Five or eleven asks?

Revisions to the National Planning Policy Statement come thick and fast, sometimes heralding fundamental change, as is the case with the latest consultation draft, and sometimes simply tweaks, as we saw in December 2023.  On that occasion the revision upped the ante on whether the planning system should “ask for beauty” as the Building Better Building Beautiful Commission called for in 2020.  This resulted in five references to (built) beauty being added to the NPPF in 2021 which multiplied to eleven in 2023, reinforcing this dimension of policy.  

Along with a range of more fundamental changes, the proposal now is to remove the latest six mentions to beauty, taking us back to the situation prior to December.  The accompanying explanation notes “The Government recognises the importance of beauty in the built environment as an important objective of well-designed places” but suggests “including further references to ‘beauty’ and ‘beautiful’ may result in inconsistency in how it is applied in decision-making, as many find the term subjective and difficult to define”.  

There is an inconsistency here.  While the number of mentions of a planning consideration may help to ensure that it is clearly heard by those receiving the message (planning authorities, developers, communities, etc.), the number of mentions does not materially impact on the weight and authority of the message, it simply duplicates it.  On that basis, one could say that the extra mentions of the term in 2023 were unnecessary, and also, following the same logic, their removal now is equally unnecessary.  Whether we have five or eleven mentions of beauty should not impact on how the term is used in local policy and planning related decision-making or on whether people find it subjective or not. 

So perhaps the key message here is not the removal of duplication (something that repeated incremental revision of the NPPF inevitably leads to), but instead that beauty as an aspiration in the NPPF has survived, albeit less prominently.  This reflects two far more important questions than how many times we should use the term, namely whether we should include beauty as a planning consideration at all, and if we do, how should we use the term?  

Situating a beauty ambition

I discussed the first of these questions in a previous blog at the time of the last iteration of the NPPF by the previous Government.  Then, drawing on evidence from my earlier analysis of planning appeals, I noted that use of the ‘B’ word had raised the national focus on design quality and so was a worthwhile addition to the planning arsenal.  BUT, I concluded, it was primarily useful as a declaration of intent and high ambition, rather than as a usable criterion that could easily be defined and measured.  So, if we are going to include an aspiration for beautiful places and development, how should we frame that ambition? 

There has long been an inconsistency between how design considerations are defined and expressed in national policy and how they are defined and expressed in the guidance that accompanies it.  The explanation accompanying the latest proposed changes notes “There is already a clear framework through policy and guidance on how to achieve well-designed places (as set out in the National Design Guide and National Model Design Code – NMDC), to enable this to be decided by local planning authorities”.  

Both are based on ten characteristics of well-designed places that concern: context, identity, built form, movement, nature, public spaces, uses, homes and buildings, resources, and lifespan.  The NPPF, by contrast has a different list of six considerations focusing on: function, attractiveness, character, sense of place, optimising potential, and health and well-being, with a range of other design criteria scattered randomly throughout the NPPF, for example relating to trees, habitats, density, height, and so on.  Before the National Design Guide was introduced in 2019 this detail was necessary, now the duplication of design criteria in a different form is what is inconsistent and confusing.

Restoring clarity to the design policy

To restore clarity, therefore, this iteration of the NPPF could be used as an opportunity (as the explanatory note suggests but does not quite deliver) to move to the principle that the design paragraphs of the NPPF focus simply on three things: 

Establishing unequivocally the high-level national ambition for design qualitySetting out expectations on how that should be operationalised through the planning systemCross-referencing and therefore empowering accompanying national guidance in which the detailed national framework for design is set out.

To this end, I offer below a more thorough edit of the design-related paragraphs of the NPPF based on the principles above while also taking the opportunity to:

Contextualising the use of beauty as part of a high level ambition to deliver inclusive, beautiful and sustainable placesAdd the critical national guidance on space standards and accessibility to the suite of guidance explicitly referred to in the main text of the NPPF (rather than in a footnote, as now)Use this as an opportunity to clarify the previous muddle on what is a design guide and what is a design code (the latter being typically a site-specific tool)Dealing more forcefully with the elephant in the room, the relationship between planning and highways, which this new Government (if it does anything on design) should prioritise sorting outClarifying that the design expectations are for all and always, and not a discretionary ‘nice to have’ when other things allowRemove repetition of messages across the paragraphs.

My efforts are below (in red), and under my signature (for those, like me, obsessed with such matters) a version showing what has been added (underlined), moved around (in italics) and deleted (crossed through) from the version out to consultation.  

Enjoy!

Achieving well-designed development and places

128. The creation of inclusive, beautiful and sustainable buildings and places is fundamental to what the planning and development process should achieve. Good design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities. Being clear about design expectations, and how these will be tested, is essential for achieving this and all local authorities should put in place rigorous arrangements to ensure that design quality is secured. 

129. Plans, accompanied, as appropriate, by more detailed design guidance should, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable. Design policies and guidance should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics. Neighbourhood planning groups can play an important role in identifying the special qualities of each area and explaining how this should be reflected in development, both through their own plans and by engaging in the production of design policy and guidance by local planning authorities.

130. To provide maximum clarity about design expectations at an early stage, all local planning authorities should prepare or require the preparation of design codes which reflect the local design vision and expectations. Design codes can provide a site-specific framework for creating distinctive places with a consistent and high quality standard of design. Their geographic coverage, level of detail and degree of prescription should be tailored to the circumstances and scale of change in each place, and should allow a suitable degree of variety.

131. Design codes can be prepared at an area-wide, neighbourhood or site-specific scale, and to carry weight in decision-making should be produced either as part of a plan, as supplementary planning documents, or, typically by landowners and developers, in support of a planning application. Whoever prepares them, all guides and codes should be based on effective community engagement and reflect local aspirations for the development of their area.

132. When preparing design policies, guidance and codes, local planning authorities should be consistent with the guidance contained in the National Design Guide, while the National Model Design Code is the primary basis for the preparation and use of local design codes.  These national documents should be used to guide decisions on applications in the absence of locally produced design guides or design codes. Planning policies for housing should make use of the Government’s optional technical standards for accessible and adaptable housing, where this would address an identified need for such properties. Policies should also make use of the nationally described space standard in order to achieve healthy living conditions in all new or converted homes.

133. The objectives of well conceived planning policies and guidance can be easily undermined by highways and parking standards that have not been developed with a view to optimising inclusive, beautiful and sustainable design outcomes.  This includes the presence of street trees which make an important contribution to the character and quality of urban environments, and can also help mitigate and adapt to climate change. Government expects planning authorities and highways authorities to work proactively together to overcome such challenges and to establish local highways codes that deliver the very best place-making, including the potential for adoptable new streets that are tree-lined.

134. Design quality should be considered throughout the evolution and assessment of individual proposals. Early discussion between applicants and the local planning authority and meaningful engagement with the local community about the design of emerging schemes is important for clarifying expectations and reconciling local and commercial interests. Applicants should work closely with those affected by their proposals to evolve designs that take account of the views of the community. Applications that can demonstrate early, proactive and effective engagement with the community should be looked on more favourably than those that cannot.

135. Local planning authorities should ensure that they have access to, and make appropriate use of, tools and processes for assessing and improving the design of development. For assessing proposals there is a range of tools including workshops to engage the local community, taking specialist design advice, making use of design review arrangements, and various assessment frameworks. These are of most benefit if used as early as possible in the evolution of schemes, and are particularly important for significant projects such as large scale housing and mixed use developments. In assessing applications, local planning authorities should have regard to the outcomes from these processes, including any recommendations made by design review panels.

136. Development that is not well designed should be refused. This means development that fails to reflect local design policies, guidance and codes and the government guidance on design referenced in Paragraph 133. Significant weight should be given to outstanding or innovative designs which depart from these provisions so long as they meet Government aspirations for inclusive, beautiful and sustainable development and positively contribute to their surroundings.

137. Local planning authorities should ensure that relevant planning conditions refer to clear and accurate plans and drawings which provide visual clarity about the design of the development, and are clear about the approved use of materials, planting and landscape. This will provide greater certainty for those implementing the planning permission on how to comply with the permission and a clearer basis for local planning authorities to identify breaches of planning control. Local planning authorities should also seek to ensure that the quality of approved development is not materially diminished between permission and completion, as a result of changes being made to the permitted scheme (for example through changes to approved details such as the materials used or the absence of agreed trees and planting).

138. The quality and character of places can suffer when advertisements are poorly sited and designed. A separate consent process within the planning system controls the display of advertisements, which should be operated in a way which is simple, efficient and effective. Advertisements should be subject to control only in the interests of amenity and public safety, taking account of cumulative impacts.

Matthew Carmona

Professor of Planning & Urban Design

The Bartlett School of Planning, UCL

@ProfMCarmona

Achieving well-designed  development and   places

128. The creation of high quality, inclusive, beautiful and sustainable buildings and places is fundamental to what the planning and development process should achieve. Good design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities. Being clear about design expectations, and how these will be tested, is essential for achieving this and all local authorities should put in place rigorous arrangements to ensure that design quality is secured. So too is effective engagement between applicants, communities, local planning authorities and other interests throughout the process.

129. Plans, accompanied, as appropriate, by more detailed design guidance 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. Design policies and guidance should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics. Neighbourhood planning groups can play an important role in identifying the special qualities of each area and explaining how this should be reflected in development, both through their own plans and by engaging in the production of design policy and guidance and codes by local planning authorities and developers.

130. To provide maximum clarity about design expectations at an early stage, all local planning authorities should prepare or require the preparation of design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences the local design vision and expectations. Design guides and codes can provide a local site-specific framework for creating beautiful and distinctive places with a consistent and high quality standard of design. Their geographic coverage, level of detail and degree of prescription should be tailored to the circumstances and scale of change in each place, and should allow a suitable degree of variety.

131. Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale, and to carry weight in decision-making should be produced either as part of a plan, or as supplementary planning documents, or, typically by landowners and developers, may contribute to these exercises, but may also choose to prepare design codes in support of a planning application for sites they wish to develop. Whoever prepares them, all guides and codes should be based on effective community engagement and reflect local aspirations for the development of their area.

132. When preparing design policies, guidance and codes, local planning authorities should taking into account be consistent with the guidance contained in the National Design Guide, while and the National Model Design Code is the primary basis for the preparation and use of local design codes.  These national documents should be used to guide decisions on applications in the absence of locally produced design guides or design codes. Planning policies for housing should make use of the Government’s optional technical standards for accessible and adaptable housing, where this would address an identified need for such properties. Policies should also make use of the nationally described space standard in order to achieve healthy living conditions in all new or converted homes., where the need for an internal space standard can be justified.

132. Planning policies and decisions should ensure that developments:

a) will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development;

b) are visually attractive as a result of good architecture, layout and appropriate and effective landscaping;

c) are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities);

d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;

e) optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space) and support local facilities and transport networks; and

f) create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.

133. The objectives of well conceived planning policies and guidance can be easily undermined by highways and parking standards that have not been developed with a view to optimising inclusive, beautiful and sustainable design outcomes.  This includes the presence of street trees which make an important contribution to the character and quality of urban environments, and can also help mitigate and adapt to climate change. Government expects planning authorities and highways authorities to work proactively together to overcome such challenges and to establish local highways codes that deliver the very best place-making, including the potential for adoptable Planning policies and decisions should ensure that new streets that are tree-lined., that opportunities are taken to incorporate trees elsewhere in developments (such as parks and community orchards), that appropriate measures are in place to secure the long-term maintenance of newly-planted trees, and that existing trees are retained wherever possible. Applicants and local planning authorities should work with highways officers and tree officers to ensure that the right trees are planted in the right places, and solutions are found that are compatible with highways standards and the needs of different users.

134. Design quality should be considered throughout the evolution and assessment of individual proposals. Early discussion between applicants and the local planning authority and meaningful engagement with the local community about the design and style of emerging schemes is important for clarifying expectations and reconciling local and commercial interests. Applicants should work closely with those affected by their proposals to evolve designs that take account of the views of the community. Applications that can demonstrate early, proactive and effective engagement with the community should be looked on more favourably than those that cannot.

135. Local planning authorities should ensure that they have access to, and make appropriate use of, tools and processes for assessing and improving the design of development. The National Model Design Code is the primary basis for the preparation and use of local design codes. For assessing proposals there is a range of tools including workshops to engage the local community, taking specialist design advice and, making use of design review arrangements, and various assessment frameworks such as Building for a Healthy Life. These are of most benefit if used as early as possible in the evolution of schemes, and are particularly important for significant projects such as large scale housing and mixed use developments. In assessing applications, local planning authorities should have regard to the outcomes from these processes, including any recommendations made by design review panels.

136. Development that is not well designed should be refused. especially where it This means development that fails to reflect local design policies, guidance and codes and the government guidance on design referenced in Paragraph 133., taking into account any local design guidance and supplementary planning documents such as design guides and codes. Conversely,Significant weight should be given to : a) development which reflects local design policies and government guidance on design, taking into account any local design guidance and supplementary planning documents such as design guides and codes; and/or b) outstanding or innovative designs which depart from these provisions so long as they meet Government aspirations for inclusive, beautiful and sustainable development which promote high levels of sustainability, or help raise the standard of design more generally in an area, so long as they and positively contribute to fit in with the overall form and layout of their surroundings.

137. Local planning authorities should ensure that relevant planning conditions refer to clear and accurate plans and drawings which provide visual clarity about the design of the development, and are clear about the approved use of materials, planting and landscape where appropriate. This will provide greater certainty for those implementing the planning permission on how to comply with the permission and a clearer basis for local planning authorities to identify breaches of planning control. Local planning authorities should also seek to ensure that the quality of approved development is not materially diminished between permission and completion, as a result of changes being made to the permitted scheme (for example through changes to approved details such as the materials used or the absence of agreed trees and planting).

138. The quality and character of places can suffer when advertisements are poorly sited and designed. A separate consent process within the planning system controls the display of advertisements, which should be operated in a way which is simple, efficient and effective. Advertisements should be subject to control only in the interests of amenity and public safety, taking account of cumulative impacts.