HBF wish to make the following observations about the Wiltshire Design Guide:
- It is not possible for the SPD to provide guidance for any Policy in a Local Plan that has yet to be adopted. Page 5 of the document need amending to remove this suggestion.
- HBF suggest the document should instead refer to the need for it to be reviewed post adoption of the New Local Plan.
- HBF is concerned that this Design Guide is in fact introducing policy, rather than providing explanation of current adopted policies. This is not the role of a Design Guide.
- For example, the mix type and tenure of homes needs to be considered in Local Plan policy making not through design guide.
- Similarly, decision on density should be made through the Local Plan, which is the appropriate place to consider the viability of any design requirements and weigh them against other policy considerations, such as Affordable Housing percentages and the need for public open space, SANGS, SUDS, BNG etc.
- It is crucial that any design requirements are considered alongside other policy requirement, which themselves need to be considered as part of the wide understanding of the deliverability of Local Plan.
- It is not appropriate to set out what are effective policy choices around design in a Design Guide or SPD that is then expected to inform the Local Plan. The Local Plan and its policies have to come first.
- And also, without specific paragraph numbers throughout the whole document, it will be difficult for developers, planning officers, councillors and members of the public to easily reference the document. Please add appropriate paragraph numbering to all the sections please.