Chapter 14
146) Do you agree that policy DP1 provides sufficient clarity on how development plans should deliver high quality design and placemaking outcomes? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons, particularly if you disagree.
The RTPI broadly welcomes much of Chapter 14, including provisions in DP1, which set out a clear understanding of high-quality design and place-making outcomes. However, the RTPI is unclear about the role of SDSs, given that provisions seem far more appropriately dealt with by local plans or neighbourhood plans.
We welcome the clear alignment with the Design and Placemaking PPG, which we will be responding to in full in its relevant consultation, however as set out in response to Q152(a), the RTPI would welcome explicit reference to the Manual for Streets.
The RTPI recognises the clear skills and capacity implications related to the local approach to design guides and codes, particularly given the recent MHCLG Skills and Capacity Survey which noted significant skills gaps relating to master planning and design codes, and urban design and architecture in local authorities. Please also see our response to Q9(a) regarding local plan resourcing.
147) Do you agree with the approach to design tools set out in policy DP2? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI understands that the use of local design codes will fit in the new plan-led system, especially in relation to the preparation of supplementary plans. However, we are unclear of how design guides and masterplans for strategic sites will fit into the new proposed system. We are also unclear about how such proposals would be expected to be brought forward through development briefs.
Regardless, we have long supported the need for such codes to reflect local contextual matters and welcome the revised framework in its reference to social, economic, and environmental contexts guide codes and masterplans. We note the move away from the legal requirement for local authority design codes and would therefore, as in response to Q145(a), ask for clarification on the role of SDSs in relation to design codes. Expanded use of design codes for strategic sites will have specific resourcing requirements for planning policy teams, including the need for review and monitoring of such expectations.
There will have to be a careful framing of local design codes through the guidance to ensure that they are just covering local matters. A careful balance will need to be struck between what can be varied at a local level and what should be approached as a national standard. There may be significant consequential details needing to be addressed as a result. The RTPI would request clarification on how policies related to DP2 and the Design and Place-Making PPG align with provisions set out in PM13(1). In particular, how proportionate and relevant evidence of local characteristic and need be justified in an event where quantitative standards are set through development plan policies, in line with PM13(1)(a).
148) Do you agree policy DP3 clearly set out principles for development proposals to respond to their context and create well-designed places? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI supports the principles set out within DP3 and the substantial weight attributed to well-designed places. In particular, we support the need to manage and balance existing contexts and the need to pivot to more sustainable approaches to urban form, as set out in policy DP3(1)(a). The RTPI would recommend that this policy be restructured to some degree, with DP3(3) moved before DP3(2), as going forward we would expect the Design and Placemaking PPF to be the starting point.
We would also welcome explicit connection with provisions in DP3(1)(e) to supporting the vision-led approach to transport planning, as set out in TP1. Similarly, as set out in response to Q146(a) the RTPI is unclear of the role of design guides and masterplans as set out in DP3(2).
149) Do you agree with the proposed approach to using design review and other design processes in policy DP4? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) If not, what else would help secure better design and placemaking outcomes?
The RTPI strongly endorses the use of design review panels, however we would recommend this policy simply encourage their use, not obligate local planning authorities to have access to them.
