Design Codes and the Pursuit of Beauty

The beginning of the year saw the open consultation for the proposed changes to the National Planning Policy Framework (NPPF) following on from the Building Better Building Beautiful Commission “Living with Beauty” report. The consultation also sought views on the new National Model Design Code, which provides further guidance on the production of design codes, guides and policies to promote successful design. We consulted with our internal planning team, some local authority friends, and expert consultants to formulate our official response to the consultation. We have summarised some of our key points below.

Beauty is a poor criterion for assessing quality

We encourage the government’s increased focus on quality, design, consultation and climate, and the acknowledgement of the critical role local councils and communities play in the creation of successful, well-loved places. However, the lack of definition of subjective terms like beauty and beautiful is concerning. There is a fundamentally flawed assumption at the root of these proposed changes: that a more beautiful place is more likely to be welcomed by the local community and that this will help speed up the democratic planning process. Most objections to development are nothing to do with beauty but relate to a general assumption that development puts additional strain on already overstretched amenities and resources.

The failure to define the word ‘beautiful’ and its use within the National Model Design Code and NPPF, will result in subjective and skin-deep assessments of what constitutes good design, leaving it open to interpretation and debate. Who decides what is ‘beautiful’? Not all well-loved and successful buildings are conventionally ‘beautiful’, and many buildings dubbed ‘beautiful’ are not fit for purpose or conducive to a sustainable future. We raised similar concerns in our response to the White Paper, Planning for the Future, in August 2020. Beauty is a poor criterion for assessing the quality of proposals.

A missed opportunity

Social and environmental sustainability, not beauty, should be the measures for assessing development. Whilst the new documents do put increased emphasis on sustainable design, they often do not go far enough, and the language used does not reflect the required urgency needed to address the climate and biodiversity crisis we have all acknowledged. Phrases like ‘targeting low carbon’, instead of ‘targeting zero carbon’, and ‘encouraging’ the reuse of existing resources, rather than ‘prioritising’, will only allow the continuation of half-hearted attempts to tackle the climate crisis, providing a get out of jail free card to developers who prioritise profit over all else.

There is also a lack of emphasis on the protection and enhancement of biodiversity. Encouraging the planting of trees along streets is all very well, but a stronger stance on the protection of nature and wildlife is needed if we are to halt the decline of our natural world.

There is an opportunity with any new national policy documents, to not merely lessen the harm of new development, but rather to make design and construction work as positive forces that repair natural and human systems. It is a shame these documents miss this opportunity.

Application and Implementation

It is unclear, given chronic lack of resource and funding in many Local Planning Authorities (LPAs), whether they will be able to implement the guidance into their own design codes. Many, particularly those outside of London, are simply not equipped and may rely on external consultants to produce them, coming at expense.

Further to implementation, having the ability to be able to effectively use, check and enforce the created design code is critical to making it a useful tool in the fight against poor design quality. The same challenges of staff resourcing apply here, particularly making sure that LPAs have skilled staff who are adequately trained and able to execute the power of the design code where necessary.

A different funding model for planning and development control that could adequately match planning resource to the needs of applications would have a much greater impact and deliver better places and more homes. The proposed changes set out in the National Model Design Code are a distraction from the real issues faced by applicants and local authorities and the public every day in the development process.

In conclusion, the application of these proposed changes will be the true test for their effectiveness. If the National Model Design Code genuinely gives authorities more power to challenge developers on design grounds, particularly those that do not take a sustainable approach to development, then this guidance could be beneficial to the process, but the lack of clear definition and ambition may mean they fall short of what they hope to achieve.