In recognising the need for the creation of high quality developments, the NPPF states that "plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable." Draft Policy 15 provides design considerations, design criteria and key questions to be addressed. It does not currently provide a clear design vision. We agree that design guidance is fundamental to the planning and

* Character We request that the following key question is added: 'Does the proposal maximise "place making" in which public realm and pedestrian spaces have prominence over parking, roads and servicing?' * Working with the Site and its Context We request the following design criteria are added: 'Proposals must demonstrate a thorough understanding and analysis of the character of the setting, identifying significant aspects, and demonstrate how the proposals respond to that analysis. Proposal

There seems no reason to increase bureaucracy with a Design Panel.

Policy 15 not only seeks to resist the loss of existing open spaces, including blue green infrastructure (Design Consideration 1 - Character) but also requires public and private spaces to be integrated into the design of new development (Design Consideration 6). This will act to limit increased density of development. Similarly, it has yet to be properly tested whether the Plan's expectations for increased housing density can also be reconciled with other policies of the Plan, but in particular

Page 85 Public Rights of Way - KCC notes that the PRoW network is not mentioned within the draft policy text, though it is noted within Appendix 6 - Section 2. Considering the value and importance of the PRoW network, KCC requests that the PRoW network is referenced within 'Design Consideration' sections 2, 4, 5 and 6. Alternatively, reference to the protection and enhancement of PRoW should be inserted into the text underneath the table, as PRoW encompass multiple design considerations. Sectio

Appendix 6 SUDS - Proposed Design Guidance: Working with the site and its context: i. It is key to know if there is any existing formal or informal drainage infrastructure that may serve a site whether greenfield or previously developed. A supplementary question may be: Is the site served by any existing drainage infrastructure e.g. natural watercourses or formal drainage systems? Has an adequate setback been provided to any watercourses? ii. It is key to identify any areas of potential flood r

This policy will require developments to be considered by a Design Review Panel and that this additional cost will be paid for by the developer. We do not consider this approach to be appropriate as it will add considerably to the time taken for a development to come forward for approval. Given the desire of Government to speed up the process such a requirement would appear to be contradictory. Experience based on past experience with CABE's Design Review process suggests that it will create mor

Policy 15 Design Principles The policy provides a clear framework for decision making, with generally good support for other policies. Clear reference should be made to Policy 6 (Safeguarding Places for Wildlife and Nature). References to GI provision are welcomed, although we would encourage requirements for GI to be more explicit. For example, the policy should seek to ensure provision of new green infrastructure and biodiversity net gain, with links to the existing green infrastructure netwo

Appendix 6 Proposed Design Guidance for Consultation We welcome support of the content of the landscape, biodiversity and GI policies within the Local Plan document. No further comment.

There is a High Weald AONB Design Guide in preparation which seeks to enable housing developments in the AONB to reflect High Weald characteristics. It is requested that this Guide be referenced in section 8 of this policy. I support the reference to AONBs in the 'Outdoor Lighting' section as the High Weald has intrinsically dark night skies which need to be protected.