December’s new NPPF introduced some significant policy changes – on housing targets, the 5-year land supply and the introduction of the Grey Belt among others. The fact that it largely removed the controversial references to the word 'beauty' has received less media attention.
So 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? Or does it remove a subjective and unquantifiable term which had little place in planning policy to start with?
Planning & Development InSite spoke to Glen Richardson, Masterplanner in Carter Jonas’ Cambridge office.
The removal of 'beauty' from the NPPF
Glen, like most planning and development professionals, welcomes the change: “I think it’s an improvement to remove the word 'beauty' as this removes the subjectivity of what is in effect a highly subjective judgement. Instead, the chapter addresses the principle of good design, which was in place prior to the July 2021 revisions. The inclusion of 'beauty' was at times disastrous, specifically for developers whose schemes were rejected at the last hurdle by Michael Gove on this basis.”
Is there a risk that, bearing in mind the government’s need to expedite housing delivery, design standards will be compromised? 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
Glen agrees: “Beauty is not ditched as a high-level aim but the focus is now on 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: one which is much better suited to planning policy than the rather vague concept of 'beauty'.
“It’s important to recognise that the NPPF is an overview of policy, a catch-all. In practice, there’s really 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. But documents which provide clear guidance and the basis for local policy, and to which both designers and local authorities can refer, do have an important role to play.”
Addressing the Housing, Communities and Local Government Committee in November last year, planning minister Matthew Pennycook stated that the government intends to update the National Design Guide and the National Model Design Code in Spring 2025. So, we can expect some tweaks in these documents imminently, but otherwise don’t anticipate substantial changes, certainly not those which would delay the process of expediting planning consents.
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 substitutes 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. 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,” says Glen. “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.”
Design codes for Carter Jonas clients
Carter Jonas has created local design codes for specific developments previously. This includes a detailed code for a new community of 1,800 homes in Swale District, Kent, Winterbourne Fields.
“Quite often we are asked by clients to provide a commentary on their proposals in relation to the National Design Guide and Building for a Healthy Life”, says Glen. “Our experience is that these documents are useful in encouraging thought and discussion about building design. While they don’t state that one style is ‘better’ than the other, they do provide the structure for assessing the quality of a proposal against key criteria such as street design, character and connectivity.
”From experience I believe that documents such as the National Design Guide and Building for a Healthy Life, which are tried and tested and cite best practice, will continue to be of use and encourage local authorities and developers to retain high design standards. The early stages of masterplanning requires considerable time to be taken to understand objectives and respond appropriately, and these documents help sign-post both designers and local authorities to best practice.”
Local vernacular and density
Paragraph 130 of 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.
Again, Glen agrees with the 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. The NPPF supports building at density, subject to good design.”
LDOs: Good design does not equate to less speed
An important role of the NPPF is to enable quality planning to occur efficiently.
As Glen says, “There’s a misapprehension that good design takes time. But good policies – those which stem from national policy but are implemented through local policy – are crucial in allowing schemes to progress quickly.”
“There are many examples, but perhaps the best is Local Development Orders (LDOs) which can promote both speed and excellence in design. We’ve researched them at Carter Jonas, such as in our work for Gascoyne Estates in in Hertfordshire. Another well-known proponent of LDOs is the King, in his new communities at Poundbury, Nansledan and elsewhere. The somewhat ‘pastiche’ Georgian style in these developments may be divisive in the architectural community, but it’s also popular with many buyers and local authorities. Despite the inspiration for these Georgian-inspired schemes coming from an era before planning was underpinned by an Act of Parliament, such developments can achieve high levels of density alongside clear design intent.
“Legacy schemes such as these succeed because they involve dedicated teams of architects who work from a site-wide pattern book. They aren’t granted any greater leniency than other schemes - design is very carefully scrutinised - but because they provide a clear vision for design from an early stage and can be designated as a special planning zone or LDO, planning approval can be fast-tracked.
LDOs: the answer to Labour’s 1.5m challenge?
This raises the question: if fast-track mechanisms such as LDOs can speed up planning consents, will the government encourage their wider use? Are we already seeing something of this nature in the recent announcement that Simplified Planning Zones will be used to expediate delivery of AI data centres?
“It could be part of the solution to enable more homes to come forward,” says Glen, “But LDOs are used quite sparingly, usually by ‘legacy’ landowners who want to retain involvement in the evolution of a scheme. While they are successful in specific circumstances, I don’t think they’d necessarily be as straight forward to roll out nation-wide.”
Conclusion
What becomes apparent in conversation with Glen is that the 'beauty' issue was a rare case of building design being politicised.
If we were to draw parallels with policy documents from other government departments – the Treasury, Department for Education or Foreign Office – the fingerprint of the party in power would be immediately visible. Perhaps partly because of the long duration and prominence of schemes such as Poundbury (by the Duchy of Cornwall), Accordia (Stirling Prize winning housing in Cambridge) and many others, there’s not really a ‘pendulum effect’ in design policy. Consider also how the work of Michael Heseltine (once dubbed the so-called ‘Minister for Merseyside’) in turn influenced John Prescot’s and Lord Rogers’ Urban Renaissance, and further how that earlier regeneration work was continued by the Coalition and later Conservative governments.
Ultimately, consistent and clear policy and guidance is what is needed to enable good quality schemes, delivered at a good pace. Addressing the current housing crisis required change to aspects of the NPPF, as we have seen in the renaming of Chapter 12, but change for change’s sake is rarely the correct option. While politics may flourish on dramatic twists and turns, policy works best when it remains clear and consistent.