The proposed revised NPPF seems to endorse the simple-minded world-view of people who want to block development in general, writes Paul Finch
‘You need to read the draft revised National Planning Policy Framework (NPPF) as a whole’, advised the government’s chief planner, Steve Quartermain, at a recent conference devoted to how we go about getting more housing.
Marginally shorter than the 2012 original, the new draft is focused on housing in many of its aspects. The document comes from the usual department, but headed with its relatively new name: The Ministry of Housing, Communities & Local Government. It is partly based on four previous consultations, three of which concern housing and took place last year. ‘Government,’ says the introduction to the document, ‘is clear that the country needs radical, lasting reform that will allow more homes to be built.’
From the start, the implication is that it is planning that is preventing this happening – a highly dubious proposition but one beloved by politicians of all parties, desperate to avoid blame for the continuing failure to provide a sufficiency of homes, despite the glaring evidence that we have not been building enough for three decades. Hey-ho.
I have read the document in its entirety, and in general it reads well and is clearly organised. As ever with planning documents, qualifications to the basic guidance come thick and fast, the words ‘however’ and ‘except’ cropping up often enough to keep the planning lawyers happy.
There are, however (it is catching), some questions which I hope will be taken up by institutional respondents to the consultation, particularly in relation to Section 12, ‘Achieving well-designed places’, a stand-alone section which replaces the sub-section in the 2012 document, so perhaps a good sign. On the other hand, the word ‘architecture’ only appears once, and you sense it has been incorporated through gritted teeth. ‘Architect’ is entirely absent in this section and, as far as I can tell, in any other. ‘Planning’ is ubiquitous of course.
The word ‘architecture’ only appears once, and you sense it has been incorporated through gritted teeth
The status of architecture and its scope of activities have already been called into question in Section 3, ‘Plan-making’, where it is stated that ‘succinct and up-to-date local plans should provide a positive vision for the future of each area’. You might think that this would involve how a place would/could look and feel, but there is no reference to architecture or design at all. In a sub-section on ‘Strategic policies’, there is a similar absence of any reference to design. Is it really not a strategic issue? It seems not: ‘Strategic policies should not extend to detailed matters that are more appropriately dealt with through neighbourhood plans or other local policies.’
Back to Section 12 on design: ‘Plans should, at the most appropriate level (my italics) set out a clear design vision and expectations […] Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics.’
Localism may have been given the elbow politically, but it is alive and well in the creation of design policies which ‘should use visual tools such as design guides and codes’, none of which are specified, except Building for Life, which CABE did so much to promote.
All this probably sounds a bit picky, but there is a big discrepancy between some of the verbiage around policies and decision-making, and the criteria for assessing design set out in Paragraph 126, which is perfectly clear and straightforward. To be fair, it is followed by the statement that ‘Design quality should be considered throughout the evolution and assessment of individual proposals’.
I nevertheless return to picky mode in comparing what the ministry says in its consultation document, which tells you about all the changes envisaged in the NPPF, and what the draft actually says in relation to ‘outstanding design’ in Paragraph 130. The consultation document claims that the paragraph in the original document has been amended so that ‘outstanding or innovative designs should not (my italics) be given great weight where they are in conflict with local design policies, or would not be sensitive to their surroundings’.
This is what Paragraph 130 actually says: ‘In determining applications, great weight should be given to outstanding or innovative designs which promote high levels of sustainability or help raise the standard of design more generally in an area, so long as they are sensitive to the overall form and layout of their surroundings.’
To my mind the interpretation is way off the mark. I don’t doubt that planning lawyers will think the same way.
So, while the overall intentions of the proposed revised NPPF are clear, there is a niggling doubt about its understanding of and attitude to strategic architectural policies and initiatives. You wonder whether, in the end, it is endorsing the simple-minded world-view of people who want to block development in general, and in particular anything that looks as though it has been designed in the 21st century.