Glen Richardson (pictured), associate partner in Carter Jonas’ Cambridge office
December’s NPPF introduced some significant policy changes – notably on housing targets and the 5-year land supply. The fact that it largely removed the controversial references to the word ‘beauty’ has received less media attention. And yet the question of whether or not design is being sacrificed by the current government remains extremely important, particularly because the revised housing targets suggest a greater average density on each new development.
Taking a step back, what does the change to the title and content of Chapter 12, Achieving well-designed places (previously Achieving well-designed and beautiful places) mean in reality? Will design standards be impacted, as the Policy Exchange asserts in Beauty and Socialism: How the Left can put Beauty back into Britain?
Like most planning and development professionals, I welcome the change. It removes a subjective and unquantifiable term which had little place in planning policy to start with. Instead, the chapter addresses the principle of good design, which was in place prior to the July 2021 revisions.
But despite this, bearing in mind the government’s need to expedite housing delivery and almost double current levels of output, is there a risk that design standards will be compromised in favour of speed and greater density? Secretary of State Angela Rayner says not: Labour’s 1.5 million homes target will not, she says, lead to “a load of ugly houses”.
Design guidance at a national level
The NPPF has shifted the emphasis, requiring ‘high quality design’ to be achieved through design coding and guides. Paragraph 133 of the NPPF states that to provide maximum clarity about design expectations at an early stage, all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code. A third document which is referenced in this context is Building for a Healthy Life, an updated version of an earlier document Building for Life.
The inclusion of these three national-level documents – which we find are frequently quoted in planning appeals and inquiries – provide a useful foundation and a point of reference to assess the quality of design.
However, it’s important to recognise that the NPPF is an overview of policy. In practice, there’s no place in a document of this type for specific design requirements – for example, the focus on Mansard roofs in the 2022 version, which appeared quite unnecessarily. So the three documents referred to above are necessary to provide clear guidance on vexing issues including density.
The lesser importance of local character?
On design codes, the NPPF has made a significant change: the previous government had required that councils prepare local authority-wide design codes, which must be adhered to when meeting housing need. In the recent revisions, in place of district-wide design coding, the government substituted localised design codes, masterplans and guides, “for areas of most change and most potential”. Examples cited are regeneration sites, areas of intensification, urban extensions and large new communities – those likely to be built at higher densities. The new paragraph 135 states that the National Model Design Code is, the primary basis for the preparation and use of local design codes and removes the requirement for local design codes to be the primary means for assessing and improving the design of new development.
It makes complete sense, in both architecture and planning, that design codes, where they exist, should be applied on a local level. To suggest that a local authority should have a single design style is the antithesis to good design: design should always respond to its immediate surroundings. Perhaps more significantly given the push for growth and a significant uplift in housing targets, it is important that the National Model Design Code exists for the benefit of those councils that don’t have the time or resources to develop their own design codes.
It’s also clear now that, where local planning authorities can provide their own specific design policies, they should do through community engagement, as per Paragraph 138 of the NPPF.
The previous NPPF included a statement (no doubt included to appease backbench disquiet) stating that local character can be taken into account when ‘councils consider their ability to meet their housing needs’ – in other words, schemes could have been rejected if local character was not met. This requirement, which specifically referred to density, has been deleted in its entirety.
I agree with this change. The new NPPF strengthens expectations that local plans facilitate an uplift in density, where appropriate. But increased density needn’t be detrimental to local character.
I think it’s wrong to assume that to build at high density, you have to build tall. It’s more a case of thinking carefully about issues such as how to design and where to place elements including car parking and gardens and providing shared open spaces. It’s about being super-efficient with a more limited amount of space and highly creative with site layout. It’s good news all round that the current NPPF supports building at density, subject to good design.
