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Government to scrap Design and Access statements for most works

Profession split over coalition’s decision to do away with ‘red tape’, with some fearing it could devalue the role of good design in planning applications

Profession split over coalition’s decision to do away with ‘red tape’, with some fearing it could devalue the role of good design in planning applications

The government has announced it will scrap Design and Access statements for the majority of planning applications later this month.

From 25 June, the statements will only be needed for major developments: buildings more than 1,000m² and housing projects of 10 dwellings or more. They will also still be required for listed building consent, though the requirements in conservation areas have been relaxed.

The coalition’s decision has split the profession. Some welcome the plan, described as a ‘more proportionate approach’ to planning applications, while others fear it will leave the public struggling to understand the design intention from drawings alone.

Robert Evans, of Matlock-based Evans Vettori, described the move as a ‘welcome red tape-buster’, adding that many statements often read as ‘marketing spiel’.

Evans said: ‘While it is helpful to articulate in writing the reason for a design being the way it is, on smaller projects this could be covered [simply] by a paragraph within the planning application form. Good design is a result of good designing, not good design statements.’

Chris Brown, of developer Igloo, agreed: ‘The reduction in information requirements for planning applications is where government should have started the process of streamlining planning. Design and Access statements have very little to do with good-quality design, as we can see in poorly designed new buildings all over the country. Their removal for small developments will not be widely mourned.’

But, despite assurances by communities secretary Eric Pickles that the relaxation was based on industry-wide consultation – and though the RIBA has backed the shake-up – many architects remained unconvinced by the changes, claiming the public is ill-equipped to judge applications by drawings alone.

Andy Puncher of London-based ph+ said: ‘Design and Access statements offer the public a narrative of a scheme, which [otherwise] is often difficult for them to read and understand.’

At best this move is careless. At worst, it’s further evidence of the government’s disregard for design quality

Stephen Harding, the RIBA’s former head of public affairs, who worked with Richard Rogers in Parliament to get the statements onto the statute books, said: ‘At best this move is careless. At worst, it’s further evidence of the government’s disregard for design quality. It makes it too easy for local planners to overlook the design elements of planning applications, leaving the rest of us to live with the consequences.’

Zoe Smith of ZS Architects added: ‘Although one could see this as a loosening of bureaucratic red tape, it does raise concerns about the wider discussion of how we define and argue for good design.’

Meanwhile, David Bonnett, formerly a member of CABE’s Inclusion by Design Group, said the change marked a ‘worrying reversal for inclusive design, especially for housing’ and feared for the future of the Lifetimes Homes standard.

He said: ‘Lifetime Homes Standards, the benchmark for inclusivity in housing, are only reviewed as part of the planning process and are not covered by later approvals stages.

‘This means that Lifetime Homes are now less likely to feature in small projects. ‘I can only hope the minister will change his mind or at least encourage local authorities to adopt Lifetime Homes standards for all projects as part of local planning frameworks. To do otherwise simply shifts the burden of poor housing, once more, to a future generation.’

David McCall of Manchester-based OMI Architects agreed: ‘This change will not speed up the process at all - it may actually embroil us in more complications. There is a potential that people won’t understand the scheme, object and we will end up having to explain it anyway.’</p>

Other comments:

Anna Scott-Marshall, RIBA head of external affairs:
‘The RIBA supports the government’s decision to simplify design and access statements. Design and access statements remain crucial in providing an outline on design concepts underpinning a scheme at pre-application stage, but we recognise that they have not always been used in the most effective way.’

Peter Stewart of PSPCA, architecture and planning consultants:
‘These statements were really just a way of codifying what was already being submitted by sensible applicants – particularly on major projects - to explain their schemes properly. Inevitably they became bureaucratised as a result of being made ‘official’. The government guidance always said they could be short and simple and proportionate to the demands of the project – somehow local authority planners and applicants, between them, managed to overcomplicate them.
‘I’d encourage applicants below the threshold, for scheme of any complexity or design ambition, to submit them anyway, to tell the story according to their own set of headings – in their own interests.’ 

Pascal Madoc-Jones, director of Madoc Architecture
‘Any architect who cares about their work will always attach to a planning application a summary of design approach. This will always be couched in the planner language, drawing attention to the relevant clauses in the UDP that apply and how the design responds to them. The reason is pragmatic – to anyone who sits through planning committee meetings and sees screeds of back of the fag packet applications waved without regard to anything but the local policies knows that design is not a primary concern. A statement is a form of insurance the application will be judged by the same criteria as the average, and not treated differently because it is different, and thus problematic.

There’s no connection between design quality and a bureaucratic requirement

‘The planning process for anything but major projects relegates design quality to a nominal issue – in fact aiming to achieve it almost certainly commits you to a hard ride through the process. Instead of design hurdles, the number of bureaucratic ones seem to increase year on year. I will continue to write up some form of statement for the pragmatic reasons above, but I do not delude myself that there is any connection between design quality and a bureaucratic requirement.’

Richard Simmons, former chief executive of CABE:
‘The government [in its response] says councils can still set design and access policies, and developers can explain their designs. I’m not holding my breath. If they do explain, where’s the saving in red tape? If they don’t, how will we know the interests of people with disabilities are being protected, and the public interest in good design is being safeguarded? Small developments can have a big impact on people. The government says it’s big on accountability, so it shouldn’t let designers and developers off accounting for their designs.’

Greg Lomas, co-founder of Foster Lomas:
‘This is a terrible idea. The design and access statement is actually a key document in explaining a scheme and communicating ideas that may not always be obvious from the drawings. Also it’s a skill to write a good statement - a marketable skill architects possess.’

Adam Knibb, founder of Adam Knibb Architects:
‘This has the potential to lead to bad and potentially unresolved designs. Although the statement sometimes can feel like additional unnecessary work, it serves to encourage a stratified build up from concept to proposal – something that should be implemented on each project. But without the requirement at planning it might be found that some less design-orientated companies take a quick fix approach and won’t consider a full design build up.

This has the potential to lead to bad and potentially unresolved designs

Nevertheless we will still continue to tackle each design on a specific site basis, building up from a concept to final design and producing background information - if not for the planners, then for the clients and ourselves.

Philip Breese, partner at WestonWilliamson + Partners:
‘This will not overly effect design. It is no secret local planning authoirty officers are already overstretched and underresourced to the point  we sometimes wonder if the thorough design and access statements we prepare are even read. Officers will continue to push hard those architects they know will deliver high quality design whilst on the flip side they will still allow through poorly designed  smaller schemes to enable targets to be met, whether a DAS is provided or not. 
‘We shall not miss writing a DAS  to reinstate a railing in RBKC but will continue to produce essential diagrams and sketches to explain our design development and conceptual thinking, no matter the size of the project. Final application drawings often can’t and don’t  convey this thinking. 
‘Fees have never really crept up to adequately cover the time required to produce a good quality statement, particularly for the smaller jobs. So perhaps we are heading back to where we actually started before the requirement for statements was introduced in the mid noughties. The question being will clients now be looking for even lower fees on smaller jobs citing our workload to prepare an application is now less?’ 

Readers' comments (3)

  • As a consultant who advises mostly on small developments the D&A is by far the most costly and time consuming element of the application. It is a matter of a few moments to set out the necessary information in a few short sentences, instead, a whole additional document is required. Planning officers are, generally, competent enough to secure all necessary details of design and to consider access for almost all small schemes without it being set out in a D&A.

    I am dealing with one application for a 24 square metre kiosk. The D&A from the original application was four times the length of to application itself! I am re-submitting after June 25th to avoid this.

    Good riddance!

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  • J MORRIS

    I reside on several design review panels across London Boroughs, and in some cases, the panellists are required to review schemes (some controversial/some small) by inclusion of wall mounted drawings and a presentation by the planning officer, minus Architect or Applicant. In these cases, the D&A forms an invaluable narrative and explanation for decision making both wrong and right. Invariably, a well formatted D&A reads true and reflects highly upon the application and design team to deliver quality, and in many cases this reassurance is important to local authorities. The current system is not infallible, and many abuse the format as a means to entice the poorly trained and the lay into thinking the scheme is delivering more than it can. The D&A is also often an excessive drain on resource and time. However, if programmed into the design development correctly and used as a record of progress, recycled regularly, it should not be a burden. Instead, a useful reference mechanism for the team, client and stakeholders. My view remains that the D&A is a useful and necessary tool. It provides an important reference tool for both local authorities and the wider community, and instils a degree of referential rigour allowing those reviewing, insight into chronic deficiencies within applications. A sense of proportion is all that is required however, and this isn't just a matter of scale, it is a matter of complexity.

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  • D7S statements are a waste of time most planning officers dont read them.

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