National Planning Policy Framework

Written evidence from Urban Design Group

 

Summary

· To ensure the efficient operation of the planning system, clear wording and definitions are needed in the NPPF that will withstand legal challenge

· The need for Resources, Skills and Leadership should be mentioned

· A consistent, robust test for sustainable development is needed

· Quality of architectural and urban design is a key contributor to "planning for prosperity"

· Quality design should be fully defined and clarity provided on what should and should not be given planning permission

· Systems for assessing quality of development are already in use and should continue to be used

· Quality architecture and urban design is missing from the list of core planning principles

· There is further potential for integrating policies – transport, planning, sustainability, design quality

· The National Planning Policy should be evidence based, the evidence should be referenced, and in particular referenced to the many completed and on going research projects in British universities.

· Existing best practice guidance should be referenced in the NPPF, including

o the Manual for Streets series

o By Design

o The Urban Design Compendium

Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?

Clear wording and definitions are needed that will withstand legal challenge

To avoid needless bureaucracy, time wasted at planning inquiries and appeals, and to give certainty to planning applicants, the wording and definitions used in the NPPF must be unambiguous, easy to understand, and robust.

Resources, Skills and Leadership need to be provided

The quality of new development passed through the planning system depends on the use of skilled architects and designers. It also depends on local politicians who have a good understanding of and training in design, and who are who are supported by competent and committed staff. It is recommended that the NPPF makes mention of appropriate resourcing.

Is the definition of 'sustainable development' contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?

A robust test for sustainable development is needed

To make the "Presumption in Favour of Sustainable development" operate efficiently, it is strongly recommended that a consistent, simple and robust test for sustainable development is specified in the NPPF, in order that planning authorities and developers may have a clear understanding of whether a proposal is likely to obtain permission.

Quality of architectural and urban design is a key contributor to "planning for prosperity"

In the definition of sustainable development offered, the section "Planning for prosperity" –omits the role of quality architectural and urban design in creating towns and cities that attract employment and investment.

Quality design should be fully defined and clarity given on what should and should not be given planning permission

Allied to the presumption in favour of sustainable development is question of minimum standards for approval. The NPPF states that:

"Permission should be refused for development of obviously poor design that fails to take the opportunities available for improving the character and quality of an area and the way it functions."

While this statement is well intentioned, there is the likelihood of lengthy legal discussion as to the meaning of "obviously poor". It leaves open the door to development that is only marginally better than "obviously poor". The NPPF needs to be clear on design quality and what should and should not be given planning permission. Quality design should be fully defined to include:

- design that is functional and enables efficient operation of the economy

- design that is attractive

- design that is sustainable,

Existing systems for assessing quality of development are available – and could be used.

There are simple and effective systems for assessing the quality of development including

Building for Life

OurPlace – 2011 Urban design award winner

Design Quality Reviewer - HCA

BREEAM

Code for Sustainable Homes

The Gold standard of the Building for Life scheme, or its equivalent, could be used as the target for quality of architectural and urban design.

Are the 'core planning principles' clearly and appropriately expressed?

Quality architecture and urban design is missing from the list of principles

The objective of obtaining quality architectural and urban design in new development should be a key planning principle, in line with international best practice

Quality design and quality places are a mark of prosperity, and a sign of a successful and growing economy. Quality of place is a key to maintaining the international competitiveness of England’s major cities.

Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear? Does the NPPF serve to integrate national planning policy across Government Departments?

Further potential for integrating policies – transport, planning, sustainability, design quality

Transport and Planning should be dealt with in an integrated way within the NPPF, rather than as separate subjects with separate objectives. Highways, as well as being the major part of the transport system, also provide the bulk of the public realm, and provide the setting for houses, shops, offices, and factories. The NPPF should address the need to balance these functions: the balancing of movement and place.

Sustainability and design quality should be addressed in an integrated way in the NPPF. Sustainability is a measure of quality of design.

Are the policies contained in the NPPF sufficiently evidence-based

The National Planning Policy should be based on evidence, and this evidence should be referenced. There is an extensive programme of research being conducted at British universities, paid out of public funds and running into £10s millions. This research should be used to help provide that evidence base.

Existing best practice guidance should be referenced in the NPPF, including:

- the Manual for Streets series

- By Design

- The Urban Design Compendium

About the Urban Design Group

The Urban Design Group was founded in 1978, to encourage the greater awareness and understanding of urban design, the multi-disciplinary process of providing the setting for life in cities, towns and villages. It has a membership of approximately 1,500 individuals and organisations.

September 2011