How inspectors are interpreting the NPPF's demands for better design

Revised national planning policy introduces new requirements for authorities and applicants that aim to boost design quality in new schemes. But how is it playing out on the ground, Colin Marrs asks.

The revised National Planning Policy Framework (NPPF) issued in July introduced a heightened emphasis on design standards in new developments. Paragraph 124 of the document states: "The creation of high-quality buildings and places is fundamental to what the planning and development process should achieve."

Paragraph 129 declares that councils should use workshops to engage the community in schemes’ design. Meanwhile, paragraph 130 says that authorities should seek to ensure that development quality is not "materially diminished" between permission and completion. So are the strengthened policies bolstering councils’ ability to resist bad design?

Since July, at least six appeal inspectors have cited the new policies in their reports. In all six cases, they backed local planning authorities’ original decisions to turn down the developments, citing design grounds among their reasons for refusal. Former RTPI president Colin Haylock, a partner at architects Spence & Dower, says the decisions are important. "Officers will track them and will be saying to members that they should have more confidence about refusing badly designed applications," he suggests.

One of the decisions (DCS Number 200-007-812) involved a riverside scheme in Mitcham in south-west London. The inspector concluded that the three-storey residential blocks proposed possessed "largely featureless elevations and buildings appearing to ‘turn away’ from the river". But the other five were in rural locations. In dismissing reserved matters applications for a seven-house scheme in Lingfield, Surrey (DCS Number 400-019-475), the inspector decided that the latest plans were "materially diminished" from outline drawings showing soft landscaping and attractive, well-detailed and proportioned homes, thus failing paragraph 130 of the new framework.

Another rejection, of a scheme to build 72 homes at Fareham in Hampshire (DCS Number 200-007-859), stated that the proposals "would not represent high-quality design and would not contribute towards an attractive, inclusive, safe, well-connected and sustainable community as required by the adopted development plan and national policy in paragraphs 134, 127 and 130 of the NPPF". Design concerns also featured in decisions to turn down plans for four houses in Langport, Somerset (DCS Number 400-019-780), and a rooftop extension to a converted block of flats in Eynsham, Oxfordshire (DCS Number 400-019-556).

Meanwhile, Ministry of Housing, Communities and Local Government officials who attended a recent meeting of the cross-sectoral National Planning Forum highlighted a decision from Worcestershire in early August as an early example of the impact the revised policy is having. In rejecting proposals for 175 homes outside the village of Great Witley (DCS Number 400-019-436), the inspector concluded that the loss of attractive landscape, and its replacement by a poorly designed housing estate, weighed heavily against the scheme’s housing benefits, when judged against the criteria in paragraph 127 of the NPPF.

Councils have always had powers to turn down planning applications on design grounds. But
according to David Birkbeck, chief executive of the not-for-profit Design for Homes organisation, these decisions are likely to give councils more confidence in refusing schemes on such grounds. "Because it was not previously clear which way inspectors were going to jump on design concerns, a lot of authorities didn’t fancy going to appeal. Now there looks like there might be greater confidence to do so," he says.

Former Royal Institute of British Architects president Ruth Reed, a director at consultancy Green Planning Studio, says developers are also likely to sit up and take notice that the strengthened regime is being enforced. "Developers like clarity, and they will prefer knowing where they stand rather than seeing design costs being ramped up later in the process," she says. But Ben Bolgar, senior director at the community development charity the Prince’s Foundation, says developers who factored low design cost assumptions into the price they paid for land could now face difficulties. "The intention of the NPPF is that any increase in costs due to stronger design requirements should come off the land value. However, some developers may now effectively have paid over the odds," he says.

Birkbeck says volume housebuilders have the skills to respond to the strictures on design. "If you walk into Barratt or Wimpey you’ll find an urban designer and get proper squares and layouts," he says. "But the smaller firms doing it well are the exception rather than the rule". But equally, not all national housebuilders have a good track record in this area, he adds. "In my experience, they don’t have any incentive to build a quality product. They know it is relatively easy to sell a house and are only answerable to shareholders, who require maximisation of profits."

Economic factors are likely to determine how hard councils push the NPPF’s design policies, says Haylock: "While economically successful areas might be heartened by these decisions, in the North East and other deprived areas of the country a lot of councils are desperate to attract development and might not have the courage to say a design isn’t good enough." He points out that councils may find themselves caught between the NPPF design requirements and another aspect of the revised framework – the housing delivery test – which will penalise authorities in which completions fall beneath certain thresholds. "On the one hand, the government is encouraging a greater focus on quality, on the other, it could be punishing councils for turning down development and missing their targets," he says.

As well as increasing expectations of councils in terms of community engagement, the revised NPPF also urges them to use design tools such as Building for Life assessments and to have regard to design advice and reviews. "Design review is fundamental and works extremely well on large schemes, but smaller ones cannot support the cost," Birkbeck warns.

Local authority design expertise will also be essential to driving up standards, experts suggest. Paul Seddon, director of planning and regeneration at Nottingham City Council and president of local government group the Planning Officers Society, says: "I’m lucky in that I have been successfully able to argue for increased planning fees to retain and bolster our in-house design team. Not all councils will find such resourcing easy."

While welcoming the recent suite of inspector’s decisions, Seddon insists it is too early to reach firm conclusions on the effect of the revised NPPF on design quality. "We are turning an oil tanker round," he says. "I don’t think we have yet won the hearts and minds of the nation for the level of housing growth needed. The spreading of good practice can help with that, but if we don’t get it right, bad design sneaks through." 

Five steps councils can take to boost the quality of design

1. Enable effective pre-application discussions. Meeting with developers to discuss early-stage proposals can help them to understand your authority’s design requirements, say Paul Seddon, director of planning at Nottingham City Council and president of the Planning Officers Society, which represents local authority planners; and David Birkbeck, chief executive of the not-for-profit Design for Homes organisation. The earlier these discussions take place, the less money developers will have to spend on amending schemes at a later stage, they say. Giving developers in-depth insight into your strategic design guidance can help them achieve planning permission, they add.

2. Make use of design reviews. Running proposals past a panel of design experts as they progress gives developers valuable feedback about where they need to make design changes, says Seddon. Councils do not necessarily need to create design review mechanisms themselves, he adds. Many regions and cities have design review panels covering a wider area with services accessible for all councils, he says.

3. Resource specific design posts. Increased income from planning application fees can allow councils to beef up their staffing levels, allowing better pre-application advice for developers and greater certainty over design requirements, say Seddon and Colin Haylock, partner at architects Spence & Dower. Cash can be set aside from central government pots such as the Planning Delivery Fund, which aims to support joint working, high-quality design and innovation, they add.

4. Give councillors design training. With ever-changing government guidance and a regular churn of councillors, it is important that those voting on planning decisions have a good grounding in local and national design policy and guidance, says Ruth Reed, a director at consultancy Green Planning Studio. The Local Government Association, in association with government adviser the Design Council, offers workshops and resources.

5. Update local plans. The revised National Planning Policy Framework says local plans should set a "clear design vision and expectations" to help officers provide certainty to applicants. It adds that policies should be developed with local communities, while supplementary planning documents should use "visual tools such as design guides and codes".

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