Do you agree that the usability and effectiveness of the draft Design and Placemaking PPG has improved? [Yes/No/Neither agree nor disagree]
Yes.
Are there any aspects where clarity, accessibility, or practical application could be improved to better support design and placemaking outcomes?
Although the RTPI welcomes the general alignment between the draft NPPF and the draft PPG, we have concerns that a lack of clarity around design guidance and where it fits with the new local plans and supplementary plans.
For most design policy matters, the NPPF signposts the PPG, which gives planning authorities agency over deciding whether design tools (including guidance, codes and masterplans) should fall within local plans or supplementary plans. Residential design guidance and similar documents are currently often Supplementary Planning Documents (SPDs) which can be drafted without being examined. We know the government intends to phase these out, replacing them with Supplementary Plans, and local authorities will not be able to adopt new SPDs after June.
Requiring design guidance to be examined (within local plans, neighbourhood plans or supplementary plans) is unlikely to fit with Government’s intended goal of streamlining plan-making and speeding up decision-making and would increase the resource burden on planning policy teams. The RTPI would encourage Government to include advice within the PPG on how design guidance, and other technical advice which supports the implementation of policies, can be produced in a proportionate and pragmatic way to facilitate high-quality development.
Furthermore, the RTPI strongly supports the use of design review panels, and the PPG should encourage their use, whether they are a local panel affiliated with a particular LPA or an independent panel that works across a region. Additionally, the wording on page 64 could be strengthened to emphasise that effective design reviews should consider design as an integrated part of the wider planning context. This would help ensure that design review feedback avoids being overly narrow in scope, and acknowledges the integrated approach needed to deliver high-quality and successful places.
We welcome the clear reference in the PPG to Manual for Streets, to promote high standards of street design. We are aware of the government’s intention to publish an updated version and would strongly encourage the publication of the revised document, which should refer to the new NPPF and PPG, alongside them. This would support the design ambitions of the NPPF and the PPG and ensure a joined-up approach across design policy and guidance.
Do you agree that the principles set out in the draft Design and Placemaking PPG adequately address the needs and requirements of traveller sites? [Yes/No/Neither agree nor disagree]
Neither agree nor disagree.
What additional considerations or clarifications might be necessary to ensure planning practice guidance supports inclusive and culturally appropriate design and placemaking?
Regarding inclusive design, the RTPI would welcome a nationally consistent approach to accessibility through building regulations that creates certainty for developers and enables them to better embed inclusive design in the places they deliver.
Additionally, as set out in our consultation response to the draft NPPF, we would appreciate clarification on how the contents of the draft PPG align with provisions set out in PM13(1) of the draft NPPF, in relation to what constitutes proportionate and relevant evidence of local characteristics for justification of local quantitative standards.
Do you agree that tools, such as model design codes, could speed up the preparation of local design codes? [Yes/No/Neither agree nor disagree]
Yes.
What other tools would support this?
We note that MHCLG intends to develop a series of model design codes, which we agree would speed up the preparation of local design codes. On top of these forthcoming model codes, frontloading effective and meaningful engagement would help speed up and improve the preparation of local design codes.
As suggested by the PPG, this could include using digital tools such as 3D visualisation tools, or gaming platforms for engaging younger audiences, or more traditional methods, like place assessment tools and workshops.
Whatever approach is utilised by local authorities, preparing local design codes will have skills and capacity implications. As we outlined in our NPPF consultation response, this is acutely relevant given the recent MHCLG Skills and Capacity Survey, which noted particular and significant skills gaps relating to design codes, urban design, and architecture within local authorities.
