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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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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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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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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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5
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Clear
to understand
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6
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No
major issues with this
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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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8
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Not
clear that responses to this survey will be acted upon.
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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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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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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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12
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I
found the whole package very easy to access and
understand.
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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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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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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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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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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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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 english in older design
guides. this one refers to 'blue infrastructure' quite early on
which is so plainly unexplained jargon it is embarassing. 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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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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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 consder
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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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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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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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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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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25
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I
need to see the following pages before I am able to answer
this.
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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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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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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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29
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Too
long winded - interest runs out before reaching end of
document.
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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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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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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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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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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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35
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too
much information
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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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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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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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39
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The
Guide is clear and concise
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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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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 incorporateS 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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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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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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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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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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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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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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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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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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50
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Landscape
Character map could be interactive - very difficult to match up
with key.
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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.
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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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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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54
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The
whole section is easy to follow and well set out.
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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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56
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The
hierachy 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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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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58
|
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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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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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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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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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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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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Please
see submitted letter for full comments.
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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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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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Sustainable
Development should go much further than the original definition.
Any development should be zero carbon and should enhance
nature.
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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 perpared 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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Response
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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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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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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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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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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.
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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.
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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.
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The
guide provides a series of design principles that will be
considered when deciding on all future planning applications
– whether it’s a resident looking to build an extension
or a developer building a large housing site.
