In December 2022, the City Council consulted the public on a draft Householder Design Guide Supplementary Planning Document. Below is the Coventry Society’s response:
We welcome this draft householder design guide supplementary planning document which will replace the 2003 version.
In particular, we support the principle of improving the quality of residential extensions and alterations. Appendix 2, ‘justification statement’, is extremely important in this respect as it highlights to householders the significance of producing a site appraisal that informs a subsequent supporting statement that should be submitted as part of a planning application or as a basis for a pre-application discussion. We would urge that this appendix should be integrated into the main text.
One of the challenges with this SPD is the issue of permitted development. The Government’s adoption of policies favouring permitted development (outside of special status areas) results in an increasing number of alterations to residential property that do not require planning permission but nevertheless impact on adjacent properties and the local neighbourhood. We, therefore, consider that reference should be made to the use of Article 4 directions in the guide to highlight how the Council might take action.
The detail in the draft SPD is appropriate and highly relevant and covers often neglected issues such as boundary treatment, hardstanding areas, impact on gardens etc. We welcome the use of images to illustrate the challenges and opportunities presented by residential extensions and alterations.
We, however, have four further detailed observations which we hope will be taken on board in the final approved version:
- One of the challenges faced by property owners is whether planning permission is required. We suggest that there should be a section (and / or appropriate links to guidance) on this issue including information etc that is required as part of a planning application as well as the value of pre-application advice (and see above) – we are aware of a number of councils that have included this in their householder design guides (eg Leeds and Newcastle).
- Property owners are also often confused over other permissions that are required when considering extensions and alterations such as building regulations, and highways approval as well as the special rules covering conservation areas, listed buildings and tree preservation orders. We recommend that this is given more detailed coverage.
- We note that Page 3 states that this SPD also focuses on ‘Conversions to residential uses and extensions & curtilage development in relation to Houses In Multiple Occupation (HMO’s)’. Conversion of property to HMOs is a major issue in Coventry (and many other local authorities in England). The recent consultation on an Article 4 direction and HMOs is illustrative of this point. We suggest that the City Council gives consideration to producing a specific SPD on HMO conversions – a number of councils have adopted this approach eg Bristol and Sunderland.
- Finally, from a public sector equality perspective, we would urge that the comment on the final page on ‘contacting the planning department if information is required in other formats and languages’ should be in more detail and located before the executive summary.
January 2023