Shaping the NPPF and National Design Code

A summary of our response to the Government consultation on England’s new planning system.

01 April 2021

At the end of March, we published our response to the Government consultation on proposed changes to England’s National Planning Policy Framework (NPPF) and new National Model Design Code - see here.

It was an opportunity to share feedback on proposals to reform the current complex system, and create a new framework that can better address the challenges facing our society – from the climate emergency to the serious lack of well-designed affordable housing.

Throughout March, we hosted a series of regional roundtables with the Ministry for Housing, Communities and Local Government (MHCLG) and our members to discuss the proposed changes. These incredibly informative sessions enabled members to outline their concerns and thoughts on the new planning system.

It’s not all about aesthetics

The primary point of concern – shared by the RIBA and members – is that the proposed reforms place far too much emphasis on external visual appearance and do too little to address better design. We need reforms that focus on the quality, safety and sustainability of places, not on their aesthetic integrity.

Where’s the focus on sustainable development?

Given the Government has committed to achieving net zero by 2050, the draft NPPF lacks the policies needed to achieve this goal. We need further amendments to strengthen environmental rules and greater emphasis on the critical role Local Authorities play in reaching these targets.

Inclusive engagement is key

To create truly inclusive places that provide for communities, we must engage with all members of society. This includes engagement with older and disabled people, and that might require more accessible methods, such as non-digital communication tools.

We also call for the NPPF to establish the accessible and adaptable standard M4 Category 2 as the regulatory baseline for all new homes, and give a national minimum for the proportion of new homes that should be developed to wheelchair user standard (M4 Category 3).

Local Authorities must be able to oppose Permitted Development

The fact these proposals will limit the operation of Article 4 directions – which have been essential in protecting areas from existing Permitted Development Rights – remains a cause for concern. Despite the resource burden that accompanies Article 4 directions, Local Authorities must retain the power to oppose the development of poor-quality PDR housing and protect the vitality and purpose of high streets.

Fundamentally, the NPPF’s current emphasis on "beauty" will not deliver housing fit for future generations. The framework places an unnecessary centrality on aesthetics and side-lines sustainability, accessibility, and adaptability in the process. Why has the word "innovation" been removed from the document? When design is not driven by an innovative approach, or lead by suitably qualified professionals, we increase the possibility of enforcing the status quo.

The National Model Design Code must also reflect these points. While we strongly endorse plans to appoint a Chief Officer for Design and Placemaking in every Local Authority, we urge the Government to ensure the Code references inclusive design; requires Local Plans set out accessible housing standards and clarifies the critical role of the Office for Place. Our Local Authorities need to be properly supported and resources to deliver the developments we urgently need.

The RIBA’s full response to the consultation can be read here.

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