6.5 Planning Briefs, Design Briefs, Concept Statements & Masterplans

1.1
There may be some confusion in this paragraph - this is an SPD Guide and is 'one of the documents that form the planning policy of the town'. It is therefore policy, it is not guidance, or advice or negotiable and is an approved document. However this paragraph then confuses the issue by stating that 'the purpose of the guide is to provide guidance for developers...' An open invitation to lodge an appeal against a refusal perhaps?
1.1.3/8
We support the definition of good design although our experience is that this is an elusive commodity.
1.1.3/9
We strongly support the intention that 'all new development will have to demonstrate (our emphasis) that the proposed scheme is a high design or it will not be considered acceptable' Again our experience is that this may prove to be problematical but it is clearly better 'in than out'.
1.1.5
We support this commitment to good design.
2.2.3/42
This checklist appers to be based on a traditional housing estate model with vehicular access to the front of the property. Undercliff Gardens does not fall into this category - it is a unique area where access is restricted to pedestrians. We would like to see a small amendment to this paragraph to include such non-conforming areas and developments.
2.2.3/43
This seems a potentially dangerous exception - a planning weakness can be a developer's strength. Who is to decide?
2.3.1.4/59
We suggest that there should be presumptions against conversion to so called chalet bungalows that include the use of dormer windows.
2.3.2.1/80
This paragraph is of fundamental importance to this Society. We suggest that there should be a modest adjustment so that the 3rd sentence reads 'Generally new buildings should respect the established building frontage lines, or line of building, however...'

We are pleased to see that the Guide reinforces the importance of this policy (not guideline) in Para 2.3.4.2/107 by stating 'building frontage lines should be respected'.

Again in Para 2.3.4.3 there is more reference to building frontage lines being respected in order to protect the established street pattern.

However there appears to be no reason why the traditional 'building line' has been changed in this Guide to 'building frontage line'. for the avoidance of doubt we understand the two phrases to have the same meaning which is established in law 'an imaginary line drawn parallel to the highway at a specified distance from the back of the footpath, the dimensions being specified by the local planning authority as part of their overall responsibility for development control. No building or part of a building may be erected between the building line and back of footpath'. This view is supported by the fact that para 2.3.2.1 includes both phrases in a single sentence. We also rely on the Council's own BLP policy document C12 which states 'the preservation of Undercliff Gardens south of the building line as an area free of vehicular traffic and parking' it does not say 'south of the building frontage line'. We therefore suggest that 'building line' should be used throughout to avoid confusion.
2.3.5.4/141
This is an important restriction on conversions. We should like to see clarity on percentages of family homes to be retained - lack of clarity has been used on appeal in some cases (including Undercliff Gardens)
4.8/250
Permitted development was changed on the 1st October 2008 by the introduction of Town and Country Planning (General Permitted Development)(Amendment)(No 2)(England)Order 2008. We presume Article 4 Directions will reflect this in due course, although it should remain as policy that there is a permanent restriction on permitted development in Undercliff Gardens.
5.1.1/254
We suggest that all materials should be permanent and short term poor quality materials not used.
5.2.2.1/346
We suggest that the 3rd paragraph should be change to '...where new balconies are proposed...it does not extend in front of the building line, and that the privacy of neighbours is not compromised'
6.2.1/399
In our opinion many planning applications fall short of an acceptable standard, and yet they are frequently accepted in the interests of speed. We suggest that details of all proposals should be clearly shown and that all planning applications include:
a. New and existing ground levels on all elevation and sections
b. Partial elevations of all adjoining properties.
3. Sufficient details to enable a decision to be made.
6.5/480
We would like to see a design brief, reflecting this Guide, prepared for Undercliff Gardens in view of the importance attached to its protection.
OTHER COMMENTS ON SPD 1
A. Grand Parade
Most of the above comments relate to the impact of this document on Undercliff Gardens.
However all plots extend to the north of Undercliff Gardens so that they front Grand Parade. In other words each plot possesses two frontages. It is obvious that clauses. i and ii of policy C12 were drafted with the Grand Parade frontage in mind, whereas clauses iii, iv and v relate to Undercliff Gardens. We suggest that this conflict needs addressing. Policy C12 is out of date in other respects and we have offered to discuss a revised policy document with the council (see our letter dated 9 July 2008). We are aware that it is the council's intention to eventually prepare and adopt a more up to date policy C12 (see your letter dated 7 June 2006).
Appendix A3.19 to C12 addressed many of the design problems referred to above but it has not been saved. We suggest that it might be re-visited in due course when C12 is up-dated.
B. Programme and Policy
As you are aware, this Guide has been under discussion for a very long time. Our understanding is that it is a policy document and therefore it is vital that applicants and residents alike have confidence that all planning matters will be covered by this important document as soon as possible.
C. Patio's and terraces
Hard landscaping is an essential element in any development but in Undercliff Gardens it makes a significant impact on the environment. The use of retaining walls, paving materials to be used, levels and relationships to buildings all need considering - Part 5.1.3/272 - 275 is very brief and could be expanded in this direction to advantage.
D. Planning Applications Generally
It would seem that the Council have recently adopted a more flexible attitude towards applications. It is not uncommon for an application to include the briefest of information which is then approved in principle, subject to details being approved. As we are not consulted when an application for approval of conditions is lodged (e.g 09/0455/ad - 102 Undercliff Gardens) it follows that approval of important details is a matter for negotiation by officers without consultation. Hopefully this Guide will remove the need for such procedures.

A) Summary
Much of the content of this document accords with Natural England's aspirations for the built environment. There are two main points:
Natural England commends the use of Concept Statements as a quick, effective and participatory tool to produce the basic development principles for individual sites to guide the ensuing master-planing process. We note that these are finally mentioned as a possibility in 6.5 but not as a requirement, as many other councils are requiring, either for all development sites or at least for key sites that require a masterplan. We would be happy to provide further information on this.
Natural England recommends the adoption of ANGSt standards to determine the size and nature of new open spaces.
The ANGSt standards as currently defined and recommended for adoption in PPG17 are:
Every home should be within 300m of an accessible natural greenspace of at least 2ha plus.
At least one accessible 20ha site within 2km
At least one accessible 100ha site within 5km
At least one accessible 500ha site within 10km
The original English Nature ANGSt model also included provision of at least 1ha Local Nature Reserve/1000 population.
Natural England would also like to see a clearer statement regarding Southend's 'Greengrid' to which the document refers. This seems to be merely an aspiration rather than a strategy and it is unclear how this fits with delivery of the South Essex Greengrid Strategy.
B) Specific comments
1.3.2 Commitment to Urban Renaissance and Thames Gateway
12. Natural England welcomes the recognition of the need to identify and enhance sense of place.
13. Natural England assisted the development of the CABE Design Pact and welcomes its proposed use.
1.3.4 Commitment to the Environment
16.
Create a 'Green Grid' of high quality, linked and publicly accessible open spaces across the town, linked to the rest of the sub-region as appropriate - Natural England would welcome clarification as to how this will be achieved.
Protect and enhance both the natural and leisure environment and setting of the River Thames - Natural England welcomes this statement of the Council's commitment.
Provide for the effective management of land on the urban fringe - the interface between town and country - to provide an effective community resource and setting that enhances and protects the Metropolitan Green Belt - Natural England welcomes this statement of the Council's commitment.
1.3.5 Commitment to Good Design
Natural England commends the use of Concept Statements as a quick, effective and participatory tool to produce the basic development principles for individual sites to be used in the ensuing planning process for example to guide the master-planning process. We would be happy to provide further information on this.
1.5 How to Use the Guide
24. The Building for Life Standards are good but are not necessarily quantitative enough.
2.1 Overview of Southend on Sea Borough
30. These are excellent aspirations. Concept statements for individual sites would assist in ensuring that they are achieved.
2.2.2 Topography and Natural Features
34. Natural England recommends the adoption of ANGst standards so that an appropriate amount and type of greenspace is incorporated into new developments. We also would wish to see that every effort is made by new developments to create/enhance linkages from this greenspace to those in adjoining sites and the wider countryside i.e contributing to Thames Gateway South Essex Greengrid principles.
2.3 The Design Concept
2.3.4
The aspirations in this section are excellent; but very lengthy and may not always be achievable. A concept statement produced quickly easily and cheaply at the very outset of the planning process can provide that essential set of development principles to guide any ensuing process.
2.3.4.4 Public Realm and Urban Design
Public Open Space
113. Natural England would wish to see more definitive wording than 'meaningful area', 'large enough' etc - ideally through the adoption of ANGSt standards.
116. In addition to the requirements stated in this section, Natural england would also wish to see aspirations to provide links to adjacent greenspaces in order to assist delivery of Thames Gateway South Essex Greengrid.
3.12 Biodiversity
182, 183 184 and 185 Natural England welcomes this section.
5.1.3 Landscaping
Soft Landscaping
269. In addition to seeking to 'plug the gaps between the borough's existing habitat links and greenways', provision of greenspace should wherever possible contribute to the Greengrid.
270. It is essential that management and financing of landscaping and biodiversity areas is planned in to the proposals from an early stage.
5.2.1 Amenity Space
It is regrettable that no minimum standards for this have been included.
6.5 Planning Briefs, Design Briefs, Concept Statements and Masterplans.
480. Natural England commends the possible use of concept statements but would prefer a policy which made them a requirement at least for sites requiring a masterplan, if not for all development sites.