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7) Recommendations

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7.1 The complexities of perceived low standards of design quality
7.2 Solutions in the shorter term
7.3 Fostering higher standards in design over the long term
 

Until recently, design quality had slipped off the agenda in the drive for housing delivery. It is unfortunate that quality design in the built environment, in the context at least of the role of planning, has alternately been promoted as a matter of interest to ministers and then relegated in successive administrations. This has meant that a sustained sectoral response has been difficult to achieve, leading to problems with maintaining skills and inconsistency in development industry outputs. Stop-start policies have had their consequences but there is a growing realisation now that unless communities have confidence that the product is good (which translates as, 'I want to live there'), there will be continuing resistance to new residential development – at almost any scale. 

7.1 The complexities of perceived low standards of design quality

There is no single cause for perceived low standards of design quality and their unquantified impact on housing delivery; the following paragraphs cite several reasons but do not provide a comprehensive list.

Housebuilders

There is not yet a general impression that the housebuilding industry, when considered as a whole, is willing to credibly commit to improving design quality on most sites, particularly in more challenging market areas. The view is that standard house types are overwhelmingly adhered to.

"Despite having a Design Guide in place for a number of years we struggle to get volume housebuilders to deliver anything but standard house types." (RTPI design survey 2019 response)

The NPPF

While design in the context of creating places is given prominence in the NPPF, when considered alongside other considerations (e.g. housing delivery and maintaining a 5-year land supply), it can often be hard for a local planning authority to refuse a scheme only on the grounds of bad design – and even harder to refuse a residential application on grounds of being only of 'average' design. Recognising that recommendations and decisions have to be based on the principles of design quality and must not be subjective, in too many cases the question for planning officers then seems to be 'is it bad enough to refuse?', as opposed to 'is it good enough to approve?'.

Precedent

Officers and members also often have to tackle precedent, where poor quality design has been permitted in the past and their decision making has to remain consistent, despite the perpetuation of poor quality design. They also have to balance competing interests on matters such as housing standards, or conservation.  In summary, there is a local authority planner and member-perceived inability to achieve high quality design, with all of these other material considerations and the ever-present threat of planning by appeal. This lack of confidence needs to be addressed urgently.

Cost, land values and viability

More widely, another overall barrier to quality design is often said to be cost; design is frequently the first aspect of a project to see reduced scope, if viability concerns arise – one reason being that it is not yet weighted highly enough in decision making.

Another reality is that quality design tends to occur in higher value areas where there is more development pressure, and where values support bespoke buildings. In lower value/ lower demand areas, the priority of politicians and planners is to encourage development as a matter of principle; design is low in the mix. It is also the case that some councils are understandably reluctant to commit resources to appeals and are concerned that too great a focus on quality will delay schemes and hold back the rate of housing delivery.

It is therefore not only the commerciality of a scheme that constrains design quality - and the extent of council expectations for the scheme to cover, or at least contribute to the wider place making agenda - but also a great many other interrelated factors that are outlined above.

In this environment, there needs to be more encouragement – and failing that, a requirement - for developers to improve design quality.

7.2 Solutions in the shorter term

The following suggestions for boosting design quality in the shorter term will only be successful if the Government explicitly supports and progresses all of them as applicable – a multi-faceted initiative is needed.

Revise the NPPF

As the very first step, higher benchmarks in design ought to be recognised by Government as essential for creating places where people want to live, work and spend time – the NPPF is not yet worded strongly enough. As Housing and Planning Minister Kit Malthouse has said [16], areas where high quality design and good urban design principles have been followed stand the test of time – they are 'the conservation areas of the future'.

The NPPF and the PPG need to explain how the development industry can embrace innovative design, alongside being very much focused on viability. It should be explained how design quality, if factored in at the outset of a project, does not necessarily add to development cost. At present, design quality is not given the weight it could be because of up-front cost considerations, but this would be different if NPPF policy made it clear that whole-life costs should be considered.

"Good design pays off in the longer term, both commercially and in terms of public benefits." (RTPI design survey 2019 response)

Give quality design appropriate weight on appeal

The consideration of design at appeal is also a current and clearly related concern. It may be a misplaced perception but there is a view that NPPF policy on design is not yet strong enough and consequently, there is at least a perceived lack of support for it from the Planning Inspectorate, when schemes have been refused on design grounds and decisions are being defended on appeal. One RTPI design survey respondent has reported how their own planning department:

'[…] might have greater confidence in securing better design quality outcomes if it was clearer that the Planning Inspectorate were doing the same.  I'm sure they are, it just needs to be more widely known.'

There is an RTPI member view that the NPPF's 'tilted balance', as well as appeal decisions generally, tend to perpetuate standard housing estate design across the country. Following a successful appeal, the conditions attached to the decision letter can limit the ability of planners to negotiate on detailed design matters (such as window reveals, material quality, brick or stone detailing) - matters which often make a difference to overall quality. 

The NPPF therefore needs to be more explicit about the degree of priority being given to local planning authorities having a 5-year housing land supply, which currently is seemingly the priority that is at the expense of everything else, including design quality. Poor design quality should be stated in no uncertain terms as sufficient grounds for appeal dismissal.

Boost the role of Homes England in promoting quality design

Homes England could have a hugely positive role to play in promoting quality design in residential-led developments.  Their current focus is on practical implementation and housing delivery; in time, this could develop to also include paying full attention to quality design.  For example, the public body should be creating guidance and examples of best practice for design codes etc. for the new generation of urban extensions and new settlements coming forward, particularly in the wider south east.

Revoke existing permitted development rights for changes of use to residential (and do not introduce proposed rights for upward extensions, or offices to residential rebuilds)

While poorly considered planning permissions can create precedents for further low quality development, a very significant problem is created by the current permitted development rights for changes of use to residential – particularly for offices changing to new homes (but also high street uses changing to residential). The RTPI has written extensively on the deficiencies of these rights and how they can create poor living conditions; the January 2019 RTPI response to the MHCLG consultation, 'Planning reform: supporting the high street and increasing the delivery of new homes'[17] is the Institute's most comprehensive and recent summary of the issues relating to there being no space standards, nor affordable housing or related infrastructure contributions (amongst many other unacceptable aspects).

Without these existing change of use rights being abolished – and the proposed rights for upward extensions and for office to residential rebuilds no longer being pursued by Government – there is an inherent contradiction in ministers or the Commission promoting design quality as a development principle.

Add to planners' design expertise, increase councillors' design training, and boost council resourcing

Commentators have often referred to a perceived lack of design skills in the planning sector. This is an issue which requires some careful analysis. As a result of deep, post-recession cuts and reduced resources, there has been a hollowing-out of design capability and understanding within local government, in parallel with the national changes highlighted in response to question 2 above.

There is an urgent need in the short term to address this lack of design expertise in local planning authorities - and in private planning practices - particularly when it comes to design details. This is based on a perception that is only in part justified, that 'planners' do not have design skills, or knowledge. Developers tend to regard their planning consultants as project managers for putting together submissions, rather than as professionals with important design inputs to be made. It is acknowledged however that there is a general misunderstanding in planning of the differences between style and design and the impact of detail; far too many post-permission changes are accepted as non-material or material amendments that in fact have a detrimental impact on design quality, as they are not properly understood on application. Less justified is a perception that planners do not understand architectural design and the costs involved in making scheme changes.

Therefore wherever planning professionals do have design skills, they should be recognised as playing an important role; developers should be encouraged to be willing and receptive to understanding that local authority and consultancy planners and urban designers can add value with their comments.

For councils, this issue is part of the much wider problem of under-resourcing. As explained in the RTPI submission to the 2019 Public Accounts Committee inquiry on planning and the broken housing market[18], the Institute's research on investing in delivery[19] led by Arup (2015 and 2018) found major reductions in planning staff, as well as evidence of other issues associated with Government cuts. Put simply, local authority budget cuts are impacting on design quality. One respondent to the RTPI survey commented how they are now, 'the only urban designer in a major size unitary LPA; until Government cuts there were 3 of us'.

This situation only adds to the overall issue of inadequate officer resourcing, summarised by a survey respondent as leading to a lack of officer time at pre-planning and in application determination, and at enforcement stage too.

Coupled with building regulations impacting on what can be achievable in design terms, and the ever-growing complexities of the planning regime that have been observed as creating a 'tick box' culture – particularly its development management processes – there is a perception that the creative aspects of the planning profession have been undermined. In response to the RTPI design survey, one member explained how instead, they 'would like to have more of a role in shaping how the design of a development can enhance its socio-economic performance e.g. pedestrian and cycle-focused design to enhance public health and social interaction'.

To help address these issues in the short term, Public Practice[20] could be encouraged to continue to grow the number of associates already being placed in hosting authorities across London and the south east. Once resource deficiencies have been made up in financial terms – the RTPI supports a further application fee increase, at least in principle, to this end – dedicated, in-house urban designer posts should be created and secured. Ideally, experienced conservation specialists should be appointed in-house too, to further promote the debate of design merits. 

 "No code or tool is a substitute for somebody who knows what they are doing and is able to exercise professional judgment".  (RTPI design survey 2019 response)

All of these more recently appointed, qualified officers would be a most important resource; they would be the first port of call for consultation on pre-application schemes, with their initial thoughts being likely to be invaluable in planning officers' assessments of emerging projects. To provide continuity, they could then advise and comment on reserved matters and full, major applications (and smaller, more complex schemes); additional resources should also be allocated to ensure that development management officers are able to properly consider and assimilate others' advice, using it to encourage scheme revisions where necessary to improve design.

Alongside boosting planners' design skills in the public sector and consultancy, councillor training on good design should be far more prevalent and undertaken as a matter of course a short time after election and appointment to any committee charged with determining applications. Building for Life 12 (see below) can be a useful training tool in this context, as well as helping in reviewing developments post-completion. This final review would help members – and other stakeholders – to learn what has worked well and what has not, and respond accordingly (via policy revisions and/ or taking different approaches to decision making).

Promote quality design-led highways' policies and standards

Beyond planning departments and council committees, many schemes are highways-led, with rigidly-applied standards tending to mean that proposed developments are first and foremost designed for the car. There is an RTPI member perception that there is, '[…] little or no willingness to ensure good quality design in local authority highway departments and also from the Department for Transport'. Housing-led development proposals that are considered to meet local highways' standards and requirements can prioritise elements contrary to quality design; twisting and curved roads for example lead to dead space which is a maintenance cost, limit permeability and harm the long term vitality of a neighbourhood.

The Department for Transport (and Highways England) should be much more focused on design quality, rather than improving the situation for cars. Additional Government and planning fee income resources should be used to focus on local highways' departments, to ensure officers have integrated training and an understanding of good design, leading to a move away from a car-led design approach to one that prioritises pedestrians and cyclists, and one that is landscape-led.

Local highway authorities can implement schemes without needing planning permission; this right could have the potential to bring about 'the biggest uplift in design quality', according to one RTPI design survey response.

A combined effort is needed to ensure that design in planning and highways interrelates and that highway standards do not trump wider, good design principles. 

Use quality design as the basis for planning policies and local guidance

Quality design should be a key factor in formulating and implementing planning policies, given that it can help to: improve health; create more environmentally sustainable places; attract investment; and support civic pride – all are key factors in place shaping. Local planning authorities should therefore ensure that their development plans include council area-specific design, and design-related, policies (both in local plans and neighbourhood plans).

Design-based statutory plan policies should then be used to prepare – and developers' attention should be drawn to – more detailed supplementary planning documents (SPDs). These can take hugely varied forms, depending on local circumstances and include: village design statements; AONB management plans; character assessments; residential design guides; and village design statements. Such SPDs generally should set out good design, area-specific approaches to development and provide some minimum guidelines for privacy, private outdoor space, sunlight etc.  Their guidelines can be revised more easily and quickly than development plan policy, if it is found that they ought to be superseded because principles underlying good design have advanced.

In one local planning authority, by way of example from the RTPI survey responses, an adopted Design Guide covers all aspects of design, consisting of 10 separate supplements on different topic areas. These are set in the context of policy requirements for development briefs and design codes for strategic scale developments, for all sites over 300 dwellings, and for smaller qualifying sites that meet specific criteria such as being located in areas of sensitivity, having multiple landowners etc.

Good practice guidance from both inside and outside England can be relevant when drafting plan policies and new guidance; for example for care home proposals, one English authority works to Stirling University's Good Practice in Design for Dementia and Sight Loss[21] and its most recently completed scheme was awarded a gold standard in terms of best practice in dementia care accommodation design. Likewise in Glasgow, there is an overarching place making policy that is supported by the Scottish Place Standard[22]; strategic development frameworks are now being prepared elsewhere on a similar basis. The RTPI's own 2017 practice advice on dementia and planning[23] is also applicable; it is being updated this year too.

Create local area design guides

There are multiple examples of local planning authorities producing and using design guides successfully – they may or may not refer to sustainability, and may cover e.g. 'urban living', housing, or simply 'design'. Examples cited in the recent RTPI member survey include:

  • South Northamptonshire Council, where the planning department has carried out its own assessments of what is 'locally distinctive' and produced its own comprehensive Design Guide[24].
  • Another authority's SPD design guide that covers a range of issues relating to local distinctiveness/ character and residential amenity.
  • Manchester City, where schemes are assessed against the Manchester Residential Quality Guidance[25] (2017); guidance in relation to character areas, and conservation areas and historical analysis, also assists with allowing new buildings to complement heritage.
  • Reference being made in one authority to the Yorkshire Dales National Park Design Guide[26] (2015) that is included in a local plan policy and is constantly used to assess design quality in the National Park.
  • Another local authority that already has a conservation and design team in place is putting together 'design quality indicators', to assess developments. Due to resources, this will be restricted to larger schemes but the intention is that the indicators could actually be used to assess a range of different development types and scales.
  • In another local authority area, design is one of the most important considerations, with much emphasis placed on the Council's Design Guide. But despite having a Design Guide in place for a number of years, the respondent here also highlighted how it can still be, 'a struggle to get volume housebuilders to deliver anything but standard house types', while also recognising how they 'drive efficiencies to keep house prices down'.

Promote quality design in planning applications and decision taking

Whenever design quality is identified as a key issue, national guidance should encourage high levels of 'end-to-end' engagement from developer teams and local planning authorities alike, from pre-application discussion and negotiations on e.g. parameters, through to discharge of conditions, including liaison with design officers, and/ or panel design review of projects (see further detail below).

At pre-application stage, council and developer team planners should be encouraged by the awaited PPG on well-designed places to work closely with the scheme architect, to ensure a full site appraisal is carried out on every project and an explanation is provided as to how this has informed the submitted scheme – both should be described in the planning application design and access statement (DAS). This suggestion is made in the wider context of a view that the role of DAS has been generally 'dumbed down' over the years, as the Government's above-referred-to focus on housing numbers has left matters of quality behind. DAS can now tend to be given to the architect and/ or planning consultants on a project to write in a matter of days, prior to application submission. They can also tend to contain very limited information about either 'the bigger picture' or the detail, e.g. of how 'places' will be constructed and the quality of materials to be used. They then become generic documents about site context and justification, and not about design quality. As such and as a generality, they can be less innovative or exciting; their role in the development management process can be limited and needs to be reviewed, and their former usefulness when first conceived reinstated.

One suggested DAS approach suggested in the RTPI design survey responses would be - potentially via the PPG - to ask applicants to establish a design narrative from aspects of the local landscape and cultural heritage that they are then responding to in the design of their buildings and landscape.  This would provide an objective framework against which planning officers could review character, and ensure the approaches to massing, articulation, materials and detailing are consistent with the narrative. 

Consideration should also be given to guidance for applicants being to combine townscape and landscape assessments (and increasingly, water management should be added into design codes and parameter plans). Landscape assessment should as a matter of course be at a more local level than that available at national and district authority scales.

In decision-taking, planning officers and other decision takers should be looking at how the proposal fits its locality and local character – relevant material considerations would include: scale; height; building line; respect for neighbours; tree protection; daylight and sunlight reaching adjoining sites and buildings; protected/ created views; vehicular access points; and materials (preferably with them being conditioned at permission stage, not left for submission via the discharge of conditions). Details can be hugely beneficial to the overall appearance of completed developments; national guidance should explain how prescriptive advice from officers and related planning conditions can be beneficial to developers in this regard.

Will improving design quality create better outcomes for place making and for communities?

Design Quality Chart 2

Design review

The role of independent, local or regional design review panels - particularly but not solely for major schemes - can be critical to ensuring that design quality is considered in terms of built form, accessibility and landscape. Likewise, design review can also assist with the recognition of landmark design, which might otherwise be 'trumped by matters of principle' – as one survey respondent put it - as a consequence of inflexible policy and guidance.

But it has to be recognised that there can be a cost involved that may render this stage unaffordable for some projects. Another form of less formal design review may then be helpful before/ during pre-application stage, where a developer's team/ their architect involves a consultant/ another architect to be 'a critical friend'. Peer review is another possibility.

Whether internal or external, or if for smaller schemes in the form of design surgeries held together with officers from other departments – design review can also be particularly effective when combined with comments from an accessibility forum.

The timing of design review is key; panel advice should not be sought too late in the day i.e. when the scheme's design is largely finalised and ready to be submitted for planning, and when there is only limited scope to make improvements beyond relatively minor tweaks.

In conclusion, the awaited PPG on well-designed places should elaborate on the extensive and versatile roles that design review can play in enhancing quality, by the timely assessment of schemes of all different scales and types.

Use available tools to help achieve design quality

There is already a vast resource of published material available for assisting the development sector in ensuring design quality in the built environment; the difficulty is that it is not all accessible on a single web site. As a consequence, not all of the sources are used and applied consistently.

While much of the guidance and advice available may have been prepared some time ago, this does not mean at all that it is outdated – the converse is often true.  Some local planning authority officers responding to the Institute's design survey are strong advocates, or make extensive use in assessing major applications, of Building for Life 12[27] (Design Council, 2015)[28] – despite other planners being of the view that it does not necessarily of itself create well-designed places. There is a concern that some housebuilders rate their own developments with 12 'greens', despite a scheme's clear and obvious issues.

And there are numerous Historic England design guides and CABE publications that are as relevant today as when published. The Urban Design Compendium[29] (Homes and Communities Agency, 2000) and Manual for Streets[30] (2000) are still potentially invaluable resources, as are many RIBA[31] and  BRE Group past publications[32]. More specialised guidance is also available, such as HAPPI[33] (Housing our Ageing Population Panel for Innovation) and Chartered Institute of Building codes of practice[34]. But next to none are tools that are frequently, or consistently, applied. Their limited scope as individual publications also means that used in isolation, they do not necessarily create a well-designed place.

There are also very up-to-date tools that should increasingly be brought into everyday use in pre-application and planning application determination processes; these tools include Vu.City, and Photoshop that can help make alterations to improve layout and elevations.

More simply, the use of 3D models of designs should be promoted, to test their quality prior to planning submission stage. 

Rather than using technological tools or design codes however, there could be clear encouragement in the forthcoming PPG to adhere to simple architectural principles as they are more likely to achieve design quality – these include symmetry, active frontages, avoiding blank facades, window hierarchies, equal casements, rhythm and interest, and above all, quality materials. This approach could provide the consistent approach to design quality that is needed across England, being a loose framework of design principles that each local planning authority can then adapt to its own local character and setting.

Post-occupancy evaluation

Not only should management and maintenance arrangements for common parts and public realm/ green infrastructure be considered early in any emerging project, there should be sufficient planning authority resources available to undertake post-occupancy evaluation (similar to DCLG's Code for Sustainable Homes[35] that was withdrawn by Government in March 2015[36], or that is still part of BREEAM[37]); post-occupancy Building for Life-type assessments are perceived in response to the design survey as inadequate by comparison.

Post-permission checklists can however be satisfactory, if based on Building for Life criteria and local plan design policy criteria, with the combination being used to assess a scheme against opportunities, constraints and client objectives. This also enables statutory design policies to be monitored e.g. annually in terms of how they are improving design.

Planning professionals should in any event visit good schemes post-occupation; likewise, there should be annual scheme reviews for members of planning committees. For example, one RTPI member's authority conducts annual 'Quality Counts' tours that include architects, planners, councillors, amenity societies and members of the public. Observations are used to inform policy making (a new residential design guide was recently adopted) and decision taking. 

7.3 Fostering higher standards in design over the long term

Over the longer term, Government, local authorities, stakeholders and the entire development sector together need to actively promote what 'good' looks like, in relation to 'higher standards in design'. There are two key suggestions relevant here, for implementation over the longer term:

Outline applications and permissions

While some planning authorities do try to bring higher quality design into their areas, this may continue to be difficult in the longer term in relation to outline planning applications and permissions for residential development - and housebuilders being able to argue that their existing offers sell well. One possible longer term remedy for this situation could be a new requirement (for full applications and reserved matters) for a specific 'Housing Design Quality Statement'. This would be a bespoke document for each housing site, focusing on the design of the individual dwellings proposed, their construction and materials, and the 'place' that they create. The emphasis would be on innovation and creating exciting new homes.

Planning and architecture education

More fundamentally and from the start of higher education, architecture and planning could explore joint ways that the education system for both professions could develop opportunities for shared teaching, particularly in early years, so as to ensure that each has a clearer understanding of the other. For example, the teaching of urban design principles and practice on both architecture and planning courses could be strengthened, to increase an appreciation of context and sustainable development.

Learning from existing good practice, such an approach to planning and architecture education could assist in fostering both professions' confidence, particularly once in the workplace and when listening to, and supporting community aspirations, and when part of multi- and cross-disciplinary teams working on larger developments.  These teams invariably include chartered town planners as the key delivery agent, working alongside high quality architects and landscape designers on ensuring implementability. Planners and architects that can bring a collaborative approach should be better equipped to help ensure the best comprehensive design is achieved, incorporating open spaces, highways, sustainable drainage systems and green infrastructure. A multi-disciplinary team approach to place making – with a greater focus on the role and benefits of spatial planning - should be considered as one of the principal routes to achieving quality design in the built environment. 

Place making, through planning and masterplanning, should also continue to be seen as core components of both professions' Continuing Professional Development.

 

[16] Hansard (2018) Beauty and the built environment. https://bit.ly/2YP3mZJ

[17] RTPI (2019) RTPI response to the MHCLG consultation, 'Planning reform: supporting the high street and increasing the delivery of new homes. https://bit.ly/30zdk33

[18] RTPI (2019) response to Public Accounts Committee inquiry on planning and the broken housing market https://www.rtpi.org.uk/knowledge/consultations/2019-responses/rtpi-response-to-public-accounts-committee-inquiry-on-planning-and-the-broken-housing-market/

[19] RTPI (2018). Investing in Delivery https://www.rtpi.org.uk/investingindelivery

[20]  Public Practice website. http://www.publicpractice.org.uk/

[21] The Dementia Centre. https://dementia.stir.ac.uk/design/good-practice-design-dementia-and-sight-loss

[22] Place Standard. How good is our place? https://www.placestandard.scot/

[23] RTPI Dementia and Town Planning. https://www.rtpi.org.uk/knowledge/practice/dementia-and-town-planning/

[24] https://www.southnorthants.gov.uk/info/145/supplementary-planning-guidance-and-documents/245/design-guide https://bit.ly/2YNEDVD

[25]Deloitte Real Estate on behalf of Manchester City Council (2017). Manchester Residential Quality Guidance

[26] Yorkshire Dales National Park Design Guide (https://bit.ly/2VGVdUT

[27] Building for Life. Built for life. http://www.builtforlifehomes.org/

[28] Design Council, Building for Life 12.  https://bit.ly/2F0epqp

[29] Homes and Communities Agency (2000). Urban Design Compendium https://www.gov.uk/government/publications/urban-design-compendium

[30] MHCLG and DfT(2007). 'Manuel for Streets', Designing and modifying residential streets. https://www.gov.uk/government/publications/manual-for-streets

[31] RIBA Publishing. https://www.architecture.com/riba-publishing

[32] Bre Publications and News. https://www.bregroup.com/certifiedthermalproducts/page.jsp?id=3060

[33] Housing our Ageing Population Panel for Innovation (HAPPI) https://www.housinglin.org.uk/Topics/browse/Design-building/HAPPI/

[34] The CIOB Codes of Practice. https://www.ciob.org/ciob-codes-practice

[35]Communities and Local Government (2008). The Code for Sustainable Homes, Setting the standard in sustainability for new homes. https://bit.ly/2VGRpDo

[36]  Ministry of Housing, Communities & Local Government and The Rt Hon Lord Pickles (2015) https://www.gov.uk/government/speeches/planning-update-march-2015

[37] BREEAM. https://www.breeam.com/

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