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RUSHCLIFFE RESIDENTIAL DESIGN GUIDE

SUPPLEMENTARY PLANNING DOCUMENT

STATEMENT OF CONSULTATION RESPONSES

MARCH 2009

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1. INTRODUCTION 1.1 This statement has been prepared in order to meet the requirements of

the Planning and Compulsory Purchase Act 2004 and the Town and Country Planning (Local Development) (England) Regulations 2004. Regulation 17 requires that before a local authority adopts a supplementary planning document (SPD) all representations that have been made on the draft SPD should be considered.

1.2 The following statement sets out a summary of the representations

received during the draft SPD consultation and how the Borough Council has responded to each representation. Where amendments to the SPD have been made these are noted alongside the relevant representation.

2. CONSULTATION

Pre production consultation 2.1 As part of the initial consultation phase a questionnaire ‘scoping’

survey was prepared and sent out to all contacts in the LDF consultation database. The questionnaire was also advertised in the spring edition of the Borough Council’s quarterly newsletter ‘Rushcliffe Reports’ which is distributed to all Borough residents.

2.2 A 6-week consultation took place between 21st April 2008 and 2nd June

2008. A total of 56 comments were received. Figure 1.1 sets out the main issues by topic area that were raised as part of the consultation process and explains how these were addressed in the draft SPD.

Figure 1.1

Issue SPD Response Local context

Design guide should advocate the use of traditional building styles and materials that respect Rushcliffe’s heritage. e.g. brick and clay pantiles

Local character and heritage is a key theme of the SPD. Section B details specific building styles and traditions that reflect the character of Rushcliffe.

Design guide should advise on importance of context and how development relates to surroundings – not just what they are like in isolation.

Context is emphasised throughout the SPD. The urban design principles that are explored through the guide continually reinforce the message that new developments need to respond to local context.

Historic environment – how development might impact on character and appearance of listed buildings

This is addressed in the draft SPD.

Urban design principles Guide should prioritise the needs of the pedestrian – create ‘walkable streets’


The speed of traffic – speed limits should Speed limits cannot be set through an

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be reduced or traffic calming measures introduced, or speed ‘designed out’

SPD. Urban design principles that can be employed to reduce speed are suggested in the SPD however.

Reduce levels of on-street parking – guide new developments to include greater off-street parking

A section on parking is included in the draft SPD. As there are advantages to on-street parking (it can positively assist in traffic calming) it is not considered appropriate for the guide to advise against all on-street parking on new schemes. It does however emphasis that all on-street parking schemes do need to be well thought through in order to ensure safety and good design.

Sustainability and energy efficiency Climate change as an important consideration to be taken into account – one representation suggested that all new build should be carbon neutral at least. BREEEM standards, ecohomes rating, 10% energy from renewable source

Sustainability is addressed through the draft SPD. It would be inappropriate to set energy efficiency targets through an SPD however as the PPS1 Supplement states that this should be done through a Development Plan Document (DPD).

Incorporation of features to increase sustainability e.g sustainable building materials


Building techniques High quality building materials These are recommended in the draft

SPD. Guidelines and further areas of guidance

Design Guide should impose height restrictions on buildings

It would be inappropriate to introduce such restrictions on residential buildings through a design guide as tall buildings can in cases be appropriate. The draft SPD provides guidance on the scale, massing and height of buildings and in doing so intends to guide future development to fit in appropriately with surrounding development.

Include guidance on dormer windows, balconies, flat roofs, overlooking.


Guidance on conversion of farm buildings


Guidance why some designs allowed & others refused

It is intended that this will be explained through the exploration of good design principles throughout the draft SPD.

Guidance on how to prevent loss of privacy, overshadowing and dominance Standards relating to length and width of access drives and distances of these from main rooms and adjoining dwellings (to prevent noise nuisance to nearby residents)


Environmental

New developments should not compromise existing wildlife habitats


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Should include guidance on trees, planting schemes and landscaping.


Importance of maintenance in landscaping

The draft SPD cannot control planting by owners within their own gardens. It is asserted in the guidance that maintenance of landscaping should be considered at the outset of a scheme.

Other

Should include a pictorial survey of ‘good’ examples of 20th and 21st Century modern houses

Guide includes various pictorial examples of good design, including good modern design.

Widen conservation area Such an issue would be appropriately addressed through Conservation Area Appraisals, not a residential design guide.

Don’t dictate too tightly as this can produce designs all looking the same

The draft SPD attempts to introduce important standards to prevent inappropriate schemes whilst leaving enough freedom to produce good design.

Guidance on industrial buildings This would fall outside the scope of the draft SPD and would be more appropriately addressed through a separate SPD if deemed necessary.

Consultation on draft 2.3 The Draft Residential Design Guide SPD and the associated

Sustainability Appraisal (SA) were approved for consultation by the Borough Council’s LDF Group on 5th November 2008. The consultation period ran for 6 weeks between 28th November 2008 and 9th January 2009.

2.4 As required under Regulation 17 of the Town and Country Planning

(Local Development) (England) Regulations 2004 the Borough Council contacted various specific and general consultation bodies. A list of those contacted is included as Appendix 1.

2.5 The specific consultees, Council Members and Parish Council’s

received a paper or electronic copy of the SPD, SA and Statement of Matters. The general consultation bodies received a letter either by post or email setting out the period of consultation, where the documents could be viewed and the deadline for comments.

2.6 The consultation was advertised through the publication of a public

notice in the Nottingham Evening Post newspaper on Thursday 27th November 2008.

2.7 Copies of the draft SPD, associated documents and SPD matters were

made available on the Council’s website at www.rushcliffe.gov.uk, and hard copies were distributed to all libraries across the Borough. Hard copies were also made available at the Borough Council’s main

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reception. A public notice inviting representations was placed in the Nottingham Evening Post on Thursday 27th November 2008.

2.8 A total of 23 responses were received as a result of the consultation on

the SPD and SA. Appendix 2 summarises each individual comment and outlines how each representation was addressed. Where changes to the SPD and SA have been considered necessary these are outlined.

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APPENDIX 1: FULL LIST OF CONSULTEES Administrator Edwalton Parish Church Carter Jonas Crest Nicholson (Midlands) Ltd

Age Concern Catherine Petti Peice CTC

Aldergate Properties Limited Cerda Planning Dalton Warner Davis

Alliance Developments Chair of the Governors The Beckett School DEFRA (RDS)

Amanda Scott Chairman Federation of Small Businesses (Notts and Derbys Region)

Dennis Singer Associates

Chairman Grantham Navigation Association Department for Transport

Chairman Lady Bay Community Association Deputy Head of Planning The Coal Authority

Andrew Martin Associates Chairman Nottinghamshire and Derbyshire Society of Architects

Andrew Thomas Planning Derby City Council

Antony Aspbury Associates Chairman Pedals Derbyshire Gypsy Liaison Group

Area Development Manager The Guiness Trust Charter Point Development Director Eastern Shires Housing Association

Area Manager Natural England Chief Executive Anchor Housing Trust Development Manager PfP Developments Ltd (NBHA)

Arup Chief Executive Derwent Housing Association Development Planner R J B Mining (U K) Ltd

Asset Protection Manager, Severn Trent Ltd Chief Executive East Midlands Housing Association Development Planner William Davis Ltd

Asset Protection Officer National Grid Chief Executive fch Housing and Care DevPlan UK

Chief Executive Leicester Housing Association Dialogue Communicating Planning

Assistant Planner Development Planning Partnership LLP

Chief Executive Longhurst Housing Association Diocesan Director of Education Diocese of Southwell

Assistant Plannner First Plan Chief Executive Midlands Rural Housing Trust Director Addleshaw Goddard

Associate Director FPD Savills Chief Executive Nene Housing Association Director Barton Willmore Planning

Associate Director: Partnerships Diocese of Southwell

Chief Executive Northern Counties Housing Association Director Beazer Strategic Land

Associate G L Hearn Planning Chief Executive Nottingham Community Housing Association

Director Bryant Homes

Associate Ian Baseley associates Chief Executive Nottinghamshire County Teaching Primary Care Trust

Director Carter Jonas

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Atkins Transport Planning Chief Executive Raglan Housing Association Director David Wilson Homes

B Line Housing Information and Policy Services Chief Executive Riverside (Midlands) Director Henry Mein Partnership

Bank's Developments Chief Executive Tun Tum Housing Association Director Lambert Smith Hampton

Barkestone, Plungar and Redmile Parish Council Circuit Planning Representative Jehavah's Witnesses in Nottinghams

Director The Theatres Trust

Barton Willmore Planning Clawson, Hose and Harby Parish Council Director Wimpey

Beckett Former Scholars Association Clerk Alverton and Kilvington Parish Director, OPUN, Regeneration East Midlands

Belvoir Health Group Clerk and Engineer Newark Area Internal Drainage Board DPDS Consulting (Central Region)

Ben Hunt Planning Clerk Breaston Parish Council DPDS Consulting Group

Bingham Access Group Clerk Burton-on-the Wolds Parish, Cotes and Pretswood Parish Counc

Dr Goulding

Bingham Labour Group Clerk Cotham Parish Meeting Dr J O'Donoghue

Bircham Dyson Bell Clerk Hathern Parish Council Dr M O'Donoghue

Blotts Country Club Clerk holmepierre point and gamston Parish Council Drivas Jonas LLP

Bottesford Parish Council Clerk Kegworth Parish Council DTZ

Bovis Homes Limited Clerk Lockington and Hemington Parish Council DTZ Pieda Consulting

Bovis Homes Limited, Central Region Clerk Long Whatton and Diseworth Parish East Leake Parish Council

Branch Planning Officer The Inland Waterways Association

Clerk Sawley Parish Council East Midlands Regional Assembly

Brian James Clerk Staunton Parish Council East Midlands Regional Housing Board

British Telecom Clerk Syerston Parish Council East Notts Traveller Association

British Waterways Clerk to the Council Burton Joyce Parish Council Edwalton Branch of Rushcliffe Conservative Assoc

British Wind Energy Association Clerk to the Council Colwick Parish Council Elliott News Service

Broughton and Dalby Parish Council Clerk to the Council Stoke Bardolph Parish Council

Browne Jacobson Clerk Wymeswold Parish Council English Heritage

Business Link, Nottinghamshire Colliers CRE Entec

C.R.O.P (Cotgrave Residents Oppose the Plan) Conservation Officer Nottinghamshire Birdwatchers Entec UK Ltd

CABE Cotgrave Local History Society Entente

Caldercotte Consultants Cotgrave Town Council Environment Agency

Campaign to keep Willoughby on the Wolds Rural Councillor Parish Councillor

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Capital Retail CPRE (Rushcliffe Group) Environment Not Trams

Escritt Barrell Golding Leisure & Tourism Manager British Waterways Mr R. Naismith

Escritt, Barrell & Golding LHW Properties Ltd Mr S Ramsden

F P D Savills (Nottingham) Liberal Democrats Campaign Mr Shaun Hussey

Featherstone Planning & Development Limehouse Software Ltd Mr Simon Seddon

Forestry Commission - Midlands Conservancy Lisa Percival Mr T Gallagher

Forward Planning Derbyshire County Council Lovejoy Mr T Player

Freeth Cartwright Managing Director Smith Stuart Reynolds Mr Tom Kingston

Gamston & Bridgford Community Partnership Managing Director The Planning Bureau Limited Mrs B Venes

geoff millner Mark Jackson Ms Jacqueline Clay

Geoffrey Prince Associates Ltd Marrons Ms Joanne Bellamy

George Crawson Mason Richards Planning Nathaniel Lichfield and Partners

Gladedale Mather Jamie National Grid

Gosia Dennis Mathew Gribben National Grid Transco

Gotham Parish Council Metropolitan Housing Trust Natural England

Gough Planning Services Miller Homes (East Midlands) Ltd Ned Roberts

Governing Body S. Wilford CE Primary School MISS JOSEPHINE KAMINSKI Network Rail

GRAHAM NORBURY MM3 Design Ltd Nex Communications

Great Central Railway (Nottm) Limited Mobile Operators Association Nottingham (South) Christadelphian Ecclesia

Hallam Land Management Limited Mono Consultants Ltd Nottingham Fire & Rescue Service Headquarters

Head of Nottingham Planning Savills Mosaic Group Nottingham Sailing Club

Head of Planning and Building Control Broxtowe Borough Council

Mr AE Small Nottinghamshire Chamber of Commerce

Head of Planning and Infrastructure East Midlands Development Agency

Mr Andrew Talbot Nottinghamshire County Council

Head of Planning Policy Charnwood Borough Council

Mr Bernard Jarvis Nottinghamshire Police

Heaton Planning Ltd Mr C Narrainen Nottinghamshire Wildlife Trust

Hepher Dixon Mr C Richards Notts Rural Community Council

Highways Agency Mr C Welsh Notts Transport 2000

Holmes Antill Mr Chris Thorpe Office of Rail Regulation

Hon. Secretary Rushcliffe Conservative Association Mr D J Loveday Ophelia Marshall

Housing Corporation Mr D Peck Organisation

Hunter Page Planning Mr Daws P.J Fletcher & Son Ltd

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Ian Baseley Associates Mr DC Moss Parry Dunstall Planning Consultants

Ian D Clarke Clarke Mr Dominic Waters Peacock & Smith

Indigo Planning Limited Mr J Breedon Pegasus Planning

Innes England Mr J Dunthorne Pegasus Planning Group

Inventures Mr J Rosley Peter Draper Associates

Jamie Westwood Mr J. Chater Peter Tyers Associates

Jane Burd Mr K Adams Peter Tyers Associates

Janet Campion Mr K Sterry PG Property

John Martin & Associates Mr Keen Planning and Local Government Officer R S P B

jon Woodhall Mr M Barker Planning Assistant Radleigh Homes

Jones Day Mr M Emery Planning Director David Wilson Estates

Joniroke Enterprise Mr M Hyslop Planning Issues Ltd

JS Bloor (Services) Ltd Mr M.S. Barker Planning Manager Castlemore

Keith Keith Mr Morley Planning Manager Savills

Knight Frank LLP Mr Nick Stevenson Planning Policy & Sustainability Manager North West Leicestershire District Council

Land & Development Consultants Ltd Mr P F Parker Planning Policy and Projects Manager Ashfield District Council

Land and Planning Manager J S Bloor (Services) Ltd

Mr Paul Kaczmarczuk Planning Policy Manager Gedling Borough Council

Landmark Planning Limited Mr Pavis Planning Policy Manager Newark and Sherwood District Council

Laura Johnson Mr Philip Franklin Principal Consultant Entec UK Ltd

Mr R Tompkin Principal Consultant John Herington Associates

Principal Planner Fisher German Team Leader Policy & Development Erewash Borough Council

Scott Wilson

Principal planner GVA Grimley Terence O'Rourke Secretary Central West Bridgford Community Association

Principal Planner Shanks The Development Planning Partnership Secretary Radcliffe on Trent Residents' Association

Principal South Nottingham College The Grantham Canal Partnership Senior Planner Government Office for the East Midlands

Rae Town Planning The Woodland Trust Senior Planner W A Fairhurst & Partners

Ratcliffe Marina Tom Genway Senior Planning and Economic Devt Assistant Melton Borough Council

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REACT 21 Trent Strategic Health Authority Senior Planning Manager Redrow Homes (Midlands) Ltd

Redburn Holding Corporation Tribal MJP Senior Planning Officer Leicestershire County Council

Regional Manager East Midlands BT Plc Turley Associates Senior Planning Officer Planning and Information Team Nottingham City Council

Regional Planner English Heritage Vice Chair Ruddington Local History & Amenity Society Senior Technical Advisor N F U East Midlands Region

Regional Planner Home Builders Federation Vice Chairman/ Planning Chairman Keyworth Parish Council

Sherwood Farms Ltd

Regional Planning Manager George Wimpey UK Ltd

Vincent and Gorbing Shoosmiths Solicitors

Right to Ride Network Virgin Media Signet Planning

Riverside Group Waitrose SLR Consultancy

Roger Tym & Partners Walker Morris Solicitors Sol Construction

Roselodge Group West Bridgford Advice Centre South Notts Association for Visually Impaired Group

Royal Mail Group West Bridgford Community Association Spirita

RPS West Bridgford Liberal Democrats Sport England

Rural Solutions Ltd West Bridgford Local Area Forum Star Planning and Development

Rushcliffe Barn Owl Project West Bridgford Traders Stathern Parish Council

Rushcliffe Local Strategic Partnership Westbury Homes Stewart Ross Associates

Rushcliffe Nature Conservation Strategy Implementation Group

White Young Green Planning Stoneleigh Planning Partnership

Rushcliffe Older People's Forum Will Martin Strutt and Parker

Rushcliffe Residents Association William Davis Ltd Taylor Young

Savills Wilson Bowden Developments All Councillors

Savills (Lincoln office) Your Energy Limited All parish Councils

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APPENDIX 2: ISSUES RAISED BY PUBLIC CONSULTATION

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Summary of Comment Initial Response/Action

1.1 1.1 General. Agrees with the principle of the Design Guide. It is interesting and informative and will form a useful part of the LDF.

Noted. Support welcomed.

1.2 1.2 General. Concern that in attempting to appeal to everyone, from the large developer to the individual householder, the document may be overly technical and long for the individual householder planning a small extension. Suggestion that a smaller companion guide which extracts the relevant information for smaller schemes could be produced alongside the guide with the main document being the one adopted as part of the LDF.

Noted. A companion guide could possibly be developed in the future. The structure of the guide has been developed to make it digestible for both the developer and individual with clearly marked sections for types of development most frequently associated with the individual i.e. loft conversions and extensions. The chapters have been designed to be stand alone and can be extracted individually or even page by page.

1.3

Cllr

. F

. M

ason

1.3 General The layout of the guide and the diagrams and pictures, particularly where these are recognisably Rushcliffe, make the document interesting. The references to other relevant documents/web-sites are helpful.


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1.4 1.4 Section C2-Page 34. Privacy. Concern that too much obscure glazing is required to protect neighbours’ privacy in some schemes. In some instances this has led to the amenity of the application property being severely compromised and does not result in the high quality design we are looking to achieve. The privacy problem can be solved more imaginatively through good design. Suggest that a paragraph could be added to page 34 which says that on overlooked sites the local authority will seek imaginative schemes to guard privacy and that the overuse of obscure glazing will be resisted.

Agree. Insert following text on page 34: "Obscure glazing, although a useful method of securing privacy, can have a negative impact on the external appearance of the building as well as the internal environment of the dwelling and will be discouraged where there is considered to be over-reliance on this method of achieving privacy"

2.1 2.1. General. Would have hoped for the draft to be more specific and prescriptive. The guides which are most useful have: a. diagrams showing good and bad examples of development/extensions, b.references to spacing distances required, c. specific car parking standards for different sizes of house/flat etc, d. statements such as if development is within x metres of a bus stop, a reduction in the parking standard would be allowed etc.

Disagree. A prescriptive approach to design issues is contrary to Government guidance contained within PPS1.

2.2 2.2 General Would like to see specific reference to local design features which the council wishes to see reflected in new development.

Noted. Local design or architectural features are referred to in Conservation Area Appraisals for individual Conservation areas. Inclusion in this document would be too prescriptive.

2.3

Sto

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2.3 General Guide doesn't provide a strong impression of the Council's position on specific design issues. Would like more specific guidance even if this opens it up for criticism and means that it needs updating regularly.

Disagree. See response to comment 2.1.

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2.4 2.4 General Problem with the 'Space Between Buildings' SPG not that it was too specific but that it has not been updated in respect of PPG3 or PPS3.

Noted. No change necessary to the SPD.

2.5 2.5 Section C2: p34 Separation distances - The separation distance of 30m between facing windows of habitable rooms sounds excessive if 30dw/ha is to be achieved. Would have thought that 20-25m for 1 & 2 storey, increasing up to 30m for 3 storey would be more appropriate. Distance for habitable windows to blank walls of 12-14m for 1 and 2 storey would also be the norm.

Agree. Replace paragraphs 4&5 with:. "In Rushcliffe, it has previously been accepted that 30m between habitable room windows across rear gardens, for one and two storey dwellings, does maintain privacy where distance is the sole determining factor. It is considered that an additional 3m for each additional floor (up to 4 storeys) or equivalent height distance created by changes in ground level e.g. on a sloping site would provide satisfactory privacy. However, in line with Government guidance, it is recognised that privacy can be achieved in many different ways and the use of alternative techniques for achieving privacy can lead to substantial improvements in the form and layout of the development.

Developers will be required to demonstrate how they have achieved privacy for existing and new residents, amenity for occupiers of new dwellings and the other design objectives set out in this guide if adequate separation distances are not met. It should be noted that Permitted Development rights for loft conversions, dormers, extensions and window replacements may be removed by Condition in any development where it is apparent that such rights may compromise the privacy of neighbours".

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3.1 3.1 General. EMRA's view as the Regional Planning Body is that the SPD is in general conformity with the vision, core objectives and approach to settlement form contained in RSS8, and the draft RSS which represents a continuation of this approach.

Noted. No change necessary.

3.2 3.2 General. Policy 2 of the draft RSS8 (July 2008) provides a useful set of criteria to consider in the design of new developments, alongside the contents of the Code for Sustainable Homes, BREEAM and Building for Life.

Agree. "Draft Regional Spatial Strategy for the East Midlands (Chapter 2)" Government Office for The East Midlands- 2008 has been added to the bullet point list on Page 5. Code for Sustainable Homes already mentioned on page 56 of the SPD.

3.3

EM

RA

3.3 General Would welcome the early involvement of CABE, especially in the case of major development such as Sustainable Urban Extensions, or any eco-town proposals which may come forward.

Agree. Insert the following text on page 6: "Where considered appropriate, for example large scale developments or sensitive sites, CABE may be invited to comment on the proposals."

4.1 4.1 General Support the principles of the draft guidance provided that all the references to movement specifically acknowledgement the importance of taking account of cyclist as well as pedestrian and motor vehicle desire lines and that the importance of giving priority in residential areas to the needs of cyclists and pedestrians, as recommended in the DfT's Manual for Streets (2007) is accepted and consistently acted upon.

Noted. No change necessary

4.2

Pedals

4.2 Section C1 Page 22. As the guide states people do prefer to "walk or cycle along routes where driver, residents and other people can see them". However, we would also support modifying the DfT's Manual for Streets principles to reflect the concept of 'filtered permeability', i.e. including some direct links for cyclists and pedestrians

Agree. Insert the following text on page 22 after 2nd para: "Where necessary some direct links for cyclists and pedestrians, which are not open to motor vehicles, may be provided subject to there being good natural surveillance and adequate lighting."

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which are not open to motor vehicles.

4.3 4.3 Section C2 Page 22 The social safety of users of direct routes away from motor traffic must also be considered, particularly in terms of the provision of good lighting as an integral part of a development. Some overlooking also helps improve perceptions of safety rather than long confined sections as on part of the riverside path towards Wilford from the Suspension Bridge, past the Rivermead Flats.

Agree. Amendments to the SPD in relation to the provision of good lighting have been made in relation to comment 4.2 above. As the other comments refer to existing residential development no change is considered necessary as the SPD is only concerned with new development.

4.4 4.4 Section C2 Page 22 Welcome statement "New pedestrian and cycle routes should be clear, safe and convenient and free from barriers and dead ends" and recognition that "streets designed for low and vehicular speeds (20mph or 30km/h) encourages safe walking as well as cycling and social interaction".


4.5

4.5 Section C2 Page 22 The same principle holds for existing urban areas as well as new developments and we would like to see strong support by the Borough Council for Nottinghamshire County Council designating area-wide 20mph zones in both, consistent with the strong encouragement for their wider introduction in the recent House of Commons Transport Committee report on Road Safety

Disagree. The actual setting of speed limits is beyond the scope of a design SPD.

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4.6 4.6 Section C2 Page 22 Important in terms of promoting cycling in residential areas is to upgrade the substandard provision in existing housing areas e.g. Compton Acres. Such areas currently suffer from poor maintenance and are poorly signed and integrated with other areas.

Disagree. The SPD is concerned with the residential design of new development and not existing development. It would therefore be beyond the scope of the SPD.

5.1 5.1 General Agrees with the principle of design guide. After 30 years of despairing at the appalling design quality of houses and flats built in West Bridgford I am amazed and delighted by the way this document encourages good design

Comment noted. Support welcomed.

5.2 5.2 General Particularly encouraged by: "bland and imaginative new housing will not be accepted" (page 1), "Pastiche designs…should be avoided" (page 14), "contemporary and imaginative solutions…can…make a positive contribution" (page 14), "It is rarely possible and often not desirable to mimic either the materials of architectural style of a bygone age" (page 32 - the examples on this page are spot on), "...innovative approaches will be encouraged...A positive design approach does not mean repetition of what went before" (page 33), "Contemporary or innovative solutions...are to be encouraged" (page 42).


5.3

Mr.

R. M

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in

5.3 General The test of the effectiveness of this guide will be if poorly designed new developments are not allowed to be built and if beautiful new homes are built. Would like to see a similar guide for non-residential buildings.

Comment noted. No change necessary.

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6.1 6.1 Section C2 Page 27 Housing Density. The average densities stated in the guide are too high and will not result in the high quality homes and well designed places that the SPD aims to help deliver through its guidelines. Will force developers to build flats and apartments in unsuitable areas. The Council should adopt a more flexible approach on housing density where these considerations are used to help guide the housing density on a site by site basis . Consider that the paragraph and text box highlighting the average densities that should be achieved in the Borough should be removed from the SPD with greater emphasis placed on the criteria identified on page 27 shaping expected densities on a site by site basis.

Insert text on Page 28 after first para. "Development should aim to meet the densities required by Government but also respect the site, its context and the place which will be the overriding considerations in determining the most suitable density for the site. If the required densities are not possible, the proposals should have a robust site assessment which demonstrates why this is the case."

6.2

Will

iam

Davis

Lim

ited

6.2 Section C2 Page 34 Privacy. Concerned by the intent to use 30 metres as the minimum distance between habitable room windows across rear gardens. This is too long and would be highly restrictive on future residential development design. Contradicts Council's intention to deliver efficient densities as separation distances of 30m would make it extremely difficult to achieve even a 30dph density. A more acceptable way of achieving privacy in future developments would be to adopt a more flexible approach encouraging different techniques of achieving privacy without regimented separation distances. This is the view held in the 'By Design' Companion Guide to PPG3 (CABE 2001). This guidance is not cited in section 1 which lists relevant guidance yet is referred to on

Agree. This has been addressed in the response to comment 2.5 above.

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several occasions in section 3. The 30m separation distance should be removed from the SPD and instead a more flexible approach to achieving privacy through careful design should be included as this is more in-line with national guidance.

6.3

6.3 Section C3 Page 55 Efficient Use and Re-use of Water. It is recognised that careful consideration needs to be given to the use and re-use of water in new residential developments to help achieve higher levels of the Code for Sustainable Homes, we consider a more flexible and less strict approach would be more appropriate at this time. Council policy should encourage the use and re-use of water in new developments rather than the current policy which has the positive design of efficient use and re-use of water in new development as a requirement. We note that on page 56 Active Solar Design is encouraged and not required. We consider such an approach to be more appropriate when considering water use in new residential developments and the SPD should be altered accordingly.

Agree. The first sentence on page 55 has been amended to read: "The efficient use of water (including recycling rainwater) should be "encouraged in any" development.

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7.1.1 7.1.1 General. Agree with the principle of a Residential Design Guide. The draft SPD is generally well written and English Heritage welcome the references to the historic environment.


7.1.2 7.1.2 Section B Document lacks reference to archaeological issues, including SAMs and how residential development needs to take this into account. Document also lacks reference to registered historic parks and gardens, of which there are three in the borough, all registered Grade II.

7.1.2 Agree. Reference now made in the document to Scheduled Ancient Monuments (SAMs) etc. Page 11 Paragraph added titled "Rushcliffe's Heritage" with the following text: "Rushcliffe has 29 Conservation Areas, 3 Registered Parks and Gardens, 25 Scheduled Ancient Monuments and over 650 Listed Buildings and structures"

7.2 7.2 Section A: Introduction, Objectives and Policy Context. Welcome reference to PPG15 although the section needs to state the corresponding para. number for ease of reference. Would also welcome reference to the joint CABE and English Heritage publication 'Building in Context' on page 5. Would like to see English Heritage's website www.helm.org.uk included on the useful website list.

Agree in part. The 'Building in Context' document is already referred to on page 5. Agree that the English Heritage website should be included on the useful website list. Amend accordingly. Also the paragraph number is inserted in reference to PPG15.

7.3.1

Englis

h H

erita

ge

7.3 Section B: Context and Character. 1. Would be helpful if this section could outline the number of listed buildings, conservation areas, scheduled monuments and historic parks and gardens within the borough.

7.3.1. Agree. Page 11 Paragraph added titled "Rushcliffe's Heritage" with the following text: "Rushcliffe has 29 Conservation Areas, 3 Registered Parks and Gardens, 25 Scheduled Ancient Monuments and over 650 Listed Buildings and structures"

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7.3.2 7.3.2 Section B: Context and Character. In addition to landscape character paragraphs there should be reference to the historic characterisation work that exists for Rushcliffe. e.g. Historic Landscape Characterisation (HLC) Study, Extensive Urban Surveys (EUS). Characterisation data will help with the detailed appraisal of historical development and character as required on page 14

7.3.2 Disagree. The SPD refers to the Nottinghamshire Landscape Character Assessment. It is felt that this should be sufficient in relation to assessing the character of areas of Rushcliffe.

7.3.3 7.3.3 Page 16 - the site appraisal requirements should include explicit reference to the need to assess the historic character and features of any given site.

7.3.3. Agree. Bullet point added on Page 16 : "Historic character and features and existing buildings or structures which make a contribution and should be retained."

7.4.1 7.4 Section C1: 1.Note that EH has produced guidance on transport and street issues.

7.4 Agree. The 'other guidance' on Page 62 amended to include EH suggested guidance

7.4.2 2. Analysis of views is an important consideration with regards to the historic environment. EH has produced draft guidance.


7.4.3

3. - it should be noted that a building or structure does not need to be tall or large in order to be considered a landmark. EH/CABE has produced guidance on tall buildings.


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7.5.1 7.5 Section C2. 1. Page 43 - backland development - would be helpful if the bullet points can make reference to the need to assess the impact on historic features, including listed buildings and conservation areas. EH has produced guidance on development in suburban areas that is relevant.

7.5.1. Disagree. New text has been inserted in regards to general development taking account of historic features (comment 7.3.3.) No additional reference here is considered necessary.

7.5.2 7.5.2. Section C2 page 44-45 - building conversions guidance is relatively thorough and appropriate. Reference should be made to the concept of 'enabling development'. Further guidance on this concept is available through EH.

7.5.2. Disagree. The concept of enabling development is complex and it would require a lengthly and indepth explanation to deal with it adequately. As the guide attempts to be as straightforward and as easy to understand as possible it is felt that this should not be detailed in the guide as such a complex detail would detract from this intended simplicity. English Heritage publications are referenced at the back of the guide.

7.5.3

7.5.3. Section C2 pp46-48 - It should be stated that stricter controls may need to be applied for listed buildings and conservation areas, i.e.. the guidelines on dimensions etc. set out in the SPD may not be appropriate for some historic sites.

7.5.3 Agree. New text inserted on page 46: "Stricter controls over the design of loft conversions may be applied to Listed Buildings or properties in Conservation Areas where these need consent. It should be noted that Permitted Development rights for loft conversions, dormers, and window replacements may be removed by Condition in any development where it is apparent that such rights may compromise the privacy of neighbours." Following text added to p47: "Stricter controls may be applied to extensions to Listed Buildings or to properties in Conservation Areas where these need consent. It should be noted that Permitted Development rights for extensions and window replacements may be removed by Condition in any development where it is apparent that such rights may compromise the privacy of neighbours."

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7.6 7.6 Section C3. 1. P56 - Energy conservation - it should be noted that extra care may need to be taken with the installation of certain energy saving measures within historic buildings and places. EH has produced relevant guidance.

Agree. 'Other guidance' on Page 62 amended to include EH suggested docs and guidance

7.7.1 7.7.1 Section D. Page 59 - appraisal checklist - additional text should be added to the 3rd bullet point to read "historic character and setting of site, including designated features such as listed buildings and scheduled monuments, as well as wider archaeological and landscape features"

7.7.1 Agree Bullet point 3 of page 59 changed to read: "historic character and setting of site, including designated features such as listed buildings and scheduled monuments, as well as wider archaeological and landscape features".

7.7.2 7.7.2. Section D Page 60 - glossary - would be helpful to include definitions of conservation areas, listed buildings etc.

7.7.2 Agree. These definitions have been added to the glossary.

7.7.3 7.7.3 Section D Page 62 - useful references - should include PPG15 and the Building in Context publication. Would be useful to include contact details for English Heritage and CABE.

7.7.3. Agree. Page 62 updated to reflect these suggestions. English Heritage and CABE websites added to the useful website list.

7.8

7.8 Sustainability Appraisal. Disagree that the relationship between SPD Objectives 2 and 5 (local character and historic settings) and SA Objective 9 (energy usage) may be incompatible. It is possible to introduce energy saving measures that do not harm local character or historic settings but it can be achieved. Suggest that the relationship between the SPD and SA objectives is shown as 'uncertain'.

Agree. Change the relationship between the SPD and SA objectives to uncertain.

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8.1 8.1 General - Agree with the principle of the design guide. Would be more useful if targeted more effectively. Good to see the VDS and Conservation Area Appraisals referred to as relevant documents. Greater emphasis should be made on the use of multi-disciplinary design teams.

Noted. Comments welcomed.

8.2.1 8.2 General. 8.2.1 The use of photographs and diagrams adds interest but often they are so small and dark that their usefulness is lost. E.g. aerial photo on page 14.

8.2.1 Noted All illustrations have been checked for quality and changed where appropriate see 8.2.2.

8.2.2. The historic plans would be useful as 1:1250 scale. Instead seem like space fillers.

8.2.2 Disagree 1:1250 scale plans would be too large for the document. It is felt that the illustration serves its purpose as an example of the type of historic maps that are available.

8.2.3 Page 20 - notes accompanying diagrams are unreadable., would be more helpful on a larger isometric view.

8.2.3 Agree Unreadable annotations have been enlarged.

8.2.4 Page 21- would be helpful to include notes on the plans that show their purpose, e.g. where are the views through, what are the blue stars and lines representing. Similarly on pages 28 and 40.

8.2.4 Agree Plans showing blue lines and stars on Page 21 have been changed to better explain permeability.

8.2.5 Page 42 - the attraction of the cul-de-sac image is not evident nor is the cottage infill. Would like to see more local examples rather than those from other publications.

8.2.5 Disagree The cul-de-sac image is not supposed to be attractive. These are local examples.

8.3.1 8.3 General 1. Generalisations often require exceptions e.g. in regards to density, conformity, contrast (page 13, 27).

8.3.1 Disagree. These exceptions are required. No change necessary.

8.3.2

East B

ridgfo

rd P

arish C

ouncil

8.3.2. The headings on page 27, column 2 are not clearly related to the text.

8.3.2. Agree. The text has been changed so that the content directly relates to the following densities a) urban b) suburban and

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c) rural

8.3.3 8.3.3 Unusual terms such as 'tracking' are used without explanation

8.3.3 Agree "Tracking" is defined in the paragraph beneath where it appears in the text. Agree that this definition could be made clearer. The following text has been deleted: "Standard solutions to traffic calming (e.g. road humps) should be avoided. A best practice technique is to design streets by 'tracking'. The arrangement of development blocks (housing) have priority and then the carriageway is 'plotted' through the space. This design technique ensures that the buildings, rather than the roads, take priority in design". Replace with the following text: "Standard solutions to traffic calming (e.g. road humps should be avoided. A best practice technique is to design streets by 'tracking' whereby the arrangement of development blocks (housing) have priority and then the carriageway is 'plotted' through the space. This design techniques ensures that the buildings, rather than the roads, take priority in design."

8.3.4

8.3.4 Could a better explanation of the distinction between suburban and rural design be provided

8.3.4 Disagree. It is felt that the definition provided on page 27 is appropriate as there is no hard and fast rule as to what does constitute a ‘suburban’ or ‘rural’ style. There are many differentiations with what would be termed a ‘rural’ type of design and likewise with ‘suburban’. As is repeated in the guide, each individual settlement has a unique type of character and style. For these reasons it is felt it would be inappropriate to go into fixed definitions.

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8.4 8.4 Section C2. Sections on infill, conversions and extensions could be more useful to an unskilled applicant if the design and planning process could be explained, perhaps with a separate section with a flow chart. Should be separated from the sections on road layout and block design.

8.4 Agree. A flow chart explaining the planning application process has been included in the guide after page 6.

8.5.1 8.5 Section C2. 1.Help with the smaller development, good examples of barn conversions, must be available. What is the purpose of interior photographs?

8.5. Disagree. Internal photo shows the very different "barn style" living referred to in the doc.

8.5.2 8.5.2 Consideration of the inexperienced developer should be given with more help for those wishing to include solar energy collection.

8.5.2. Agree Solar panel advice is contained in the English Heritage document that is listed under the 'other guidance' listed on page 62 (added in response to comment 7.7).

8.5.3 8.5.3. Page 56. What is the purpose of the images as neither are attractive. Would like to see advice on wind turbine installation.

8.5.3.Agree Illustration changed to show better image of a green roof.

8.5.4

8.5.4. The impact of such things on historic buildings is dealt with in new EH guidance but is not referred to.

8.5.4. Agree In response to comment 7.7 this guidance is now referred to on page 62.

9.1 9.1 General. Surprised at how open ended some sections are and wonder if scope for judgement means too much scope for dispute.

9.1 Disagree. Flexible guidance provided through the guide allows each case to be judged on its own design merits. This approach is in line with government guidance contained within PPS1. Judgement means every case on its merits and is partly the aim of government guidance.

9.2.1

Cllr

. R

. Jones

9.2 Section B. 1. Page 9 - description of Rushcliffe as 'rolling farmland' is fair but should mention that within it there are distinctive landmarks of wooded hills such as Bunny Woods, Sharphill Woods and Blackberry Hill Woods. Pp10-15.

9.2.1 Disagree. The Notts CC Landscape Appraisal is referred to and adequately describes the predominant character of the area.

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9.2.2 9.2.2. The distinctive characteristics of Rushcliffe are described - but West Bridgford is not described. Surely it should be. Street trees are an important aspect of much of WB. The presence of street trees in developments should be advised in later sections of the guide. e.g. p36.

9.2.2 Agree. The following description of WB which refers to street trees has been inserted at the end of page 14: "Although there was probably a settlement at West Bridgford before the Norman conquest & the church dates from the 12 century, it remained a small village until the end of 19 century. By the beginning of the First World War, Lady Bay and the area between Trent Bridge, Loughborough Road and Melton road as far south as Devonshire Road had been substantially developed although Central Avenue was still incomplete. There were a few large houses in Edwalton, around the railway station.

9.2.2 (Cont) West Bridgford has continued to grow ever since. The late Victorian and Edwardian villas on mainly tree lined streets have a distinct and valuable character, as do some of the later inter-war and early post war developments."

9.3.1 9.3 Section C1. 1. P19 - Can the section about movements connect with the broader section on noise? A consideration about movements should be that they do not generate unsocial/unacceptable noise levels for people in private/public spaces.

9.3.1 Agree. The following text has been inserted on page 20 after 2nd paragraph: "Where it is considered that multiple use of the street may result in undue noise for residents additional mitigating measures may be required". Other noise issues are referred to on page 38. Additional text suggested for the final sentence on noise to read "Planting has little effect on noise attenuation. A 10 metre deep belt of planting is required to produce a barely discernible reduction of 3 Decibels".

9.3.2

9.3.2 Section C1 P23 - the section on parking should include reference to cycle storage.

9.3.2 Agree. The following text has been inserted on page 22 after the 4th para: "Cycle parking will be a requirement in all apartment schemes"

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9.4.1 9.4 Section C2. 1. P29 - Dislike picture at the foot of the page as it has a flat roof which we should not be encouraging. .

9.4.1 Disagree. This is intended to show that flat roofs can be incorporated in a quality design and that they can still be in context even when sited next to a traditional building.

9.4.2 9.4.2 P32 - welcome the emphasis on warm colours as described. Would like to examples of colour schemes which do not work well e.g new buildings with blank areas of cream or white render.

9.4.2 Disagree. It would be difficult to include significant examples of everything. We would have to follow the theme of good and bad examples throughout the doc.

9.4.3

9.4.3. P36 - Garden sizes detailed are not conducive for vegetable growing which is an activity that should be promoted. On developments above a certain size, e.g. 500, should promote the provision of an area of allotments for residents

9.4.3 Partly agree. Allotment provision would be a policy issue or covered through S106 Agreements. It would be inappropriate to refer to this in a design SPD. However it is acknowledged that the guidelines on garden size should better reflect government guidance which encourages a variety of garden sizes. The first three paragraphs on page 36 have been deleted. The header "Gardens and boundaries" has been replaced with "Garden Size, Privacy and Orientation". The following text has been inserted: "In Rushcliffe it has been accepted under previously established guidelines that there should be rear gardens with a depth of 10m to the boundary and garden sizes of 110 sq m for detached properties, 90 sq m for semi detached and terraced properties and 55 sq m for 1 and 2 bed properties. However, it is accepted that, in line with Government Guidance, a variety of housing is required, and this should include a variety of garden sizes too. Developers should aim to meet the above guidelines whilst providing a variety of sizes.

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Where these guidelines are not met, developers will be required to demonstrate why smaller gardens are acceptable and explain how they meet the overall objectives of the Design Guide. Gardens smaller than the footprint of the dwelling excluding the garage are unlikely to be acceptable. Larger sizes will be necessary where gardens are overshadowed or overlooked, narrow or irregular in shape or include significant changes in level. Availability of two or more of the following will help in demonstrating why smaller gardens should be allowed.

9.4.4 9.4.4. P38 - Noise section appears to be tacked on at the end - should be referred to in previous sections. The impacts of normal domestic noise have an impact on privacy and perceptions of safety - this should be noted in this section.

9.4.4 Noted. Noise issues have been covered in response to 9.3 above.

9.4.5 9.4.5 Section C2 (cont) P41 - last sentence of 2nd para., should the emphasis be on both requiring a landmark feature to be an advantage and not outweighing the effects it would have on neighbouring properties and the street scene.

9.4.5 Noted. English Heritage guidance on tall buildings now included on Page 62.

9.4.6 9.4.6. P45 - should we reconsider chimneys on barns as part of increasing the options for future energy sources and higher discharge of any products of combustion.

9.4.6 Disagree. Brick chimneys are not appropriate on barns unless they already exist but occasional flues (which are generally more energy efficient) are acceptable as such flues would be found on working barns for such things as curing hams etc.

9.4.7

9.4.7. P46 Loft conversions - can there be more guidance on overlooking as this is an undesirable effect of further level development. Can the type of statement as made in the last para re: extensions be made here? i.e. to consider the impact on the street scene if adjacent

9.4.7. Agree. The following sentence on page 46 has been deleted: "Privacy can be an issue when adjacent buildings overlook new windows created as a result of extensions or roofspace conversions". The following text replaces the deleted sentence: "Privacy can be an issue where new loft conversion

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properties had loft extensions in a similar manner. windows overlook existing gardens or other buildings".

9.4.8 9.4.8. P47 - last para on side extensions - should the word be 'adjacent' instead of 'adjoining'. Don't think that the section deals with the extensions issue adequately enough. Should only approve these in exceptional circumstances.

9.4.8. Agree. Changed to "adjacent"

9.4.9

9.4.9 . P53 - Wildlife - hopes Notts Wildlife Trust have been invited to comment.

9.4.9. Wildlife Trust consulted.

10.1

CA

BE

10.1 General. Unable to comment on this document. However have some general points that should be considered: 1. Robust design policies should be included within all LDF documents and the Sustainable Community Strategy. 2. Treat design as a cross cutting issue - consider how policy areas relate to urban design, open space management, architectural quality, roads and highways, social infrastructure and the public realm. 3. Design should reflect understanding of local context, character and aspirations. 4. Should include adequate wording or 'hooks' within your policies that enable you to develop and use other design tools and mechanisms.

Comments noted.

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11 11.1 General - Best practice section could include reference to Sustainable Developer Guide for Notts and the EA guide" building a better environment - a guide for developers"

Agree. These examples have been added to the bullet point list on page 5.

11.2.1

11.2 Section C3 Page 54. Flood risk. 1 EA welcomes the promotion of SuDS and recommends that new text is added to ensure that due consideration is given to the legal issues associated with the adoption and maintenance of SuDS features. It is important to resolve these issues at the desing stage. Further guidance available through the CIRIA publication 'Interim Code of Practice for Sustainable Drainage Systems'.

11.2.1. Agree. The following text added on Page 54 after the bullet points: "The future ownership/adoption, management and maintenance of any open watercourses or SuDS features should be discussed and resolved at the design stage"

11.2.2

11.2.2. EA is concerned over the prescriptive nature of the text explaining that open channels and swales in residential areas should be limited to 1.5m depths and slopes no steeper than 30 degrees. Unclear on the source of this statement. A variety of channel profiles should be encouraged as this maximises the wildlife of as this maximises the wildlife benefits of open water. The design standard promoted in the guide would create trapezodial channels devoid of any features which are not conducive with promoting wildlife.

11.2.2 Agree. The 1.5m depth and 30 degrees referred to was not intended to be construed as a single fixed guideline. It is acknowledged that this should be made clearer in the SPD. Text has been revised in paragraph 4 to read: "Where open channels/swales are proposed within residential areas their depth must not exceed 1.5m with side slopes no steeper than 30 degrees above the horizontal. A variety of channel profiles should be encouraged as this maximises the wildlife benefits of open water."

11.2.3

Environm

ent A

gency

11.2.3 Section C3 Page 54 (cont) 3. EA recommends that new text is added to provide further guidance in relation to flood risk. It is important to ensure that appropriate levels of flood resilience and resistance are incorporated into the design and construction of developments in areas of high flood risk. EA would

11.2.3. Agree. The following text has been inserted on page 54 after the blue box: "It is important to ensure that appropriate levels of flood resilience and resistance are incorporated into the design and construction of developments in areas of high flood risk. More innovative and bespoke design solutions to mitigate against the risk of flooding to new houses are to be encouraged and may be a

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encourage LPA to require more innovative and bespoke design solutions to mitigate against the risk of flooding to new housing. Further guidance available in the DCLG publication entitled 'Improving the Flood Performance of New Buildings' and ODPM's 'Preparing for Floods'.

requirement in areas of particular risk. Further guidance is available in: “Improving the Flood Performance of New Buildings” DCLG and “Preparing for Floods” ODPM.

11.2.4

11.2.4.Reference to PPG25 should be replaced with PPS25 and the Practice Guide.

11.2.4 Agree. Text on Page 54 changed to read "All new residential development must adhere to flood risk management measures as set out in Planning Policy Statement 25 and the practice Guide. Further guidance on this issue can be provided by the Environment Agency."

11.3 11.3 Section C3 Page 56 - Sustainable Development - statement that 'new residential development should aspire to the guidance for the 'Code for Sustainable Homes'. We would recommend the designation of a specific 'level' that the LPA will be expecting.

11.3 Disagree. The Supplement to PPS1 states that local requirements for sustainable building have to be set through a Development Plan Document and not a Supplementary Planning Document. Such a document may be forthcoming the the LDF process. No change therefore necessary.

11.4 11.4 Section C3 Page 59 - The 'site appraisal checklist' should include Flood Risk. Under 'other references - national policy guidance' - PPS25 should be included.

11.4 Agree. "Flood risk" added to bullet pointed 'site appraisal checklist' on page 59. PPS 25 added to bullet pointed 'National Planning Guidance' list on page 62.

11.5

11.5 Section C3 Page 55: Groundwater Issues - 1. Drainage features that can contribute to recharging local groundwater reserves include porous pavements, swales, storage basins and soakways. The cleaning of surface water through a suitably designed scheme should be stressed in the document.

11.5 Agree. The following text inserted on page 55: "Drainage features such as porous pavements, swales, storage basins and soakaways contribute to recharging local groundwater reserves. In all cases developers will be required to design suitable water cleansing features into such drainage features where this is considered necessary."

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11.6 11.6 Section C3 Page 53 - Biodiversity - should include a bullet point suggesting that new developments could incorporate biodiversity initiatives within their physical fabric through the installation of green roofs, bird bricks, bat bricks and bug boxes during construction (approach in line with PPS9)

11.6 Agree. The following list added at the end of the bullet point list on page 53: "Biodiversity initiatives such as the installation of green roofs or the use of bird bricks, bat bricks and bug boxes will generally be encouraged."

11.7

11.7 SA Report - EA welcomes the SA Objective to 'reduce flood risk and the impacts of flooding'. The above recommendations for new text will make a positive contribution toward achieving this objective. SA Objective 7 - would recommend that the production of the guidance under 'option A' should be changed from neutral to positive. The guidance ensures that biodiversity is considered as an integral part of the design of new developments which would not otherwise occur.

11.7 Agree. Amend SA accordingly.

12.1 12.1 General Agrees with the principle of the design guide.


12.2

Cllr

. B

. V

enes 12.2 Section C2 Page 34- Layout and Space - No 3

storey houses opposite each other across a narrow road as there would be a lack of privacy in bedrooms. 2. Lack of privacy in existing properties when trees are removed and footpaths created at a higher level or on a bridge. This was not considered when Station site in Ruddington was given planning permission. Also EA allowed new housing to be built much higher than existing land resulting in flooding to existing gardens which were at original height.

Disagree. Setting a height limit on buildings would be contrary to national guidance contained within PPS1 which states that design guidance should not be prescriptive. If the design of a building did not adequately address the privacy issues then the application can be refused on general amenity reasons.

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12.3 12.3 Section C2 Page 46 - Loft conversions and dormers - design of dormers should be considered on effect of the building. Some like a crows nest on a ship!

Noted. These issues are covered on page 46.

12.4 12.4 Section C3 Page 56 - Energy and conservation - Triple glazed windows - when do we request this and should this be included in planning permission?

Noted. Triple glazed windows are a Building regulations matter - beyond the scope of the SPD.

12.5

12.5 General I find this design guide good but it does need implementing on new properties.

Comment noted. No change necessary

13.1

Sport

Engla

nd

13.1 General The guide does not appear to include any advice about the provision of open space or facilities for active recreation such as Multi Use Games Areas (MUGAs). It is assumed that the Council intends to cover the sporting and active recreational needs of residents through the companion SPD for Open Space, sport and Recreation as mentioned on the RBC website. Sport England would be keen to comment on that SPD.

Comment noted. As a statutory consultee Sport England would be consulted on the Open Space, Sport and Recreation SPD.

14.1

Theatr

es

Tru

st

14.1 General Due to the specific nature of the Trust's remit we have no comment to make on this document.


15.1

Ente

c

15.1 General Agrees with the principle of the design guide. Overall we support the Council's intention to introduce a tailored guide to promote higher standards of urban design within Rushcliffe, however, believe that for the SPD to be fully effective it needs further work before being finalised.

Comment noted.

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15.2.1

15.2 General - 1. SPD would benefit greatly from the inclusion of clear local examples and/or case studies of both good and bad urban design. At present we believe the guide is too generic rather than identifying common design failings against stated design principles, and outlining and illustrating design solutions relevant to different character areas within the Borough.

15.2.1 Disagree. It is acknowledged that this is an approach that has been adopted in some design guides. However, in this case it is considered that if each section was to illustrate design issues with both good and bad examples it would result in an excessively long document. Instead the approach has been taken to illustrate the guide with good local examples, where appropriate. This has resulted in a more compact guide which would be more digestible to the user. Further guidance is provided in individual Conservation Area Appraisals.

15.2.2

15.2.2. To avoid repetition and to strengthen the overall message of the guide, the structure of the SPD could be improved. e.g. much of section C reproduces what is set out in section B.

15.2.2 Disagree. The structure of the guide reflects the required content of the guide. It is felt that local character and distinctiveness is a critical issue to be considered in the SPD and that this repetition strengthens and consolidates this importance.

15.2.3

15.2.3. Importance of ensuring that the local community can effectively engage in the design process should be highlighted in the SPD.

15.2 3. Agree Local Community involvement has been shown in the Planning Process diagram (see comment 8.4).

15.2.4

15.4.4. Should make reference to open space and draw attention to design solutions for open space in new developments. Would also like to see further examples of good hard and soft landscaping.

15.2.4. Disagree Open space issues will be explored through the Open Space SPD

15.2.5

15.2 General.(cont) 5. A number of the illustrations are not labelled e.g. page 13 which means it is not always clear what the images are meant to convey to the reader.

15.2.5 Disagree. These are simply illustrations to show different materials and do not need titling.

15.2.6

15.2 6. In other cases where supporting text is provided the illustration in many cases appear inappropriate. e.g. a) page 20 - both the home zone images and those intended to illustrate shared surfaces could be improved.

15.2.6 .a) Agree. A more appropriate image has been selected to replace this example. .

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15.2.6 b)

b) page 22 - the physical barriers before the road in the main photo does not give the impression that pedestrians and cyclists have priority in this example.

b) Agree. A more appropriate image has been chosen to replace this.

15.2.6 c)

c) p24 - the images could do more to illustrate use of good quality materials &/or provide a good example of an integrated transport system.

c) Agree. An image of the new East Midlands Parkway station has been chosen to replace this.

15.2.6 d)

d) p29 - none of the images illustrate the point made in the text - final image contradicts the message.

d) Disagree. The annotation to the image explains how the building responds to its context which justifies its inclusion as an example of good practice

15.2.6 e)

e) P41 - central image - without showing the surrounding buildings it is impossible to say whether this is a bad or good example of responding to context.

e) Partly agree. This is the rear view of the same building used on page 29 as an example of a building responding to context. Amend the annotation to the image on page 41 to link the two images. Taken together the two images will better illustrate the point.

15.2.6 f)

f) P54 - the final image is not considered a good example.

f) Agree. Image of the swale as been replaced with a better illustration.

15.3.1

15.3 Section B. Page 12 - Settlement Patterns - 1. the 'positive elements' referred to under para 4 are not explained.

15.3.1 Disagree. The positive elements are given by example e.g. the open spaces Car Colston or the treed environment of Colston Basset. No change necessary.

15.3.2

15.3.2. Section B. Page 12 Illustrations (photos) are needed to accompany and support references to examples in para 5.

15.3.2. Agree. These illustrations are provided on page 15 but it is agreed that this link could be made clearer. Text amended by inserting a direct reference to these illustrations on page 12. Also see 15.3.3.

15.3.3

15.3.3. The caption accompanying the small plan of Bingham town centre should be amended to read "the historic centre of the Market town has a grid structure". Note that the plans of SB and Bingham are replicated on P14.

15.3.3. Agree. The caption has been changed as suggested. The plans to Sutton Bonington, Bingham, Wysall and Langar have been removed and replaced with plans of Flintham, Car Colston, Colston Bassett and Hickling. This better illustrates the text and responds to 15.3.2 above

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15.3.4

15.3.4 P14 - reference to undertaking appraisals and the scope of that work is repeated under the next section on page 16.

15.3.4 Disagree. The appraisals referred to on page 14 Appraisals refer to the immediate site whilst the appraisals on page 16 refer to the broader context and constraints. Therefore no repetition.

15.4.1

15.4 Section C1 1. P21 - the SPD would benefit from better images and examples to illustrate the point.

15.4.1 Agree. In response to comment 8.2 the annotations to the diagrams have been improved. This addresses this concern.

15.4.2

15.4.2 Section C1 pp23-24 - images and illustrations are needed to provide examples of what represents good practice.

15.4.2 Disagree As above this would involve over expansion of the document if examples of everything to be provided.

15.5.1

15.5 Section C2 - 1. P28 - plot arrangement - the message being made with reference to plot depths, is not very clear. Does best practice guidance call for “individual plot depths to be as small and as narrow as practicable”? It is considered that isometric drawings rather than cross-sections would better convey the point being made in the SPD i.e. dwellings with narrow street frontages have higher ridge lines and are typically deeper than dwellings with wider street frontages, with consequential implications for the character of the street etc.

15.5.1 Agree. The message could be made clearer. On Page 28 the following text has been deleted: "However, best practice guidance for individual plot depths to be as small and as narrow as practicable. This uses land efficiently and provides a greater number of dwellings within the street. It also invariably results in higher ridges than the local vernacular, and as a result frequently conflicts with the height of buildings found in our historic villages". The following text has been inserted in the paragraph underneath 'plot arrangement' to replace this deletion: “However, best practice guidance to maximise the use of land is for individual plot widths to be as narrow as possible. This not only uses land efficiently it also provides a greater number of dwellings within the street. Unfortunately, it also invariably results in higher ridges than the local vernacular, and as a result frequently conflicts with the height of buildings found in our historic villages".

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15.5.2

15.5 Section C2 2. Gardens and boundary sizes - the criteria by which the ‘private garden size’ requirement will not apply in new developments are questioned. Presently the draft SPD states that if, for example, through new development the street scene in a conservation area is maintained or enhanced and if, at the same time, residents in a given new development can view landscaped open space and sky from within a dwelling, then the stated ‘private garden size’ requirement would not apply. Application of the criteria as suggested in the SPD does not appear conducive to the delivery of good design.

15.5.2.Disagree. No change, further requirements would be too prescriptive and run contrary to national guidance contained within PPS1.

15.6

15.6 General - On a general point there are a number of typos and formatting issues which we have not highlighted here but assume will be corrected in the final version of the SPD.

Comment noted. The typing errors have been addressed.

16.1 16.1 General Agrees with the principle of the design guide. 1. Will provide a useful insight to Cllrs becoming involved in planning decisions. 2. It will provide a 'yard-stick' against which parish council can review planning applications and make appropriate comments in our returns to RBC.

Comments noted. Support welcomed.

16.2

Cllr

. T

. G

reen

16.2 General Parish Council agrees with the intentions listed to 1. make better and safer places, 2. stop bland and unimaginative new housing, 3. make the best and most efficient use of land available. 4. for old buildings woven into the fabric of the living and working community'. However, planning applications approved by

Comments noted.

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RBC in the past year appear to have neglected them (with examples provided) The observations overleaf are some of the many we would like to discuss with RBC planners. Notwithstanding these comments we applaud the Draft Rushcliffe RDG.

17.1

Cllr

Heth

eringto

n

and C

llr. M

. M

ale

s 17.1 Section C2 Page 38 Does not appear to be any

reference in the document to noise attenuation requirements as required by the Inspector for the new houses on Gotham Road. Expected to find a reference to it along with the glazing etc. Suggested additional text: “Where properties are built under an airport flight-path, appropriate noise attenuation measures should be incorporated to ensure the building meets applicable national guidance limits”.

17.1 Agree. Insert the suggested additional text to P38.

18.1 18.1 General The principles of the document are sound & could provide a general guide through the maze of information and references to other publications; particularly for the 'non-professional'.


18.2

Nott

s. A

nd D

erb

ys.

Socie

ty o

f A

rchitects

18.2 General Document repeats guidance available elsewhere - would perhaps be better referenced instead of repeated. Because of this it comes across as a textbook rather than focusing on the special circumstances of Rushcliffe.

Disagree. Concentrates on Rushcliffe as a place, no change

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18.3 18.3 General Greater use of analysis of "village plans" and strategic visions for the future would be an asset

Comment noted. No change necessary. Conservation Area Appraisals referred to which provide greater detail and are subject to community consultation.

18.4

18.4 General Although the Manual for Streets is referred to one assumes that NCC Highways will adapt their guidance and will accept a less prescriptive approach to highway design which generally is a hindrance to residential layout.


19.1 19.1 General Agrees with the principle of the design guide. Is an excellent document. Provides a starting point for improved communication between the Borough and Parish Councils on planning issues


19.2 19.2 Section B: Settlement patterns Page 12 and Section C2: Infill development P42: The boundary or extent of a settlement should be clearly defined by Development Control to enable Parishes to refer to specific guidelines when considering applications for infill and backland development.

Comments noted. The Borough Council does not apply village envelopes. If these were to be employed they would be decided through a Development Plan Document which would be developed through the LDF process. As such it is beyond the scope of this SPD.

19.3

Aslo

ckto

n P

arish C

ouncil

19.3 Section C2: Page 29 Scale, massing and height. No reference is made in applications to the height of adjacent properties in relation to new development, therefore parishes cannot 'scale' the plans. Several applications have been permitted in Aslockton which in the Parish Council's opinion are over height and out of proportion to the surrounding properties.

Disagree. Street scene views are a requirement of planning applications and this information is publically accessible.

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19.4 19.4 General The design guide will provide the Parish Council with a good reference point when considering planning applications, however, more and better communication on planning is needed between the Borough and Parishes.

Comments noted. A Parish Forum was held on policy matters and a further Parish Forum on Development Control is scheduled for 11 February 2009.

20.1 20.1 General Agrees with the principle of the design guide. It gives a detailed, clear picture of what constitutes good design in specific areas in Rushcliffe to assist development in a way that is sympathetic to its surroundings and needs of the local population.


20.2 20.2 Section A: Excellent presentation of guidance Comments noted. Support welcomed.

20.3 20.3 Section B: Excellent presentation of guidance Comments noted. Support welcomed.

20.4 20.4 Section C1: Thoughtful details provided. E.g. sympathetic road markings and signage, avoidance of speed bumps, retention of front boundaries to properties to retain appropriate street scene while considering parking options that are more fitting.


20.5

Keyw

ort

h P

arish C

ouncil

20.5 Section C2: Excellent presentation of guidance. Agree that contemporary buildings and innovative design of new buildings can enhance a neighbourhood, rather than trying to emulate the design of the surrounding older properties. 2. Agree that infill should always be sympathetic to neighbouring buildings by design and scale, particularly as this is an important feature of development potential where green belt restricts other devt. Also agree that the green belt should be protected from devt.


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20.6 20.6 Section C3: Excellent presentation. Comments noted. Support welcomed.

20.7

20.7 Additional comments: An informative document, comprehensive, thoughtfully produced, relating strongly the local nature of Rushcliffe areas to appropriate development of the built environment to maintain and enhance what is good design in the context of this part of the county.


21.1 21.1 General. Client supports the principle of the guide as this is in line with PPS1. There is much within the Guide that the Client supports. However it is felt that some areas of the Design Guide contain a level of detail which is at odds with both para. 38 of PPS1 which advises against "unnecessary prescription or detail" and the stated approach of the SPD not to be prescriptive (page 2).

Comments noted. See responses to comments 21.2, 21.3, 21.4 and 21.5 below.

21.2

Pegasus P

lannin

g

21.2 Section C2: Page 27 Layout, Form & Space - Support reference to provision of mixed use development comprising a range of tenures, household types, community facilities and services creating the more successful and inclusive communities. Reference to large scale development looking to include compatible uses and provision of community facilities and uses also welcomed.


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21.2 21.2 Section C2: Page 27. Given the inclusion of the references in regards to supporting a balanced mix of densities (comment 21.2) it is surprising that the Council have been so restrictive in the way in which density is applied to specific locations (urban, suburban, rural) across the Borough. It is important the SPD allows for a range of densities on larger sites, from 30dph in some parts to 55dph in others. This range of densities will ensure a suitable urban design response to create a varied development. It is therefore suggested that the SPD includes a para. which seeks to clarify that a range of densities will be appropriate on larger development sites.

Agree. The following text has been inserted on page 27: "On very large schemes, involving the inclusion of district centres, schools and businesses, a range of densities will be expected with the higher densities close to centres and to routes served by robust and regular public transport."

21.3

21.3 Section C2: Page 34. Requirements in relation to layout, form and space are too prescriptive and too focused on the achievment of specific standards relating to measurements. This was a criticism of the Space Between Buildings SPG. There is too great an emphasis being placed on quantitative rather than qualitative requirements. This approach is contrary to Government policy. It is also contradictory to the stated aims of the guide (page 10). Page 3 of the SPD refers to Government guidance 'By Design'. Again the need to avoid prescriptive detail is an integral part of this guidance. Reference to a 30m seperation distance between habitable rooms is therefore considered inappropriate. Page 53 of 'By Design' acknowledges that general planning standards prescribing minimum seperation distances can frustrate

Comment noted. Reference to space standards text changed as in response to comment 2.5 above.

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the creation of attractive residential environments by denying the ability to provide privacy through careful design. References to prescriptive requirements should be removed and not form any part of the

21.4

21.4 Section C2: Page 36. Similar comments as 21.3 in relation to garden size, privacy and orientation. There does not appear to be any justification for the requirement for the private gardens of new dwellings to be at least equal to the area of the footprint of the dwelling. Flexibility should be allowed, perhaps by suggesting that if two out of a range of exception criteria are met this requirement could be relaxed. It is preferable in our view to avoid reference to requirements for garden sizes. It is sufficient for the SPD to seek to ensure an acceptable degree of privacy to the occupant. Such an approach would be consistent with Government guidance.

Agree. Text changed in response to 9.4.3. See proposed response to this comment.

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21.4 21.5 Section C2: Page 37 It is acknowledged that existing and proposed occupants have a right to adequate levels of daylight and sunlight. It is unnecessary, however, within the context of an SPD to require developers to accord with a specific guide to good practice. The Guide is not Government policy therefore it is inappropriate for the Council to require adherence to it. The SPD should restrict itself to a requirement that all buildings and spaces between them receive good natural daylight as well as adequate sunlight throughout the year.

Comment noted. Amend final paragraph on Page 37 to the following text: "Where there is doubt that this has been adequately achieved, the Building Research Establishment’s publication “Site layout planning for daylight and sunlight : a guide to good practice” by P J Littlefair will be used to test the adequacy of available daylight and sunlight for buildings and spaces throughout the scheme. Where necessary developers will be required to produce cross sections to demonstrate this. As a rule of thumb, the guide provides for unobstructed views of the sky from a window above a 25 degree angle measured from 2m above ground level. The angle may be increased if the obstruction is a continuous block"

22.1 22.1 General. Recognising that the document is predominantly focused at a local level we focus our comments on the Movement and Connection section of the SPD and how this may have future implications on the strategic road network for which the Agency is responsible.


22.2.1

Hig

hw

ays A

gency

22.2 Section C1. 1. Welcomes the promotion of integrated development through road, footpath, cycleway and bridleway networks. HA recognise that addressing local movement issues through new design approaches can erduce the impact of local trips on the strategic road network.


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22.2.2

22.2.2. Pedestrian and cyclist routes are important to new development and the inclusion of these principles is welcomed by the Agency. PPG13 paras 75-78 look at how walking and cycling can offer attractive alternatives to using the car for short journeys.

Comment noted. No change. Comment noted.

22.2.3

22.2.3. Public transport - reference to early discussion with bus operators to access provision within new developments is a prudent approach. However, the reference to financial contributions for public transport may not be appropriate in this document. This may be more appropriate in an SPD or DPD on developer contribution which would also included reference to contributions to the HA and local highway authority.

Disagree. As developer contributions are only referred to generally it is not considered that reference should be removed. It is acknowledged that Developer Requirements document would be produced separately.

22.3

22.3 General. Overall the HA welcome and agree with the content of the SPD considering the approach taken with regard to transport and movement to reflect the principles of sustainability.


23.1

Pete

r T

yers

Section C Page 27. The guide defines rural settlements as "(Consisting) of cottages and houses with farms and few or no local facilities". The guide states that this category "includes all of Rushcliffe's villages and hamlets". This is inaccurate as Rushcliffe has several larger villages which do have facilities. e.g. Sutton Bonington and Gotham. It is proposed that this statement is changed to state that "this category includes most of Rushcliffe's villages and hamlets".

Agree. Amend the text as suggested.

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23.2 23.2 Add definitions of backland development and tandem development to the glossary.

Agree. Add these definitions to the glossary.

Reclaimed building materials An additional change has also been incorporated into the SPD as a result of the recent publication of the Borough Council’s ‘Generic Conservation Area Management Plan’. This was published after the period of consultation for the draft SPD had started. To make the guidance on reclaimed building materials consistent the SPD has been amended to take into account the published Generic Conservation Area Management Plan’. The draft SPD stated: “Reclaimed materials, unless obtained from local structures, are generally inappropriate and, in any event, any advantage gained locally is invariably as a result of a loss of a heritage asset elsewhere”. This has been changed to “Reclaimed materials are generally desirable for immediate repairs to structures where a precise match is required, such as infilling a window opening. However, reclaimed materials are generally inappropriate for larger scale projects such as extensions. More detailed guidance on the use of reclaimed materials is provided in the Generic Management Plan for Conservation Areas in Rushcliffe”.

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