The future of the planning system in England Contents

10Design and beauty

Government proposals

187.The first pillar of the Government’s White Paper was the reforms to Local Plans. The second pillar of the reforms focused on design. The key proposals were:

188.The Secretary of State, in his forward to Planning for the Future, wrote “Our reformed system places a higher regard on quality, design and local vernacular than ever before, and draws inspiration from the idea of design codes and pattern books that built Bath, Belgravia and Bournville.”625 The Government’s proposals followed hot on the heels of the Building Better, Building Beautiful Commission whose final report was published in January 2020.626 The Institute of Historic Building Conservation welcomed this new focus: “There has not been enough focus on design throughout the planning process and we welcome the move towards a more design-led approach.”627

189.In January 2021 the Government announced further measures on design, including launching a consultation on changes to the NPPF, and asked about its newly published National Model Design Code.628 Its objective was described as taking forward “our commitment to making beauty and place making a strategic theme in the National Planning Policy Framework.” The Government wanted local councils to create their own local design codes which would “provide a local framework for creating beautiful and distinctive places with a consistent and high-quality standard of design.” The required design details would be tailored to the specific place. An Office for Place would be established to support the creation of local designs. It also wanted “greater emphasis on beauty and place-making,” in the NPPF, including ensuring “that all new streets are lined with trees.” This would help ensure “poor quality” proposals were rejected. In contrast good designs would be encouraged, and were defined as either a “development which reflects local design policies and government guidance on design, taking into account any local design guidance and supplementary planning documents”, or be “outstanding or innovative designs which promote high levels of sustainability, or help raise the standard of design more generally in an area,” whilst being otherwise compatible with their surroundings.

Current situation

190.The Government’s wish for reform reflects wider concerns about the standard of design in recent buildings. There have been successful examples of design, such as the 2019 Stirling Prize winning development of council housing in Norwich.629 But the broad consensus was that design had been undervalued. We were told surveys and research had showed declining design standards,630 and low levels of satisfaction with the houses that people moved into.631 Local buildings were denounced as “boring and unimaginative.”632 Place Alliance drew our attention to their A Housing Design Audit for England, which found that 54% of new schemes were judged “mediocre”.633 They argued the root cause of poor design resulted from the main stakeholders failing to prioritise “the delivery of well-designed coherent bits of city that maximise ‘place value’.” Whilst developers standard house types might be thought to be of “popular design … they give rise to the sort of homes that the Housing Design Audit identified as sub-optimum in terms of overall character and sense of place”. This resulted in resistance to their construction by local councillors.634 CPRE cited the same report to argue 75% of recent housing schemes (and 94% in rural areas) would not have been permitted under current design guidance.635

191.Different explanations were offered for this fall in standards, including the merger of Commission for Architecture and the Built Environment (CABE) with the Design Council,636 builders being able to ignore local design codes,637 the stronger negotiating position of housebuilders especially over design issues,638 and the tendency of schemes refused on design grounds to be overturned on appeal resulting in LPAs becoming risk averse about rejecting proposals.639 Accordingly, Richard Blyth on behalf of the RTPI told us 87% of their members “did not feel that the planning system has enough control over design at the moment.”640 Blame was also laid upon high land prices,641 permitted development rights,642 prioritisation of “quantitative measures rather than aesthetic quality”,643 the 1980s policy change that removed design considerations from the planning system,644 and that housebuilders imitated the housing built elsewhere in the country.645

192.There was disagreement over whether poor design was reducing support for housing developments. The District Council Network expressed doubts that a greater focus on design would remove objections to planning proposals, arguing infrastructure and pressures on public services tended to be of greater concern to local residents.646 Contrastingly ADEPT argued local authorities did challenge proposals lacking local distinctiveness and reducing carbon.647 Furthermore, the RICS mentioned their own research had found people were prepared to pay a premium for places where there good placemaking and master planning.648


193.The Government proposed to promote a “fast track for beauty”, following the recommendations of the Building Better, Building Beautiful Commission.649 The Government would establish this fast track through updating the NPPF to give preference to schemes complying with local design guides and codes. It would require that in growth areas a masterplan and site-specific code would need to be agreed as a condition of permission in principle. Legislation would also enable “popular and replicable forms of development” to be accelerated through permitted development.650 The most common phrase used in our evidence in response to the Government’s proposals for beauty was that “beauty is in the eye of the beholder.”651 This reflected a wider perception that beauty is too subjective a criterion, and focusing on it overlooked other important aspects of design. The National Trust declared that “Good design is not just about design codes and aesthetics, it is about how a place works.”652 The idea that beauty is subjective tied to doubts about a community-based approach to determining it. We were told “It is clearly not a legitimate purpose for the planning system to impose the personal stylistic preferences of the more vocal members of the community on the wider community.”653

194.Nonetheless we were surprised by the witness from the Royal Institute of British Architects (RIBA) telling us that “At the end of the day, ultimately, the aesthetic that comes out at the end is perhaps one of the least important aspects of the whole design process.”654 We were more persuaded by the view of Richard Blyth from the RTPI:

I suspect that, if it is a building in your own street, an infill, a replacement, a small site in your area, what it looks like is very important to you because you might be looking at it outside your window all the time … When it comes to major greenfield expansion, design is nothing like as important to existing residents because they do not tend to see so much of it. It is of importance to people who are going to move into those new settlements.655

195.There was also criticism of the ‘fast track’ for beauty. We were told that the current rules on design, focused on ‘appearance’ were too vague and unenforceable,656 and that good design would require “site and scheme-specific participation”.657 Instead, various submissions urged a broader approach to design. Actions with Communities in Rural England (ACRE) noted that the Government’s National Design Guide mentioned ten characteristics of good design “context, identity, built form, movement, nature, public space, Uses, homes and buildings, resources and lifespan”, and argued these should be incorporated in design codes.658 A different emphasis was on the importance of function.659 Historic England emphasised that beautiful buildings “cannot be considered in isolation; the planning system must create beautiful and sustainable places.”660 They accentuated how historic environments could foster “good, modern design”. Environmental quality and climate change were also emphasised.661 In terms of public engagement, the focus on appearance rather than design quality “patronises local communities by implying that they do not understand more fundamental design issues.”662

196.Concerns were also expressed that prescriptive measures—for example pattern books—would be a barrier to innovation.663 It was argued that “areas may not be seen as beautiful in the traditional sense, but can still be fun, vibrant and exciting spaces that people want to spend time in.”664 We were told that innovation in materials and methods was vital to tackling climate change and that design codes should accommodate that.665 The need for design to tackle energy efficiency was also stressed.666

197.We put these concerns to the Minister. He argued that:

If you get a group of people together, they will give you their view of beauty and there are probably some key themes that come out of that consideration. Fundamentally, we are trying to achieve a system whereby local people’s views of what looks good in their environment is properly taken into account.667

It was explained that the Government’s reforms would permit proposals in renewal and protected areas to be brought forward that did not conform to the design requirements through the usual planning process.668

Public involvement

198.A key part of the Government’s proposals is to involve the public in the design aspects of the new Local Plans. We were informed that currently “neither developers nor local authorities were very interested in involving the community. Many of the participants downplayed the role of community engagement in shaping design outcomes.”669 Some welcomed this greater involvement by the community.670 We were also urged to consider a possible role for neighbourhood plans in setting local standards, drawing on their existing practices in setting detailed design policies.671 However, doubts about public involvement were also expressed. There were fears locally popular design codes would become a popularity contest rather than focus on high quality in design”;672 and that elected members would favour “a more traditional pastiche approach … which could become a barrier to great design that stands the test of time.” Instead it was argued that Design Review Panels, with technical specialists, should have a greater role and influence.673

199.It was also argued that community support for a wider design code did not mean consent for a development on a specific site. The National Housing Federation argued that “the most effective codes appear to be site-specific”, citing the Housing Design Audit that found they were five-times more likely to produce good or very good design outcomes.674 The loss of participation with specific sites was cited as reducing “the ability of people to influence detailed design matters. Design codes will not pre-empt all circumstances. The focus of design proposals on beauty, rather than design fundamentals, increases this problem.”675

A National Design Body

200.The Government’s proposal for establishing a national design body was broadly welcomed.676 We were told past successes had been achieved through the work of the former Commission for Architecture and the Built Environment (CABE) and by current Design Panels.677 We were advised that it should not be situated in Homes England and it should not only focus on aesthetics and beauty.678 Instead it should “positively promote innovative and creative design”.679

National and Local Design Guides and Codes

201.The National Design Guide was published on 1 October 2019,680 and praised for showing how well-designed places can be achieved.681 It is also seen as primarily focused on residential developments.682 The National Design Code was published in January 2021, after most of our evidence was received.683 Opinions about the principle of national and local design codes were divided. Advocates of design codes argued that they would provide better design control over officers’ discretionary judgement.684 Those who thought they had been neglected supported greater weight being given to them.685 We were told that design codes should also apply to non-residential developments.686 How the national and local codes should interact was touched on by the City of London Corporation:

The proposed national design guide, national model design code and the revised manual for streets could provide a framework for local decision making but should not provide an inflexible framework. National level guidance is not, in most instances, able to properly reflect specific local circumstances or the needs of local communities–vernacular building styles reflect local traditions and should be encouraged as part of a push to improve the beauty of buildings, for example.

They supported local design solutions agreed by local communities.687 The British Property Federation wanted clarity from the Government about the distinction between local and national design codes and guides. If the latter inform the former that might conflict with what is “popular and characteristic in the local area”. They argued however that significant differences in local codes would require different processes, material, and ways of working. Hence, they favoured nationally set design principles, which are “light touch design codes, that guide and inform rather than stipulate and require.”688 Similarly, it was emphasised that Local Plans needed to “set out clear tangible requirements” and not have subjective assessments.689

202.We also heard about the limitations of the current proposals. There were calls for greater information, for example about the definition of “popular and replicable forms of development”, and clarity on who judges “whether a proposal achieves acceptable design standards and how and what happens to proposals which don’t meet with a locally agreed design code”.690 The CPRE commented “Design codes in themselves cannot guarantee the design quality of future development.”691 The Place Alliance argued there had to be a move away from a standardised approach towards appropriate design for each site.692 There was scepticism that the design code could ensure the community would approve of the resultant buildings,693 and worries that the codes would take a long time to prepare and add little beyond other design statements such as masterplans.694 It was feared that the codes would adversely impact on historic areas be inappropriate for the local contexts.695 They were seen as possibly stifling innovation yet still permitting unsuitable developments.696 Consequently there were calls from the National Trust and from Southwark Council for a framework rather than a code which were more embracing and not a “tick-box exercise”.697

203.The Government’s focus on beauty, whilst laudable, must not detract from other important aspects of design. The Government must ensure that its national design code, advice for local authorities about local design codes, and other aspects of design policy reflect the broadest meaning of design, encompassing function, place-making, and the internal quality of the housing as a place to live in, alongside its external appearance. Given the problems with defining beauty, and to ensure a wider approach to design, there should also not be a ‘fast track for beauty’. Many discussions about beauty and design are very localised, concentrating a specific site, building or street. We do not think these discussions can be incorporated into Local Plans covering an entire local authority. Therefore, the Government must clarify how the public will be able to offer views about developments at this small scale. This is doubly significant given the Government’s proposed reduction in the opportunities for people to comment on individual planning proposals.

626 Building Better, Building Beautiful Commission, Living with Beauty: Promoting health, well-being and sustainable growth, January 2020

627 Institute of Historic Building Conservation (FPS0044)

629 The Smith Institute (FPS0038)

630 Cllr John Crawford (FPS0008)

631 Q73 (Richard Blyth)

632 North Southampton Community Forum (FPS0018)

633 Place Alliance, A Housing Design Audit for England, February 2020

634 Place Alliance (FPS0054)

635 CPRE the countryside charity (FPS0077)

636 Institute of Historic Building Conservation (FPS0044)

637 Rother Association of Local Councils (RALC) (FPS0012)

638 CLA (FPS0049)

639 Greater London Authority (FPS0149)

640 Q73 (Richard Blyth)

641 The Chartered Institute of Building (FPS0096)

642 LSE London (FPS0139). See also Newcastle City Council (FPS0159)

643 St Albans Civic Society (FPS0057). See also The Chartered Institute of Building (FPS0096)

644 Professor Malcolm Tait (Professor of Planning at University of Sheffield); Dr Andy Inch (Senior Lecturer in Urban Studies and Planning at University of Sheffield); Dr Aidan While (Senior Lecturer in Urban Studies and Planning at University of Sheffield); Dr Madeleine Pill (Senior Lecturer in Urban Studies and Planning at University of Sheffield) (FPS0098)

645 National Organisation of Residents Associations (FPS0005), Tamworth Borough Council (FPS0013), Ashford KALC (Combined parish, town and community organisations in the borough of Ashford, Kent) (FPS0060)

646 District Councils’ Network (FPS0082)

647 Q72 (Paula Hewitt)

648 Q73 (Tony Mulhall)

649 Building Better, Building Beautiful commission, Living with Beauty: Promoting health, well-being and sustainable growth, January 2020, pp 71–2

651 Tenterden Town Council (FPS0003), National Organisation of Residents Associations (FPS0005), MCS Charitable Foundation (FPS0102), Land Promoters and Developers Federation (FPS0138)

652 National Trust (FPS0157)

653 Urban Vision Enterprise CIC, D2H Land Planning Development (FPS0037)

654 Q72 (Philip Waddy)

655 Q73 (Richard Blyth)

656 Civic Voice (FPS0076), London Borough of Hackney (FPS0091), City of London Corporation (FPS0148)

657 Urban Vision Enterprise CIC, D2H Land Planning Development (FPS0037)

658 Action with Communities in Rural England (ACRE) (FPS0161)

659 Mr Daniel Scharf (Consultant at PfT Planning) (FPS0002), South Worcestershire Councils (FPS0015), Bartlett School of Planning, University College London (FPS0097)

660 Historic England (FPS0092)

661 Mr Daniel Scharf (Consultant at PfT Planning) (FPS0002), South Worcestershire Councils (FPS0015), Richard Harwood OBE QC (Joint Head of Chambers at 39 Essex Chambers) (FPS0059), Friends of the Earth England, Wales and Northern Ireland (FPS0081), City of London Corporation (FPS0148), Q71 (Paula Hewitt), Q73 (Richard Blyth)

662 Urban Vision Enterprise CIC, D2H Land Planning Development (FPS0037)

663 Pocket Living (FPS0023), St Albans Civic Society (FPS0057), Rutland County Council (FPS0071), Southwark Council (FPS0110), PricedOut (FPS0129)

664 Locality (FPS0086)

665 Q75 (Tony Mulhall)

666 CPRE the countryside charity (FPS0077)

667 Q164 (The Minister)

668 Qq165–167 (The Minister and Simon Gallagher)

669 Dr Chris Foye (Knowledge Exchange Associate at UK Collaborative Centre for Housing Evidence); Dr James White; Prof. Flora Samuel; Ton Kenny; Dr Gareth James; Dr Bilge Serin (FPS0033)

670 CPRE the countryside charity (FPS0077), CifA CBA & ALGAO UK (FPS0080), Sustrans (FPS0151)

671 Mr Richard Gilyead (FPS0022), Oxfordshire Neighbourhood Plans Alliance (FPS0052), Locality (FPS0086), Sustrans (FPS0151)

672 Institute of Historic Building Conservation (FPS0044)

673 Lifestory Group (FPS0116)

674 National Housing Federation (FPS0158)

675 Urban Vision Enterprise CIC, D2H Land Planning Development (FPS0037)

676 Pocket Living (FPS0023), Dr Chris Foye (Knowledge Exchange Associate at UK Collaborative Centre for Housing Evidence); Dr James White; Prof. Flora Samuel; Ton Kenny; Dr Gareth James; Dr Bilge Serin (FPS0033), Urban Vision Enterprise CIC, D2H Land Planning Development (FPS0037), Institute of Historic Building Conservation (FPS0044), Canal & River Trust (FPS0048), Local Government Association (FPS0056), Homes for the South West (FPS0070), GL Hearn (FPS0141), Centre for Cities (FPS0144)

677 GL Hearn (FPS0141)

678 Institute of Historic Building Conservation (FPS0044)

679 Urban Vision Enterprise CIC, D2H Land Planning Development (FPS0037)

680 MHCLG, National Design Guide, October 2019

681 CLA (FPS0049)

682 Accessible Retail (FPS0053)

683 MCHLG, National Design Code, January 2021

684 Dr Chris Foye et al (FPS0033)

685 South Worcestershire Councils (FPS0015)

686 Place Alliance (FPS0054), CPRE the countryside charity (FPS0077)

687 City of London Corporation (FPS0148)

688 British Property Federation (FPS0127)

689 Midland Heart (FPS0152)

690 Neighbourhood Planners London (FPS0032), National Trust (FPS0157)

691 CPRE the countryside charity (FPS0077)

692 Place Alliance (FPS0054)

693 YIMBY Alliance, London YIMBY, Oxford YIMBY, Brighton YIMBY, PricedOut, Cambridge YIMBY (FPS0017)

694 Home Builders Federation (FPS0073)

695 Institute of Historic Building Conservation (FPS0044), Canal & River Trust (FPS0048), National Trust (FPS0157)

696 Canal & River Trust (FPS0048)

697 Southwark Council (FPS0110), National Trust (FPS0157)

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