APPENDIX A2 – Full list of unedited comments with councils’ response included

Part 5: Introduction sections

Question 3: The Introduction sections of the website aim to provide you with information on how to use the draft Joint Design Guide and about the districts, to give yourself the best chance of securing planning permission with a high-quality development. How clear (easy to understand) do you think these sections are?

	Comments	Council’s response
1	Too many words. Too many pages. Too many concepts. Too much everything.	· Noted.
2	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.	Noted, we will explain and clarify when this flow chart needs to be followed.
3	This has no purpose. As a resident I should not have to be asked about the design of promo material.	This  is not promotional material but a Supplementary Planning Document
4	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.	Noted, we will explain and clarify when this flow chart needs to be followed.
5	Clear to understand	· Acknowledged
6	No major issues with this	· Acknowledged
7	Please add a search engine so that the document can be searched for key words.	· Noted and in review
8	Not clear that responses to this survey will be acted upon.	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.
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 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.	· Noted.
11	I haven’t got to section yet so how can I ascertain if easy to use . Stupid question	· Noted.
12	I found the whole package very easy to access and understand.	· Acknowledged
13	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 ?	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.
14	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.	· Acknowledged
15	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”” .	We have tried to avoid technical language wherever possible. A glossary of terms can be found on the website which define such concepts.
16	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	· Noted.
17	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?	The design principles outlined in the design guide are applicable to all scales of development. Will review.
18	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?	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.
19	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.	Some of the issues need to be considered at the outset of the design process and with the relevant authorities (County Council).
20	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.	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.
21	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.	· Noted.
22	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.	· Acknowledged
23	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””	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.
24	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.	· Noted.
25	I need to see the following pages before I am able to answer this.	· Noted.
26	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.	· Noted and in review
27	I found the sections clearly labelled, and the main text was clear and easy to understand. The use of graphics helped enormously.	· Acknowledged
28	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.	· Acknowledged
29	Too long winded – interest runs out before reaching end of document.	· Noted and in review
30	While coverage is intended to apply to large scale developers and individual householders, the impression comes across as focussing on major developments	· Noted and in review
31	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.	· Noted and in review
32	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	· Noted and in review
33	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.	· Noted and in review
34	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.	· Acknowledged
35	too much information	· Noted.
36	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.	· Acknowledged
37	Not really applicable for a small rural Parish Council. It is useful as guideline for Planning.	· Noted.
38	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.	· Noted and in review
39	The Guide is clear and concise	· Acknowledged
40	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).	· Noted and will review
41	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: 3^rd bullet incorporates and/or linkS; 9^th bullet ombatment mixed uses; 10^th 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.	· Acknowledged
42	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.	· Noted and will review
43	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.	· Noted and will review
44	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.	· Noted and will review
45	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.	· Noted and will review
46	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.	· Noted and will review
47	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.	· Noted.
48	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.	· Noted and will review
49	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.	· Noted and will review
50	Landscape Character map could be interactive – very difficult to match up with key.	· Noted and will review
51	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.
52	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.	· Noted and will review
53	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	· Noted and will review
54	The whole section is easy to follow and well set out.	· Acknowledged
55	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.	· Noted.
56	The ombatme of the Plan structure of NPPF tp LP etc isn’t clear and there is no mention of adopted Neighbourhood plans.	· Noted and will review
57	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.	· Noted and will review
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	· Noted and will review
59	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.	· Noted and will review
60	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.	· Noted and will review
61	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.	· Noted and will review points individually
62	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?	· Noted and will review
63	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.	· Noted and will review
64	Please see submitted letter for full comments.	· Noted
65	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.	· Acknowledged
66	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	· Noted and will review
67	Sustainable Development should go much further than the original definition. Any development should be zero carbon and should enhance nature.	· Noted and will review
68	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.	· Noted and will review
69	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’	· Acknowledged
70	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.	· Noted and will review
71	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.””	· Noted and will review
72	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.	· Noted and will review points individually
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

Part 6: Key Design Objectives

Question 4: Considering all of the key design objectives at the outset of a proposal will help you to deliver high quality sustainable development. How clear (easy to understand) do you think the key design objectives are?

	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.

Part 7: Maps, graphics and pictures

Question 7: We have used pictures, graphics and interactive maps throughout the draft Joint Design Guide. How helpful do you think they are?

		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.

Part 8: Design Principles

Question 8: Place and setting Click here to see the ‘Place and setting’ design principles section in the guide. If you’d like to comment on them, please use the space below:

	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.
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
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.
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.	Select:
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
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
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
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
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.
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!	· Noted and will review
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
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.
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
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
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
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.

Part 8: Design principles

Question 9: Design principles – Natural environment Click here to see the ‘Natural environment’ design principles section in the guide. If you’d like to comment on them, please use the space below:

	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
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.	· Noted.
21	Good to see emphasis on trees and biodiversity.	· Acknowledged
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	· Noted and will review
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 4^th 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.	· Noted and will review
25	Very important to consider the impact of the natural environment.	· Noted.
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	· Noted and will review
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.	· Noted and will review
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.	· Acknowledged
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.	· Noted and will review
33	Again, of little relevance to minor householder developments.	Noted. Applies to all scales of development.
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	· Noted and will review
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	· Noted and will review
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
40	All good here, sets out clearly what needs to be considered for a scheme.	· Noted and will review
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
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)	· Noted and will review
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 18^th 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
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.	Select:
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.	Select:
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:
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:
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).	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.

Part 8: Design principles

Question 10: Design principles – Movement and connectivity Click here to see the ‘Movement and connectivity’ design principles section in the guide. If you’d like to comment on them, please use the space below:

	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?	· Noted.
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.	· Noted and will review
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.	· Noted and will review
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.	· Noted.
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?	· Noted.
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.	· Noted and will review
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.	· Noted and will review points individually
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.	· 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	· Noted and will review points individually
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.	· Noted and will review points individually
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.	· Noted and will review points individually
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.	· Noted and will review points individually
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	· Noted and will review points individually
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).	· Noted and will review points individually
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?	· Noted and will review
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.	· Noted and will review points individually
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.	· Noted and will review points individually
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.	· Noted and will review points individually
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).	· Noted and will review points individually
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.

Part 8 Design principles

Question 11: Design principles - Space and layout Click here to see the 'Space and layout' design principles section in the guide. If you'd like to comment on them, please use the space below:

	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	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.	· Noted and will review
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
4	Meaningless	· Noted.
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
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	· Acknowledged
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.
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	with much new land it is time to connect all the transport sources and make it cheaper to travel by train or bus.	· Noted.
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.	· Noted.
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.
12	Include employment zones, retail and leisure to cut down the need for travel	· Noted.
13	Amneity parameters is the best bit of the whole doucment so far	· Noted.
14	concern that the principles may be used by officers without an ability to discern intuitive and skilful design innovation	· Noted.
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 .	· Noted and will review
16	Houses need decent size gardens	· Noted.
17	We must do better than the higgledy piggledy, bits and pieces developments currently in vogue.	· Noted.
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.	· Noted.
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 ?	· Noted.
20	Biased towards developers, create a summarised version for householders	· Noted and will review
21	page not working	· Noted.
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.
23	Would like to see reference to Neighbourhood Plans	· Noted.
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.	· Noted and will review
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.
26	I found the figures in this section to be confusing.	· Noted and will review
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.
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
29	Consider developing communities within communities.	· Noted.
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.
34	High density housing is inappropriate in rural areas/edges of small towns and villages	· Noted and will review
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.	· Noted and will review points individually
59	No mention of neighbourhood plans. Building to edge of boundary and neighbouring buildings not included. Street boundary not emphasised.	· Noted and will review
60	EV charging points should be available for all vehicles (cars, cycles etc) and not just consideration given to this. Otherwise a good section.	· Noted and will review
61	Please refer to submitted representations.	· Noted
62	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.	· Noted
63	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	· Noted and will review points individually
64	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.	· Noted and will review
65	Should also include any design guides in the Neighbourhood Plan - Neighbourhood Plans are missing from this guide.	· Noted and will review
66	Response manually entered, submitted in an email format. No comments.	· Noted
67	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.	· Noted and will review points individually
68	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.	· Noted and will review points individually
69	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.	· Noted
70	Please see submitted letter for full comments.	· Noted and will review points individually
71	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.	· Noted
72	Lighting important again - not just external but also light coming out of buildings or attached to buildings.	· Noted and will review points individually
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	· Noted and will review points individually
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.	· Noted and will review points individually
75	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

Part 8: Design principles

Question 12: Design principles - Built form Click here to see 'Built form' design principles section in the guide. If you'd like to comment on them, please use the space below:

	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 inv