Testun llawn:
The Guide is very well presented and a great deal of the design and detailed technical content is excllent and to be welcomed. However there are some important underlying principles which are open to question and should be reviewed, especially in the light of recent national/local policy changes and available research.
SECTION 3 - POLICY FRAMEWORK
Page 11 Garden Suburb Policy
The new NPPF now out for consultation does not emphasise the Garden Suburb approach as implied in this draft. Its new focus is on best use of land through good design and higher densities.
This section therefore may need considerable review and redrafting - or at least modification - to incorporate the following suggested changes to:
a. raise the minimum density objective to 45- 50 dwellings per ha
b. link this objective explicitly to sustainable transport objectives - in particular of accessible, frequent and affordable public (bus) services. Studies have shown that 50 + dwellings per ha is required.
c. clearly state that the local Plan requirement for around 50% of demand for all dwellings, private and social, is for one and two bedroom properties
d. encourage terraced and mid-rise apartment solutions - the latter seem to be discouraged in the draft - to achieve these density and smaller unit objectives. Give examples of attractive historic and recent buildings both terraced (eg Clapham Terrace) and 3/6 storey Regency/Victorian streets and modern developments (eg........??) which meet these criteria.
SECTION 4 -DESIGN STEPS
Page 19
BE1 p) The minimum energy efficiency rating required could be stated in this section.
BE2 c) Minimum density objective should be revised to 45-50 dwellings per ha
e & h) Transport modes should be clearly placed in descending priority order -
walking, cycling, buses...with cars last of all.
SECTION 5 -DESIGN CONSIDERATIONS
Page 24 - Densities
As stated in comments on Section 3, densities should be set at a minimum of 45-50 per ha in the 'garden suburb' areas and at higher densities near to Town Centres and public transport interchanges. Rationale is given in Section 3 and footnotes 1,2 and 3
Modify the discussion of exceptions to the density policy to underline the requirement to meet small unit and affordable housing policies, as well as better land use; and state that only rare exceptions will be made.
Page 25 - Amenity Space
Clarify if the minimum amenity spaces specified include or exclude off-street parking spaces (should surely exclude ?)
Encourage use of balconies/convertable to conservatories for flats, to provide private amenity space.
SECTION 6 - DESIGN PRACTICALITIES
Page 30 - Quality environments.
This is a golden opportunity for this SPD to introduce minimum space standards as laid out by both DCLG in 2015 and by RIBA's similar case for space in 2011.
Independent local research shows clearly that up to 75% of houses are being built below these minimum standards .
Experience suggests that local professionals would welcome minimum standards being set. Purchasers would be protected and developers encouraged to on design and quality. Have archhitects and other professional been consulted ?
By introducing minimum space standards alongside higher minimum densities, this SPD could achieve a win-win for residents and developers with no uplift in property prices.
Page 30 - Energy conservation
Is there an opportunity to revise upwards the minimum energy efficiency requirements set out in the Local Plan - given its long gestation, recent national policy guidance and the local Administration's declared intention to stimulate eco-friendly housing ?
A requirement to incorporate solar panels/tiles into all new developments 'where appropriate' might be a sensible specific adjustment to add.
Page 31 Policy H4
Is it appropriate that a 'viability exception' to this policy should be explicitly made, given that the approved Plan has assessed viability as part of the overall process and the Inspector has agreed ?
If it is appropriate, then it may be considered good practice to set a minimum % for affordable housing as other authorities do. Perhaps at 30%.
It should also be pointed out here or elsewhere in the document that viability assessments and their evaluation will generally be made public (as confirmed by the recent decision over Riverside House/Covent Garden developments).
Affordable housing should be clearly defined here as per our Local Plan; 40% split 24% at social rents, 10% at 'affordable' rents and 4% as shared ownership. This needs to be explicit, to avoid confusion with the NPPF looser definition currently out for consultation.
SECTION 10 THE WAY FORWARD
Pre-application advice
Page 62 it should be stated that all pre-application advice given will normally be publicly available when each application is validated and uploaded on to the planning portal for public consultation.