Summary/Notes on the SPD – The Good, The Bad, and The Ugly

Some of the content of the Supplementary Planning Document is to be praised, and some notice has been taken of the feedback in the 2020 consultation, except for the rejection of high-rise tower blocks (see our post, where 86% of responses about building heights rejected High Rise – more than 6 storeys – new buildings)

The document is divided into 15 ‘Guidance Notes’, most of which have good proposals. Then it outlines more detail proposals for it’s Areas and Sub-Areas. Please see our (slightly annotated) copy of the whole document:

Content that we find laudable:

• Section 4.4 from the NPG “well-designed places are based on a sound understanding of the surrounding context… responsive to local history, culture and heritage. Creating a positive sense of place helps to foster a sense of belonging and contributes to well-being… Well-designed places respond to existing local character….“, as it is proven that using architectural elements from the town centre heritage buildings help give a sense of place, belonging and community.
• Improving the accessibility and integration of the Palace Park to Queens Gardens

Even more detail… the actual Guidance Notes:

The Guidance Notes, to govern new buildings in the Town Centre (height, design, consultations, retrofitting, consideration of heritage buildings, provision of routes through sites, health impact, providing green spaces, sustainabilty)

• SPD guidance note 1 : – “Development proposals should provide sufficient information to demonstrate how they have addressed the six design principles set out within this SPD and specific guidance relating to the character area within which they are located”. Note, these are: Contextual (Character and Identity), Responsive (Architecture and Landscape), Connected (Movement and Connectivity), Inclusive (Access and Inclusion), Healthy (Health and Well-being), Sustainable (Sustainable Design, Adaptability and Resilience).
• SPD guidance note 2 : – “Development proposals should make a positive contribution to the setting, by identifying existing physical, natural, social and cultural assets and seeking to strengthen them in the design of new schemes in order to reinforce local identity and sense of place.”
• SPD guidance note 3 : – “The Council will seek to promote design excellence to ensure that new development achieves the highest standards of visual, functional and environmental quality to engage and inspire people, reflecting local identity, values, and aspirations… major development proposals … subject to independent design scrutiny by an appointed Design Review Panel … subject to meaningful collaboration and community engagement…”
• SPD guidance note 4: – Development proposals should establish a clear hierarchy of permeable routes and spaces ensuring that new connections correspond with existing routes to promote greater ease of movement and improve wider connectivity.
• SPD guidance note 5 : – Applicants should carry out meaningful engagement with relevant user groups at an early stage in the design process… highest standards of inclusive design, contributing to a built environment that is safe, accessible, and convenient for all.
• SPD guidance note 6 Good design can significantly improve quality of life. Development proposals should seek to promote and prioritise health and well-being… Major development proposals are encouraged to submit a Health Impact Assessment (HIA) to … including guidance produced by the NHS.
• SPD guidance note 7 Development proposals should explore opportunities to provide spaces which are publicly accessible and promote health and wellbeing. This might be in the form of public parks, squares and gardens, pocket parks, and, where taller buildings are considered appropriate, public space at height such as viewing terraces, and rooftop gardens.
• SPD guidance note 8:- Development proposals… allow for future social, economic, and environmental change … include adopting circular economy approaches to promote resource efficiency… encouraged to follow a ‘Retrofit first’ approach… to fully investigate whether existing buildings can be re-purposed (either wholly or in part) instead of demolishing and rebuilding…
• SPD guidance note 9:- Development proposals must clearly set out any positive and/or adverse impacts on heritage assets. A Heritage Statement will be required in certain circumstances, as set out in the Council’s validation requirements; all applications are encouraged to submit a Heritage Statement where the proposed development is in close proximity to a heritage asset. The level of detail should be proportionate to the asset’s importance and no more than is sufficient to understand the potential impact of the proposal on its significance.
• SPD guidance note 10 Development proposals should seek to optimise site capacity ensuring that development is of the most appropriate form and land use for the site… with a focus on quality of place over quantum of development.
• SPD guidance note 11 Development proposals for tall buildings must provide detailed justification relating to their visual, functional, environmental and cumulative impact… will be required to make a positive contribution to the townscape ensuring that their massing, scale and layout enhances the character of the surrounding area… be appropriate to their local location and historic context, including taking account of ‘Views of Local Importance’; the view of Keston Ridge from southern section of Bromley High Street (looking south), and the view west and south from Martins Hill…
• SPD guidance note 12 Development proposals should link with existing pedestrian and cycling key routes, and should seek to improve these routes or create new routes where appropriate (particularly major developments)… east-west routes will be a particular priority…
• SPD guidance note 13:- Applicants should demonstrate how their development proposals enhance the ecological richness of the local environment… to achieve a biodiversity net gain. Proposals near to existing green and open spaces…to enhance biodiversity and create a joined-up sequence of functional, publicly accessible green spaces through the town centre and beyond.
• SPD guidance note 14:- The London Plan sustainable infrastructure policies must be addressed in full, with provision of detailed and timely information… same principles apply to refurbishments of existing buildings as to new buildings… replacement of a building should reuse demolition materials on site… The comfort of users should be a key part of designing development proposals, minimising the need for heating or powered cooling in particular.
• SPD guidance note 15:- Where considered necessary to protect the vitality and viability of the town centre…planning conditions will be used to remove the provisions of Use Class E and to remove specific permitted development rights… therefore limiting the ability to change…to residential use.