted.
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15
|
See
above plus what about playing fields and formal/informal
recreational spaces? I suggest looking at our activity hubs which
can be found on the above web link.
Careful consideration is required for the long term maintenance of
these areas is fundamental to ensure the spaces continue to be
attractive and have longevity .
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·
Noted and will review
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16
|
Houses
need decent size gardens
|
·
Noted.
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17
|
We
must do better than the higgledy piggledy, bits and pieces
developments currently in vogue.
|
·
Noted.
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18
|
Never
followed due to commercial drive to maximum amount can build on a
piece of land. Buildings not built in brick/natural stone
courtyard-styles as builders synnical about maximizing profit of
space.
Need views, open areas and courtyard spaces....unless these forced
developers will only comply in high conservation areas like the
Cotswolds.
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·
Noted.
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19
|
Good,
but little attention to achieving continuity of 'green cover' and
visual landscape structure through age diversity. That is difficult
when faced with spatial constraints.
I need to mention LITTER somewhere. It is a national scourge! I see
not reference in the guidelines as to how to overcome/minimise the
problem through a combination of continual design and management
education at all levels, especially in schools, colleges and
universities. The threat of penalties doesn't work - how about a
combination of rewards and incentives? maybe with some penalties
that are enforceable ?
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·
Noted.
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20
|
Biased
towards developers, create a summarised version for
householders
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·
Noted and will review
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21
|
page
not working
|
·
Noted.
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22
|
Variable
styles of houses preferred to allow the various types of families
and the elderly to be accomadated. Meeting places such as ""village
Halls"" to enhance life are essential.
|
·
Noted.
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23
|
Would
like to see reference to Neighbourhood Plans
|
·
Noted.
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24
|
This
is one of the sections where you helpfully give mention to EV
charging. However, the guide would I believe be much more impactful
if you took this topic a stage or two deeper. For example, it's
important to explain that not all EV chargers are the same (in
regard to their kW capacity and rate of delivering charge) and the
right chargers are needed in the right places. For example,
supermarkets or short stay carparks that provide 7or 11kW charge
points are doing little more than greenwashing; on the other hand,
visitors passing through our communities and stopping off to use
local facilities for an hour, need a Rapid charger (50kW minimum).
The rapid chargers are very valuable for on-route recharging but
are more costly devices; there are charge point operators who will
install them at their own capital cost (and make their return
through a margin on the relatively large amount of energy they
handle) but they won't invest unless the charge points are secure,
well-sited and visible... These are planning and design
considerations, so I suggest relevant to your Guide. We have looked
into many of these aspects in Thame and Thame Green Living
organisation would be pleased to share its findings and
experiences.
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·
Noted and will review
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25
|
As
above, space and layout have a major impact on the sounding
environment eg sound baffling measures where developments are
located close to A roads or bypasses eg the Slade End development
(Wallingford OX10) which is built next to the Wallingford bypass;
or the development inEast Didcot on the A4130 just East of the
Tesco/Halfords Development. This is hard on the road with no sound
baffling measures. Similarly as Great Western Park sweeps down to
meet the road to Milton Park there is no sound baffling. The
proximity of the road, the type of road surface, the speed limit
all contribute to the auditory well-being of those living in the
development. This does not seem to have been taken into
consideration at all.
|
·
Noted, we consider the impact of noise to be important, however
this is covered by criteria outside of the design
guide.
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26
|
I
found the figures in this section to be confusing.
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·
Noted and will review
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27
|
Parking
policy is vital, as too many houses are built without parking,
leading to an increase of on-street parking, parking on pavements,
and obstructing traffic
|
·
Noted.
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28
|
These
principles are sound on paper but are very abstract - too much room
for interpretation - local communities need to be able to influence
these factors as part of the approval process - eg after planning
agreed in principle - local communities need more authority over
the designs - after all they will be living with the results. I am
mindful of the proposed development in Watlington - a well
integrated thriving community - what measures are used to insure
this in maintained and enhanced?
|
·
Noted
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29
|
Consider
developing communities within communities.
|
·
Noted.
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30
|
Creative
and challenging play areas for small children with seating for
parents/grandparents, including trees for shade in summer and
separate for adventure playgrounds for teens to be supplied in
quantity by developers on ALL new development sites in proportion
to the number of properties being built. ie - developments of 100
properties = one of each. Developments of 200 = 2 of
each.
|
·
We cannot insist on this approach but recommend as much tree
planting as is applicable to each site on a case by case
basis.
|
31
|
And
yet again, only relevant to major developments.
|
·
Noted.
|
32
|
Good
|
·
Acknowledged
|
33
|
as
above I would like to see a greater conservation and natural
habitat preservation contribution to the use of space. Developers
often produce cosmetic but unnatural space development
|
·
Noted.
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34
|
High
density housing is inappropriate in rural areas/edges of small
towns and villages
|
·
Noted and will review
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35
|
There
is an estate on Cumnor Hill (Kimmeridge Road) that is so squashed
up there is no room for the dustbin lorry to pass. The road through
the estate is so narrow and there is no room for visitors to park.
All the houses seem to be built on top of each other, it looks so
untidy and will certainly look like a slum in a very short
time.
|
·
Noted
|
36
|
resist
building so closely that you cannot provide garages and gardens and
playgrounds for children.
|
·
We agree and recommend it as best practice.
|
37
|
It
might be preferable to write the principles in bullet points and/
or emphasise key words in bold or italics.
|
·
Noted and will review
|
38
|
As
above! Consistently well-formatted, with enough detail not to leave
things ambiguous but easy to access from the point of view of a
member of the public.
|
·
Acknowledged
|
39
|
no
reference found to the role of neighbourhood plans in space and
layout
|
·
Noted and will review
|
40
|
not
enough
|
·
Noted.
|
41
|
There
seem to be a lot of rigid rules in this section e.g. 4.3. Are these
rules enforceable? And can they be maintained when small infill
developments are proposed? I think that you may be encouraging
subsequent householders to fill in gaps which may have been
deliberately left to meet the design principle which you rightly
regard as important.
Also building which face outwards when on the edge of a
development, can end up facing a massive housing estate some years
later (NE Didcot for example affects the outlook of the homes on
the edge of Ladygrove.)
The private amenity space rules at 4.11 seem to mirror current
rules. Current rules are however unenforceable, and take no account
of whether the setting is designed to be lower density by virtue of
being towards the countryside edge. The guide needs to ensure that
space and layout at the edges of communities is safe from future
development.
|
·
Yes these rules are enforcable regarding standards.
|
42
|
Again,
the emphasis is exclusively urban.
|
·
Noted and will review
|
43
|
No
adverse comments. Seems clear enough.
|
·
Noted
|
44
|
the
more space between neighbours the better
|
·
Noted.
|
45
|
This
section could also benefit from a reference to context, which can
be found in neighbourhood development plan (NDP) village character
area appraisals.
|
·
Noted.
|
46
|
We
have no specific comments to raise in this section which follow
well established principles of good design.
|
·
Acknowledged
|
47
|
The
small section on 'Play space and youth provision' is quite
uninspiring. I suggest looking at
https://ribabooks.com/Urban-Playground-How-Child-Friendly-Planning-and-Design-Can-Save-Cities_9781859469293
It shows how urban designers and city planners can incorporate
child friendly insights and ideas into their masterplans, public
spaces and streetscapes.
|
·
Acknowledged
|
48
|
Response
manually entered, submitted in an email format.
1. This section is very useful, especially on outdoor amenity space
and the spacing apart of buildings.
|
·
Noted.
|
49
|
Response
manually entered, submitted in an email format.
Space and Layout - Amenity and Space Standards
Whilst HLM are supportive of the national space standards, the
Guide must adhere to Footnote 49 of the National Planning Policy
Framework (July 2021) which requires LPAs to evidence need,
viability and timing to support their implementation.
HLM do not support the imposition of private amenity standards
which go beyond the scope of national standards which, where
justified, relate solely to internal spaces.
|
·
The guide follows National space standards. It does however refer
to them as a comparative measure to garden
sizes.
· The guide does not ask for standards beyond National space
standards.
|
50
|
Response
manually entered, submitted in an email format.
1. The Guide should ensure that there is adequate parking as the
number of vehicles should not be expected to reduce even if the
number of journeys does.
2. Rules on parking should ensure that there is adequate electric
charging capacity available securely.
8. The Guide should consider whether some developments should be
laid out with housing near to small office/workshop to reduce
travel to work.
|
·
This comment raises issues that fall outside the scope of the
design guide.
|
51
|
Stand
alone solar farms need some guidelines as to how they will fit into
their context, and how we can make sure they are safe for residents
and other land users. Can we promote and encourage south facing
rooflines in new development so that solar panels are possible and
effective? I think we need to use all our rooftop spaces
well.
|
·
This comment raises issues that fall outside the scope of Space and
Layout. These issues are raised in other sections of the
guide.
|
52
|
Goal,
second paragraph. Please add after 'a range of densities, building
types and forms will be required.' -- The development of smaller
homes is to be encouraged, both to address the local shortage of
affordable homes and to build dwellings with a smaller carbon
footprint.
Inform your design, first paragraph after 'as well as the character
of the landscape.' -- the shortage of and demand for affordable
homes,
Please include principles in the 4.1 series:
- Dwellings should be fitted with underfloor heating to facilitate
movement to heat-pump heating.
- Dwellings should include storage of roof run-off to allow for
garden watering or dirty water systems in the future.
Principles 4.3: Include: Proposals for affordable homes will be
considered where these distances are not achieved.
Please add new principle: Smaller dwellings in terraces and blocks
should have access to communal outdoor amenity space.
Design Principles Parking, please include: Parking areas should be
provided under multi occupancy blocks.
|
·
Noted and will
review
· We cannot insist on this approach (regarding
heating).
· Run off water is covered under
sustainability.
· Housing mix must be tender blind. We cannot specify
requirements for affordable housing within the
guide.
· Parking scenarios will be reviewed.
|
53
|
4.3 -
Back to boundary - it would be useful to clarify that this is back
of dwelling (rear wall rather than conservatories/pods)
4.11 - Amenity space - it would be useful to separate 3 and 4 beds,
rather than 3+ beds, and having 75sqm and 100sqm respectively.
Terraced house calculation is welcomed. West Oxfordshire also have
garden to be same as the footprint of the house. Should say that
the majority of the scheme is in compliance as there are often
physical constraints or development block shapes.
4.25 - A break of the size equivalent to a parking space seems
larger than required and can cause parking spaces to mis-align with
the dwelling (in front of another owners house) - a tree can be
planted within a 1.5m wide area.
4.30 - Porous materials for driveways - This is not practical
– many sites cannot deliver porous drainage due to ground
conditions and strategy should be considered on a site by site
basis.
4.32 - EV charging - OCC recently adopted street design guide is
more pragmatic (every plot with on-plot parking) and the guidance
should correspond/refer to OCC policy.
4.49 - This may be site specific and should be considered through
the submission of the phasing plan and/or conditioned if
required.
|
·
Noted and will review
|
54
|
variety
of frontage and roof line, rhythm, and visual interest are
important and welcome - but not buildings which violently clash
with those around them. Buildings which aren't obviously ""in
tune"" with the locality must be of exceptional architectural
merit. Energy efficiency is not, by itself, a ""get-out-of-jail""
card, if it is otherwise destructive of harmonious
community.
|
·
Noted
|
55
|
The
section on parking is completely off-track for a zero carbon
development. It's clear the author of this section is totally
unaware of the likes of Vauban where cars are not allowed to park
in street adjacent to housing. This section would therefore deter
developers from creating exemplar modules of housing designed for
the future. Car ownership is already on a downward trend it is
highly likely that car sharing, electric bikes and cargo bikes plus
new shopping and work patterns will change quite considerably in
the future. Therefore, promoting car parking along streets is very
irresponsible in this case.
|
·
Noted.
|
56
|
SPACE
AND LAYOUT FRAMEWORK AND STRUCTURE :
FORMATTING: Needs a chapter/subsection number for reference. Could
an interactive mini contents list be included under each chapter
title/heading for easier navigation of the sub-sections, to avoid
scrolling? Principles should really be first, and then follow up
with explanation text, diagrams and helpful links below.
[4.3] SPECIFIED DISTANCES: Please could this principle wording
specify that it would be "facing habitable upper-floor windows".
The diagrams infer this, but it may be could for the wording to
specify this for the avoidance of doubt.
PLOTS AND AMENITY:
FORMATTING: Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below. **Officers note
that location of the principles box needs to be relocated –
as currently under ‘storage and facilities’.
SUBTEXT FOR "Neighbouring Amenity"
(above Figure 25) - ‘Proposals should not give rise to any
unacceptable harm.’ Officers commented that it’s not
possible to say that there won’t be any harm. Policy DP23
makes reference to significantly ‘adverse’ harm. Unsure
of South Local Plan wording, but is Officers recommend that
consistent wording is used. Perhaps the wording could be changed
to: "Unacceptable impact’ rather than
‘harm’.
[4.11] AMENITY SPACES are all included under "Detached or
Semi-Detached Dwellings should have a minimum of" – the
amenity space for terraced properties and apartment buildings may
need to be under their own separate heading.
[4.11] JARGON ACRONYM "GIA" – It is recommended that the full
wording for ‘gross internal area’ is used
[4.12] GARDEN SHAPES - Without an accompanying definition, Officers
consider that the sentence "Awkward shaped gardens should be
avoided" could be left open to interpretation. It is recommended
that the wording is changed to include "Awkwardly shaped, or
unusable, garden areas should be avoided". This could also then
capture unusable garden space located under huge trees.
[4.16] BOUNDARY TREATMENTS – Please could the wording at the
end of this sentence be strengthened more? For example; changing it
from: Visible boundary treatments in public areas need to have
cohesive treatments and strongly avoid close board fencing; to:
Visible boundary treatments in public areas need to have cohesive
treatments. Close-boarded or panel fencing is generally not an
appropriate boundary treatment for prominent location, such as
street frontages".
STORAGE, SERVICES AND UTILITES :
FORMATTING: Needs a chapter number for reference. Principles should
really be first, and then follow up with explanation text, diagrams
and helpful links below.
[4.18-4.22] INFOLINK vs PRINCIPLE WORDING Please could the bin size
standards/ waste storage be included in the principle wording .
Perhaps along the lines of "that the relevant waste storage methods
are in accordance with current District standards" (and include
those standards within the wording if possible?) There is a link in
the "Supporting Your Design" section, but this makes reference to
outdated policies.
PARKING STRATEGY AND SOLUTIONS ~
FORMATTING: Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below. **Does the
title need to be written in bold purple too?
[4.24] PARKING: Policy CP35 of Local Plan 231 Part 1 refers to the
standards in the current Design Guide, so reference could also be
made to the Oxfordshire County Council parking standards.
[4.31] GARAGES: The Garage standards referred to in ‘BUILT
FORM’, should really be included here if possible. Could the
link to current on-plot car parking standards be included within
the principle wording? Officers are mindful that most people will
be looking at the principle boxes for the main sources of
information.
[4.23-4.34] OCC STREET DESIGN GUIDE: Officers raised concern that
OCC are planning to adopt a Street Design Guide soon and queried
how much overlap there would be between the Districts Design Guides
and the County’s Design Guide
|
·
Noted and will review points individually
|
57
|
Clearly
set out, so no comments
|
·
Acknowledged
|
58
|
The
Role of an SPD
As highlighted in Bloor Homes’ response to Question 9, the
NPPF, PPG and recent case law have clearly established that the
role of an SPD is to provide guidance in relation to existing
policies in adopted local plans, and that it is not within the
remit of an SPD to introduce new policy requirements. Rather, they
have highlighted that the introduction of new policy requirements
should be deferred to local plan reviews, where impacts on
viability can be considered. To reflect the scope of SPDs,
therefore, the Design Guide SPD should not state that applicants
should "ensure" that a scheme adheres to specific principles, but
instead should state that development schemes which seek to follow
the principles set out will be supported.
Density
Bloor Homes welcomes the reference within design principle 4.0
that, in achieving an effective use of land, increased densities
may be utilised in appropriate locations, and that higher density
sustainable developments are encouraged by the Councils. That is a
wholly appropriate approach to ensuring that schemes utilise the
land available in an effective manner (as is required by NPPF
paragraph 199).
Separation Distances
Bloor Homes also notes the proposed minimum separation distances as
set out within the draft Design Guide SPD, which seek back-to-back
separation distances of a minimum of 21 metres between facing
habitable rooms, back to boundary distances of a minimum of 10.5
metres, back to side distances of a minimum of 12 metres, and front
to front distances of a minimum of 10 metres. Whilst those
separation distances appear to be reasonable as a starting point,
Bloor Homes welcomes the flexibility provided within design
principle 4.3; which allows applicants to "demonstrate how the
design proposals ensure that privacy is maintained" when those
separation distances are not met. That is an entirely sensible and
appropriate approach that allows some flexibility for schemes to
respond to site-specific considerations; for example by
incorporating areas of higher density development where reduced
separation distances could be sensitively accommodated whilst still
maintaining the privacy and amenity of new and existing
dwellings.
Moreover, the inclusion of Figure 27, which demonstrates how
appropriate separation distances may be achieved between dwellings
at differing ground levels, is also useful guidance and is
therefore welcomed.
Internal Amenity Space
In relation to internal amenity space, it is noted that the Design
Guide SPD makes reference to developers and applicants having
regard to the space standards set out in the Nationally Described
Space Standards (NDSS). Whilst it is noted that the adopted Local
Plan Part 2 for the Vale of White Horse District and the South
Oxfordshire Local Plan require one and two-bedroom market homes and
all affordable housing to be in accordance with NDSS Level 1 (as
per Development Policy 2 in the Vale’s Plan, and Policy H11
in South Oxfordshire’s Plan), that is not made sufficiently
clear within that passing reference.
External Amenity Space
The minimum private amenity spaces that are set out in design
principle 4.11 are also noted. As above, Bloor Homes welcomes that
the design principle / guidance provides some degree of flexibility
where those areas cannot be achieved, subject to the applicant
providing robust justification for that departure from the
guidance.
With that said, however, Bloor Homes does have some comments on the
suggested private amenity spaces set out in design principle 4.11.
Whilst the suggested private amenity spaces for 1-bed houses (+=
36m2), 2-bed houses (+= 50m2), 3+ bed houses (+= 100m2) and
terraced houses (+= 80% of the GIA) appear sensible, those
suggested external amenity spaces will inevitably have an impact on
the site layout, the ability to achieve an efficient use of land,
and the viability of the scheme. It would be sensible, therefore,
for the Design Guide SPD to clearly allow for flexibility within
schemes, reflecting that the SPD is, by its nature, a guidance
document rather than planning policy.
Moreover, there is some confusion in relation to the suggested
standard for apartment buildings; which refers to += 40m2 or shared
space. In the first instance, it is currently not clear whether
that relates to a standard of 40m2 per apartment, or whether that
is a standard for the entire apartment block. The approach that is
being taken by the Councils will need to be clarified to ensure
that the guidance is clearly written and unambiguous, as required
by NPPF paragraph 16d.
If the former approach is taken (i.e. a per unit standard), that
would appear counter-intuitive in that; (i) a standard of 40m2 for
a 1-bed apartment would exceed the 1-bed house standard (36m2),
(ii) a blanket standard for all apartments, regardless of their
size, would not be appropriate for schemes with larger apartment
units. Conversely, however, if the latter approach is taken, a
combined standard of 40m2 for each apartment block may not be
appropriate. In the instance of a 3-storey, 6-dwelling block, for
example, that would clearly not be a sufficient amount of amenity
space for the residents of the block.
Therefore, it is suggested that, rather than seeking to set
external space standards for apartment blocks, the SPD seeks to
ensure that apartment blocks are served by "adequate outside
amenity space". That would provide the flexibility required to
ensure that the quantum and type of external amenity space responds
to the needs of its residents.
Front gardens
Similarly, the wording of design principle 4.14 is unclear as
currently drafted, and gives rise to some concerns in relation to
the practical application of this guidance. Currently, that
principle states that schemes should have front gardens with
"planted or permeable areas" of "no less than 1m in depth on higher
order streets, increasing in size in line with the street
hierarchy, density and sense of enclosure." However, that wording
could be read in a number of different ways, and thus should be
re-written to provide clarity and appropriate
flexibility.
However, whilst the wording of the design principle should be made
clearer, it should also allow for some flexibility in any event. It
would be incorrect, for example, to suggest that garden lengths
alter in line with the street hierarchy, which appears to be the
suggestion in design principle 4.14. Rather, flexibility should be
given to allow for a bespoke response to plot designs (and
specifically front garden sizes, in this instance). For example, at
larger sites that have a range of streets across the hierarchy, it
may be more appropriate for dwellings on higher order streets to
have very shallow front gardens, with garden sizes then increasing
when heading down the hierarchy where the density of development
becomes lower (i.e. in fringe locations). In other sites, however,
the garden length may reduce further down the street hierarchy. For
example ‘mews’ style areas may incorporate much smaller
gardens (or no garden at all) in order to create a specific sense
of character in those locations. Therefore, to suggest that garden
sizes should increase / decrease linearly to reflect the street
hierarchy would not be accurate. As such, considerably more
flexibility should be built into design principle 4.14 to allow for
front gardens to respond to the site, the sense of character that
is being pursued, and the nature of the street typology.
Parking and Electric Vehicle Charging
It is noted that "in the absence of County Council standards",
design principle 4.32 recommends "one (on plot) EV charging point
per dwelling" and that, where parking is provided communally
(courtyards and flats) "at least two EV points are recommended."
That is not, however, a requirement that is included in the adopted
local plans of either authority, nor is it a County Council
standard.
As such, design principle 4.32 effectively seeks to introduce a new
development requirement, which is outside of the remit of an SPD.
Indeed, that is discussed in Bloor Homes’ response to
Question 9, which highlights the position of the NPPF, PPG and
recent case law that SPDs should not seek to introduce new
development requirements or have any additional cost implication
(over and above adopted policy requirements), and instead that
their scope is to provide additional guidance in relation to
existing policies in adopted documents.
That is particularly prevalent in relation to recommendations for
EV charging, given that the Department for Transport’s
‘Electric Vehicle Charging in Residential &
Non-Residential Buildings’ in October 2019 set out the
Government’s proposals to implement a nationally standardised
approach to EV charging through a new functional requirement under
Schedule 1 to the Building Regulations 2010. To seek to implement
such a standard through an SPD (contrary to the role of SPDs) ahead
of that would, therefore, be in opposition to the
Government’s intentions in that regard. From a point of
principle, therefore, the introduction of EV charging standards
should be deferred, at the very least, to the emerging Joint Local
Plan, or be deferred to an update to the Government’s
Building Regulations.
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Noted and will review points individually
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59
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No
mention of neighbourhood plans. Building to edge of boundary and
neighbouring buildings not included. Street boundary not
emphasised.
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Noted and will review
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60
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EV
charging points should be available for all vehicles (cars, cycles
etc) and not just consideration given to this. Otherwise a good
section.
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Noted and will review
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61
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Please
refer to submitted representations.
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Noted
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62
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It is
vital that Oxfordshire County Council as Highway Authority are full
on board with the parking solutions especially integrating
on-street parking and street trees. Adoption standards need to be
reconciled fully with District urban design aspirations.
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Noted
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63
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Response
manually entered, submitted in an email format
The picture of Tadpole Garden Village
This picture with its large expanse of glazing shedding light over
the countryside is not appropriate and should be replaced with one
creating less light pollution.
Design principles - Space and Layout Framework and
structure
4.0 Space is a finite resource and maximum effort must be put into
obtaining the highest densities. This includes rural areas and
villages where the tradition of terraced cottages provides both
lower cost housing and a solution to the challenge of
density.
Suggested addition: Provide links to resources showing good
high-density developments in rural & urban settings.
Storage, servicing and utilities
In the Steps section – Communicate your design it says
"Prepare a plan showing the routes for service vehicles to access
each building/dwelling, also known as a Swept Path Analysis or
Vehicle Tracking Plan.
Service vehicle access is often obstructed by parked vehicles
causing them to mount, and damage, paths or green boundaries.
Designers should be encouraged to devise means of preventing such
parked vehicle obstructions noting that parking restriction
markings are often ignored through lack of enforcement. Good design
does not rely on human behaviour.
Design principles - Open space
We would like to see open & greens spaces incorporate pathways
suitable for wheelchair users and pushchairs – such as bound
gravel.
Design principles – play space & youth provision
design
Spelling correction: 6.64 should read quiet space, not quite
space.
Resources
The Oxfordshire County Council Street Design Guide, must be
included as a resource.
https://www.oxfordshire.gov.uk/residents/roads-and-transport/transport-policies-and-plans/transport-new-developments/transport-development-control
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64
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Needs
to give examples of good high-density developments within South
& Vale districts, especially examples in rural areas in
addition to the example of the Tadpole Garden Village in Swindon.
For example, Farm Place, Henton, OX39 4AD - P90/N0765.
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Noted and will review
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65
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Should
also include any design guides in the Neighbourhood Plan -
Neighbourhood Plans are missing from this guide.
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Noted and will review
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66
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Response
manually entered, submitted in an email format.
No comments.
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Noted
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67
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The
Space and Layout chapter also makes no reference to climate
change.
This is not a matter of complying or not with pollicies in the
existing Local Plans. It is an attempt to deal with the climate
emergency (and the ecolological emergency but that is better
catered for in the Natural Environment chapter although I would
like to have had more references to the need for continuous nature
corridors in that.
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Noted and will review points individually
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68
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Response
manually entered, submitted in an email format.
Space and Layout (Design Principles – Space and Layout
Framework and Structure)
The principles proposed are effectively a continuation of the
standards included within the Vale of White Horse Design Guide
(March 2015).
Gladman welcome the flexibility proposed in the design principles
for space and layout framework, namely in criterion 4.3 which
allows for applicants to demonstrate that design proposals still
ensure privacy.
It is considered that Criterion 4.10 should be reworded for greater
clarity, Gladman propose the following text for your
consideration:
"4.10 avoids awkward/vulnerable corners within the design proposal
arising from left over space, ensuring safety, land efficiency and
a clear definition of public and private space"
Space and Layout (Design Principles – Private
Amenity)
Again, the suggested minimum amenity space sizes are a continuation
of the guidance provided in both the South Oxfordshire Design Guide
(2016) and the Vale of White Horse Design Guide (March 2015). In
this respect, we also welcome the ability for these to be
approached on a case-by-case basis, where needed, as there may be
some instances where deviation from the proposed guidelines is
required.
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69
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Space
and Layout Framework and Structure
Bloor Homes welcomes the reference within design principle 4.0
that, in achieving an effective use of land, increased densities
may be utilised in appropriate locations, and that higher density
sustainable developments are encouraged by the Councils. That is a
wholly appropriate approach to ensuring that schemes utilise the
land available in an effective manner (as is required by NPPF
paragraph 199).
Separation Distances
Bloor Homes also notes the proposed minimum separation distances as
set out within the draft Design Guide SPD, which seek back-to-back
separation distances of a minimum of 21m between facing habitable
rooms, back to boundary distances of a minimum of 10.5m, back to
side distances of a minimum of 12m, and front to front distances of
a minimum of 10m. Bloor Homes welcomes the flexibility provided
within design principle 4.3; which allows applicants to
‘demonstrate how the design proposals ensure that privacy is
maintained’ when those separation distances are not met.
There are many award winning schemes where these standards are not
met (for example, Goldsmith Street in Norwich and Barton Park in
Oxford). Where higher density development is appropriate and the
use of land needs to be optimised, a reduction in the back-to-back
distances in particular will be necessary. Reduced separation
distances to those set out can be sensitively accommodated in most
developments whilst still maintaining the privacy and amenity of
new and existing dwellings.
Internal Amenity Space
In relation to internal amenity space, it is noted that the Design
Guide SPD makes reference to developers and applicants having
regard to the space standards set out in the Nationally Described
Space Standards (NDSS). Whilst it is noted that the adopted Local
Plan Part 2 for the Vale of White Horse District and the South
Oxfordshire Local Plan require one and two-bedroom market homes and
all affordable housing to be in accordance with NDSS Level 1 (as
per Development Policy 2 in the Vale’s Plan, and Policy H11
in South Oxfordshire’s Plan), that is not made sufficiently
clear within that passing reference.
Private / External Amenity Space
Bloor Homes welcomes the flexibility in these suggested standards
where those areas cannot be achieved, subject to the applicant
providing robust justification for that departure from the
guidance. In some cases, in particular where higher densities would
optimise the use of the land, these standards are likely to impede
good design. There are already a number of higher-density award
winning schemes across the county that would contravene these
standards.
Whilst the suggested private amenity spaces appear sensible, they
will inevitably have an impact on the site layout, the ability to
achieve an efficient use of land, and the viability of the scheme.
It would be sensible, therefore, for the Design Guide SPD to
clearly allow for flexibility, reflecting that the SPD is a
guidance document rather than planning policy.
Front gardens
The wording of design principle 4.14 is unclear as currently
drafted, and gives rise to some concerns in relation to the
practical application of this guidance. It is incorrect to require
that garden lengths alter in accordance with the street hierarchy
(which is required in design principle 4.14). Rather, flexibility
should be given to allow for a bespoke response to plot designs
(and specifically front garden sizes, in this instance). For
example, it may be appropriate to have larger gardens on primary
streets where a sense of openness is sought, and on lower order
streets, ‘mews’ style areas may incorporate much
smaller gardens (or no garden at all) in order to create a specific
sense of character in those locations. Therefore, to suggest that
garden sizes should increase / decrease linearly to reflect the
street hierarchy would not be accurate. As such, flexibility should
be built into design principle 4.14 to allow for front gardens to
respond to the site, the sense of character that is being pursued,
and the nature of the street typology.
Parking and Electric Vehicle Charging
It is noted that ‘in the absence of County Council
standards’, design principle 4.32 recommends ‘one (on
plot) EV charging point per dwelling’ and that, where parking
is provided communally (courtyards and flats) ‘at least two
EV points are recommended.’ That is not, however, a
requirement that is included in the adopted local plans of either
authority, nor is it a County Council standard.
Design principle 4.32 effectively seeks to introduce a new
development requirement, which is outside of the remit of an SPD.
The NPPF, PPG and recent case law indicate that SPDs should not
seek to introduce new development requirements or have any
additional cost implication (over and above adopted policy
requirements), and instead that their scope is to provide
additional guidance in relation to existing policies in adopted
documents.
That is particularly relevant in relation to recommendations for EV
charging, given that the Department for Transport’s
‘Electric Vehicle Charging in Residential &
Non-Residential Buildings’ in October 2019 set out the
Government’s proposals to implement a nationally standardised
approach to EV charging through a new functional requirement under
Schedule 1 to the Building Regulations 2010. To seek to implement
such a standard through an SPD (contrary to the role of SPDs) ahead
of that would be contrary to the Government’s intentions. The
introduction of EV charging standards should be deferred to the
emerging Joint Local Plan, or an update to the Government’s
Building Regulations.
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Noted
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70
|
Please
see submitted letter for full comments.
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Noted and will review points individually
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71
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High
density, one and two-bed units should be emphasised. We know these
are what we need, and these can be arranged to maximise social
interaction. The Bioregional development in Brighton (by the
station) is highly social (judged by the number of neighbours
people know), has no cars and has high density.
Importantly, there needs to be space for air sourced heat pumps,
which are ugly and can be noisy (if they are cheap). Better still,
community air sourced heat pumps should be provided (district
heating) and heat sold to each home rather than fuel.
Thank you for mentioning car-free developments. These should be
pushed much harder. An external (or underground) carpark can be put
in to provide car-access. Such a space can be repurposed if we ever
get to a car-free or car-low society. Ensure there are many (not
just two) EV charging points in carparks. Such a lot of
hard-surfaced space is wasted on cars sitting unused on forecourts
and roadsides.
Point 4.42 should refer to blue networks too. There should be a bit
more emphasis on waterways - people love water and so does
wildlife.
On play spaces - today we were planting trees at Wilding Rd green
in Wallingford. It has been a desert of grass with no features save
for one tree that all the children run to. The community are
thinking of natural play facilities such as adding a couple of old
tree trunks and willow tunnels. These should be considered as an
option.
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Noted
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72
|
Lighting
important again - not just external but also light coming out of
buildings or attached to buildings.
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Noted and will review points individually
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73
|
Response
manually entered, submitted in an email format.
Framework and structure
• Suggest new wording added to this sentence as follows - The
appropriate size for a perimeter block should strike a balance
between adequate provision for amenity space and parking, while
allowing a permeable and walkable street pattern for all
modes’
• Suggest wording is added to this sentence as follows:
‘Increased densities should be focused on key movement
intersections where public transport facilities are
provided...’
• Suggest wording is added to this sentence as follows:
‘The quality of our streets and spaces can be undermined by
the clutter of bins, bikes and services if these are not properly
designed into the building. Screening and enclosures which add to
the character of a street frontage can be a useful tool in
providing waste storage without detracting from the street
scene.’
• Communicate your design box – the content of this box
appears to be the same as the place and setting design box –
is this intentional?
• Image of Tadpole Garden Village as an example of a
countryside edge development – not sure this is a great
example image. It isn’t sympathetic in design for a
countryside edge due to large areas of glazing causing light spill,
white render likely to be too visually strong, not recessive in
landscape, and homes too uniform, large high and of a repetitive
design. Suggest this image is swapped for something more
sympathetic.
Storage, servicing, and utilities
• Suggest sentence added after last sentence in paragraph, as
follows: ‘When considering bin storage, think of imaginative
solutions that incorporate storage as part of the front façade
and visually screened from the street scene. When designing cycle
storage, consider ease of access, as well as bicycle security, to
ensure the facilities are used as intended’.
• There are lots of great images and examples of innovative
cycle parking design, however it is not mentioned in the
principles. This may not be the most appropriate place for cycle
storage/parking to be added as explained by previous comment about
bike and bin storage being located separately. However, the above
sentence addition and a principle about cycle parking should be
added in the most appropriate place in the guide – example of
potential principle,: ‘creative solutions for attractive,
convenient and safe (secure and overlooked) residential and on
street cycle parking’.
• Figure 28 - Are the garden sheds for cycles? And bins in
the front? How does the top shed get their cycle out? (if the
answer is between the 4 parked cars on the left, this is very
narrow and not ideal for potential scratches to cars).
• Image of ‘cycling storage’ – expand and
state these are folding bike lockers and Sheffield stands or
something similar.
Communicate your design
• Suggested new wording – ‘Prepare a plan showing
the location of bin storage areas and collection points and the
access provided between the two. Include adequate accessibility to
bin storage for those occupiers with mobility issues and
impairments;’ - (it sounds a little like we needed the bin
store to be accessible to waste collection personnel with poor
mobility).
Design Principles – Private Amenity
• 4.11 – ‘+=’ is a little unclear, could we
potentially simplify it to 1 Bed = 36 sqm etc.?
Design Principles – Storage, services and utilities
• 4.18 – this should read ‘recycling, diversion
from landfill and restrict the level of residual....’ Or
volume could be used instead of ‘level’.
• 4.20 - is there a maximum drag distance for waste
collection personnel? If so this should be referred to.
Parking Strategy and Solutions
• Suggest add the following wording to the end of the first
paragraph of the accompanying text ‘...this challenge.
Developments should be future proofed to ensure expensive
retrofitting isn’t required in the future (electric charging
points).’
• Regarding the third paragraph here - this accompanying text
portrays the message that there is a preference for on-street
parking (unlike 4.23 later on), it would be good to provide more
text on the other types of parking here.
• A range/variety approach would be much better than
on-street only. Terraced houses for example, would allow for just 1
parking space per unit (which maybe suitable) but would also result
in all resident frontages having parking in front, and no
opportunity for planting or breaks in on-street parallel parking
(or may cause overspill parking on neighbouring streets), this also
causes issues for emergency vehicle passing, and passing in
general, if the road width is narrow. Equally we do not want too
many vehicle crossovers to garages or forecourts where conflict
between pedestrians and vehicles can occur. This then allows DM
planners to make the decision of appropriateness on a case-by-case
basis.
• The accompanying text in this section states how parking
courts are not successful parking solutions yet Figure 31
illustrates this type of parking. Perhaps it could be explained
that, if other types of parking aren’t possible parking
courts should be designed like this (could link this and 4.28
together).
• Image of ‘Electric charging point (North West
Bicester, Oxfordshire) – this isn’t a great example of
a electric charging point. The actual charging point is concealed
by the bush – could a clearer image be used?
Design Principles – Parking
• 4.24 – Recommend adding ‘Local Plan(s) and
County level car parking standards’.
• 4.25 – should be ‘driveway parking’ or
‘private forecourt parking’ as ‘frontage
parking’ could have meant on street until reading
4.27
• 4.32 – Recommend adding ‘until the emerging OCC
parking standards (which will consider EV charging requirements)
are adopted we recommend...’
• 4.33 - development should attempt to screen parking,
without creating potential target areas for unsociable
behaviour
• 4.34 as per 4.25, please keep consistent with term used
across the two points
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74
|
Response
manually entered, submitted in email format.
Figure 20 (Block Structure) of the draft Design Guide states that
"The structure/layout of a proposal must create or contribute to a
grid form (be it regular or irregular) or perimeter blocks...".
Thakeham consider this type of layout requirement is only suitable
for strategic scale sites and suggest that the councils provide
clarity on how this is to be interpreted for smaller scale sites.
Paragraph 4.2 also requires the use of ‘perimeter
blocks’ and Thakeham would echo the above comments in
relation to this requirement.
Paragraph 4.10 of the draft Design Guide requires developers to
ensure a scheme "incorporates awkward/vulnerable corners into the
proposal arising from left over space in order to ensure land
efficiency, and a clear definition of public and private space".
Thakeham agree that all sites should be designed
holistically.
Paragraph
4.11 prescribes minimum amenity space requirements; however, it is
not clear what standards these are based on and Thakeham would
therefore suggest the evidence is provided in support of these
requirements so they can be better understood. Notwithstanding
this, Thakeham consider these requirements to be generally onerous
and are unable to support them. For example, Thakeham note that the
draft Design Guide requires 3 Bed homes (or greater) to have a
minimum of 100 sqm of amenity space; 16% larger than the Nationally
Described Space Standard for a 3 bed, 2 storey dwelling. Thakeham
query whether it is reasonable to expect a development to provide
more external space than internal space standards. Paragraph 4.12
requires "...gardens that are rectilinear and in the orientation of
the buildings flank walls. Awkward shaped gardens should be
avoided". Thakeham consider that this requirement should be
flexible and related to each individual site. In many instances
sites can be irregular in shape due to land forms and features and
it would be unreasonable to expect developments to provide
rectilinear gardens in this instance – it would also appear
to conflict with the draft Design Guides comments at paragraph 4.10
(see commentary above), in relation to incorporating
‘awkward/vulnerable corners into the proposal’.
Additionally, paragraph 4.13 states that "The size of private
amenity space should reflect the prevailing character of the area.
These are the general/minimum standards for amenity
space...".
Thakeham therefore consider that it is unclear whether the amenity
space requirements are set by paragraph 4.11, or by the
‘prevailing character’ as noted in paragraph 4.13.
Moreover, in instances where there is a conflict it is also unclear
which takes precedence. Thakeham suggest that the councils are
clearer in their requirements for amenity space, along with the
evidence in support.
Paragraph 4.28 of the draft Design Guide suggests that rear parking
courts should be avoided and "These should be a last resort once
all other options have been exhausted". Thakeham would note that
good masterplanning requires strong and active frontages that are
also attractive to the user. In some instances, it can therefore
benefit the development to introduce rear parking areas to relieve
the pressure on the streetscene. This is again something that will
ultimately be site-specific. If the councils are specifically
opposed to this design solution, Thakeham suggest that the
rationale should be clearly explained within the draft Design
Guide. Moreover, Thakeham would note that providing easy access to
cars, i.e., locating them to the front of properties, promotes
their priority in sites and undermines the focus in relation to
sustainability/climate change and the need to promote sustainable
forms of transport. Thakeham therefore consider that the focus
should be on ensuring better access for pedestrian and cycle
use.
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75
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The
space and layout principles give the most concern in the
guide.
We note the reference within design principle 4.0 that, in
achieving an effective use of land, increased densities may be
utilised in appropriate locations, and that higher density
sustainable developments are encouraged by the Councils. That is a
wholly appropriate approach to ensuring that schemes utilise the
land available in an effective manner (as is required by NPPF
paragraph 199). However, this does not go far enough to meet the
requirements, particularly of the South Oxfordshire Local Plan,
which requires higher densities in those development on the edge of
Oxford in order to optimise the use of this former Green Belt
land.
This issue was discussed at length in the South Oxfordshire Local
Plan Examination, and evidence was presented by a number of parties
(including Barton Willmore, that shows densities of greater than
50dph are difficult to achieve, and up to 70dph are not possible to
achieve with the back-to-back and ‘amenity space’
parameters identified in the guide.
The Inspector specifically identified in the Examination that the
current South Oxfordshire Design Guide (which has the same
requirements as the new guide) would become outdated due to the
requirements for higher densities on (for example) STRAT 11 Land
South of Grenoble Road. The requirement for densities in excess of
70dph are not deliverable whilst complying with the standards set
out in the SPD.
Proposals that do not ‘ensure’ the parameters set out
in the SPD do not necessarily result in poor quality development.
On the contrary, many schemes with smaller back garden lengths and
smaller garden sizes, and smaller back-to-back distance than those
identified in the guidance have won design awards. Locally, Barton
Park is an RTPI award-winning scheme that does not wholly comply
with the proposed design principles. Goldsmith Street in Norwich
has also won design awards including the Stirling Prize, and does
not comply with many of the proposed SPD requirements.
We have attached to these representations an appendix with our
evidence to the South Oxfordshire Local Plan Examination. This sets
out where examples of development already consented in South
Oxfordshire (such as at Great Western Park) do not comply with the
guidance; and examples of existing development (such as East
Street, Thame) that comprise good quality development, but have
small gardens or reduced back-to-back distances.
The appendix also provides diagrams that show in order to achieve
higher density developments (such as those required by SODC Policy
STRAT 11m section 3.iv) will need to contravene the proposed SPD
guidance in order to achieve the densities set out by the
policy.
The guidance should therefore specifically recognise that the
proposed ‘rural’ requirements as set out will not apply
to developments delivering the higher densities needed to optimise
the use of land in strategic, edge of town (or city) sites,
including land south of Grenoble Road, STRAT 11 of the South
Oxfordshire Local Plan.
Separation Distances
SOSP notes the proposed minimum separation distances as set out
within the draft Design Guide SPD, which seek back-to-back
separation distances of a minimum of 21m between facing habitable
rooms, back to boundary distances of a minimum of 10.5m, back to
side distances of a minimum of 12m, and front to front distances of
a minimum of 10m. We refer to the comments made in relation to
‘Space and layout’ above, and the attached evidence as
prepared for the South Oxfordshire Local Plan
Examination.
Private / External Amenity Space
Where higher densities would optimise the use of the land, and
where they are required by policy (for example South Oxfordshire
Local Plan Policy STRAT 11, which requires densities in excess of
70dph) the standards will not be achievable in all locations. We
refer to the comments made in relation to ‘Space and
layout’ above, and the attached evidence as prepared for the
South Oxfordshire Local Plan Examination.
Front gardens
The wording of design principle 4.14 is unclear. Garden lengths
should not necessarily alter in accordance with the street
hierarchy (which is required in design principle 4.14). Rather,
flexibility should be given to allow for a bespoke response to plot
designs (and specifically front garden sizes, in this instance).
For example, it may be appropriate to have larger gardens on
primary streets where a sense of openness is sought, and on lower
order streets, ‘mews’ style areas may incorporate much
smaller gardens (or no garden at all) in order to create a specific
sense of character in those locations. Flexibility should therefore
be built into design principle 4.14 to allow for front gardens to
respond to the site, the sense of character that is being pursued,
and the nature of the street typology.
|
|
76
|
4.
The proposed back to back distance standard of 21m is in 4.3 of the
Space and Layout section is supported, but it is considered that
some flexibility should be allowed where circumstances mean that
privacy concerns could be addressed satisfactorily by other means.
flexibility for side to rear is also recommended.
5. Concern Is raised in relation to draft clause 4.28 which states
that parking courts should be a last resort once all other options
have been exhausted. At the same time the guide suggests that a
range/variety or car parking solutions are provided, which relate
to the street order. Parking courts often provide a clear function
for apartments and act to remove parking from the streetscape. It
is considered that parking courts can provide opportunities for
safe and conveniently located parking for apartments. Good design
and landscaping can ensure that they are attractive spaces with
opportunities for good passive surveillance
|
|
|
Comment
|
Council’s
response
|
1
|
Too
many words.
Too many pages.
Too many concepts.
Too much everything.
YOu get the idea.
The guide is too elaborate and lengthy.
Nice concept.
Poorly implemented.
|
·
Noted.
|
2
|
-
Section 5.35 should read 'has been informed...'
- Points 5.38, 5.33 and 5.32 all say essentially the same
thing.
- 'Potentially acceptable in principle' means nothing? if something
is acceptable in principle its acceptable, or its not. There is no
half-way-house The design guide should provide details on set in
and drop down distances etc.
- The entire section should accord for permitted develpment rights
and development that can be built without planning permission. For
example, the two RED box dormers can likely be constructed under
permitted development.
- The design guide should state where landscape plans and 3d models
are required. Also why is it written as 'three
dimensional'???
- Section 5.62 has nothing to do with design and solely relates to
planning policy, should be removed from the design guide.
- Development principles of mixed-use development has nothing to do
with built form and mostly talks about the location and mix of
development rather than its details.
|
·
Noted and will review
|
3
|
Height
restriction in line with existing structures should be maintained
to preserve the character of an area, therefore also its value and
quality of life.
|
·
Noted
|
4
|
1:
What is Built form? Do you mean the eventual shape of the
structure? If so, say so.
2: Predominant Scale and Massing. What?
3:Clear Rhythm of Fenestration? Do you mean matching windows? Who
came up with ""Rhythm of Fenestration""?
|
Built
form is a standard term that encompaises everthing 'built' ie the
design of all buildings or
structures.
Scale
and massing are standard term, these relate to the size and bulk of
a building or structure in relation to surrounding
buildings.
Rhythm of Fenestration is a standard term that relates to the
openings in a building's
facade.
|
5
|
The
landmark feature need not be one of the developments buildings but
could be some other public building - a pub, church, meeting place,
that draws the eye and creates a centre of common
activity
|
·
Acknowledged
|
6
|
The
build quality will be essential. Proper roof drainage and a strong
cement mix will be required as this is where corners are often cut.
They look good but damp and mould ensue in a very short
timeframe.
|
·
Noted
|
7
|
Built
form appears to have been abandoned in this area judging by some of
the new developments.
|
·
Noted
|
8
|
The
existing Vale design guide is very clear, and yet in Faringdon we
see multiple large developments being approved which skip the
guidance . A cursory look at multiple exits and entry suggestions,
space for growing food, movement framework, etc. shows there is
little point in making new guides, if the implementation of
existing guides is so poor. If the same people and processes are at
work in the approval process, there is no point in investing in new
guidelines.
|
·
Noted
·
The new guide will be delivered with training for officers to
ensure the guide is more closely
followed.
·
The more accessible online form of the guide will allow greater
clarity around expectations and its use as a tool to review
development proposals.
|
9
|
all
look like little boxes from the 1950,s Get real and use no brick
houses with sustainable wood and well insulated structures, which
will cost less and use collection of water to recycle and solar
panels will save energy
|
·
We cannot insist on this approach but recommend aspects if it as
best practice regarding sustinable materials.
|
10
|
These
are very helpful.
|
·
Acknowledged
|
11
|
""Respect the
local context"". Local context = The neighboring houses are
faceless characterless red brick boxes, so please build more
faceless characterless red brick boxes.
|
·
We provide information on what the authority expects as regards a
'character assessment'. Where there is a lack of local character
applicants are expected to propose a scheme that has its ow design
merits.
|
12
|
See
11.
|
·
Noted
|
13
|
I
would like to see bungalows in all developments to support an
ageing population, and buildings to incorperate nature friendly
bird bricks
|
·
This would be established through the preapplication or planning
application process.
|
14
|
I feel
that the renovations of old buildings instead of demolition and
rebuild should be favoured as environmentally beneficial as well as
keeping some of our lovely local buildings
|
·
We cannot insist on this approach but recommend it as best
practice.
|
15
|
it is
fundamentally wrong to say that an line side extension is not
acceptable in principle there are many cases where that will be an
acceptable design solution
figure 42 is far too dictatorial and will be misused and
misinterpreted. it does nto flow from the logia of oehter elements
of the guide.
'do what is right for the particxlar situaiton'
this section refers to a terracing affect- that only relates to
development in towns. detached countryside houses have no danger of
terracing. this doesn't even relate to the local context.
figure 43 suffers the same problem the red boxes are actually
showing two perfectly acceptable design solutions. the lean-to
(larger) bieng more appropriate than the top right small
green.
this is wrng and must go. never before has a design guide stated
not acceptable in principle i am gravely worried about this
section
(dormers i agree with however)
the red imge on figure 46 is inappropriate and wrng and fails to
recognise context of development. do not use these colours codes so
definitively. i can show you bad cases of what you show as
green.
on shopfront design why not just use the traditional shop front
guide that wored perfectly well 10 years ago. However this draft
guide does nto distiguish between Didcot and Henley-
clealrydiffertns sop fronts will work in each case
|
·
Noted and will
review.
·
The Shopfront design guide is incorporated within the joint guide,
this will be made
clearer.
|
16
|
concern that the
principles may be used by officers without an ability to discern
intuitive and skilful design innovation
|
·
Noted and will review
|
17
|
See
above
I think there is a missed opportunity by not expanding the
non-domestic buildings - there is a photo reference to milton Park
but I think more should be done here. Milton Park has a lot of good
features which could be used.
Culham may not be the best example of outstanding design but it
does have a lot of good points - the use of landscape of landscape
is not bad and the way the buildings have been laid out.
Sports and community buildings could be mentioned here. The village
hall is an integral building in Vale and South and we need to raise
the bar with them. Sport England have some good designs you could
reference.
|
·
Noted and will
review.
·
We will seek in include applicable level of guidance around Sports
and community
buildings.
|
18
|
Should
be in keeping with local building traditions - no concrete boxes or
""Tesco on the hill"" like was built near Ipsden/Hailey
|
·
Acknowledged
|
19
|
Conversions and
extensions must be considered relative to the setting as well as to
the individual building.
|
·
Acknowledged
|
20
|
Sounds
good but the design idea of ‘softening the edges of a
development where it meets the countryside by spacing further apart
and less dense building’ is fake idea used by developers to
make more money as buildings with nice views over land and more
detached sell for more.
Design already flawed in Wantage......see high density blocks of
houses/apartments opposite Wantage Firestation. Design and
Materials not in keeping with town centre, density of housing too
high for tiny area and too high blocking out light and
oppressive.
|
·
Noted
|
21
|
Comprehensive -
thank you, but diversity of structures e.g. roof lines, eaves,
overhangs etc, along with unity needs to be encouraged. Many of the
drawings provided as examples lack diversity and thus visual
interest. I am bored by continual straight lines and continuous
symmetry. Diversity, within an overall design concept provides
excitement, surprise, a sense of anticipation, wonder - qualities
that are so often neglected. PLEASE TRY HARDER!!
|
·
Noted
|
22
|
Biased
towards developers, create a summarised version for
householders
Completely hypocritical. Even where all the design standards on
front dormers are followed the planning officers still reject based
on their own bias. And yet rear dormers are passed, even where they
are visually very ugly and are visible from the street.
Nice Front dormers are more attractive than plain roofs, and are
more environmentally friendly as they build on the existing
footprints
|
·
Noted
|
23
|
page
not working
|
·
Noted
|
24
|
Agreed
that good views from properties will improve well-being.
|
·
Acknowledged
|
25
|
Would
like to see reference to Neighbourhood Plans
|
·
Noted and will review
|
26
|
I
would like to see more notice taken of public opinion regarding the
loom of buildings, after all residents live here whilst designers
are just passing through !
|
·
Acknowledged
|
27
|
My
comments above continue to apply - great words but how will they be
measured - examples of great practice elsewhere could be
useful
|
·
Noted and will review
|
28
|
There
is a very small reference to the Chiltern Design Guide not being
superseded, but little other reference to materials or how to
reflect the local vernacular. I can see that you don't want to
re-state everything, but something more is needed to indicate the
importance of understanding how materials and forms have been used
in the past and how they give particular identity. This is a bit
sad.
I like the new direction towards simplicity as I do not think that
the higgledy-piggledy variation of different house formulae used by
many developers constitutes good design. Together with constantly
bending streets, this doesn't make for pleasing variety - just a
mess!
|
·
Acknowledged
|
29
|
Long
rows of connected buildings might give more cheaper buildings for
the budget but this is boring and does not give the opportunity for
individuality and personal place development.
|
·
Noted
|
30
|
Use of
traditional / reclaimed materials where inserting new build between
existing historic buildings or preferably use brown field sites or
refurbish/ redevelop commercial buildings to residential
|
·
Acknowledged
|
31
|
At
last, something relevant for all scales of development.
|
·
Acknowledged
|
32
|
Good
|
·
Acknowledged
|
33
|
Whether this is
achieved is subjective. Currently developers are permitted build 3
and 2.5 storey, houses in inappropraite places
|
·
Noted
|
34
|
It
might be preferable to write the principles in bullet points and/
or emphasise key words in bold or italics.
|
·
Noted and will
review
· The design principles are numbered for clarity and
reference.
|
35
|
More
of the same here; helpful and directive to aid the design and build
of the structure itself within its immediate
surroundings.
|
·
Acknowledged
|
36
|
no
reference found to the role of neighbourhood plans in built
form
|
·
Noted and will review
|
37
|
Concerning
apartments, visually interesting should not be interpreted as
fussy. Clean simple lines are needed. The arrangement of parking
bays, visitor parking and bin storage all matter and are included.
But provision also needs to be made for charging points for
electric vehicles, and for parking for cycles and prams. And I'm
not satisfied that personal security at night is adequately built
in.
5.35 needs to be cross referenced to the point which I've made
above about the rules at 4.11.
Rear extensions need firmer guidance. 5.46 needs to say more about
harm - for example a tall building north of a bungalow will have a
major impact especially during winter months. The light reaching
the bungalow is more than just direct sunlight and the indirect
light is reduced by a tall building to the north.
5.100 refers to mixed developments. Two matters are not in my view
adequately addressed. Firstly business hours for commercial
buildings can be very long and the 5 am stock delivery can affect
the viability of the dwelling. Secondly active surveillance needs
must be met for the residential accommodation as well as for the
commercial part. The shift worker coming home at 3 am needs to feel
safe.
|
·
Noted and will
review
|
38
|
It
does not apply, as it takes no account of built form in a rural
setting.
|
·
Noted and will review
|
39
|
Suitably succinct
and to the point.
|
·
Acknowledged
|
40
|
its
this simple do not build houses with short term considerations in
mind build a house that will be standing albeit with new this and
new that in 500 years time
|
·
We cannot insist on this approach but recommend it as best
practice.
|
41
|
I like
the recognition that it is important to keep ridge lines in
proportion with surrounding buildings.
|
·
Acknowledged
|
42
|
This
section urges applicants to undertake a 'character assessment'.
Where a neighbourhood development plan exists, this has already
been done! The emphasis placed on the 'wider context of the site'
ticks all the boxes that an NDP exists to fulfil...Understanding
the area where you're trying to develop, what makes it special, why
is it unique, how can this uniqueness or locality be protected and
enhanced?? Part of the idea of a design guide like this is that you
don't end up with identikit places built by identikit developers -
NDP appraisals can help with teasing out local distinctiveness, so
a design guide should point applicants to this information, already
supplied in the process of creating neighbourhood plans.
|
·
Noted and will
review
·
Note; not all areas have an up-to-date NDP or adopted NDP. Some
NDP's also lack detail or a robust character assessment. A
character assessment as part of a Design and access statement is
strongly encouraged by the guide and should refer to the character
identified within an applicable NDP where one is
present.
|
43
|
We
have no specific comments to raise in this section which follow
well established principles of good design.
|
·
Acknowledged
|
44
|
Some
unfriendly phrases here again, such as ""Note that articulation of
massing and roof line can help to present variety along the
building frontage."" I have no idea what 'articulation' and
'massing' mean in this context.
I'm also not convinced about the sentence ""Apartments, also known
as flats, are sustainable forms of development because they
increase housing density and therefore reduce the pressure for
development on greenfield land."" - blocks of flats are not in
themselves inherently 'sustainable'! And custom-built blocks of
flats may not be appropriate in all contexts. which is not
mentioned at all.
|
·
Noted and will
review.
· Apartments their design and use in relation to density and
sustainability will be better defined.
|
45
|
There
could be more content on heritage assets; including the importance
of good design in Conservation Areas and how to meet energy
efficiency standards in Listed Buildings without harming their
importance. It might also be useful to highlight the importance of
pre-application advice in this section.
It is not clear whether the shopfront/traditional shopfront design
section has been lifted directly from the Shopfront Design Guide or
whether this now supersedes that document, some clarification in
the text would be helpful.
|
·
Noted and will
review.
· Additional information will be added to the subject areas of
Heritage and
conservation.
· shopfront/traditional shopfront design has been
incorporated within the guide with modification from the
previous shopfront guide. The original document will be
superseded by the Joint design
guide.
|
46
|
Response manually
entered, submitted in an email format. For reporting purposes
additional text is marked as ''xxx'' and deleted text as *xxx*. The
original submission is attached to this comment form for
reference.
We recommend the addition of the ''Chilterns Buildings Design
Guide''
Buildings in rural and lower density areas within South and Vale
should be integrated into their landscape setting and site contexts
in a sensitive manner. Buildings should not be located on
ridgelines or exposed sites where the buildings will become a
dominant visual feature to the detriment
3 of the existing landscape character. ''The introduction of light
spill and glare is to be avoided.''
Chilterns Buildings Design Guidance **(This document *does not
supersede the districts design guide*) should be read alongside the
districts design guide). Justification. The CBDG carries equal
status as a supplementary planning document.
Figure 49 - Those images are from Thame.
We support the image referring to knapped flint and would be
grateful for that to be ‘ ''hand'' knapped flint’.
Justification. The use of flint in precast panels is best avoided
in most design situations. SODC now, usefully, impose conditions to
prevent this, for example the development at Highlands Park,
Henley.
|
·
Noted and will
review.
· We will consider the weight of guidance and benefit of
information provided by the Chilterns SPD in relation to the
Districts
SPD.
|
47
|
Response manually
entered, submitted in an email format.
1. A wider range of the plans for extensions of houses with a
variety of existing roof styles would be more helpful, as this is
the most common type of building which householders undertake
without specialist architectural help, and which needs more support
in this Guide.
|
·
Noted and will review
|
48
|
Response manually
entered, submitted in an email format.
5. The Design Guide should recognise increased working from home
and an increase of commuting perhaps only on several days a week
rather than every day
8. The Guide should consider whether some developments should be
laid out with housing near to small office/workshop to reduce
travel to work.
10. The Parish Council would query whether commercial development
gets included in the Design Guide? E.g. what happens about future
possible development, such as a reservoir?
|
·
Noted and will
review.
· Commercial development is covered under the guide in
mixed-use buildings. This may be extended under non-domestic
buildings.
|
49
|
Response manually
entered, submitted in an email format.
Built Form
• The Committee noted that parts of this section are badly
written, with spelling mistakes.
• "..striving for excellence in architectural quality". The
Committee endorses the aspiration but thinks it is unlikely to be
realised on current evidence.
|
·
Noted and will review
|
50
|
Can we
camouflage solar panels into the built environment? I have no idea
how, but I'm recalling mobile telephone towers made to look like
trees. Security fencing and lighting needs to be appropriate in
renewables development. Keeping residents safe and not annoying
them with unnecessary light pollution. In the guide, I think this
section is particularly beautiful.
|
·
This comment raises issues that fall outside the scope of the
design guide.
|
51
|
Goal,
first paragraph, please add: and play their part in reducing the
carbon footprint of the district.
Final paragraph' after 'explain why your solution is better', add
-- and how your design will achieve a reduction in carbon
footprint.
Principle 5.6 after 'parking area or public space', add -- unless
these are designed to be living walls.
Goal for Householder extensions and outbuildings. Please change to:
--To achieve extensions to dwellings, insulation of dwellings and
measures to reduce the carbon footprint of dwellings that respond
to the needs of the occupants in a way that is sensitive to the
character of the original dwelling and street scene.
Add explanation: Many householders will recognize their
responsibility to respond to the climate emergency by insulating
their homes and taking steps to reduce their carbon footprint.
Measures to adapt existing homes will be considered even if they
may change the external appearance of the dwellings.
|
·
Noted and will
review
· Some of these aspects are covered under the Climate and
sustainably section of the guide.
|
52
|
General principles
- ""good contemporary design that respects context will be
welcomed"" - this is ambiguous, and should also be considered in
relation to specific locations.
General principles - conflicts between zero carbon and other design
principles - very ambiguous and no clarity on what is the
priority.
5.18 - individual entrances on ground floor - should say where
possible.
5.105 - Materials - There are ongoing industry-wide issues with
material availability across the country. A shortage of supply
results in higher costs, and some of the aspirations could impact
deliverability of schemes (in terms of programme and
viability).
|
·
Noted and will review
|
53
|
Design
needs to achieve a sense of particularity of place. It should not
be a pastiche of new building elsewhere. Least of all, should a
community be indistinguishable from many others created in other
parts of the country. Sculpture in public places, too, should
respond to and reflect the identity of the neighbourhood, and not
be something which could be put just anywhere for no particular
reason.
|
·
Acknowledged
|
54
|
This
section is both poorly written and is bad advice for sustainable
building design. It is the weak point in this design guide. It is
clear that who ever wrote this, has little idea of building physics
nor passive design principles. The way a building looks is in any
event very subjective and all this does, is to promote the
development of ""mock Tudor"" type buildings with silly detailing
(fake chimneys, twee dormers, bit of wood painted black and fixed
onto external cladding etc) that add cost but do nothing for
promoting sustainable design. Vauban, the renown zero-carbon,
solar-powered, car-free suburb of Europe's most sustainable city,
Freiburg, doesn't look anything like the historic city centre and
for good reason. It was designed and developed for the community,
by the community for present day zero carbon
livelihoods.
|
·
Noted and will review
· There is a balance between the character, design,
construction and the sustainability of a building. The guide does
not seek to dictate character but provide design guidance on the
composition of built form in relation to its
context.
· Design guidance on the incorporation of passive and active
design approaches for sustainability are included in the
‘climate and sustainability’ section of the
guide.
· Some sustainable schemes have a different appearance to
their local context, the balance of appearance and sustainability
has to be considered among other design and planning
factors.
|
55
|
ABOUT
THE CHAPTER
FORMATTING: Needs a chapter number for reference. Could an
interactive mini contents list be included under each chapter
title/heading for easier navigation, to avoid scrolling? Principles
should really be first, and then follow up with explanation text,
diagrams and helpful links below.
GENEAL BUILT FORM
FORMATTING: Needs a chapter/subsection number for reference.
Officers liked the inclusion of the Principles box at the top of
this sub-section.
[5.12] BALCONIES: Really appreciated the reference to balconies
with space for table and chairs and for planting/kitchen gardening.
Should this wording and accompanying drawing proposed also be
included in Para [4.47]? Also wonder whether this wording [5.12]
should actually be included in the principles for
APARTMENTS.
APARTMENTS ~
FORMATTING: Needs a chapter/subsection number for reference.
Officers liked the inclusion of the Principles box at the top of
this sub-section.
[5.12] BALCONIES: Should the wording for this bullet point, and
proposed drawing, actually be included in the principles for this
section?
[5.19] AMENITY STANDARDS Link needs to be inserted for Para [4.11]
, or amenity standards specified in the wording of this
principle
HOUSEHOLDER EXTENSIONS AND OUTBUILDINGS ~
FORMATTING: Needs a chapter/subsection number for reference.
Officers were concerned that there was a lot of information under
this sub-section. Would it be possible to separate Householder
extensions into a separate section? Or could the JDG have the
general householder extensions principles under the BUILT FORM
chapter, as it is currently, but then list "Side Extensions" "Rear
Extensions" "Front Extensions" etc. in bullet points underneath,
with separate linked webpages for each (as a way to break it up
more)?
MORE VARIED EXAMPLES NEEDED: Officers asked for more successful
examples/diagrams of smaller schemes, e.g. nursing homes, or more
rural schemes. A lot of examples/diagrams provided are of
town-based examples – so more examples relevant to the varied
sites that we deal with would be good.
HYPERLINKS NEEDED IN THIS SECTION: If the principle wording does
not specify standards, there needs to be a hyperlink back to the
relevant sections within the JDG for forestry / drainage / parking
/ amenity / ecology guidance.
[5.24-5.38] "HOUSEHOLDER EXTENSIONS" – Officers suggested
that this title be renamed "General Design Principles" before
moving into the following subsections for the Side/Rear/Front
Extensions . Or that the current Principle box for the general
design principles is moved to the top of this section; so that it
is underneath the section heading for "Householder Extensions and
Outbuildings".
[5.24-5.33] PARKING STANDARDS: For someone who is just looking to
extend their property and has not thought to look at the rest of
the design guide - Officers suggested that wording about the
parking standards is included in the general principles here. For
example; "maintains a sufficient level of well-integrated parking
provision, in accordance with Oxfordshire County Council guidance"?
A hyperlink could then be provided back to the relevant part of the
design guide?
[5.37] DISTANCES SPECIFICATION – These specs don’t seem
to match up with the distances specified under Para [4.3] in SPACE
AND LAYOUT. Could a link be provided back to the specs of [4.3], or
the same wording reiterated here to avoid back and forth/scrolling.
Terminology should also match up (e.g. flank walls/side elevations
etc.). Officers expressed preference for use of ‘side
elevations’.
[5.33/5.38] 45 DEGREE RULE (& BRE Guidance) - Could the wording
under para. [5.33] be changed to say; "demonstrate that it will not
result in the significant loss of light (as determined by BRE
calculations where deemed necessary)’? Officers had concerns
with the inclusion of "set out within the BRE guidance" for para.
[5.38] and recommend this is removed. The concerns stem from how
this would be applied/ assessed/ the detail required to be included
in every delegated report. Generally we don’t apply other
sections of the BRE to householder development – it is
recommended that if the BRE guidance really needs to be referenced
here, that the relevant section of the guidance is isolated and a
link provided to it under this section.
45 DEGREE RULE DIAGRAM – Officers thought that the
positioning of this was confusing. The diagram should be placed
after the first written reference of the 45 degree rule is made
within the principles box for "HOUSEHOLDER EXTENSIONS" Para.
[5.38]. Could the wording on the diagram be updated to say "No
[two-storey/multi-storey] extension should go beyond a 45 degree
line taken from the centre point of the nearest habitable room
window". This is because single-storey extensions can often be done
using a householder’s permitted development rights.
SIDE EXTENSIONS ~
FORMATTING: Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below
[5.40] SUPPORTING TEXT: "it should be set back at least one third
of the depth of the dwelling." – principle wording says
"significantly set back" -it may be good to make the wording
between the principle and the supporting text consistent?
[5.41] GAP TO BOUNDARY: does this apply to all extensions? Officers
are mindful that permitted development could negate this guidance.
Additionally, SUPPORTING TEXT states 1.2 metres should be the gap
to the boundary, but the principle wording says ‘not less
than 1 metre’. Officers recommend that one value is chosen
for consistency.
REAR EXTENSIONS ~
FORMATTING: Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below
[5.47] DISTANCE SPECS – The wording on distances previously
written under para [4.3] should really be specified again here for
the avoidance of doubt, or a hyperlink provided back to the
relevant section
[5.48] 45 DEGREE RULE – consistency needed with wording seen
on diagram and under para [5.38]. It should be made clear that the
45 degree rule [as in 5.48] applies to two-storey (multi-storey?)
extensions, and not to single-storey extensions
FRONT EXTENSIONS ~
FORMATTING: Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below
[5.49] – EXCEEDING NEIGHBOURS PRINCIPAL ELEVATION - The
second to last sentence "Front extensions should not exceed any
neighbouring dwellings principle elevation" is unreasonable and
should be removed. Officers suggest this taking into consideration
the relationship of many terraced/ semi-detached properties and
what can be achieved under permitted development within a
homeowner’s curtilage. Officers can judge this on a case by
case basis.
[5.49/5.50/5.51] REWORDING OF PRINCIPLES – it is recommended
that the principles for FRONT EXTENSIONS are reworded along the
lines of the following so that each principle addresses
‘design’, ‘neighbouring impact’ and
‘parking’? :-
""5.49 Front extensions will be resisted where they have a
significant impact on the street scene or are damaging to the
appearance of a dwelling. Modest front extensions that reflect the
character of the existing property are more likely to be
acceptable. Large, flat-topped porches should be avoided. Where the
building line is staggered or where the dwelling is set well back
from the road, front extensions are more likely to be
acceptable""
""5.50 When located close to a neighbouring property, front
extensions should not have a negative impact on the amount of light
afforded to that property, nor should it have an overbearing
impact. ""
""5.51 Front extensions should not reduce the space available for
parking below adopted standards outlined within Oxfordshire County
Council Guidance [INSERT HYPERLINK HERE TO RELEVANT SECTION IN
‘SPACE & LAYOUT’?] ""
LOFT CONVERSIONS AND ROOF EXTENSIONS
FORMATTING: Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below
[5.52-5.53] REWORDING OF PRINCIPLES – it is recommended that
the principles are reworded along the lines of the
following?
""5.52 Dormer roof extensions must be set within the roof slope.
They should be designed as features principally to provide light
and ventilation, and should sit well above the eaves line, well
below the ridge line and should be set in from the gable ends.
Dormer windows should not just be used as a means of generating
additional headroom. ""
""5.53 The size, pitch and ridge height of dormers should be
informed by the character and appearance of the existing building,
and the local vernacular. The chosen design should complement the
rhythm of the existing fenestration and roof pitch. The position
and proportion of dormer windows should respond to existing windows
and doors. Single, large flat roofed, box dormers must be avoided.
"" ?
GARAGES, ""ANNEXES"" AND OTHER OUTBUILDINGS ~
FORMATTING: Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below. **Officers
recommend that ‘Annexes’ are included in the heading of
the section.
DIAGRAM – Officers commented that the drawn traffic light
diagrams could be confusing where the orientation of the
garage/outbuilding is shown as green, and the label says ‘No
domestic features’ with a greyed out dormer. It is
recommended that this label is just included once on the first red
"Not acceptable in principle" diagram - and is removed from all the
diagrams where we have indicated in green that the design of the
proposal is acceptable.
RURAL AND LOW DENSITY DWELLINGS ~
FORMATTING: Needs a chapter/subsection number for reference –
and to more clearly separate it from ‘Householder
Extensions’ Principles should really be first, and then
follow up with explanation text, diagrams and helpful links below.
**Officers were glad to see reinclusion of the principles for this
type of development, thank you!
BUILDING CONVERSIONS ~
FORMATTING: Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below. *Officers
recommend that the title of this section is simplified to Building
Conversions.
GUIDANCE NEEDED ON CONVERTING MODERN BUILDINGS – Officers
commented that more design guidance/best practice principles are
needed on the conversion of more modern buildings, as well as the
more traditional; "Vernacular" vs "Non-Vernacular" buildings.
Increasing numbers of applications are coming in for this now, with
permitted development fallback. Photographs/examples of where this
has been done successfully would be greatly appreciated.
SHOPFRONTS ~
FORMATTING: Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below
CHOSEN PHOTOGRAPHS: Officers expressed disappointment that a lot of
the photographs were based in South. Could more Vale District
examples be included? Officers believe that the photographs of the
Prezzo may actually be in Henley, not in Wallingford as annotation
suggests.
DIAGRAMS: Officers found the diagrams of the shop frontage
terminology really useful.
NON-DOMESTIC BUILDINGS ~
FORMATTING - Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below
PHOTOGRAPHS – Officers commented that photographs of
buildings in shade were difficult to appreciate.
[5.89] USE OF JARGON - Reference to B2 and B8 uses, which should be
explained as this is technical jargon. Perhaps this could be
included in the glossary. *Officers thought that the specification
of the use classes may need to be caveated in some way as Central
Government have made changes to the use classes over recent years
with little warning.
MIXED-USE DEVELOPMENT ~
FORMATTING - Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below
MATERIALS, MAINTENANCE AND MANAGEMENT ~
FORMATTING - Needs a chapter/subsection number for reference.
Principles should really be first, and then follow up with
explanation text, diagrams and helpful links below **Officers
believe that this sub-section should be at the beginning of the
BUILT FORM chapter.
INCLUSION OF APPENDIX ‘E’ AREA ZONING AND MATERIALS -
[FIGURE 54] shows some photos of materials? – but Appendix E
of the Vale’s Design Guide 2015 – ‘Vale of White
Horse Character’; Material Palettes was more detailed,
area-specific. It was frequently used. Is there a way to
incorporate this and the equivalent within the South Ox Design
Guide into the JDG for new development?
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·
Acknowledged
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56
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Clearly set
out.
This section lacks a reference to the importance of preserving the
character and appearance of the existing built environment,
including such issues as light and noise pollution that have a far
greater relevance in a rural environment.
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·
Noted and will review
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57
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The
‘built form’ design principles that have been set out
within the draft Design Guide SPD appear to be appropriate, and are
clearly written and unambiguous.
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·
Acknowledged
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58
|
Again
neighbourhood plans. No mention of loss of light for PV
cells.
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·
Noted
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59
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This
section incudes sub sections on small extensions etc (as referred
to in our earlier responses) . These are somewhat hidden away and
we wonder if it would be sensible to have an entirely separate
Design Guide for such developments so as to facilitate the clear
distinction and different approach.
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Noted and will review
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60
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Please
refer to submitted representations.
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·
Noted
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61
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It's
not particularly helpful to say materials should be attractive or
built to last. What does this mean in practice? Volume
housebuilders prefer cheaper and more plentiful concrete products
to more durable natural materials such as slate, stone and clay
tiles which are often better suited to context. How do you resolve
the sustainability impacts of natural materials?
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Noted and will review
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62
|
Response manually
entered, submitted in an email format.
It would be really good to see in the final version some more
details on specific features that can support different
people’s needs in the built environment - potentially through
the use of case studies from the perspective of the person. From a
design perspective, there are great opportunities when developing a
design guide to flag the range of needs that different societal
groups (e.g. age, race, gender, caregiver status, physical and
mental ability/disability) have and the issues that can arise for
individuals in the built environment, and then provide tangible
solutions.
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·
Noted and will review
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63
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Response manually
entered, submitted in an email format
General principles
Goal: Respect the local context whilst striving for excellence in
architectural quality and sustainability.
This section contains the text ‘Note that in order to design
a building to be as energy efficient (as close to zero-carbon) as
possible this may result in conflict with other design principles
in this Design Guide. When this occurs, be prepared to explain why
this happens and explain why your solution is better’.
Amendment suggestion: We strongly recommend that this be altered to
emphasise the overriding need for carbon neutrality and reads
‘When this occurs, be prepared to justify why carbon
neutrality has not been obtained.’
Design principles - Apartments
No mention is made of letter boxes or provision for parcels drops
– an increasingly important consideration as internet
shopping continues to increase. No mention of provision of natural
drying facilities for washing, important to tackle climate change
& reduce energy consumption.
Amendments suggested.
Designs must include provision of letter boxes & area for
parcel drops.
Designs must include provision of natural drying facilities for
washing.
Householder extension & outbuildings – Side
Extensions
Paragraph 2 line one should read ‘where extending’ not
‘were extending’.
Design principles - loft conversions and roof extensions
5.54 requires that ‘Roof lights should be used sparingly and
where they are less likely to be visible in the street
scene’. This ignores the contribution of roof lights to light
pollution and should, therefore, require that special glass be used
to reduce light pollution.
Garages and outbuildings
Paragraph 1 should read ‘general principles’ not
‘genal principles’.
We welcome the inclusion of the guidance on Annexes.
Rural and low-density dwellings
Goal: Maintain a balance of local character and new
development
This is intended for hamlets or small clusters of dwellings within
the open countryside. To encourage developers to make more
efficient use of land we suggest this be reworded to "This is ONLY
intended for hamlets or small clusters of dwellings within the open
countryside’
We also note that in many hamlets there are clusters of high
density former rural workers cottages & former local authority
housing. If a hamlet contains such developments, developers should
be encouraged to emulate this model thus providing lower-cost homes
and reducing the land take.
Design principles – Building conservation &
conversions
5.70 should read ‘a building’s adaptation’ not
‘a buildings adaptation’.
Traditional shopfront design principles
5.81 should read ‘for people including those with’ not
‘for people including with’.
5.82 The guidance seems to accept that towns and villages will be
lit all night. Strongly recommend that the design requires such
lighting to comply with measures aimed at reducing light
pollution.
We note that hours of lighting can be imposed through conditions
applying to any planning permission but if measures can be taken to
design-in the limitations then this reduces the need to rely on
human behaviour.
5.82 should read ‘late-opening’ not ‘late
opening’.
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Acknowledged
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64
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Rural
and low density dwellings
Hamlets and other clusters of dwellings are listed in the SODC
LP2035 as ‘Other Villages’. For clarity the term
‘Other Villages’ & the equivalent term in the Vale
LP should be used in this guide. The guide should make it clear
that many ‘Other Villages’ may contain high-density
dwellings such as former farm workers cottages e.g. Clare Cottages
(OX9 7HQ) and Portabello Cottages (OX49 5HU) and therefore,
efficient use of land is encouraged on within these settlements,
for example, Farm Place, Henton, OX39 4AD - P90/N0765
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We
make clear reference to the settlement hierarchy for both South and
Vale.
It is not the guides purpose to specify densities within specific
locations.
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65
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Response manually
entered, submitted in an email format
Admin note, the pictures referred to below are attached at the end
of this form.
I spotted the following error in the captions. In the pictures from
below – it’s in the shopfront bit I think - the images
below are labelled Wallingford but both are actually Thame. Just
FYI.
I don’t know how you feel about the two images that go with
the descriptions marked with X’s but I’ve got a few
generic sample materials photos that might fit with your captions
better? This is kind of near the bottom of the built form bit I
think.
Just a suggestion. I’ve attached a couple of pictures that
might fit better. The ones named samples are from a DIS app
submitted by an applicant so aren’t pictures I have
specifically taken but they are pretty generic. Give me a shout if
there are others you need, we might have something that
fits.
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Noted
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66
|
""
Support your design"": Missing Neighbourhood Plan design policies
again!
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·
Noted; whilst it is important to refer to neighbourhood plans. It
will not be best practice within the guide to add 'refer to
neighbourhood plans' under each 'support your design'
subsection.
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67
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Response manually
entered, submitted in an email format.
The design principles – general built form, are
understandably high-level, and set out a range of broad
considerations that will apply to most types of
development.
Towards the end of Section 7, there is guidance headed ‘Mixed
use development’. We would suggest that the heading for this
section is amended to ‘Mixed use centres and Neighbourhood
Hubs’ as that is what the content of this section seeks to
address, rather than mixed use development more
generally.
There will of course be mixed use development in the two District
areas that is not part of a mixed use centre or community hub, and
it is important therefore that the intended application of this
section of the Joint Design Guide is made clearer. By way of
example, the delivery of mixed use development may be aligned with
main infrastructure corridors, which is a different form of mixed
use development to that addressed in this section of the Joint
Design Guide. We are not proposing that there needs to be a further
section in the Joint Design Guide, as many of the principles
outlined in the document will be relevant to mixed use developments
that are brought forward outside of Mixed use centres and
Neighbourhood Hubs, and it would be unworkable for the Joint Design
Guide to seek to have a section covering every potential type, form
and mix of development.
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·
Acknowledged
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68
|
In
particular, the Built Form chapter seems to explicitly ignore its
suggestions.
The Climate and Sustainability chapter mentions:
Siting / Orientation as a Factor to consider
and
Figure 58: sensibly illustrates Combining active and passive design
approaches can reduce the carbon emissions of a dwelling.
and the design principles include
includes the use of renewable energy technologies to reduce the
site’s conventional energy needs;
and demonstrates the use of solar technologies on roofs for
applicable minor development of all types;
There is no sign of this in the Built Form chapter. In fact the
illustrations there seem devoid of any consideration of climate
issues - not a solar PV or thermal panel in sight! The comments on
roofs obviously have no thought for designing buildings to have
south facing roofs to accommodate solar panels where
possible.
As you may know, we have a LOT of new development in Benson. I am
getting surprised comments from local people that none of the new
dwellings have solar panels on their roofs. Nor do they have heat
pumps. Just more new gas mains. (Because planning permission for
these was granted sometime ago, mostly before I got back on the
council). To say the least, this is very embarassing.
The sections on extensions appear to totally ignore issues of good
themal insulation. The green illustrations almost look to me the
least energy efficient designs you could come up with! I am sure
this is not intentional but I would appreciate a discussion on the
Built Form chapter please and on its illustrations in particular
before the next edition comes out.
(Nothing to do with climate but I am pretty sure that in
Figure 49: Traditional shopfronts along street, the top right photo
is not Wallingford - looks more like Thame to me but I stand to be
corrected)
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Noted
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69
|
Bloor
Homes has not comments on this section of the guide.
|
·
Noted
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70
|
Please
see submitted letter for full comments.
|
. The
principles outlined in the design guide are applicable to all
scales of development, urban and rural.
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71
|
There
is a strong tendency in the guide towards urban forms. S.Ox and
Vale have a lot of villages where a difference in scale, materials
and the use of vernacular forms are key issues. Why doesn't the
guide address these as equally important? Many villages are happy
to encourage small-scale development and infill of the right form
and quality, but this is barely recognised in the guide.
|
·
Noted and will
review
· Zero carbon in construction and operation – is a
holistic consideration and would not be predicated on a single
housing typology.
· Sustainability must be considered in relation to
overall design.
· The majority of extensions are too small a scale to
negatively impact nature at a scale where green corridors are
considered.
· Extensions would be expected to meet the criteria of
building regulations.
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72
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Zero
carbon in construction and operation - not sure why this should be
in conflict with other design principles. It lends itself well to
sociable terraced housing (only two exterior walls), and flats.
Compactness and density should be achieved to reduce
land-take.
I wish we would replicate the beauty of the facades of older
buildings, with their intricate detailing and colours. In
Wallingford we have lovely brick colours ""overburnts"" and white
and red bricks patterned together (Reading Road) and use of
flint.
Vertical gardens - great idea!
We have a climate emergency and must insulate our homes better. In
some cases that will require external wall insulation, at the front
of the building, and air source heat pumps at the front of the
building. These should be allowed don't you think, even if they
spoil a line of similar buildings?
How can nature be protected when extensions are built? Could it be
advised that green corridors should be maintained?
I have made energy assessments of lovely old buildings that have
received enormous modern extensions at their backs. The people then
live in the rear extension and never venture again into the front
part. Please emphasise that extensions should in themselves be zero
carbon, and that full retrofit should be made to the older parts of
the buildings.
Triple glazed roof lights should be used, as heat loss is greatest
at the roof. Triple glazing should be encouraged everywhere, even
when it differs from existing fenestration (5.65).
I don't understand 5.72. ""allowing significant spaces to remain
open"" - not sure what that means.
Cornerstone Arts Centre is not a good example of a building
'designed appropriately for their function"". It is too small to
act as the concert venue intended.
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·
Noted and will review
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73
|
Bulkit
form should reference the most locally specific policiues as a
starting point - these are often to be found in Neighbourhood Plans
- reference to which seem to be absent from this proposed design
guide
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·
This comment raises issues that fall outside the scope of the
design guide.
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74
|
Lighting again -
follow guidance from ILP and AONB.
|
·
Noted and will review points individually
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75
|
Response manually
entered, submitted in an email format.
Design specifics
• The guidance on back-to-back, back to side and front to
front distances are welcome, although disquiet was felt at the
reduction of back-to-back distances from the previous guide. No
reason for the reduction has been given.
o However, the development adjacent to or above single-story
elements that are faced by a frontage have given rise to
considerable concern and neighbour disputes. A front-to-side
distance is required, or exceptionally clear guidance on gable /
roof heights, windows, glazing, etc. Examples of where
front-to-side distances caused issues can be given.
• The EV charging standard for shared, community courtyards
was felt to be inappropriate as the same standard (two EV points)
would appear to apply to communal parking regardless of the number
of units that are served.
• References to the 45-degree rule in Figure 41 do not
explain that this can be applied vertically, as well as
horizontally.
• Side extensions – The gap between an extension and a
boundary is, in paragraph 5.41 recommended to be "no less than 1
metre wide" yet in the introductory text above the minimum is given
as 1.2 m wide. This requires clarification or
standardization.
Other observations
• The first photograph supporting the shopfront design guide
section "Traditional shopfronts along street" is from Thame, not
Wallingford.
• It was felt necessary for the user to be able to enlarge
all of the more complex diagrams, many are currently locked to a
size limit presumably due to resolution concerns (e.g., the
Landscape Character Map, Figures 3, 8, 20, etc.).
• Autocorrect appears to have inserted some alternative
words, a sense check is required, for example there is reference
made to "loft conversations"!
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·
Noted and will review points individually
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76
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Response manually
entered, submitted in an email format.
Built Form
General comments
• This section is much longer than the others – could
this potentially be broken up into separate sections to avoid so
much scrolling? E.g. Design principles for householder extensions
would make a good separate section, as would materials. We
understand if this is not possible at this stage.
• Figure 38 – these homes are shown only as detached.
We understand that it is showing an example of a low-density
development, but we don’t want to convey that low density
only means large detached dwellings, as it could also include
semi-detached and terraced buildings.
• If you had more time which we know you don’t –
We’d like to see another section with advice on how to
densify the suburbs – with drawings on what kind of
development we’d support in areas of different character e.g.
Victorian terraces, 30s suburbs, 60s housing estates etc. so that
we encourage gentle densification (we could perhaps explore this is
for the future for the joint local plan)
Apartments
• 5.22 –We think it should be mentioned that the cycle
parking should be well designed/attractive
• Figure 39 – this image appears more reflective of a
very urban environment such as Manchester or Liverpool in its
scale/massing/design, there are no trees etc. Understand its
purpose is to show design principles, but is there any way to make
it more reflective of the built environment in south and
vale?
Extensions
• It appears here that the ‘householder
extensions’ element is the overarching design principles for
all household extensions, and then there are further design
principles depending on whether it is a rear, front or side
extension, and these are set out below. However, there is no
distinction visually or in the text between these to indicate that
they are linked – think it would be helpful if there could be
more of a distinction throughout the guide where design principles
link like this. Maybe having them in a different shade of the main
colour, or having the
‘leading’/’overarching’ design principles
title in bold? So it is easier for those who need to meet this
criteria to easily see which elements apply to them, i.e. if they
are building an extension they’d know easily that they need
to look at the overarching extension principles and then the more
specific criteria that relates to the siting of the
extension.
• Figure 41 – think it would be helpful clearly
labelling this drawing as being ‘shown from
above’.
• Sometimes the 45 degree rule also has the 25 degree rule
applied – has this been considered? I.e. 45/25 degree
rule.
• Figure 42 – the key on the left should be moved so it
sits under the figure, it would be clearer this way.
Non-domestic buildings
• 5.91 - think it would be useful to state ‘including
attractive, convenient and safe cycle parking’, instead of
just ‘cycle parking’, just to really emphasise what is
meant by that. Or provide a link to the area which describes how
cycle parking should be.
• 5.93 – would making their design simple/limit the
geometric forms not emphasise the size/bulk of the building? We
would have thought we would encourage what has been done in 5.16
and try and reduce the bulk of the building by breaking it down
into components
Rural and Low-Density Dwellings
• Think we need to be really carefully with what we are
promoting in this section of the guide. We need to be encouraging
the efficient use of land as this is required by paragraph 124 of
the NPPF. The section is intended for hamlets or small clusters of
dwellings within the open countryside, however design principle
5.56 refers to ‘over-intensive housing development’ -
according to both of the Council’s Local Plans housing
development would not be acceptable in principle in these locations
unless it meets specific criteria – this needs to be
clarified.
• This section may be more appropriate to be used to guide
development in smaller villages, to reflect that the design
approach for Didcot/edges of Oxford, won’t be appropriate in
for example Woodcote or Uffington. Recommend deleting ‘This
is intended for hamlets or small clusters of dwellings within the
open countryside.’ And replacing with ‘Development in
hamlets and within the open countryside is strictly controlled by
government policy and local plan policy. This section is intended
for rural villages and the countryside’.
• Could more principles be added here? i.e. design to
minimise light pollution, recommendations regarding boundary
treatments, colour/materials? If this is covered in another list of
principles maybe this should be clearer.
• 5.58 – are we sure we want to allow front driveways
here?
• We would also consider that the Design Guide needs to
provide more guidance on how higher density development could still
be designed to reflect the plot size and prevailing character of
lower density areas if done creatively/well.
• The reference to the Chilterns Buildings Design Guidance
states ‘(This document does not supersede the districts
design guide)’. Suggest these words in brackets are deleted
as it potentially devalues the Chilterns Design Guide and it is
hopefully clear that the most recent design guide would hold the
most weight in decision making.
Materials
• Would be good to cross reference to these Technical Notes
for the Chilterns AONB: Chilterns Flint (1.98Mb) Chilterns Brick
(2.85Mb) Roofing Materials (2.77Mb)
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·
Noted and will review of relevant
exxmaples.
· Noted and will review furthur infoamtion on examples of
permitted development were to be included
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77
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Response manually
entered, submitted in an email format.
NEED FOR RELEVANT ILLUSTRATIVE EXAMPLES
With regard to the contents of the draft guide it is considered
that illustrative examples of successful solutions for the
integration of parking spaces and car parking areas across
different densities of residential development would be
helpful.
With regard to extending and altering existing buildings it would
be helpful if examples of permitted development were to be included
or cross reference to the Planning Portal’s 'interactive
guides' were to be included. The design guide could include
preferred design solutions which differ from those possible under
permitted development rights, but failure to acknowledge that
permitted development rights exist and where guidance is available,
could result in confusion and a lack of confidence in planning
guidance.
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·
Noted and will review points individually
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78
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Response manually
entered, submitted in an email format.
Paragraph 5.3 of the draft Design Guide requires schemes to "break
down larger footprint buildings to comprise a number of simple,
geometric forms to reduce their apparent bulk. Floor plans that
necessitate flat roof sections should be avoided". Thakeham firstly
consider that this is too prescriptive, however Thakeham also
consider that it directly conflicts with paragraph 5.14, which
states schemes should "incorporates green and/or brown roofs/roof
gardens on flat roof buildings and vertical gardens. Building
design should seek to integrate biodiversity enhancements wherever
possible. These could be through the provision of green
walls/roofs, or faunal features (bird/bat boxes). They can be
discretely incorporated into structures, or made into focal points,
and will contribute to the need for development to deliver
biodiversity net gain". It would be difficult to comply with this
requirement if larger footprints and imperatively flat roof
sections are resisted. Thakeham consider the councils should
therefore be clear on how these requirements are designed to be
interpreted.
At paragraph 5.11 of the draft Design Guide with regard to
materials, it states that a scheme should use "materials that are
sustainable and have been informed by the character and appearance
of the surrounding area". Thakeham consider that further guidance
is needed to understand what the councils consider to be
‘sustainable materials’. For example, reference could
be made to BRE Green Guide, BES 6001, or simply expanded to state
that materials chosen should be based on a consideration of their
impact across their lifecycle, balancing social, economic and
environmental considerations in making responsible procurement
decisions, to deliver long-term sustainable solutions.
Paragraph 5.23 requires refuse areas to be provided within the main
buildings of apartments ‘close to main entrances’.
Thakeham disagree with this approach and do not consider that an
internal bin store is best placed close to the main entrance of the
building, due to obvious conflicts that may arise in relation to
odour and disturbance, and consequently not being desirable to the
end user.
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·
We cannot insist on this approach but recommend it as best
practice.
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79
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GOAL:
mixed use development or neighbourhood centres should be design as
a focus for the community.
There is an opportunity in this section to recognise the changing
nature of large new developments as the emerge and evolve over
time. Recognition should be given to the ability of meanwhile uses
to assist in generating vitality and helping to grow communities
and social capital (social connections and community wellbeing).
OSVP suggest: -
(*remove text*) *The* Development should *ensure* explore
opportunities for: -
5.97 ...
5.103 provide meanwhile uses in emerging or evolving development
areas, to maximise the short-term opportunities available to create
new places, activities, social and economic functions.
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·
Noted
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80
|
Response manually
entered, submitted in an email format.
General Principles
Figures 35-38 potentially contradict with Design Principles -
Parking Para. 4.28 in that each of the scenarios
shown would require rear parking courtyards.
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·
Noted and will review points individually
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81
|
Response manually
entered, submitted in an email format.
Specific points
Built form and Apartments: We like the points about massing and
avoiding flat roofs, room depths, having natural daylight and
ventilation etc. These are particularly useful when considering
apartments, could they be included here too?
Materials: We do not want to encourage a huge variety of materials
(see Persimmon development in Grove), keeping the palette simple in
the local vernacular is more appropriate. The design guide is
focussed on urban design yet most of the district is rural and we
need to ensure the local vernacular is emphasised.
MMC: Is MMC appropriate for all development, maybe this needs to be
tailored to a specific scale of development and would not be
appropriate in sensitive areas? (Para 6.11)
Garages: Generally, we would prefer garages set more forward,
rather than as illustrated (Fig 29). This will provide more
animation to the street scene, waste storage could be brought
through garage or provided in waste storage at the side of the
building or even possibly at front (additional guidance on this
welcomed). Single garages set back between houses look particularly
awful.
Conservation / Heritage: A section on conservation, heritage,
including registered parks and gardens would be necessary to assist
officers working on schemes in those more sensitive
locations.
Distances: The distances between 3 storey dwellings, or where there
is a change in levels of gardens etc needs to be more than 21m.
Orientation also needs to be considered. The diagram does not
represent what we would require.
We suggest that where there are level changes the distance needs to
be increased to at least 25m, maybe more if there is shadowing.
Similarly, the flank wall to rear should be increased where there
is a 3-storey development/ level changes, at least 15m or more if
shadowing. So there would be a differentiation between various
building heights. This is something that has been successful in
achieving good design on major developments elsewhere. Happy to
talk through this point.
Amenity space: There is an inconsistency with 1 bed dwellings and
apartments. For apartments it is currently suggested that 40 sq m
per dwelling is to include private amenity space (e.g balconies or
ground floor terraces which can accommodate a table and chairs) and
communal space.
Should 1 bed dwellings be at least 40sqm? For flats and apartments
we would seek clarity on this point and suggest a minimum amount of
private amenity space should always be required (in balconies or
ground floor gardens), with the remainder provided in communal
space. It is currently worded in such a way that
developers/applicants could argue all of the required amenity space
can be provided in a communal space.
It is important to emphasise that communal-amenity space should be
accessible, and useable, this is cropping up with apartments /
elderly persons accommodation in particular. Design guidance on how
to achieve this would be welcome – for example by avoiding
awkward shapes and sizes, convoluted routes through developments
and dominance of parking and roads. Verges would not be communal
amenity space for example.
Play Areas: Please can we advise in the guide that the design of
play areas should be accessible for children who are disabled and
that appropriate equipment and experiences are available? On a
strategic site with a community building, we should also ensure
that toilets are accessible / available near to play areas for
children who are disabled.
Public Art / public realm: There is no longer a policy in the SOLP,
but we want to ensure that public art, improved public realm can be
achieved, particularly on larger major sites. Does the design guide
cover this? Perhaps this could be included as part of a
commentary/design principles of the design of shared amenity
space.
Movement: Cul de sacs are very popular (quieter, children play in
street etc) - can we add an extra caveat saying cul de sacs should
be avoided unless there is pedestrian connectivity that is safe,
does not lead to the dominance of hard standing, parking courts and
visitor parking and the area has surveillance?
Solar Farms: At a meeting I had with Cabinet member and Adrian
there seemed to be some expectation that the new design guide would
cover solar farms. We don’t recall anything included of that
nature? Solar PV appears to be covered in the climate change
section but only on dwellings. We are also not clear at this point
what could be included with respect to solar farm design so this
may need further input from various officers who would be happy to
assist.
Waste:
Our waste team have their own guidance for communal bin storage
– however, there could be perhaps some inclusion of design
guidance on appearance, materials etc of bin stores for communal
buildings. Apologies if this has been missed in our
review.
Oxfordshire Streets Design Guide (Sep 2021):
Have you had the opportunity to input or review this document? As
this is not likely to carry any weight as an SPD, there could be an
opportunity to incorporate some design principles or diagrams from
this document into our own to ensure it can be secured. We would
envisage limited additional words beyond design principles, and the
use of diagrams and layouts would assist within increasing the
length of the document.
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82
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Response manually
entered, submitted in an email format.
Building design
There is only very limited coverage of the design of
houses.
There is nothing about the appearance of houses which are often
bland in design. The provision of dormer windows, bay windows and
porches and variation of materials can do much to improve the
appearance, particularly where the designs are varied along a
frontage.
Building design should generally respect the character of the
settlement, but poor quality design of houses built in the past
should not be used as an excuse for repeating the same poor
designs. New development should reflect the best of the local
character.
Extensions
This section gives very useful guidance on the design of
extensions.
The section on garages suggests that domestic elements are
unacceptable but there is a growing trend for the addition of
offices or gyms above garages, frequently where these are detached
from the main dwelling. This is not covered by the design
guide.
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83
|
Response manually
entered, submitted in an email format.
The Council considers the joint design guide to be elegantly
designed, giving a broad-brush view of the subject. The guide would
do very well as a short textbook on the subject: every professional
(architect, developer, planning consultant etc) would read and
understand the guide, but the Council believes that, for someone
starting on a planning application, the guide is long on principles
and short on practical instruction. For example, a householder
starting on a planning application would struggle to apply the
following principle:
""The building forms used along a street should create rhythm and
interest. Subtle variations in the height and width of buildings
can add visual interest to the street, making it more attractive
and interesting. The scale of new development should be appropriate
and sensitive to its context. Heights of buildings should be
informed by contextual analysis. A variety of building heights
along street frontages can also help to achieve this.""
The non-professional may want to know whether he or she can use
tiles or slate for the roof, but is unlikely to know how to assess
whether their proposed building is going to create rhythm and
interest in the street. Given that the language is supposed to be
simple, there are no definitions, eg what is meant by 'high
quality', and what does ‘realm' mean?
Indeed, it seems that the guide is principally aimed at developers,
and, what is more, seems only to cover urban/town development where
there are local services. There is no mention of rural communities
which often have very poor or limited local services.
Light pollution is only mentioned once, with regard to floodlights
for recreational areas/play spaces, but the Council considers this
surely to be important when designing new housing developments.
There is no mention also about affordability and affordable
housing. It is striking that, in the section on the Built Form,
there is no section on domestic dwellings, but apartments,
extensions, outbuildings, shop fronts, non-domestic buildings and
mixed development are dealt with.
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|
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Comment
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Council’s
response
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1
|
Too
many words.
Too many pages.
Too many concepts.
Too much everything.
YOu get the idea.
The guide is too elaborate and lengthy.
Nice concept.
Poorly implemented.
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·
Noted
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2
|
Generally
speaking, a lot of this is covered by policies within the Councils
recently adopted local plan. there is no need to repeat something
that has already been prvided.
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·
Noted
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3
|
I
would like to see these measures as a mandatory requirement on ALL
new buildings. Not just a few solar panels as a nod to
environmental concerns, Planning permission should not be given if
real efforts to adapt the design.
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·
Noted and will review
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4
|
Thoroughly
support these principles and goals
|
·
Acknowledged
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5
|
If
airsource and groundsource heating systems are being considered
then people need to understand the culture change required to make
and keep that sustainable. Having solar panel or similar is fine
but will only cover a % of energy costs given our
climate.
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·
Noted
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6
|
It is
essential new developments are future proofed to take account of
rapid climate change and the need to move quickly to a carbon
neutral/negative society.
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·
We agree and recommend it as best practice.
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7
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The
existing Vale design guide is very clear, and yet in Faringdon we
see multiple large developments being approved which skip the
guidance . A cursory look at multiple exits and entry suggestions,
space for growing food, movement framework, etc. shows there is
little point in making new guides, if the implementation of
existing guides is so poor. If the same people and processes are at
work in the approval process, there is no point in investing in new
guidelines.
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·
Noted
·
The new guide will be delivered with training for officers to
ensure the guide is more closely
followed.
·
The more accessible online form of the guide will allow greater
clarity around expectations and its use as a tool to review
development proposals.
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8
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some
of the PYE houses in Hendred have recycle of rain water for toilets
etc
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We agree and recommend it as best practice.
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9
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Important
and helpful.
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Acknowledged
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10
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Nothing
about bike storage in the ""Space and layout"" section. Developers
should only consider ""the promotion of car clubs/ rural car
clubs"". The ""Climate and sustainability"" section is not joined
up with ""Movement and connectivity"" or ""Space and layout""
sections. Here is a ""highly efficient and ultra-low energy""
house, please park your car out front.
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·
Noted
· We will review integrating sustainability more
comprehensively throughout the guide.
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11
|
Again,
I like the emphasis on ecological design. I would also add water
efficiency (very relevant to us here, threatened by a massive
reservoir). I would like to add the suggestion that rainwater can
be collected in underground tanks then used as grey water to flush
toilets. This both saves energy in treating and pumping water, and
decreases the overall water in the sewage system. The runoff from
heavy rainfall is slowed down as much will be caught in tanks, and
it will be released slowly as people flush their toilets
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·
We agree and recommend it as best practice.
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12
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With
apologies comments on this entered earlier in
questionnaire
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Noted
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13
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See
11.
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Noted
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14
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The
guidance is ""best in class"", but in my professional experience in
working with developers, the building regulations must be revised
to require sustainable solutions to be implemented. I have written
to my MP in this regard
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·
Acknowledged
·
We can only encourage going beyond current building regulations
unless specified within Local plan policies.
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15
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Extension
is preferable to rebuilding any properties
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·
This would be considered on a case by case basis.
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16
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concern
that the principles may be used by officers without an ability to
discern intuitive and skilful design innovation
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·
The new guide will be delivered with training for officers to
ensure the guide is more closely
followed.
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17
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The
design principles should apply to all buildings however they need
to be applied at an appropriate level - e.g a new sports pavilion
should be treated differently from an extension to a sports
pavilion.
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·
The principles outlined in the design guide are applicable to all
scales of development, unless otherwise specified.
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18
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I
think this should be more prescriptive - e.g. all new development
must be built with insulation of walls and roof, with pv panels and
with heating by heat pump (rather than consideration given to ---)
. I have seen plenty of development locally that has been allowed
without pv panels - why?
Also even listed buildings should be able to install double glazing
using sympathetic materials and designs.
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·
We cannot insist on this approach but recommend it as best
practice.
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19
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It is
interesting to note that both Vale of White Horse and South
Oxfordshire Councils have declared climate emergencies and signed
up to carbon emission reduction targets.
Yet both are currently throwing up poorly designed, badly built,
poorly insulated, fossil fuel heated developments. By definition
these are unsustainable developments and should be halted
immediately.
It is good to see that the Councils are aware of passive design
techniques. These have been around fro 30 years and if properly
implemented mean that no external power sources are required. The
Councils should require developers to use them.
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·
Noted
·
Passive design approaches do not result in no external power
sources, this is a common
misconception.
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20
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Ensure
dont commit to these Technologies as council too early as changes
ongoing.
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·
Noted
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21
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Comprehensive.
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Acknowledged
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22
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Biased
towards developers, create a summarised version for
householders
I can find no discussion here about the advantages of building
upwards, and maximising the existing footprint. Has this even been
discussed? Do yo have any view on it? Do planners just want our
towns and villages to expand outwards and not upwards?
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·
Noted and will review
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23
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page
not working
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·
Noted
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24
|
This
is well though through and I fully support these ideas.
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·
Acknowledged
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25
|
Good
use of renewables, good insulation essential. But these should not
render the buildings to only be available to the
""well-off""
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·
This would not be a material planning consideration so may not be
covered by the design guide. Only material considerations can be
taken into account when deciding a planning application which the
SPD helps inform.
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26
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Would
like to see reference to Neighbourhood Plans
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·
Acknowledged
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27
|
Has
sounding heritage and sustainability been considered. What is the
impact of the increase in 'noise' on the wild-life of a particular
area for example. Has data been gathered?
|
·
Noted.
· No data is available on this subject.
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28
|
Adding
in provision for fast car charging and integrated waste systems to
help facilitate and promote recycling and composting.
|
·
We cannot insist on this approach but recommend it as best
practice.
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29
|
Goals
are too vague and need to be measurable. Otherwise how can you
demonstrate that you have achieved them
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·
Noted and will review
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30
|
Some
of these are looking like policy by default as they are much more
precise than DES10? I support the aspirations in most instances but
was a bit concerned that the principles didn't seem to make much
allowance for special circumstances, eg listed building
alterations/extensions.
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·
Noted and will review
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31
|
Developing
contractors should include carbon used in manufacture and cargo
mileage of materials into UK when seeking manufacturers of all
materials for new build development.
|
This
is now advised in the guidance under Climate and sustainability -
we refer to' whole life carbon assessment' as an assessment
method.
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32
|
While
applicable to all scales of development, these principles are at
the heart of smaller scale developments. I would like to see
guidance in this section raised to the status of a mandate where it
exceeds national criteria.
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·
We cannot insist on this approach but recommend it as best
practice.
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33
|
Strongly
support the best practice aims -am concerned that allowing for the
possibility of not meeting these standards as the text implies
could be highly detrimental to achievement.
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·
Noted and will review
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34
|
OK
|
·
Noted
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35
|
Solar,
water storage, ground/air source, insulation all should be
mandatory
|
·
We cannot insist on this approach but recommend it as best
practice.
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36
|
The
principles in this section are not as detailed as the others; a
little elaboration wouldn't go amiss on terminology such as ""heat
island effects"" - especially if the term ""vernacular"" needed to
be defined in brackets in the Built Form section above.
Also, point 6.9 lost me completely- but maybe that's just
me?
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·
Noted and will review
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37
|
Good
guidance
|
·
Acknowledged
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38
|
no
reference found to the role of neighbourhood plans in climate and
sustainability
|
·
Acknowledged
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39
|
not
enough
|
·
Noted
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40
|
In
this section ""Reducing embodied carbon"" - there is an ambition to
"" encouraged to minimise the embodied carbon of a building,
focusing on its material fabric.""
But there needs to be a reference to the methodology that can be
used...
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·
Noted and will review
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41
|
It
needs to be possible to police the ""built to last"" principle.
""Good design is only successful if it is built to last. Spaces and
buildings that are difficult or expensive to maintain will not
achieve good, long-lasting quality in their design. Proper
consideration must be given at the design stage to the effects of
ageing, weather and climate conditions, normal wear and tear on
buildings, streets and spaces, and landscape."" The materials to be
used are often dealt with only at the reserved matters stage. That
is too late for adequate public scrutiny.
Solar technology should be more than simply an optional extra, and
6.6 and 6.7 should be clearer about this.
The section about thermal efficiency is fine but what is meant by
""an airtight building, mechanically ventilated, in order to
maintain air quality and avoid cold spots and condensation"".
Mechanically ventilated should NOT mean air conditioning which
generates carbon dioxide emissions even if it uses
electricity.
I am not convinced that the paragraph about embodied carbon
sufficiently firm and clear. ""Encouraged"" sounds like something
which is good to have rather than something which must always be
considered.
|
·
Noted and will
review
· We cannot insist on this approach but recommend it as best
practice.
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42
|
We
support the principle of sustainable development and in particular
use of renewable energy technologies to reduce conventional energy
needs.
|
·
Noted
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43
|
Generally
clear and understandable.
|
·
Acknowledged
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44
|
this
is all well and good.but if the materials required to build a house
that lasts for 500 years does not meat green standards in the short
term still build it because in the next 50 years there may be no
green problems
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·
Noted and will review
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45
|
It is
great to see reference to climate and sustainability. But where is
the ambition in working towards climate 'positive' building, as
championed by innovative Oxfordshire companies like Greencore
Construction? There are various innovative Oxfordshire companies
doing good things in this area that will affect our emissions e.g.
https://origencarbonsolutions.com and
https://www.greencoreconstruction.co.uk.
Also, there is no guidance as to how to upgrade buildings with
solid wall constructions (generally pre-1919) - these require
different treatment from modern buildings with cavity walls. There
are lots of ways historic buildings can be retro-fitted without
damaging their fabric. The key is to use breathable materials,
including lime plaster and hempcrete. Snug-fitting secondary
glazing can save as much energy loss as double glazing, which
creates waste and emissions by requiring the removal of an existing
window frame. Marianne Suhr's book 'Old House Handbook: A Practical
Guide to Care and Repair' contains useful information on
retrofitting old buildings, with lots of figures, data and
practical examples to back up the text - the author lives in
Blewbury, and could usefully have been asked to contribute her
expertise to this Joint Design Guide.
The Design Guide should be more ambitious in this section,
especially as both the Vale and SODC have declared a 'climate
emergency' and signed up to 'One Planet Oxfordshire'.
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·
Noted and will review
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46
|
In
producing a SPD it is important that the document builds on the
principles established within the adopted Local Plan but does not
seek to introduce more onerous requirements into the process. It is
important to note that the strategic sites that were included
within the Local Plan included a viability analysis which included
assumptions around the level of sustainability within new builds
that could be reasonably expected to be delivered whilst
simultaneously delivering the necessary infrastructure package;
this is notably the case in Berinsfield in which there is a
significant imperative for wider regeneration. For example, as
drafted the requirements include that all residential developments
aspire to meet Passivhaus Certification. The section should include
a more general reference to ensuring that the measures proposed can
be viably supported without detriment to the wider delivery of the
scheme.
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·
Noted and will review
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47
|
Climate
Change resilience and adaptation should be at the heart of the new
design guide, the Council are concerned that by placing this at the
end of the document that this is not demonstrating its
importance.
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·
Noted and will review
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48
|
Response
manually entered, submitted in an email format.
1. This is a very competent section, but in a post-Covid
environment there could be more detail provided on systems for safe
room ventilation with a volume change and filtration
required.
|
·
Noted
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49
|
Response
manually entered, submitted in an email format.
Climate Change and Sustainability
HLM supports the principle of a joint commitment to move towards
greater resource efficiency. HLM considers that the design guide
must adopt an approach that is ‘in-step’ and aligned
with government guidance and must avoid prescription at local
level. Whilst we note the reference to the requirements of Policy
DES10 South Oxfordshire District Council’s adopted Local
Plan, this policy does not apply to proposals in the Vale of White
Horse District, and therefore should not be used to justify
application of higher standards sought through this joint
SPD.
Amendments to the Building Regulations will come into force in June
2022 that seek to reduce carbon emissions from homes and other
buildings, with improvements to fabric efficiency, installation of
electric vehicle charging points, revised heating and ventilation
system requirement, and overheating prevention measures. These
amendments are then due to be followed by The Future Homes and
Buildings Standard that will come into effect in 2025 to set higher
standards for greater sustainability and lower carbon
emissions.
Whilst standards and efficiencies that exceed those nationally
described can of course be welcomed within the Guide, and relative
benefits of any uplift can be considered as part of the
determination of development proposals, HLM considers it critical
that the guidance should progress ‘in-step’ with
national guidance, and support delivery towards a targeted solution
as advocated by a set of nationally prescribed standards that are
to in force in the short and medium term.
Passive and Active Design
HLM note the approach taken in the guidance that "encourages"
opportunities for passive and active design to be integrated into
new developments. HLM supports this flexible approach, reflecting
that such opportunities will differ depending on sites locations,
features and their wider physical and socio-economic contexts,
which will raise differing, design, practicality, and
deliverability considerations. Flexibility should be given when
assessing schemes and particularly with how they align with current
requirements.
Passivehaus
HLM does not agree that all new buildings, including minor
applications within South and Vale should aim for Passivehaus
Certification. Whilst opportunities may exist for some features to
be integrated into the design of new homes in some circumstances,
it is critical that design and construction ambition is carefully
and flexibly balanced with wider considerations, having regard to
cost, practicality and deliverability. Passivehaus is one such
example of where commitment to an ‘uplift’ in
sustainability credentials could be considered as part of the
overall benefits of a development proposal. i.e., it may weigh in
the planning balance.
Towards Zero Carbon Design and Construction
HLM notes South and Vale’s ambition to encourage a collective
move towards zero carbon in both design and construction. However,
any uplift in construction and design standards will need to be
considered as part of a whole Plan viability – a step to be
explored and tested as part of the emerging Joint Local Plan, it is
not possible to predict future policies and seek their application
now. The principle of seeking uplifts to sustainability performance
and/or reductions in emissions on schemes, that is solely justified
through planning guidance and where there is no supporting national
nor local policy basis to require such provision, has been found to
be flawed approach by the Secretary of State1.
Therefore, insofar as the approach to be taken in this SPD, that is
being progressed ahead of new Local Plan policy, HLM considers such
construction and design standards must be in step with the scope of
the forthcoming changes to Building Regulations in June 2022 and
Future Homes and Buildings Standard which the Government is
intending to introduce as national policy commitment from
2025.
Electric Vehicle Infrastructure
Whilst HLM supports investment in electric vehicle infrastructure,
the true costs for provision of charging points and the power
requirements to the local network are only just being understood.
Before imposing a standard of provision, due and evidenced
consideration must be given to the technical and viability impacts
for such technologies, and therefore reference to national guidance
including Government proposals (and those to be defined under
Building Regulations) is critical.
HLM would suggest provision of active or passive infrastructure
provision, should be applied flexibly having regard to cost,
practicality, and deliverability.
We trust these comments are helpful in advancing the Design Guide,
at the appropriate time, and in line with the progression of
evidence and policy formation in respect to the emerging Joint
Local Plan.
|
·
Noted and will review points individually
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50
|
Response
manually entered, submitted in an email format.
2. Rules on parking should ensure that there is adequate electric
charging capacity available securely.
6. The Guide should recognise the need for pre-installed electrical
connectivity such as:
- fibre internet
- electric charging capacity
- matters like solar panels
7. The Guide should recognise the impact of flooding
including:
- need for water absorption to reduce fast run-off (eg reducing
tarmac area; water butts; individual house rain soakaways)
- need to retain existing waterways and flood areas to continue to
serve built development.
|
·
Acknowledged
|
51
|
Response
manually entered, submitted in an email format.
Climate and Sustainability
• The Planning and Development Committee support
this.
|
·
Acknowledged
|
52
|
The
need for exploring and using new sources of energy is clear.
However we should be taking a balanced and thoughtful appraoch,
especially given all the other points and considerations that go
into good design. I would be keen to see something included on the
installation of solar panels - be this in existing or new
develoments, and in particular with respect to any large scale
solar farms on agricultural land which will have a huge impact on
the character of the environment. There will also be a huge impact
on the ecosystem which should be taken into account. This would
similarly apply to Windfarms etc if these were to be condiered for
the local area.
|
·
Acknowledged
|
53
|
The
principles in this section as so important. I think this is the
most important section of all.
|
·
Acknowledged
|
54
|
Response
manually entered, submitted in an email format.
In the Climate and Sustainability section, the work of South
Oxfordshire District Council is referenced but there also needs to
be recognition of the work that the Vale of White Horse District
Council are doing at the moment in terms of moving towards the
introduction of higher levels of sustainable design than those
included in the current building regulations.
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·
Noted and will review
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55
|
What
is sustainable development? Please add: -- Public and political
awareness of the need for resilience and low carbon footprint
development will accelerate as we experience in our Districts the
extreme weather events predicted by climate change
scientists.
What is a Climate Emergency? Please make this statement more
relevant locally by following 'by the Committee on Climate Change.'
with the statement now in the background section: -- South and Vale
are signed up to the carbon reduction targets of the Oxfordshire
Energy Strategy, which committed to a 50% reduction in carbon
emissions by 2030.
Please expand what is meant by Active Design: -- Active Design
includes measures to sequester carbon and encourage biodiversity.
Measures to support biodiversity and carbon sequestering include
planting trees, living walls, gardens, allotments, wild areas,
preserving farmland, bird nesting and feeding, insect friendly
plants and nesting places, wild flower areas for bees to feed,
clean water courses to encourage fish.
Active Design Principles to include:
- Support for Biodiversity
- Living Walls
Design principles - sustainable development
6.0. Please change to: Uses tree planting in open spaces and
streets and living walls for and in proximity to buildings to
mitigate heat island effects.
What are carbon emissions?
Please include construction emissions at this stage: -- Achieve the
optimal design approach to minimise energy usage and reduce carbon
emissions in the construction and use of developments.
Follow this by - Reduction in the carbon impact of construction is
covered in the reducing embodied carbon section below.
Standards and Certifications.
It is essential, if the SODC and Vale are to achieve a 50%
reduction in carbon emissions by 2030, for the construction of
Domestic buildings to be included in the Standards and
Certifications scheme. Choosing the right set of standards must be
a high priority for the Design Guide Team. The BREEAM code for
sustainable homes is an optional planning standard, subject to
local authorities’ justifying the case for their application
on the basis of need and viability. Passivhaus is not always
viable.
The Planning Guide must state at this stage that domestic buildings
should achieve either Passivhaus or The BREEAM code for sustainable
homes with a note that the planners will consider applications
which achieve higher standards than those covered by these
schemes.
Please insert a Box ""Residential Buildings' alongside that for
""Minor non-residential Buildings' pointing downwards to Passivhaus
and The BREEAM code for sustainable homes with a note, exceptions
to these codes achieving a lower carbon footprint will be
considered.
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Carbon
sequestration is not currently calculatable; therefor we cannot
specify requirements around it as it is not
quantifiable.
Support for Biodiversity and Living Walls are not Active design
principles.
Living walls do not mitigate heat islands.
Construction emissions are measured under embodied carbon, not as
emissions under regulatory policy and technical
definition.
Guidance on measuring and reducing Embodied carbon are already
referred to.
Both Passivhouse and BREEAM are optional standards of development
unless specified by Local plan development policy. Currently only
SODC have an adopted requirement for BREEAM, and only in certain
types of development.
References to residential, non-residential, both minor and major
development, will be reviewed regarding BREEAM and
Passivehouse.
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56
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I
think adopting Passivhaus for new residential development is
excellent and I support that.
However, for non-residential, this design guide will result in
buildings continuing to emit carbon, albeit at a lower level than
currently, though that is easy given the low standards currently in
place.
The weakness of BREEAM is that it does not result in a nil carbon
building. To meet Net Zero by 2050 then BREEAM on its own will not
deliver that. I think that BREEAM is a well understood measure and
so it seems sensible to keep it, but, it needs to be supplemented
by the requirement that any new building or development must
state
1 - it's carbon emissions (which should be set at passivehaus
levels), and
2 - how it is achieving net zero by 2050. Any new development must
have a plan for how it does or will achieve net zero. At present we
are worried about how to retro-fit old stock to contribute to net
zero and that is a tough problem - however, new buildings should be
held to a far higher standard.
At present many builders do not know how to build to this level but
they must increase their skills and capabilities so that they can,
and this requirement will help I think
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Both
Passivhouse and BREEAM are optional standards of development unless
specified by Local plan development policy. Currently only SODC
have an adopted requirement for BREEAM, and only in certain types
of development.
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57
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6.4 -
Rainwater harvesting - this is more successful on the back of
garages rather than a house, and particularly intrusive on a small
semi-detached or terraced houses with a narrow rear
elevation.
6.6 - PV on all buildings - not necessarily the best technology on
all sites nor all buildings.
6.13 - ""all development aspires to go beyond Part L assessment"" -
this is above Building Regulations - there is not a Vale policy to
support this.
6.15 - Passivhaus is again above Building Regulations with specific
criteria to gain accreditation. Building Regulations should be
implemented.
The industry is going through a significant period of change with
regard to carbon targets and climate change. As the largest volume
housebuilder, the Barratt group (including David Wilson Homes) have
set ambitious goals for our operations committing to Zero Carbon
Homes from 2030. We have a dedicated Group Technical and Innovation
Team responsible for delivery, who are developing our future ways
of working with new products and technologies. This change will
take time to bed in to the supply chain at a scale to support the
quantum of housing needed across the district and country, and the
2030 target considers a realistic timeframe in which the industry
and its supply chain can achieve zero carbon. The industry is also
working on increased off-site production of components and Modern
Methods of Construction. Whole-life carbon assessments will be
difficult to provide given that supply of materials is currently
not known far in advance of delivery, and changing materials
through the construction period would become difficult and possibly
threaten delivery. We would reiterate the above point on material
availability issues affecting the sector, and our reliance on our
suppliers to help meet these targets.
|
Both
Passivhouse and BREEAM are optional standards of development unless
specified by Local plan development policy. Currently only SODC
have an adopted requirement for BREEAM, and only in certain types
of development.
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58
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sustainability
and renewability must be geared to achieving the best possible
environment, with good air quality. Without exception, all new
buildings should be fully-fitted with solar panels to their maximum
capacity.
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·
Noted and will review
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59
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This
section refers to Passivhaus standards at the target energy
performance standard which is admirable. It would be better here to
be much more specific e.g. 15kWh/m2/yr heat requirement; 0.6 ACH
for airtightness and specifics for the number of solar panels etc.
This is because many developers might insist on meeting the minimum
standards e.g. UK building regs even though they are not fit for
purpose in a new zero carbon world.
There is no reference to linking waste water/sewage management to
renewable energy via the likes of AD plants. It would be very
logical for communities to want to use their waste in this way and
create community owned district heating systems as their solution
to becoming net zero C.
Of course developers won't just do this because it involves
increased capital expenditure without any guarantees of future ROI.
However, the planning guide doesn't need to present these types of
community based infrastructure as a favoured option for future
planned developments rather than just relying on every house being
equipped with a heat pump connected to the electricity grid.
Why are there no mention of links between waste water management,
SuDs, biodiversity and energy? The report was intended to be simple
and clear but by missing out linkages between technologies, it will
just led to continued development of unsustainable sole less
housing estates.
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We
cannot insist on this approach but recommend certain aspects of the
approach where applicable.
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60
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FORMATTING:
Needs a chapter number for reference. Could a mini contents list be
included under each chapter title/heading for easier navigation, to
avoid scrolling? Principles should really be first, and then follow
up with explanation text, diagrams and helpful links
below.
POSITION WITHIN THE JDG – the initial text for this chapter
says that ‘Sustainable development has many complex and
interwoven dimensions to it that must be considered from the
earliest stages of development, as the potential environmental
impacts are significant’. Officers think that this chapter
needs to be put right at the start of the JDG – before
‘PLACE AND SETTING’ – to highlight its
significance. It could then host hyperlinks to connecting bits
located within other chapters with the JDG.
[6.10-6.15] STANDARDS AND CERTIFICATIONS - Officers raised concerns
that specific reference had been made to standards and specifically
South Oxfordshire Local Plan policies. This should be more generic,
as although there will be a Joint Local Plan, it is not clear when
Vale will have the stronger policy context in place.
[6.14] "BREEAM EXCELLENT" – Please be aware that the BREEAM
excellent standard is being brought into dispute in some instances
for applications in South Oxfordshire. It is recommended that the
wording of this principle is considered carefully, and Emily
Hamerton contacted about this before it is formalised.
|
Contents
and navigation will be reviewed as part of the website design and
structure of the guide.
Aspects of sustainable development that relate to other sections of
t guide will be reviewed and possible re-structures.
Both Passivhouse and BREEAM are optional standards of development
unless specified by Local plan development policy. Currently only
SODC have an adopted requirement for BREEAM, and only in certain
types of development.
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61
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Clearly
set out.
This section should give more attention to technological
developments and their future refinement that will allow individual
dwellings to generate and store their own energy requirements using
renewables, and also to facilitate retro-fitting as technologies
develop. This has particular relevance to rural areas. It is all
encapsulated in the 'active design approach', all of which can
apply to 'rural design'.
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·
Noted and will review
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62
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Structure
of the ‘Climate and Sustainability’ section:
As highlighted in Bloor Homes’ response to Question 9, the
NPPF, PPG and recent case law have clearly established that the
role of an SPD is to provide guidance in relation to existing
policies in adopted local plans, and that it is not within the
remit of an SPD to introduce new policy requirements. Indeed, the
introduction of new policy requirements should be deferred to a
local plan review, where impacts on viability can be considered
fully.
Whilst that is a general comment that has been made in relation to
the Design Guide SPD as a whole, it is perhaps most applicable to
the ‘climate and sustainability’ section which, as
currently drafted, could be read as introducing new policy
requirements. As such, this section should be refreshed to reflect
the role of an SPD as providing guidance for applicants to ensure
that they adhere to relevant policies.
To make that clear, it is suggested that the section begins with a
‘planning policy’ sub-section that sets out the policy
requirements within the adopted local plans for the Vale of White
Horse and South Oxfordshire, so that it is clear to applicants and
decision-makers what the development requirements are in that
regard. So that users of the document are able to fully understand
the policy requirements for each authority, the text contained
within design principles 6.13 and 6.14 should be subsumed into the
‘planning policy’ section for South Oxfordshire, making
clear that these are requirements for South Oxfordshire
only.
That ‘planning policy’ section should then be followed
by an explanation that the following text and design principles are
seeking to highlight matters that could / may be considered by
applicants when seeking to adhere to those policy requirements,
with the goal of delivering sustainable development schemes. It
should be made clear at this point that development proposals are
not required to meet each of those design principles in order to be
policy compliant, but that a combination of those design principles
may assist in a scheme demonstrating its policy
compliance.
Design Principles:
On the basis of that approach, the Councils should also amend each
‘design principles’ section / box to make clear that
each of the design principles set out are highlighting matters for
applicants to consider, and are not policy requirements in
themselves. That is an important distinction to be made, in order
to ensure that this section is clearly written and unambiguous, and
so that decision-makers are aware of the status of this guidance.
Thus, the wording of the design principle boxes should be updated
to read "applicants may consider", rather than suggesting that
applicants should "ensure the scheme" meets the design principles.
Whilst a minor alteration, that will allow for decision-makers to
have a greater understanding of the role and status of the SPD, and
therefore will also assist in the application of this guidance
within the development management process.
Moreover, the wording of each design principle should be updated to
reflect the purpose of the SPD. Taking principle 6.11 as an
example, a more suitable wording would be "applicants may
consider... prioritising modern methods of construction (MMC) for
the built form and its envelope." That reflects more accurately
that each design principle is effectively a potential design /
construction principle that could be pursued to ensure that the
scheme is policy compliant.
However, other design principles require more substantial
amendments to reflect the purpose of this section of the Design
SPD. Whilst a full audit should be carried out by the Council to
identify all instances, design principle 6.9 is one such example.
As currently drafted, design principle 6.9 seeks to ensure that
schemes demonstrate "strategies for energy infrastructure including
that for proposed on-site generation, with a feasibility study, for
distributive or on demands shared networks." Even when presented as
a solution that applicants may consider, that will clearly not be a
feasible or viable solution for the vast majority of sites. Rather,
this design principle should suggest that "applicants may wish to
consider... for larger development schemes, whether on-site energy
generation, including distribution and / or on-demand shared
networks, would be feasible."
Alternatively, other current design principles should be reframed
in terms of how they are presented. For example, design principle
6.15 seeks that "all residential properties aspire to meet
Passivhaus certification." Whilst inspirational, that is not a
policy requirement set out within an adopted plan, and the Design
Guide SPD itself recognises that "we understand that this may not
always be appropriate due to some development types and / or
reasons of viability." References to inspirational standards that
go over and above existing policy requirements should not be
presented as design principles at all, and instead could be
included in a separate section that relates to those developments
that are seeking to exceed the required sustainability
standards.
Other design principles, however, should be removed entirely. For
example, the suggestion that a "whole life carbon assessment [...]
focusing on the product and construction stages" should accompany
the submission of a planning application is wholly unsuitable. For
the vast majority of developments, that requirement would not
constitute proportionate evidence in comparison to the scale of
development involved and, in any event, the submission of such a
document is not included in the adopted plans of either authority,
be that as a formal policy requirement or in passing.
In light of the above, it is clear that the ‘Climate and
Sustainability’ section of this Design SPD requires a
substantial review to ensure that it reflects the purpose of SPDs,
is clearly written and unambiguous, and appropriately reflects the
existing policies that are set out in adopted local plan
documents.
|
Both
Passivhouse and BREEAM are optional standards of development unless
specified by Local plan development policy. Currently only SODC
have an adopted requirement for BREEAM, and only in certain types
of development.
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63
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No
metion of green bus shelters. Current car spaces should be designed
to be repurposed with ease. Solar energy capture has differerent
voltage outputs for different scales. Solar farms need to have a
33,000V output so need to be near a major sub station. Maitenance
and disposal of need to be accommodated.
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·
Noted and will review
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64
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The
design principles mandate the "use of solar technology on all
roofs...." but makes no mention of heat pumps (ground, air or
water) We should like to see these added rather than being an
optional item in the generic catch all of the item under
6.5
In section covering principles 6.10 to 6.15 and 6.16 to 6.21 we
feel the use of phrases such as "aspire to" and "prioritised" allow
avoidance by developers. We would prefer more prescription
including the exclusion of any gas technologies.
Likewise, for example "reduce materials with high carbon
footprints" (6.18) has little if any meaning.
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·
Noted and will review
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65
|
Please
refer to submitted representations.
|
·
Noted
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66
|
Response
manually entered, submitted in an email format
We strongly support all measures to achieve net zero carbon and
believe that, given that CO2 emissions pose an existential threat
to humanity we recommend that the Design Guide make it clear that
designs that do not achieve this cannot and will not be considered
acceptable.
We do recommend that Street Light design also be included in Fig 55
as an ‘Issue to consider when designing to zero
carbon.’
The challenge to designers, architects and developers must, despite
the inevitable complaints about extra costs, be to achieve
beautiful design once the net zero performance has been designed
in.
A design that adds to climate change, which is increasingly
threatening the lives, health and well-being of human and all life
cannot be considered acceptable.
The Oxfordshire County Council Street Design Guide, must be
included as a resource.
https://www.oxfordshire.gov.uk/residents/roads-and-transport/transport-policies-and-plans/transport-new-developments/transport-development-control
Sustainable Development – Active design
Goal: Achieve an optimal active design approach
Greater emphasis should be placed on these design
’considerations’. The guide should place a strong
expectation that these WILL be included unless a strong case can be
made for their exclusion.
Design principles - sustainable development
6.6 solar energy capture is an essential component of a sustainable
building. In this context major is not defined adequately and will
result in disputes with developers. This section should
specifically include all homes and buildings (both private &
commercial) of more than a specified footprint or volume.
Reducing carbon emissions
Spelling: Should be ‘Regulated energy: is energy consumed by
a building and its controlled, .....’ not ‘Regulated
energy: is energy consumed by a building and it’s controlled,
.....’.
Standards and Certifications
Should read ‘South Oxfordshire Local Plan policy DES10 not
‘South Oxofrdshire Local Plan policy DES10.
|
Street
lighting is an issue controlled by OCC (Oxfordshire County
Council) and outside of the districts control and scope of
the SPD.
Net zero cannot currently be required as there is no local plan
development policy requirement in either district currently adopted
to support it.
This is beyond the scope of the SPD.
The (OCC) Street Design Guide is already included as a
resource.
Design ‘considerations’ is design guidance that meets
the ambition of corporate targets set by the local authorities but
cannot currently be made mandatory as there is no local plan
development policy to support them.
References to residential, non-residential, both minor and major
development, will be reviewed.
Spelling and grammar are under review.
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67
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The
objective for the Joint Design Guide is to raise the quality of
design and sustainability in new development across both districts.
However the guide has failed to recognise the importance of design
in minimising light pollution. The negative impacts of light
pollution on humans, wildlife & biodiversity are well known and
recognised by South Oxfordshire District Council. Furthermore,
energy is wasted by light spillage & undirected light, and the
council should be looking to reduce this waste of energy. The
council must include & insist on good design that will minimise
light spillage to ensure harm to the environment is minimised,
energy is not wasted, and the development will help the council
meet is carbon reduction targets.
Therefore, this document must include reference to reducing wasted
light energy, i.e. pointing individuals, developers &
architects to the guidance issued by the Institute of Lighting
Professionals - https://theilp.org.uk/, as well as making
individuals, developers & architects to the issues of light
pollution, and giving examples of good designs, that use light
spillage reduction glazing, minimal amount of glazing on wasted
spaces, such as vaulted ceilings (which in themselves are not good
for heating energy efficiency), and examples of correctly directed
external lighting.
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·
This comment raises issues that fall outside the scope of the
design guide.
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68
|
Missing
Neighbourhood Plan design and climate change policies
again!
|
·
Acknowledged
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69
|
Response
manually entered, submitted in an email format.
The introductory text for this section provides an overview of the
issues around climate change, sustainability and sustainable
development. As a responsible promoter and developer, CEG fully
supports the need to address climate change, and the need for
schemes to deliver sustainable
development in its widest sense.
Nonetheless, the Joint Design Guide SPD cannot step beyond its role
as a document that is supplementary to the adopted development
plans for Vale of White Horse and South Oxfordshire District
Councils.
By way of example, in the Vale of White Horse, Core Policy 43:
Natural Resources, encourages developers to make provision for the
effective use of natural resources, including maximising passive
solar heating, and Core Policy 40: Sustainable Design and
Construction, encourages developers to
incorporate planting, shading and advanced glazing systems to
reduce solar heat gain. There is nothing in the Vale Local Plan
Part 1 or Part 2 that explicitly requires solar panels on new
buildings, and yet the ‘Design principles – sustainable
development’ in the Joint Design Guide suggest it is ensured
that schemes use solar technology on roofs for all [emphasis added]
major commercial, noncommercial, and industrial
buildings.
Solar may not always be the optimal solution in any event, but the
important point of principle is that the Joint Design Guide cannot
create new policy requirements. Here and elsewhere, if there is no
development plan policy (or Act of law) requiring something, the
Joint Design Guide can only
encourage, or require consideration of the relevant matter. To
avoid Officers and applicants needing to constantly refer back to
the adopted development plan policy for matters addressed in the
Joint Design Guide, it is vitally important that the next version
of the Design Guide is clear and robust throughout, in terms of
those matters where encouragement is given, and those matters where
there is a development plan policy requirement (which can of course
then be presented as a requirement in the Joint Design Guide).
Where relevant, the different requirements that apply in Vale of
White Horse district and South Oxfordshire district, also need to
be made clear.
In relation to the section ‘reducing emissions’, there
is clearly an evolving set of requirements, with the new Building
Regulations, requiring a 30 per cent cut in carbon for all new
homes, coming into force in June 2022, and the Future Homes
Standards to be subject to further consultation in 2023. The Joint
Design Guide should recognise the evolving nature of the
requirements, and make it clear how the Council will keep the Joint
Design Guide up to date and relevant in relation to national
requirements aimed at reducing emissions.
The ‘Design principles – Standards and
Certifications’ state that applicants should ensure that all
residential proposals aspire to meet Passivhaus certification
(paragraph 6.15). How will the Council assess whether a scheme has
aspired to Passivhaus certification? There is no development
plan
policy requirement for Passivhaus certification, and we would
respectively suggest that the wording in paragraph 6.15 needs
clarifying, perhaps to state that ‘all residential proposals
should aspire to Passivhaus principles’.
In relation to BREEAM, whilst the South Oxfordshire Local Plan
requires all non-residential proposals to meet BREAM excellent
standard, unless mitigating circumstances can be demonstrated, the
Vale Of White Horse Local Plan (Parts 1 and 2) make no reference to
BREEAM. Paragraph 6.14 of the Joint Design Guide therefore needs
amending to make it clear that the requirement to meet BREEAM
excellent standard (for all non-residential development) only
applies to schemes in South Oxfordshire, and that in the Vale of
White Horse, the Council will encourage development to
this
standard.
|
Both
Passivhouse and BREEAM are optional standards of development unless
specified by Local plan development policy. Currently only SODC
have an adopted requirement for BREEAM, and only in certain types
of
development.
The wording of guidance and expectations of solar panels and their
incorporation as part of sustainable development, will be
reviewed.
Additionally wording of guidance and technical specification in
relation to sustainable development will be
reviewed.
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70
|
Response
manually entered, submitted in an email format.
Now that the consultation period on the Draft joint design guide
has ended I shall be very interested to hear what the responses
say.
At an earlier stage of consultation I did say that climate change
issues should not be a bolt-on extra but should pervade everything
we do in the council (and not just in planning).
However the draft design guide has a chapter at the end entitled
Climate and Sustainability. I don't disagree with anything written
in that chapter. It has lots of good stuff in it. But I wish its
suggestions had been taken on board in the other
chapters.
|
The
wording of guidance and technical specification in relation to
sustainable development will be
reviewed.
|
71
|
Response
manually entered, submitted in an email format.
Climate and Sustainability (Design Principles – Sustainable
Development)
Gladman recognise that the planning system has an important role to
play in tackling the climate emergency and the underpinning
intentions of the proposed sustainable development design
principles However it is important to reiterate that SPDs should
provide clarity and guidance on existing development plan documents
rather than being a mechanism to fast-track the adoption of policy
requirements without the corresponding consultation and independent
examination.
In this regard, we welcome that the proposed sustainable
development design principles are not intended to be applied
rigidly and are worded to provide flexibility where required. It is
important to note that some of the requirements set out in the
design principles have not been subject to the viability testing to
understand any potential implications on the delivery of other
Local Plan objectives, which may need to be completed if it was the
intention to apply the proposed guidelines rigidly in all
cases
Amending the initial design principles wording from ‘Ensure
the scheme’ to provide greater flexibility such as
‘Considers the delivery of’ or ‘Optimises the
following elements’ would support the Councils aspirations
while also not rewriting Local Plan policy requirements.
Climate and Sustainability (Design Principles – Standards and
Certifications)
Gladman have no specific comments to make on the design principles
set out within the Standards and Certifications element of the
Design Guide. Again, we welcome that the principles employ terms
such as ‘aspire to’ and ‘prioritise’ which
allow for flexibility in the application of the principles whilst
also seeking to achieve the policy requirements set out in the
adopted Local Plans.
|
The
wording of guidance and technical specification in relation to
sustainable development will be
reviewed.
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72
|
Many
of the sections of this part of the guide, for example the sections
relating to climate emergency, the definition of net zero carbon,
carbon emissions, MMC are explanatory rather than
guidance.
Case law has established that the role of an SPD is to provide
guidance in relation to existing policies in adopted local plans,
and that it is not within the remit of an SPD to introduce new
policy requirements. The introduction of new policy requirements
should therefore deferred to the current Local Plan
review.
The sections of the SPD should be clear as to what is explanatory,
the Local Plan policy requirements; and what further advice is
given to assist applicants in meeting these policies, via the SPD.
Currently, the guidance is unclear. There are some references to
Local Plan policies (e.g. DES10 of the adopted SODC Local Plan) in
paragraph 6.13), and what appear to be new policy
requirements.
Bloor Homes suggests that this part of the SPD provides a
‘planning policy’ sub-section that sets out the policy
requirements within the adopted local plans for the Vale of White
Horse and South Oxfordshire, and then provides additional advice
setting out how applicants might then meet the policy requirements.
It should be made clear that development proposals are not required
to meet each of the design principles in order to be policy
compliant, but that a combination of those design principles will
assist in designing a scheme that demonstrates policy
compliance.
Design Principles:
In order to be clear that the design principles in this section are
areas for consideration in the design process, the wording of the
design principle boxes should be amended to ‘applicants
should consider’, rather than requiring applicants to
‘ensure the scheme’ meets the design
principles.
The wording of each design principle should also be updated to
reflect the purpose of the SPD. Taking principle 6.11 as an
example, a more suitable wording would be ‘applicants should
consider... prioritising modern methods of construction (MMC) for
the built form and its envelope.’ That reflects more
accurately that each design principle is effectively a potential
design / construction principle that could be pursued to ensure
that the scheme is policy compliant.
Other design principles require more substantial amendments to
reflect the purpose of this section of the Design SPD. Whilst a
full audit should be carried out by the Council to identify all
instances, design principle 6.9 is one such example. As currently
drafted, design principle 6.9 seeks to ensure that schemes
demonstrate ‘strategies for energy infrastructure including
that for proposed on-site generation, with a feasibility study, for
distributive or on demands shared networks.’ Even when
presented as a solution that applicants may consider, that will
clearly not be a feasible or viable solution for the vast majority
of sites. Rather, this design principle should suggest that
‘applicants may wish to consider... for larger development
schemes, whether on-site energy generation, including distribution
and / or on-demand shared networks, would be
feasible.’
Alternatively, other current design principles should be reframed
in terms of how they are presented. For example, design principle
6.15 seeks that ‘all residential properties aspire to meet
Passivhaus certification.’ Whilst inspirational, that is not
a policy requirement set out within an adopted plan, and the Design
Guide SPD itself recognises that ‘we understand that this may
not always be appropriate due to some development types and / or
reasons of viability.’ References to inspirational standards
that go over and above existing policy requirements should not be
presented as design principles, and instead could be included in a
separate section that relates to those developments that are
seeking to exceed the required sustainability standards.
Some of the design principles should be deleted. For example, the
suggestion that a ’whole life carbon assessment [...]
focusing on the product and construction stages’ should
accompany the submission of a planning application is wholly
unsuitable. For the vast majority of developments, that requirement
would not constitute proportionate evidence in comparison to the
scale of development involved and, in any event, the submission of
such a document is not included in the adopted plans of either
authority, be that as a formal policy requirement or in
passing.
In light of the above, Bloor Homes submits that the ‘Climate
and Sustainability’ section of this Design SPD requires a
substantial review to ensure that it reflects the purpose of SPDs,
is clearly written and unambiguous, and appropriately reflects the
existing policies that are set out in adopted local plan
documents.
|
·
Noted
|
73
|
Please
see submitted letter for full comments.
|
·
Noted
|
74
|
Please
ensure that you require sustainable principles for all future
development.
|
·
We cannot insist on this approach but recommend it as best
practice.
The wording of guidance and technical specification in relation to
sustainable development will be reviewed.
|
75
|
Brundtland
Commission definition of sustainable development is (arguably)
out-of-date. It should be clear that a building is only sustainable
if it is zero carbon in construction and operation; has generated a
significant increase in bioabundance and biodiversity; and is free
from risk of overheating, drought, flood and storm. These aspects
should be insisted upon.
It is better practice to refer to zero carbon rather than net zero
or carbon neutrality.
Please delete references to 'natural gas'. It should be insisted
upon that heating systems are electric, air source heat pumps
(ASHP). Gas boilers going in now, will need replacing in 13 years
time just as the government bans new gas boilers. It is not always
easy to 'bolt on' an ASHP to a system designed for a gas boiler. NO
gas boilers should be being used.
A misprint in the first section? ""Here are the climate action
targets for the districts"" should then say that South
Oxfordshire's is zero carbon by 2025 for council operations, and by
2030 for the district. (Plus twice in this section it says
Oxfordshrie not Oxfordshire).
Fuel cells? I do not think these are likely to be a useful source
of energy for homes. Perhaps delete.
Homes should be built to Passivhaus standard (thank you - but could
we be more insistent)?
Thank you for including water harvesting and storage
provision.
LETI believe that mechanical ventilation and heat recovery should
be used, and passive ventilation not relied upon. I think this is
right. It ensures that a home can be kept airtight in the winter,
and fresh, dry air can be brought in, warmed by the outgoing stale,
damp air.
Please note, construction can be zero or negative carbon by
sequestration of carbon in the building (hemp or wood building
materials). This is not always calculated in and subtracted from
the construction carbon emissions and is not always recognised as a
means of achieving zero carbon (pers comm, Ian Pritchett, Greencore
Construction Ltd).
Taylor Wimpey calculate 200T of carbon dioxide is emitted for each
home built, on average, just in construction. It would take 10,000
mature trees a year to absorb that carbon dioxide.
|
·
Acknowledged
|
76
|
Remember
that too much solar can be intrusive and ugly. Glint & glare
must be considered from large numbers of panels.
|
The
wording of guidance and technical specification in relation to
sustainable development will be reviewed.
|
77
|
Response
manually entered, submitted in an email format.
We are impressed by the overall principles embodied in the plan for
sustainability, beauty and design. Although the focus of the plan
is urban, we would like to see the plan make recommendations with
those same principles for the local green environment in which our
communities are embedded. We urge you to include content on
development of the green landscapes surrounding our
communities.
Two particular types of new land development deserve more
attention:
1. Solar farms
We have recently seen proposals for two solar farms in Cumnor
parish. Both are likely to have a negative impact on an area which
provides rural leisure both for the local inhabitants and walkers
coming out from Botley and Oxford. Of course we need all the green
energy we can get. But two solar farms within the bounds of a
parish of Cumnor’s size seems self-evidently inappropriate.
Both proposals come from investment companies from outside the
County.
2. Carbon Capture
External investors are offering farmers considerable incentives for
land purchase to offset carbon dioxide by forest planting. Farmers
and their communities are unable to compete with the same speed of
action as investment companies and face the prospect of having
limited control over the long term use of the land , and the
likelihood of mono-culture pine forests, with their risk to
biodiversity. Some of the issues were highlighted in the BBC
programme "Costing the earth " on 8 March 2022,
https://www.bbc.co.uk/sounds/play/m00154b2
We believe both types of development are necessary but there are
drawbacks when they come from external companies whose prime
motivation is cash generation and who have no loyalty to the future
of the localities. We know that farmers have faced considerable
challenges in recent decades. Those challenges are increasing as
society reviews farming practices in the light of climate
change.
It is a poor state of affairs when farmers who have preserved our
agricultural production and our landscape for centuries are playing
a lesser role in what happens to that land for years to come. We
need planning policies that can favour that heritage.
We appreciate this is not in your brief but believe urban and rural
issues are closely connected in districts such as South and Vale,
and we hope you can find ways to ensure these issues are not
overlooked.
|
Graphics
and photography will be reviewed and
updated.
Specific guidance on the siting and design of renewable energy
schemes will be added to the design
guide.
The wording of guidance and technical specification in relation to
sustainable development will be reviewed.
|
78
|
Response
manually entered, submitted in an email format.
General Comment
• This is an excellent section in terms of explaining the
different elements of design and how they relate to climate
change/sustainability
• Would be beneficial to move this chapter higher up to match
our corporate objectives and reflect its importance. It seems at
the moment a little stuck on the end.
• Figure 55 – this graphic seems a little random i.e.,
a large selection of icons which don’t relate to each other-
not sure this works? Could this be more of a drawing of a house? Or
have labels?
• Ground source heat pump photo – looks almost
offputtingly large – is this for a multi-house scheme? if so
would be useful to label as such, or is it possible to find a photo
of the kit you need with a domestic scale GSHP e.g. more like this
image from
https://www.insulationsuperstore.co.uk/help-and-advice/product-guides/plumbing-heating/everything-you-need-to-know-about-ground-source-heat-pumps/
General Comment
• We note that there is no specific guidance on the siting
and design of renewable energy schemes and would suggest that some
guidance is added to support developers of these types of schemes
and promote renewable energy generation.
• This could include guidance on site selection, such as
appropriate types of land and connectivity; landscape and visual
considerations; biodiversity considerations; heritage
considerations; and flood risk; and also guidance on the detailed
design of a scheme, such as the layout of the scheme; broad
specification of the technology; ground works; security fencing and
lighting; maintenance; safety and wellbeing and public rights of
way.
• We also consider that additional guidance should be
provided to assist homeowners and housebuilders with the
installation of domestic-scale renewable technologies including
protecting the residential amenity of neighbouring properties and
existing domestic scale renewable energy technologies.
Standards and Certifications
• BREEAM – Don’t think there is a requirement for
non-residential buildings in Vale to meet BREEAM Excellent –
this requirement is only for non-residential buildings in
South.
• Principle 6.13 – the 40% requirement will increase in
2026 to 50% and in 2030 to 100%
|
Passivehouse
is an optional standard of development unless specified by local
plan development policy. Passivehouse is a methodology of achieving
sustainable
developmen.
More flexible approached to achieving sustainable development
including Passivehouse certification will be reviewed and
incorporated into the
guide.
The wording of guidance and technical specification in relation to
sustainable development will be reviewed.
|
79
|
Response
manually entered, submitted in an email format.
Paragraph 6.4 of the draft Design Guide notes that water harvesting
is required for ‘all major and minor development
types’. Thakeham agree with the intent of this requirement in
principle, however Thakeham consider further guidance is needed to
detail what this will mean in practice. For example, can this
requirement be met via a water butt at each property, or does it
require a more substantial communal tank? In providing clarity on
this it should also be made clear what type of solution is
applicable to what scale of development and where there is a
graduation, thinking specifically about the viability of smaller
schemes.
Figure 60 illustrates Policy DES10: Carbon Reduction from the
adopted South Oxfordshire Local Plan 2035, which requires a 40%
reduction in carbon emissions (compared with a code 2013 Building
Regulations compliant base case) to 2026, a 50% reduction to 2030
and a 100% reduction from 31st March 2030. Thakeham support this
approach and our own commitment to Net Zero by 2025 will mean that
Thakeham exceed these targets.
The draft Design Guide includes a section on
‘Passivhaus’ and paragraph 6.15 requires that "all
residential proposals aspire to meet Passivhaus certification".
Thakeham do not support this requirement. Whilst following the
principles of Passivhaus encourages a strong fabric-first design,
our experience is that Passivhaus homes present issues from an
occupier perspective that requires training, understanding, and
constant monitoring to avoid health issues from mismanagement of
the complex systems. Airtightness exceeding Building Regulations
can reduce energy consumption, however Passivhaus requirements of
over fifteen times tighter than Building Regulations has unintended
consequences for people in the home. Thakeham’s Zero Carbon
specification focusses instead on the Space Heating Demand through
fabric efficiency improvements; exceeding Passivhaus’ target
of 15KWh/m2/year down to our figure of 13.44 which Thakeham believe
is the most effective and beneficial for the long-term. Delivering
this alongside air tightness that is over twice as tight as
building regulations means the home is still intuitive and
convenient for all. Thakeham therefore suggest that some
flexibility is built into this section of the draft Design Guide,
to allow for other innovative solutions which meet or exceed the
levels set by ‘Passivhaus’. Thakeham would additionally
note that within the Passivhaus text the draft Design Guide states
"...we understand that this may not always be appropriate due to
some development types and/or reasons of viability". Such
commentary does not appear within the ‘design
principles’ section and therefore the guidance itself is
contradictory.
Regarding embodied carbon, the draft Design Guide discusses the
need for this to be minimised with regard to the material fabric of
a building. Thakeham support this approach and would add that as
part of our commitments to Net Zero by 2025, Thakeham has committed
to all homes being Carbon Neutral in Production – including
monitoring and reducing the embodied carbon of each home Thakeham
produce. Thakeham is a leader in this area and can therefore help
inform the resulting process that the councils wish to
see.
|
The
wording of guidance and technical specification in relation to
sustainable development will be reviewed.
|
80
|
Many
of the sections of this part of the guide, for example the sections
relating to climate emergency, the definition of net zero carbon,
carbon emissions, MMC are explanatory rather than
guidance.
The role of an SPD is to provide guidance in relation to existing
policies in adopted local plans, and it is not within the remit of
an SPD to introduce new policy requirements. The introduction of
new policy requirements should therefore deferred to a future Local
Plan review.
Design Principles:
Many of these design principles replicate the issues raised in the
NDG that are required to be considered by applicants. The wording
of the design principles should be amended to clarify that these
issues are for consideration, and not necessarily issues with which
all proposals can comply. Applicants may not be able to
‘ensure’ that high quality schemes meet all of the
principles as set out, and the wording of text in the SPD should be
amended. An appropriate alternative would be ‘applicants
should ensure consideration has been given to...’.
|
Both
Passivhouse and BREEAM are optional standards of development unless
specified by Local plan development policy. Currently only SODC
have an adopted requirement for BREEAM, and only in certain types
of
development.
More flexible approached to achieving sustainable development will
be reviewed and incorporated into the
guide.
The
wording of guidance and technical specification in relation to
sustainable development will be reviewed.
|
81
|
Response
manually entered, submitted in an email format.
Design Principles - Standards and Certifications
CEG questions whether Para. 6.13 requiring 40% reduction in carbon
emissions and Para. 6.14 requiring BREEAM excellent in
non-residential development needs restating beyond the Local Plan
requirements when potentially the Local Plan could be superseded
during the lifetime of the Design Guide.
This part of the document also states that applicants should ensure
that all residential proposals aspire to meet Passivhaus
certification. Clarity of the priority outcomes is required in
order to evaluate whether Passivhaus is a suitable certification to
achieve. Principles can be aspired to without a requirement to
achieve formal certification.
In relation to the ‘reducing emissions’ section, the
JDG should recognise the evolving nature of national changes
(specifically in relation to Building Regulations and the Future
Homes Standard) and set out how the JDG will remain up-to-date and
relevant amidst these national changes.
As a general comment, it should be noted that the SPD cannot go
beyond its role as a document that is supplementary to the adopted
development plans for Vale of White Horse and South Oxfordshire
District Councils. If there is no development plan policy (or Act
of law) requiring something, the Joint Design Guide can only
encourage, or require consideration of the relevant
matter.
|
|
82
|
Response
manually entered, submitted in an email format.
Infill development
The design of infill development is often a cause for concern,
particularly where 2 or 3 houses replace a single dwelling in a
large garden. Assessing the impact on neighbours is a key issue.
There are only two short sentences about neighbour
amenity.
The guidance on separation between buildings is useful but does not
take into account unusual orientations of houses on infill sites or
backland development, where front to back or front to side
distances are key.
The guidance on amenity space and particularly, access to rear
gardens and avoidance of long narrow alleyways is useful in
assessing small infill developments. However, a situation that
frequently arises is backland development that often leads to long
drives to provide access and parking for the rear property which
have a detrimental effect on the front property and neighbours.
Guidance in this area would be useful.
Climate Change
This provides a useful guide to the issues facing development today
and the steps that can be taken to address those issues.
|
|
|
Comment
|
Council’s
response
|
1
|
I
can’t remember the details of them and can only get back to
them by trashing this reply and starting again. This form should
have a facility to dive back in to them without losing the place on
the page - Shame as I’d have liked to respond
|
Apologies,
the online survey does however have the ability to save your
progress and re-enter or edit your comments.
|
2
|
The
guide is too elaborate and lengthy.
Nice concept.
Poorly implemented.
|
·
Noted and will review
|
3
|
Fundamentally
the design guide MUST differentiate between small householder/minor
development, and large scale mass housing projects. There is simply
too much information in a single place to sift through to find what
is being sought after. The design guide should be broken down into
3 documents. MAJOR DEVELOPMENT : HOUSEHOLDER DEVELOPMENT :
EVERYTHING ELSE.
This would be clear and concice and allow applicants to know
exactly what they need to provide.
|
·
Noted and will review
|
4
|
The
problem most of have is the public consultation never really
considered to be important. We feel powerless when dealing with
developers and all levels of local government. Our views and
concerns are ignored and developers' wants are the only
consideration. We feel that we are fighting YOU and the developer.
You are the enemy rather than our employees. We pay your salaries
and you work against our interests.
|
·
Noted
|
5
|
They
are things that are important to think about at the start of the
process
|
·
Acknowledged
|
6
|
The
question is worded so that you are a numpty if you do not agree.
The draft joint design guide is only good if all of the principles
are met and the quality of the build and finish are complied with.
My stronger question is who will oversee the work and how much
influence will they have if the quality is poor? There are already
pressures on developers given the manpower shortages and the
building supply shortages. There are incentives there for them to
cut corners. The guide is fine - the finished product is what
counts.
|
·
Noted
·
Urban design officers are principally responsible for judging the
design quality of a
development.
|
7
|
They
will be extremely useful if they are used and applied which means
they have to be more than merely aspirational.
|
·
Acknowledged
|
8
|
The
existing Vale design guide is very clear, and yet in Faringdon we
see multiple large developments being approved which skip the
guidance . A cursory look at multiple exits and entry suggestions,
space for growing food, movement framework, etc. shows there is
little point in making new guides, if the implementation of
existing guides is so poor. If the same people and processes are at
work in the approval process, there is no point in investing in new
guidelines.
|
·
Noted
·
The new guide will be delivered with training for officers to
ensure the guide is more closely
followed.
·
The more accessible online form of the guide will allow greater
clarity around expectations and its use as a tool to review
development proposals.
|
9
|
See
above
|
·
Noted
|
10
|
Employees
have been paid huge salaries to compile these reports in an ideal
world in rainbow land probably work in south Oxfordshire
zero
|
·
This comment raises issues that fall outside the scope of the
design guide.
|
11
|
In my
experience, most people are attracted by new opportunities, such as
the promise of a swimming pool for local people. Or they live in
poorly designed accommodation and don't understand how bad
development reduces their enjoyment of their local environment.
Money drives most decisions. This guide looks like a useful way to
help focus developers on doing the right thing. It will be more
influential on small and local developers than on the big blue-chip
investment and building companies.
|
·
Acknowledged
|
12
|
Well,
I like them but I am extremely sceptical that developers will pay
anything other than lip service to them....
|
·
Noted
|
13
|
See
comment above on climate & sustainability
|
·
Noted
|
14
|
Please
please please do not adopt this guide wihtout major
changes
|
·
Noted
|
15
|
concern
that the principles may be used by officers without an ability to
discern intuitive and skilful design innovation
|
·
Acknowledged
|
16
|
the
concern here is that the average person in Abingdon High street
will not be that interested until they submit a planning
application for their extension or find the house their were hoping
to buy is £25K more expensive due to the additionality this
guidance will cause them. It is the age old planning issue: how do
we educate the population and get them to buy into more expensive
solutions in order to protect the environment.
Perhaps there needs to be an ongoing commitment to take this
message in to schools and parish councils? Perhaps also to update
the document on a regular basis with good practise cases studies -
the use of Youtube may help to get the message across and sharing
of best practise drawing details?
|
·
This comment raises issues that fall outside the scope of the
design guide.
|
17
|
Worried
that all sounds good but already and very recently principals arent
being followed.
The amount of money collected from developers is not to be shouted
about on its own which is what Vale have just done!
Have to look at
a) Does local community want it
b)is it best good-looking practical cost efficient design
c)is it sympathetic in lanscape and to its
wildlife/environment
Seems too much of ‘yes you can build it...this is what you
will pay planning/community infrastructure’ Its no good
letting developments trash the environment and have a few quid
after to supposedly improve the area with!...its too
late.
Stop shouting about £14 million collected...show and tell us
what you are going to do with it and how you will seek to minimise
further Wantage expanion!
|
·
This comment raises issues that fall outside the scope of the
design guide.
|
18
|
Thank
you for the opportunity to comment. Good luck with the 2nd
draft
|
·
Acknowledged
|
19
|
I
like the simplicity with good examples and written in plain English
- nice to see less jargon
|
·
Acknowledged
|
20
|
You
follow all the design standards and your plan is just rejected
based on the officer's own bias
|
·
Noted
|
21
|
I
love the general structure, clarity and balance of diagrams to
words - overall it has a useful simplicity about it - which I think
will mean that the document will be well used by a wide range of
audiences - brilliant - well done!
|
·
Acknowledged
|
22
|
See
comments above - lawyers from the developers will run circles
around you.
|
·
Noted and will review
|
23
|
See
above for availability to all levels of incomes!!
|
·
Noted and will review
|
24
|
Would
like to see reference to Neighbourhood Plans
|
·
Acknowledged
|
25
|
please
see my comments in section 11
|
·
Noted and will review
|
26
|
This
helps householders and developers understand what is expected of
them, and consider factors they may not have thought
about.
|
·
Acknowledged
|
27
|
Past
experience tells me that future build will very likely be just as
cramped and miserable looking as new build during the past 5
years.
|
·
Noted
|
28
|
Very
useful if applied.
|
·
Acknowledged
|
29
|
Far
too wordy for none professionals to digest.
|
·
Noted and will review
|
30
|
It
will make sure that proposers of major developments 'tick all the
boxes' in their proposals. However, planning decisions are made on
the balance of benefits and harms, and applicants can still 'talk
the talk' in their proposals without 'walking the walk'.
|
·
Noted
|
31
|
What
concerns me is the weight they would actually have when planning
permission is sought. Even more to the point, to what extent they
might be applied in the face of national government
directives.
|
·
The guide is a material consideration as a supplementary to both
adopted local
plans.
· The guide is written to follow current adopted government
policies.
|
32
|
These
design principles are like having your own notecards for writing a
report- I think they they're brilliant and pretty much cover
anything you would need to consider. The fact that examples of and
solutions to common design issues are included within this Guide is
fab too, as a civilian who would otherwise be clueless.
|
·
Acknowledged
|
33
|
no
reference found to the role of neighbourhood plans
|
·
Acknowledged
|
34
|
Too
much to read, and take in, need to be simple and in laymans terms.
Not bamboozled with all this
|
·
Noted and will review
|
35
|
The
Design Guide principles are adequate but could be much
better.
|
·
Noted and will review
|
36
|
see
comments from earlier sections that apply to these
heading
|
·
Noted
|
37
|
However,
most of it does not apply to a rural setting. Regrettably it is
unsatisfactory in rural settings.
|
·
Noted and will review
|
38
|
One
of the better sections. Reasonable clear and simple
explanations.
|
·
Acknowledged
|
39
|
but
remember forget the humbug and the we want to win an award for this
design. A security B houses that last
|
·
Noted
|
40
|
It is
good to have everything in one place for someone considering a
planning application, although, as I've already said, it's not
quite hitting the right language for a lay person (and a
professional probably knows all this stuff as they do it
daily).
|
·
Noted and will review
|
41
|
The
principles are superb. Is it the case that we are unable to REQUIRE
compliance until building regulations come up to the level of these
design principles? How strongly can we urge developers to actually
DO these things?
|
We
require all development to meet to current building
regulation.
South Oxfordshire district Council have an adopted Local plan
policy (DES10) that requires development over a certain size to go
beyond building regulations under certain
criteria.
All other design guidance for development is an
‘encouragement’ to go beyond building
regulations.
|
42
|
I
have graded the design principles 'Somewhat useful' as the changes
in legislation and public awareness forced on us by future climate
change events will demand flexibility in the application of the
principles. The change mechanism for the Joint Design Guide
documentation must be agile so that it may react quickly to new
Government guidance and public pressure.
The fact that no Standards and Certifications for residential
buildings are mandated is a major omission in the Guide and
approvals process. The Planning team are requested to address this
complex area as a top priority task.
|
The
change mechanism for the guide is the regulatory mechanise of an
SPD, see:
https://www.legislation.gov.uk/uksi/2004/2204/part/5/made
The guide currently states the Standards and Certifications that
are required by legislation or regulation. Additional certification
for sustainable development if referenced within the climate and
sustainability section of the guide, including PASSIVHOUSE and
BREEAM.
|
43
|
I
think in the absence of sensibly challenging building regulations
then driving the increase in standards through the planning process
is all we can do and this guide is a good attempt
|
·
Acknowledged
|
44
|
I
think this design guide would be pretty useless in assessing a
""Hockerton"" style development which is probably what we need more
of in the district. It is also doubtful whether it would prevent
the development of poorly designed housing estates as they would
still have car dependency, look like mock Tudor developments with
limited local input and kitted out with the cheapest plumbing and
electrical appliances.
|
·
Noted. Hockerton housing development in Nottinghamshire is not a
mandatory model or form of development, and we cannot insist on
this in the guide. Additional Fixtures and fittings within a
dwelling cannot be dictated by the design guide.
|
45
|
Extremely
useful, subject to stronger principle wording in some instances.
Thank you for all of your hard work on this so far!
|
·
Acknowledged
|
46
|
This
is an excellent design guide, which is easy to follow and covers
all the relevant factors that need to be considered. It should be a
model for other design guides across the Chilterns.
For it to be successful in influencing design, it must be embedded
into the policies in the emerging Local Plan.
|
·
Acknowledged
|
47
|
Please
refer to Bloor Homes’ comments in response to Questions 9 to
13 above, which raise specific comments in relation to the design
principles set out in each section of the Design Guide
SPD.
|
·
Noted
|
48
|
The
navigation is poor and cumbersome. Check lists would be
useful.
It appears to be developed solely for medium sized to large
developments and not very helpful for individual houses - infilling
or extensions which are most common in our parish in the Green
Belt.
|
·
Noted and will review
|
49
|
Some
areas of the guide are clear , with additional clarity provided by
diagrams. Other areas introduce large amounts of explanatory text
and what seem to be new policy requirements that should properly be
part of a Local Plan review.
|
·
Noted and will review
|
50
|
Please
see submitted letter for full comments.
|
·
Noted
|
51
|
The
lack of reference to the public rights of way network and other
off-road access that is currently available to
vulnerable/non-motorised road users is a significant omission
within the guide. NPPF specifically requires that planning
decisions ""...should protect and enhance public rights of way and
access, including taking opportunities to provide better facilities
for users, for example by adding links to existing rights of way
networks including National Trails.""
|
·
Noted and will review
|
52
|
Not
as useful as they could be if they were extended to cobver some of
the most pressing development and design issues - such as multiple
applications for solar power stations on farmland rather than on
brown field sites athe solar PV lobby claim
|
·
Noted and will review
|
53
|
Some
areas of the guide are clear, with additional clarity provided by
diagrams. Other areas introduce large amounts of explanatory text
and what seem to be new policy requirements that should properly be
part of a Local Plan review.
The below comments are in response to question 15:
The key design objectives replicate the National Design Guide (NDG)
to some extent, but are not completely in accordance with the NDG.
The SPD should ensure that National Design Guidance is not
replicated, but that the SPD adds a layer of relevant local
detail.
|
·
Noted. The design guide does align with the National Design guide
and seeks to build upon it, inline with Local development
policies.
|
|
Comment
|
Council’s
response
|
1
|
As
above - it doesn’t seem to work on an ipad and there’s
no ability to refer to the text to respond intelligently to the
questions
|
·
Acknowledged. We have now fixed this.
|
2
|
The
guide is too elaborate and lengthy.
Nice concept.
Poorly implemented.
It is expected that one will be negated.
|
·
Noted and will review
|
3
|
As
previously, too much information in a single place. It is
imperative the information is broken down to actually relate to
specific development.
|
·
Noted and will review
|
4
|
The
design guide has its own priorities.
|
·
Noted
|
5
|
Like
most surveys from local government, my views will be ignored unless
they happen to be positive. I find it difficult to understand why
we even need three layers of bureaucracy when you just ignore local
views and follow government directives.
|
·
Noted
|
6
|
Only
on the developers delivery of what is promised (whoever the
developer(s) are).
|
·
Noted
|
7
|
See
note about search engine.
|
·
Noted and will review
|
8
|
The
existing Vale design guide is very clear, and yet in Faringdon we
see multiple large developments being approved which skip the
guidance . A cursory look at multiple exits and entry suggestions,
space for growing food, movement framework, etc. shows there is
little point in making new guides, if the implementation of
existing guides is so poor. If the same people and processes are at
work in the approval process, there is no point in investing in new
guidelines.
|
·
Noted
|
9
|
Already
commented written as a thesis not actually possible
|
·
NA
|
10
|
I
have read it one time. The only weakness I cannot test for is how
easy it is to find something that I read in the guide when I return
six months later to uncover it - the search function. Also, I am
not currently involved in any development, so I do not have a
particular need for information. Often well-intentioned websites
fall down because the user asks a question in a way that the
content designers did not consider.
|
·
Noted and will review
|
11
|
I do
hope that on the design team you will have some seniors, to give of
their very wide opinions of living in our beautiful area
In the last 10 years I have watched the A417 turn into a HGV and
building lorry highway and the pollution from all the diesel
traffic onway to biulding sites.
|
·
Noted
|
12
|
You
have done a great job. I like it. Thank you.
|
·
Acknowledged
|
13
|
No.
|
·
Noted
|
14
|
I
like it !
|
·
Acknowledged
|
15
|
I
wish to highlight the failure within it to recognise the existence
of Local Plans and Neighbourhood Plans as key determinants of local
popular views.
|
·
Noted and will review
|
16
|
This
looks to me as something that was produced by Consultants; and I am
not sure who they were working for?
|
The
Design guide was not produced by an external
consultant.
The guide was produced in house by
both Urban design team for South Oxfordshire and the Vale of White
Horse.
|
17
|
It's
a great tool for industry professionals, but I suggest a simpler
guide for lay people is produced and widely communicated to help
them provide informed comment on planning applications. If members
of the public demonstrate their support for quality design, it
would surely help officers and committees insist developers provide
the best designs
|
·
Acknowledged
|
18
|
Designed
more for trades people than general public
|
·
Acknowledged
|
19
|
it
doesn't really work
|
·
Noted and will review
|
20
|
its
not bad
|
·
Acknowledged
|
21
|
Too
wordy...needs bullet points.
Most presentations 12-13 pages for common person. Many wont comment
as too longwinded......unfortunately then means you arent engaging
the general public en masse only those who can be bothered to read
it/take time to comment.
|
·
Noted
|
22
|
I
think it looks fantastic - attractive and functional.
|
·
Acknowledged
|
23
|
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
|
·
Noted
|
24
|
Great
to see innovation of this type.
|
·
Acknowledged
|
25
|
I
think the interactive bit is perhaps a bit gimicky - but nice - its
the content and layout that 'do the job extremely well'
|
·
Acknowledged
|
26
|
Hmmm.
I guess I'm too old. I get my information from the printed page -
why do you think newspapers and books still sell so
well?
|
·
Noted
|
27
|
I
found initial access difficult. Age is not on my side!!
|
·
Noted
|
28
|
Would
like to see reference to Neighbourhood Plans
|
·
Noted and will review
|
29
|
none
|
·
NA
|
30
|
I
much prefer this to a dense, wordy document. It is far easier to
use. It's intuitive, the colours help define the subject areas, and
it's easy to follow through the guide.
|
·
Acknowledged
|
31
|
It
feels like a really positive step to ensure all developments are
positive and enhance local communities and existing
features.
|
·
Acknowledged
|
32
|
Sorry
to seem so negative but no recent build in my area inspires me with
feelings of joy or hope for the future. I can only imagine that
most newcomers had such dreadful previous surroundings that they
consider the new stock acceptable, or even desirable.
|
·
Noted
|
33
|
As
noted above, the buttons on the side are not clear. It would be
better to have a 'next step' at the bottom of the page as well,
plus an index at the top.
|
·
Noted and will review
|
34
|
Bright
and inviting for users to alight upon - fresh and clean - well laid
out and documented -
|
·
Acknowledged
|
35
|
The
website format is good but needs to be more signalled. The
individual pages are large and it would be helpful to have an
initial indication of content so that you can see what will be
covered and in what order - otherwise you won't know whether it is
going to help. Otherwise a very good move.
|
·
Noted and will review
|
36
|
Font
size of diagrams??
Are there audio/tactile options for Visually Impaired members of
the community? Not just large print. Or other options for people
with disabilities to be able to be involved and have the
opportunity to respond?
|
·
The website is being developed to Web Content Accessibility
Guidelines
(WCAG).
This is a requirment for public sector bodies regarding
accessibility.
This includes those with:
- impaired vision
- motor difficulties
- cognitive impairments or learning disabilities
- deafness or impaired hearing
|
37
|
Relatable
diagrams and photographs seem to be mainly restricted to Abingdon
and Didcot
|
·
Noted and will review
|
38
|
Just
one minor suggestion, the buttons to access each section could be
palced a bit more obviously.
|
·
Acknowledged
|
39
|
It
merits a ""Good Try"" I wonder if it would be better presented as
an essential outline for the potential householder, with more
detailed technical sections for the architects and
builders.
|
·
Noted and will review
|
40
|
The
pictures and diagrams are excellent in aiding
understanding
|
·
Acknowledged
|
41
|
quite
like it.
|
·
Acknowledged
|
42
|
easy
to follow and understand, well done.
|
·
Acknowledged
|
43
|
It is
innovative, meticulous and very well executed.
|
·
Acknowledged
|
44
|
Some
of the initial discussion found for each section could be written
in bullet points and/ or have key words highlighted in bold or
italics. Otherwise, good.
|
·
Noted and will review
|
45
|
It is
a scrupulously put together document that I think will be hugely
beneficial to those in the District planning to develop in the
future; it's fully accessible, it holds a person's attention unlike
most other DGs (literally because of all of the pictures and nice
colours- you're onto a winner there!), it still holds all of the
information that it needs to but has brought it down to a level
that people can actually understand - I'd be very happy to use this
Guide as an average member of the public.
|
·
Acknowledged
|
46
|
what
about potential users who for whatever reason cannot access or use
an interactive website
|
·
A low resolution version will be available to download and we will
break up the file into different parts if necessary.
|
47
|
The
""dots"" down the side of the web site which are the navigation
were not clear to me
|
·
Noted and will review
|
48
|
It
needs to be searchable. I made a lot of notes about paragraphs
which weren't numbered and then struggled to find the relevant
place. This is particularly a problem with the drop down
information on the interactive plans.
|
·
Noted and will review
|
49
|
The
guides aims are admirable - ""short and concise with a simple set
of rules"", ""provide a simple set of design criteria"", ""is
relevant for all scales of development"". However I don't think it
achieves them. Section of it are verbose, with overly complex
descriptions/explanations. Why use a simple word when you can
prefix it with another (e.g. well-overlooked). Why stop at one
explanation when two can do the job. I'm probably being more than a
little unfair but short, simple and concise this guide is
not.
|
·
Noted and will review
|
50
|
full
page diagrams make diagrams big and even better artists
illustrations
|
·
Acknowledged
|
51
|
The
key difficulty is finding universal agreement of what is a
""beautiful"" design. This will be extremely difficult and probably
impossible to define as it is so subjective. It may be better to
drop this objective or find an alternative that can be more easily
defined.
|
·
Noted and will review
|
52
|
I
really like the way this document is presented especially its
interactive website and photos.
|
·
Acknowledged
|
53
|
It
would be useful to also have a PDF version of the document when the
final version of it is produced.
|
·
A low resolution version will be available to download and we will
break up the file into different parts if necessary.
|
54
|
It's
fine. The left hand navigation of dots is a little odd because, at
least on my Mac/Safari the labels for those dots pop up over the
top of the website text. But it's fine.
|
·
Noted and will review
|
55
|
Whilst
it is encouraging that the guide is interactive and digitally
accessible, it is difficult to navigate and the menu is hard to
find. The guide would benefit from a contents page at the beginning
of the document with sign posting and links used throughout the
document.
|
·
Noted and will review
|
56
|
I
have struggled somewhat but on the whole it comes across as
reasonably clear to a non-professional
|
·
Acknowledged
|
57
|
Top
marks for the team that has built this. I hope it will have the
impact on future development in South and Vale that we all want and
need.
|
·
Acknowledged
|
58
|
Thank
you for producing a very helpful draft of the Joint Design Guide
supported by an excellent web site and an easy way to comment. The
amount of work that has gone into this masterpiece is greatly
appreciated. The inclusion of the section on Climate and
Sustainability is excellent. Perhaps this topic is becoming so
important that it should appear as the first subsection rather than
the last section of the Guide.
|
·
Acknowledged
|
59
|
I
agree with this statement; the website with illustrations, plans
and photos is much more accessible and easy to understand than a
normal document would be.
|
·
Acknowledged
|
60
|
It is
an improvement on many official publications
|
·
Acknowledged
|
61
|
The
presentation with illustrations and photos is useful but including
photos of Didcot with mowed lawns and cement pavers is not really
showing exemplar developments that are future-proof and low carbon
as required.
|
·
Acknowledged
·
We are seeking to update the images to ensure they are
relevant.
|
62
|
Officers
wanted to say thank you for the sheer amount of work that has been
put into the JDG. However, Officers did not feel that the website,
as currently formatted, was user friendly. A lot of scrolling is
required to reach the information needed. Please see comments
overleaf.
|
·
Acknowledged
·
Noted and will review
|
63
|
It is
excellent!
|
·
Acknowledged
|
64
|
No
comments.
|
·
Noted
|
65
|
Where
there are bullet points within sections they should be lettered for
accuracy.
|
·
Noted and will review
|
66
|
Overall
we very much approve of the approach and content. It is a shame it
was not in place 10 years ago
|
·
Acknowledged
|
67
|
We
are supportive of the webpage links that have been provided within
the Joint Design Guide to direct the user of the document to
relevant Local Plan policies and guidance. In general, we consider
the interactivity of the document and the fact that it consolidates
various policies and guidance into one document is helpful and
reduces the time required to review specific policy
requirements.
|
·
Acknowledged
|
68
|
Usability
– poor. One needs to be able to search the whole document in
one go, rather than searching for a word in each individual
section.
|
·
Noted and will review
|
69
|
Yes,
the navigation is poor and cumbersome. It needs a large PC screen.
Check lists and forms with tick boxes would be useful as with
Oxford City's Character Assessment forms, which are helpful and
have scores
|
·
Noted and will review
|
70
|
The
format of the guidance and the diagrams work well. Clarity is
needed on what is ‘policy requirement’ and what is
‘SPD guidance’.
|
·
Acknowledged
|
71
|
Please
see submitted letter for full comments.
|
·
Acknowledged
|
72
|
See
earlier comment about the lack of headings for the bulleted links
on the first page of the Guide.
Overall, the guide is relatively simple to follow once one
understands how the different sections are structured and how to
access and navigate them, however it is very easy to overlook a
section. The Guide should also be made available as a downloadable
pdf to enable those needing to refer to it regularly to review it
as a complete document rather than in discrete sections.
|
·
Noted and will review
|
73
|
It
looks very accessible. Congratulations
|
·
Acknowledged
|
74
|
I
think this is an excellent design guide. Thank you very
much.
|
·
Acknowledged
|
75
|
too
many line drawings (aka artists impressions) rather than the
locally evidence based photos that are often to be found in
neighbourhood plans
|
·
Noted and will review
|
76
|
Too
many errors in the English.
Some diagrams are not clear.
The Landscape Charters map is unclear, inaccurate and tries to put
too much detail in one page - the colours are not distiguishable in
many places.
|
·
Noted and will review
|
77
|
The
below comment is in response to question 16:
The key design objectives replicate the National Design Guide (NDG)
to some extent, but are not completely in accordance with the NDG.
The SPD should ensure that National Design Guidance is not
replicated, but that the SPD adds a layer of relevant local
detail.
The format of the guidance and the diagrams work well. Clarity is
needed on what is ‘policy requirement’ and what is
‘SPD guidance’.
|
·
Acknowledged
|
|
Comment
|
Council’s
response
|
1
|
Fix
that problem and my response will be more revealing
|
·
Acknowledged
|
2
|
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.
|
·
The principles outlined in the design guide are applicable to all
scales of development.
|
3
|
no
other comments
|
·
Noted
|
4
|
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.
|
·
The height of a developemnt should be reviwed on a case by case
basis. The guide should not specify height limits to development.
The guide does generaly state that development should be visually
subservient to the adjacent development.
|
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.
|
·
Noted
|
6
|
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??!
|
·
Acknowledged
|
7
|
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.
|
·
Acknowledged
|
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.
|
This
would be established through the preapplication or planning
application process, chiefly the submission and management
agreements and maintenance strategies. The bankruptcy of a
developer is beyond the scope of the SPD.
|
9
|
I
hope this carries weight and is implemented as soon as
possible.
|
·
Acknowledged
|
10
|
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.
|
·
Noted
|
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.
|
·
Noted and will review
|
12
|
I
think I have made my views clear
|
·
Noted
|
13
|
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
mary69thomas@gmail.com
|
·
This comment raises issues that fall outside the scope of the
design
guide.
· Acknowledged
|
14
|
More
developments need to be monitored as the work progresses or things
will be added that cannot be undone once a build has
finished.
|
·
This would be established through the preapplication or planning
application process.
|
15
|
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?
|
·
Noted
|
16
|
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.
|
·
Noted and will review
|
17
|
My
comments have been recorded above. It is incomplete as it
stands.
|
·
Noted
|
18
|
Please
see comment for Questions 3 & 11.
|
·
Noted
|
19
|
My
main point is to lobby government to get the building regulations
amended to force developers to do the right thing!
|
·
This comment raises issues that fall outside the scope of the
design guide.
|
20
|
concern
that the principles may be used by officers without an ability to
discern intuitive and skilful design innovation
|
·
Acknowledged
|
21
|
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.
|
·
Acknowledged
|
22
|
The
needs of disabled people, ie dropped kerbs clearly marked, easy
access to all areas, and good infrastructure, cannot emphasise both
issues enough.
|
·
Noted and will review
|
23
|
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.
|
·
Noted.
·
The guide does make reference to both passive and active approches
to sustainable design under the Climate and sustaianbility
section.
|
24
|
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.
|
·
Noted and will review
|
25
|
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.
|
·
Noted and will review
|
26
|
Only
that it is implemented quickly and that the major developers buy
into it.
|
·
Acknowledged
|
27
|
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
|
·
Noted and will
review
· This comment also raises issues that fall outside the scope
of the design guide.
|
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 secretary
@ogt.co.uk
Much of this information has been deposited with the
HER.
|
·
Acknowledged
|
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.
|
·
Noted
|
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.
|
Inclusive
design is a key principle within the design guide and we have tried
to cover areas not already govered by
regulations.
Aspects
of access are covered by building
regulations.
Through traffic and speed restrictions are applied by
OCC.
|
31
|
Would
like to see reference to Neighbourhood Plans
|
·
Acknowledged
|
32
|
All
good, but with reservations expressed about EV charging in section
11
|
·
Noted and will review
|
33
|
to
many house being build we need carparks and primark in didcot to
many cafes in didcot
|
·
Noted
|
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.
|
·
NA
|
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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·
Noted and will review
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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.
|
·
Noted
|
37
|
These
included in the various sections of the survey thank
you.
|
·
NA
|
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?).
|
·
Acknowledged
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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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·
Noted and will review
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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.
|
·
NA
|
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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·
Noted
|
42
|
Neighbourhood
plans are not mentioned.
Discussion with local town/parish councils needed pre application-
to fully understand the local context, and local
initiatives.
|
·
Acknowledged
|
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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·
NA
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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.
|
Noted.
The guide currently has a glossary, spelling and grammar will be
reviewed as part of the editorial process
|
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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·
Noted and will review
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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
|
·
Acknowledged
|
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)
|
·
Acknowledged
|
48
|
See
my previous answer.
|
·
Noted
|
49
|
see
comments made in earlier sections re Neighbourhood plans - their
policies will heavily influence the design at location
level
|
·
Acknowledged
|
50
|
It is
an impressive piece of work but sadly biased in favour of urban
situations.
|
·
Acknowledged
|
51
|
crime
is a major problem the elite are in denial make all estates ect
mugger no go zones
|
·
Noted
|
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.
|
·
Noted
|
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.
|
·
Noted
|
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.
|
·
Noted
|
55
|
Response
submitted in an email format and is attached below.
Admin note: please view attachment below for detailed
comments.
|
·
Noted
|
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.
|
·
Noted
|
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.
|
·
Noted
|
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.
|
·
Noted
|
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
|
·
Acknowledged
|
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.
|
·
Acknowledged
|
61
|
N/A
|
·
Noted
|
62
|
The
original email submission is attached below.
|
·
Noted
|
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.
|
·
Noted and will review the furthur use of case
studies.
·
The Design guide has links to both the National design guide and
code.
· The structure of the Joint design guide looks to closley
align to the National design guide
|
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.
|
·
Noted and will review
|
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).
|
·
Noted and will review
|
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.
|
·
Noted and will review
|
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.
|
·
Acknowledged
|
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.
|
·
Acknowledged
|
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.
|
·
Acknowledged
|
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
|
·
Acknowledged
|
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.
|
·
Noted and will review
|
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.
|
·
Noted
|
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?
|
·
Noted and will review
|
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.
|
·
Acknowledged
|
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.
|
·
Acknowledged
|
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.
|
·
Acknowledged
|
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.
|
·
Acknowledged
|
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.
|
·
Acknowledged
|
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!
|
·
Noted
|
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
|
·
Noted
|
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?
|
An
integrated approach to sustainability in line with development plan
policies is present throughout the guide. There are currently no
tick box criteria or exercises within the guide.
Eco Towns: PPS 1 Statement, provided the standards any eco-town had
to adhere to before it was cancelled for all areas excluding
northwest Bicester on 5 March 2015. This statement is not relevant
as there are no Eco-towns within South or Vale covered by this
PPS.
All applicants, not just developers, are encouraged by the guide to
integrate sustainable approaches to new development through their
design. An integrated approach to sustainability in line with
development plan policies is present throughout the guide. There
are currently no tick box criteria or exercises within the
guide.
There is no requirement of any applicant to follow an individual
model or approach towards development including the Hockerton style
of development.
Green infrastructure – water – planters –
orchards – grow areas
The SPD is only applicable to the two district councils, it is not
a regional document. Improved Biodiversity is established under
design principle:
2.13 retains and enhances existing important habitats, creates new
habitats and aims to deliver at least 10% Biodiversity Net Gain
(Environment Bill 2020);
The SPD is only applicable to the two district councils, it is not
a regional document. Innovative technology would be deployed by the
use of technologies indicated for sustainable development under the
Climate and sustainability section of the guide.
There is no requirement of any applicant to go beyond the energy
performance levels as set out win Building regulations. Development
policy DES10 of the South Oxfordshire Local Plan specifies
increased level of energy performance, for South Oxfordshire only,
this is covered under the climate and sustainability section of the
guide.
There is no Development policy context to require developments to
deliver these specific issues in combination, therefor the guide
cannot elaborate on these other than where there is supporting
development policy.
The SPD cannot promote additional self-build beyond the current
specified quantum by each Local authority.
The guide has incorporated guidance from LETI and builds upon
concepts where applicable.
|
82
|
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?
|
Select:
|
83
|
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.
|
·
Acknowledged
|
84
|
No
other comments.
|
·
Acknowledged
|
85
|
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.
|
Select:
|
86
|
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.
|
·
Acknowledged
|
87
|
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.
|
·
Noted.
|
88
|
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.
|
·
Noted and will review
|
89
|
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.
|
·
Acknowledged
|
90
|
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).
|
Noted.
Play space section has been expanded..
|
91
|
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.
|
Noted.
Will review points individually.
|
92
|
The
original email submission is attached below.
|
Noted.
Will review points individually.
|
93
|
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.
|
Noted.
Will review points individually.:
|
94
|
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?
|
Paragraph
numbers will be added.
|
95
|
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
|
Noted.
|
96
|
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.
|
Noted.
Will review points individually.
|
97
|
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.
|
Noted.
Will review points individually.
|
98
|
Response
manually entered, submitted in an email format.
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!
|
Noted.
|
99
|
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.
|
Noted.
|
100
|
Response
manually entered, submitted in an email format. The original
submission is attached below for reference.
|
Noted.
Will review points individually.
|
101
|
Please
see submitted letter for full comments.
|
Noted.
Will review points individually.
|
102
|
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.
|
Select:
|
103
|
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.
|
More
references on PROW have been added
|
104
|
This
is great.
|
Acknowledged.
|
105
|
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.
|
Noted.
Beyond the remit of the design guide.
|
106
|
How
this fits in to the planning process is not at all clear - see
notes at start of survey.
|
Noted
|
107
|
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.
|
Noted.
Will review points individually.
|
108
|
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.
|
Noted.
Will review points individually.
|
109
|
Response
manually entered, submitted in an email format.
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
|
Noted.
|
110
|
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....
|
Acknowledged.
Links have been checked.
|
111
|
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
|
Noted.
Will review points individually.
|
112
|
The
original submission is attached below.
|
Noted
|
113
|
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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Noted.
Will review points individually.
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114
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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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Noted.
Will review points individually.
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115
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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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Noted.
Will review points individually.
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116
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The
original submission is attached below.
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Noted.
Will review points individually.
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117
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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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Noted.
Will review points individually.
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118
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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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Link
to Dark skies documents added. Search facility to be
explored.
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119
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The
original submissions is attached below for reference.
|
Noted.
Will review points individually.
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120
|
The
original submission is attached below for reference.
|
Noted.
Will review points individually.
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121
|
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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Noted.
Will review points individually.
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122
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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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