o Update on Local Plan key policies
The Partnership received a presentation from Ian Drew, LBB Urban Design Officer, Ben Johnson, LBB Head of Planning Policy and Strategy and Ben Terry, LBB Urban Design Officer, providing an update on the Urban Design Guide and Bromley Town Centre Supplementary Planning Document (SPD). A copy of the presentation is attached at Appendix A.
The Urban Design Officer highlighted the following points in relation to the scope and purpose of the Urban Design SPD:
- Supplementary Planning Documents (SPDs) built upon and provided more detailed guidance on policies in the Local Plan. SPDs could not introduce new policy but were material considerations in determining planning applications.
- The purpose of the document was to provide clear design guidance to inform and engage developers, architects, planners, and all other parties who had an interest in bringing forward development proposals in Bromley.
- The document set out the key principles for achieving good design with the aim of significantly raising the quality of development in the borough.
- The document was not a Design Code and did not set specific parameters but aimed to provide an overarching vision outlining key design principles that should be followed.
- The aim was to promote good design for buildings, landscape and public realm, establishing the desired characteristics for successful places and providing a quality benchmark for how new development should look and feel.
The document was divided into the following five sections:
1. Introduction (purpose and status)
2. Planning policy framework / planning application process (overview)
3. Character appraisal (understanding Bromley past and present)
4. Principles of good design (key design principles for Bromley)
5. Design guidance (application of key design principles)
It was noted that section 4 introduced six key design principles which were considered to be essential for delivering good design:
- Contextual – Character and Identity
- Responsive – Architecture and Landscape
- Connected – Movement and Connectivity
- Inclusive – Access and Inclusion
- Healthy – Health and Wellbeing
- Sustainable – Sustainability, Adaptability & Resilience
These principles were also included in the emerging Town Centre SPDs for Bromley and Orpington and aimed to adopt a consistent approach, or “golden thread”, across all design guidance. The borough-wide Urban Design SPD sat alongside the Town Centre SPDs, and its content would inform an integral part of the Local Plan review and future workstreams such as characterisation studies, site capacity assessments and design coding. The Urban Design SPD was a comprehensive document which demonstrated the commitment to improving design quality in Bromley.
The LBB Head of Planning Policy and Strategy informed members of the Partnership that the Bromley Town Centre SPD consultation had launched the previous week. This was an emerging document which provided guidance for development within Bromley Town Centre. The document set out the relevant local, regional and national policy frameworks which underpinned the guidance and referenced the six “golden thread” key design principles previously mentioned. The SPD divided Bromley Town Centre into a series of character areas (Bromley North, West, East and South, and further sub-areas) which were derived through context of the wider area and represented those parts which were considered to have similar characteristics. General guidance notes were provided which were applied consistently across the areas including density, tall buildings and sustainability. For each of the sub-areas detailed design considerations were provided in terms of guidance on building heights, public realm and green connections. A plan was also provided for each sub-area which visualised the guidance.
The LBB Head of Planning Policy and Strategy advised that the consultation on the Urban Design SPD would run until the 9th December 2022, and the Bromley Town Centre SPD until 27th January 2023. It was highlighted that any feedback on the documents would be welcomed, and the SPD consultations could be accessed via the following link: https://www.bromley.gov.uk/planning-policy/supplementary-planning-guidance
The Chairman encouraged members of the Partnership to view the SPDs as it was important that a wide spread of voices was gathered to inform the final documents. It was noted that the consultation on the Orpington Town Centre SPD had closed in July 2022. In response to a question from the Chairman, the LBB Head of Planning Policy and Strategy advised that nearly 1,000 consultation responses had been received – officers were working their way through these responses, which was a big undertaking, and it was anticipated that the final document would be adopted in spring/summer 2023.
In response to questions from Lee Thomas – Fairlight Group, the LBB Head of Planning Policy and Strategy emphasised that the SPDs could not create new policies – steps were taken within the SPDs to try and encourage certain uses, but this was not binding. Residential use was suitable in town centres; however they had looked to balance this with other uses as far as possible. The introduction of Class E provided flexibility and, if a suitable commercial use was identified for the ground floor, they were unlikely to discourage residential use on upper floors. It was noted that the Local Plan review could be used to try to influence uses, but this was not guaranteed. The Chairman advised that funding for the revision of the Local Plan had been approved and evidential studies would soon be starting. The SPDs provided a clear direction of travel which would be reinforced in the Local Plan. The LBB Head of Planning Policy and Strategy highlighted that the review of the Local Plan would be a lengthy process – however the Plan would gain weight throughout, and they would not need to wait until the final version was adopted to start using the document in planning determinations, albeit the weight given to emerging policies would be reduced.
In response to questions from the Vice-Chairman, the LBB Head of Planning Policy and Strategy advised that the SPDs would be a ‘material consideration’ when planning applications were assessed. In terms of how the Local Plan was progressing, members of the Partnership were advised that a ‘call for sites’ had been undertaken. This was the preliminary stage of the process but, as the budget for evidential work had been approved work, would move forward at pace. Consultation responses would be invited throughout the process, with at least two further rounds of consultation planned. The Vice-Chairman said that research had been undertaken by London Biggin Hill Airport, looking at things such as their clients’ businesses and growth plans. The LBB Head of Planning Policy and Strategy said that there were various considerations to be taken into account and they would welcome the submission of any research produced by London Biggin Hill Airport as part of any future consultation exercise.
Mike Humphries – Handelsbanken enquired if the SPDs would apply to existing planning proposals, and whether they would apply to developments over a particular size. The LBB Head of Planning Policy and Strategy advised that the SPDs did not have emerging weight and would only become a relevant consideration once adopted. In principle, both SPDs would apply to any scale of application – with regards to the Urban Design Guide, the scale of the application may influence the amount of information that they would expect to be provided. In response to a question from Zoe Carr – Penge SE20 BID Company, regarding an application that would soon be submitted for a large development in Penge, the LBB Head of Planning Policy and Strategy advised that if the Urban Design Guide was adopted by the time the application was determined it would be a relevant consideration. The Urban Design Guide was a tool aimed to improve design and quality, and pulled together existing national and regional guidance and best practice and this information could be used to inform an application.
Russell Clarke – Sundridge Investments Limited noted that no potential sites had been identified within the SPDs. The LBB Head of Planning Policy and Strategy advised that the SPDs could not allocate sites – however guidance on existing site locations within the current Bromley Local Plan had been included, as well as potential opportunities that had come forward since. Mr Clarke noted that, due to the recent pressures around town centre allocations, the SPDs would be important documents. From experience, it was requested that the Urban Design Guide was not made too prescriptive as it was considered that it could be used by objectors to frustrate developers. The LBB Urban Design Officer said they were mindful of not being too prescriptive, but stressed that the document was not a Design Code. The purpose of the document was not to set strict parameters, but instead provide key principles – it was left open for architects to be creative whilst quality was ensured. Gary Hillman – N. Hillmans & Sons echoed Mr Clarke’s comments and questioned if there was any weight on the commercial and economic benefits, or just the visual aspects, of a development. The LBB Head of Planning Policy and Strategy advised that economic benefits were a material consideration, but so were building designs within a Conservation Areas, and it was about achieving a balance.
Mr Thomas considered that the positives should be taken from the SPDs, and worked with, as he believed they may be beneficial in the long run. In response to a question, the Chairman noted that there were a number of vacancies in the Planning Department, which they had looked to address. A third party had been tasked with processing some of the planning applications, but had also struggled to recruit promising more resources than they were able to provide. The LBB Head of Planning Policy and Strategy advised that this was an issue across the country. Liz Lakes – London South East Colleges informed members of the Partnership that, in collaboration with Bromley Council, they would be holding a borough employment event in January 2023 for ‘hard to fill’ positions, and the need for Planners would be highlighted to the organisers. Mr Thomas emphasised the need for members of the Partnership to be positive and proactive in encouraging people/businesses to come to Bromley. Mr Clarke considered that having planning staff back in the office would also have an effect, and suggested that planning officers could be shadowed by a trainee.
The Chairman thanked the LBB Head of Planning Policy and Strategy and Urban Design Officers for their presentation to the Partnership.
RESOLVED that the update on the Urban Design Guide and Bromley Town Centre SPD be noted.