Design and Townscape Guide - Refresh 2009 (Consultation Draft)

Representation ID: 216

Received: 09/06/2009

Respondent: Inspire East

Representation Summary:

Mixed-use is key to substainability
Within Section 3 - Sustainable Development and Design there is a sub-section on the benefits that a mix of uses can bring to a development. However, this appears too late in the section, after issues such as water recycling. Mix of use is one of the most significant ways to deliver environmental, social and economic sustainability and as such, needs to be brought upfront in this section. For example, a further sub-section is on maximising travel choice and this can only be realistically achieved through mixed-use development.

Full text:

There is support from Inspire East for what is a very comprehensive document covering all the main policy areas and subjects that need to be addressed if high quality and design and townscape is to be delivered. The inclusion in the refreshed edition of sections dealing with intensification, tall buildings and pavement cafes are significant and are key amendments that are welcomed.
Inspire East would also wish to support authority in undertaking the refresh process. Too often policy and guidance is left too long before being reviewed leading to the need for substantial reworking. Regular monitoring and review such as this is efficient and leads to a better policy framework and better decision making. There has clearly been a great deal of effort from officers and members to produce this work and ensure it is embedded into the local, regional and national policy framework. This is commended.
However, the comprehensive nature of the work gives rise to the document's main weakness, a degree of complexity that can often make the document confusing and quite difficult to read effectively. Strict editing and streamlining is required to tackle this main concern. In doing so, the Council will have a much sharper planning and design tool which will influence more of the agents for change that shape and make the places in the Borough.
A further weakness is in the inclusion of the movement and access section towards the back of the document (para 277-286, page 72-74). This is a subject of design that has substantial infuence on the success or failure of a scheme yet it does not have the prominence it requires. Moreover, the guidance appears quite dated and is unlikely to deliver the desired balance between places for people and places for cars that so much recent design guidance (at national, regional and local level) seeks to create. Inspire East is willing to review the guidance specific to access and movement in greater detail if the Council feel this would be useful.
The lack of illustrative material in the consultation draft (i.e text only, no photos) has made response more difficult to prepare than otherwise. Inspire East would therefore like to see a more fully formatted version at a later date prior to adoption by the Council.
Identify and acknowledge the changes
The final adopted version of the refreshed document will benefit from very short foreword or similar setting out the differences between the new document and the original version, together with a brief explanation as to why these particular changes have been introduced as part of the refresh. It would be good if this foreword is written by an elected member who is also the design champion - if this role is identified withing the Council - as it will add significant political weight to the guide.
Be positive and visionary
The foreword should also set out the aims and objectives of the guide, a statement about the qualities of the Borough and who the intended users of the guide are (i.e. who should read this and why). This message should be uplifting, visionary and sound a positive note and send a message that the Council wishes to encourage high quality development. While there is some inspiring writing on page 6 of the draft under secion 1.3, this is too far into the guide to convey the necessary uplifting start. Also, while the purpose of the guide and how to use it are explained on page 8, they are expressed in purely practical terms, are too far into the guide and therefore easy to overlook. This also duplicates with a brief set of aims and objectives set out in para 1.1 on page 1.
Demonstrate practical value
The inclusiion of some case studies would add value to the document. Can officers identify high quality developments that have been planned (and ideally, built) since the original publication of the guide in June 2006 that were directly or indirectly infuenced by the guidance? These case studies would add interest, demonstrate a practical value and show where and how the guide has made a difference. A case study that can demonstrate the lift in economic value that can be generated though good urban design will be of particular interest to developers and agents who will read and use the guide.
Document Structure
The main weakness of the consultation draft is the complex document structure comprising a hierarchy of six main sections, within which are main headers, sub-headers, sub-sub-headers, various bullet point lists, extracts from national, regional and other local policy (often quoted with their own organisational structure). The result is a paragraph numbering system that at times is four digits long (i.e This makes the document difficult to access and read. While each topic area needs to be covered in its own right, a good design guide should also have a general narrative arc that engages the reader/user and tells a compelling story about why good design is important, the quality of life it can help sustain and the design process - with a beginning , middle and end - through which it can be delivered. Crucially a design guide should 'demystify' and while not over-simplifying, it should explain clearly and precisely to non-designers alike what is required, why and how. The complexity of the document structure obstructs the good messages trying to get out. It is therefore suggested that the number of sub-sections are reduced significantly and that the number of main sections is increased from the current six. Paragraph numbering can be retained for ease of reference but the inclusion of an alphabetical index at the back to allow users to quickly look up the details that they need to find may remove the need for much of this. The result will be sharper, clearer text that sits more cleanly on the page and sections that flow more easily.
Too many quotes and cross-references
The regular appearance of, 'see also...'and, 'policy link...' while no doubt useful, also begin to clutter the document somewhat. Consideration should be give to how these references can be rationalised so as to not interrupt the flow of the main text. Techniques to consider may be a 'box-out' graphic at the end of each section accompanying the checklists. It is also felt that the document quotes national, regional and local design policy too often and often in substantial sections (e.g. pages 22-23 repeats a substantial section of Guidance on Tall Buildings by CABE 2006). Again, consideration should be give to where and when these quotes can be rationalised to the benefit of the document. Repetition of national, regional or other local policy should occur only when absolutely necessary and, when it is considered necessary, the quote should be a short as practicable.
Page layout
It is noted that page layout on the consultation draft consists of one wide column of text. This is not the easiest of layouts to read. However, it is also noted that the adopted document is formatted as two narrow columns of text per page, with supporting graphics and illustrations. This is much easier to read and the Council is encouraged to adopt a similar page layout for final adoption to make to document as engaging as possible.
Illustrations, photos and graphics
It is noted that the consultation draft is currently devoid of graphics and illustrations but that the final version is likely to have a substantial amount, reflecting the currrent adopted version (June 2006). This is to be encouraged. It is recommended that in the refreshed version even more emphasis is placed on illustrative material than in the original version. Clear diagrams, graphics and photographs illustrating good practice and techniques will not only make the document more engaging and practical in its application, but will also assist the editing process and the streamlining of the document, allowing for some text to be removed and making it more accessible still.
Understanding the context
The background and history of the Borough and its settlements, local character and identity is currently addressed in para. 27-30. This is generally descriptive and while it goes some way to 'setting the scene' for those reading/using the guide, more could be done by the Council here to express the qualities and identity of the Borough as it sees it. This is an opportunity for the Council to set the agenda in terms of a vision to which developers and their designers can respond.
For example, para. 30 states that,' is essential to preserve the diversity of the town and the distinctive characters of each area'. Yet how does this diversity manifest itself and what are the particular qualities of each area? The Council should consider the inclusion of plans, maps, photos and diagrams here to give developers and their designers a 'head start' in understanding the context. This will inspire confidence in potential investors if the Council can be seen to demonstrate an understanding of its own patch in this way. Such a section should also be made more prominent, though its own section or similar, and be introduced early. It should be remembered that many developers and designers working in the Borough are often from outside the local area, sometime from outside the region, and this sort of expression of the local character by the authority is therefore often useful.
Policy context
Sectiion 1.1.1 sets out the policy context within which the guide sits but this takes five pages. Consideration should be give to how this can be edited and reduced so that only the essential policy information necessary to allow the document to be endorsed/adopted is included.
Design principles - from large scale to small scale
It is recognised that there is a general logic to the sequence in which the issues in Section 2 - Design Principles section are addressed, starting out from a site appraisal and wider area analysis (large scale) zooming down to site level detail (small scale). This is commended and reference should be made to the fact that the order in which a developer tackles these issues in their project program should reflect the order set out in the guide, and for good reason. For example, it is little use to carefully detail the streets and spaces if the layout does not effectively connect the development with its surroundings. In short, there is a need to get the 'fundamentals' right before moving on the the 'detail'.
It is therefore suggested that this section is reviewed to see if adjustments could be made to the running order and sequence to strenghten this logic. Certain issues, such as Density (para. 48) seem to appear too early while others, such as Sense of Place (para. 100-101), Continuity and Enclosure (para. 110) appear too late. Also, issues that need consideration but are only indirectly linked to the sequential process of developing design principles, could be removed completely (e.g Airport Safety Zones, para, 77) to increase clarity and reduce complexity.
The 'design concept' sub-heading
Secion 2.3 is called the Design Concept but this title does not add any usefulness to this or the following sections. It is also quite confusing as the topics that sit under this title are just as comfortable under the overall heading of Design Principles. It is therefore recommended that the title Design Concept is deleted to assist in clarity and reducing complexity.
A distinct section on sustainability
It is noted that by dedicating Secion 3 to Sustainable Development and Design, the subject of sustainability gets increased prominence and recognition. However, sustainability is inherent in all good design (a point that needs to be noted at the very start of this section- and it could be argued that the contents of this section could be effectively subsumed into other sections to the benefit of streamlining the whole document.
There is inevitable overlap between elements of this section and other parts of the document. Examples include para. 138-144 'Conversions' and para. 150 'Redevelopment or Refurbishment'; para 90-93 Layout of Buildings and Spaces and para. 157 'Site Layout and Orientation'; para 55 'Flexibility' and para. 155-156 'Flexibility'.
If the Council wishes to retain this dedicated section on sustainability it is recommended that a series of checks and edits are made to ensure any overlap is reduced to the minimum and that where overlap does occur, clear and distinctly different messages are being conveyed by each section.
Mixed-use is key to substainability
Within Section 3 - Sustainable Development and Design there is a sub-section on the benefits that a mix of uses can bring to a development. However, this appears too late in the section, after issues such as water recycling. Mix of use is one of the most significant ways to deliver environmental, social and economic sustainability and as such, needs to be brought upfront in this section. For example, a further sub-section is on maximising travel choice and this can only be realistically achieved through mixed-use development.
Maximising solar gain
Site orientation to maximise of passive solar gain is raised in para. 157 as a means of reducing the need for artificial heating. However, with temperature increases brought about through climate change, the need to minimise the need for artificial cooling is likely to be a more a pressing issue in terms of sustainability. Maximising solar gain may exacerbate this problem and this paragraph should be reworded to reflect the balance required.
Access and movement, not highways and roads.
Under heading 'New Public Roads', para. 279 states that, '...roads are classified as either distributors or non-distributors in the Local Transport Plan'. This classification is unhelpful and recently published national guidance Manual for Streets (DCLG, DoT 2007) is critical of such a definition. This guide states in para. 2.2.3 that such a split between road types has led to, '...layouts where buildings were set in the space between streets rather than on them and where movement on foot and by vehicle was segregated... many developments constructed using such layouts have had significant social problems'.
Also, para. 279 of the consultation draft also makes reference to Environmental Improvement Areas - the areas between distributors. This is vague and required further clarification.
Terminology and language is important, as are definitions and the way in which they are supplied to the policy context. There has been a substantial shift within street design policy and practice in recent years and the design and townscape guide needs to reflect this through the refresh process. Para. 277 of the consultation draft is an encouraging start to this section in the way it refers to the needs of all users, not just vehicles, but is then let down by subsequent sections.
The Council are therefore strongly urged to develop a fresh set of design guidance for streets and spaces - not roads and highways - that reflect current thinking, as found in Manual for Streets.
Need for greater flexibility over adoption
The first sentence in para. 280 encourages imaginative highway designs, with high quality materials and the, ' possible highway designs' yet the very next sentence states that such design will not be suitable for adoption. This appears unreasonable as there should be little or nothing to prevent a 'best possible design' being adopted. This message is not encouraging for those developers that wish to be more imaginative with their streets and spaces in order to add environmental, social and economic value to their schemes. They are likely to be dissuaded from pursuing such ideas if they are told from the very outset that their design are unlikely to be adopted. A much more positive and encouraging form of words is required here and an offer to work with developers to find the best solution.
The guide states that the Council is prepared to adopt new roads to, '...allow for the free flow of pedestrians or vehicular traffic'. This ignores the wide range of uses to which streets are put and assumes the 'place' function is subservient to the 'movement' function, which is not automatically the case. More on this balance between 'place' and'movement' can be found in Section 2.4 of Manual for Streets and the consultation draft should reflect the concept of finding a particular balance between these two key functions on a street by street basis.
Sections 11.7.9 - 11.7.18 of Manual for Streets set out guidance on adoption. It encourages local authorities to be more accomodating of imaginative designs. The Council are therefore requested to look again at the relevant parts of the consultation drat in light of this advice.
Cycle tracks as a last resort only
Reference is made to the inclusion of new pedestrian and cycle links to and through new developments in para. 283-284 yet this does not recognise that these types of movement patterns are best accommodated within a well-connected street layout that caters for a range of travel choices (see para. 4.2.4 and table 4.1 of Manual for Streets.) The creation of dedicated infrastructure for pedestrians and cyclists is usually a less than satisfactory approach and a reflection that the main street network fails to accommodate their needs effectively. This section should be redrafted to reflect current thinking. Para. 6.4.1. of Manual for Streets states that cyclists should generally be accommodated on the carriageway and in areas with low traffic volumes and speeds there should be no need for dedicated cycle lanes. The refresh process needs to reflect this thinking for the new design and townscape guide.
Too much parking guidance, not enough on streets
The consultation draft contains five and half pages on parking yet only two pages on street design. The emphasis here appears imbalanced and the Council should look at how this can redressed.
Pre-application discussions
It is very encouraging to see reference to the need for pre-application discussions (para. 398, page 103) and this is welcomed. Inspire East would like to see more made of this section as it is widely acknowledged that successful pre-application discussions often lead to better schemes. Issues to include in a revised section would be: how to go about booking a pre-application discussion, which technical officers should be present, who co-ordinates and arranges the attendees and chairs the discussion (officers or developers), how many times the teams can meet with officers prior to submission, whether or not any fees are required and what the aims of the discussion should be.
On the last point, consideration should be given for setting out in the guide the issues that a pre-application discussion should focus on, namely the fundamentals of place payout, mix of uses, access, and scale and massing. Issues such as materials, colours, textures, paving details and soft landscaping should not be discussed until broad agreement has been reached on the more essential structuring elements.
What to include
The guide states in para. 406 that additional visual representations, such as street scene drawings, level diagrams and sections, while not a statutory requirement, may be requested. Inspire East would like to see the majority of applications include such drawings as they greatly assist the determining authority but also their production creates a 'check' within the design process for the developer's team which can often lead to revisions in the scheme prior submission. An agreement on the type of drawings considered necessary should be part of a pre-application discussion.
Design awards
Inspire East is encouraged to see that the Council run a Design Award scheme to recognise and reward good design. However, this is tucked away at the back of the document (para. 479). Instead, this should be brought forward and made more prominent (perhaps as part of the foreword) to help demonstrate the Council's commitment to design quality.
Historic environment
While there is a specific section on issues surrounding the historic environment (Section 4), some guidance relevant to the historic environment can be found in other sections. For example, resource minimisation and renewable energy generation (para. 153 and 169 respectively, both in Section 3). There needs to be consideration for how all guidance specific to the historic environment can be brought together in one section. Given the way the guide will be used by developers, this may prove to be more practical (e.g a particular site is in a Conservation Area or not; a property is a Listed Building or not and so all the guidance will or will not apply.
Other comments
Paragraphs 112-116 (page 31-32) fall under the sub-heading 'Public Realm and Urban Design' but this should be reworded to simply read 'Public Realm' as the term urban design is more correctly used to reflect the totality of the issues that the guide covers.
Paragraph 165 (page 44) states that the Council's primary drainage concerns are associated with highways. This is not perhaps the message residents and communities within the Borough wish to read. It is suggested that this paragrah is reworded to place emphasis on effective drainage to protect homes, communities and businesses rather than just on highways.
Paragraph 167 (page 44) lists a variety of SUDS techniques and this will be greatly enhanced by a corresponding series of photos or diagrams to illustrate each type.
Section 4 (page 54) should read 'Historic Environment', not 'Historical Environment'.
Paragraph 195 (page 55) on enabling development to fund the restoration of the historic environment should be included later in this section. Issues on works to Listed buildings, the Local List, Conservation Areas and Archaeology all come after this and it is felt these should be given more prominence by being addressed earlier.
Southend on Sea is now a cycling demonstration town (para. 89, page 26) - more needs to be made of this. Inspire East would expect words to the effect that additional efforts should will be required by developers and their design teams to assist the Council in its aims to see a significant incrrease in levels of cycling. This status places greater emphasis on the need to improve the sections of design guidance relating to streets and spaces (mainly para. 277-286).
The section of guidance for pavement cafes (para. 381, page 94) should include options for locating seating further out from the building line (e.g in a central block of seating serviced by waiting-on staff from the adjacent premises) to reduce any impediment to the flow of pedestrians along a shopping street. This is successfully done elsewhere in Europe and allows non-retail uses to mix more effectively side by side. Reference to 'continental style umbrellas' (third bullet) required clarification.
Not all satellite dishes are necessarily unsightly (para. 395. page 99) so reword to say 'are often unsightly'. Also, para. 396 suggests that a dish should respect the character and architectural features of a Conservation Area yet this will be difficult to achieve simply as a result of the newness of the technology relative to the age of the Conservation Area. Location and angle of the fixture is usually driven by technical requirements and the guide needs to acknowledge this too. Para. 397 suggests blending the colour of the dish with the background as a means of reducing visual impact but a black or very dark colour is likely to be the least conspicuous, no matter what the background colour may be.
The list of additional supporting documentation that may be required (para. 408-478) is substantial and does not necessary add to the main point of the document, which is achieving high quality design. This list could perhaps could be removed but more made of what the Council would like to see in terms of Design and Access Statements (DAS), in particular the process undertaken and the rationale and reasoning behind a design. The DAS is a potentially powerful means to lifing design quality and helping the planning process support good design and reject poor design. Only minor references to DAS are made in the document (final bullet, para. 399) and this should be strengthened.
Inspire East is happy to discuss further any of the issues and comments raised in this consultation response with the authority. Inspire East wishes the Council well with the refresh process and look forward to working with it again in future.