With a design lens, design partner at Marrons, Luke Hillson, gives his thoughts on the latest changes to the National Planning Policy Framework (NPPF), which concern clarity of communication, density, character and continue to emphasise beauty further
The proliferation of references to “beauty” can be attributed to the creation of the Building Better Building Beautiful Commission (BBBBC) and the publication of its report Living with Beauty in 2020.
The report received a mixed reaction, with some heralding it as a long-overdue aspirational call to arms for high quality design; while others were uncomfortable with it, feeling it was unrealistic and naïve.
The Living with Beauty report offered three scales of beauty: buildings (materials, proportions etc), places (streets, squares and the incredibly subjective “spirit of place”) and placed (ie location and wider connectivity), piling on the pressure for masterplanners, urban designers, architects and planners to deliver beauty at all levels.
The NPPF fails to define how beauty can be measured and scored
Despite introducing beauty, the new National Planning Policy Framework (NPPF) fails to define what it means and how something so subjective can be measured and scored.
According to the new NPPF “attractive” routes through developments are no longer sufficient, they much be ‘beautiful’ and there is an enhanced requirement for “appropriate densities” – potentially placing a cap on the number of dwellings within a development (beautiful, or not) and potentially a revised reason for refusal from local planning authorities.
However, the counterargument is that development proposals should only be refused if they are “wholly” out of character with the local context.
This will require urban designers and master planners to undertake more comprehensive and robust contextual analysis as part of the design process. It is anticipated that out-of-character development will be cited as a reason for refusal for applications moving forwards.
Conversely, it is anticipated that applicants will demonstrate that on many sites the context is of a mixed character; given the context is mixed it would therefore be difficult to be “wholly” out of character with it. It may not be long before we see this argument played out at appeal.
There is also further emphasis on the requirement for design codes and subsequent adherence to them. One of the issues is that some local authorities do not have the time, resources or expertise in-house to be able to produce the design codes for their development sites, neighbourhoods or regions.
Therefore, it is anticipated that we will continue to see applicants, often by appointing private design consultants, producing these design codes in collaboration with the local authorities or for the approval of the local authorities to expedite the process.
The requirement for the increase in design quality of proposals is clear
The requirement for the increase in the design quality (and beauty) of proposals is clear. Aligned with this is now a clear requirement that all submitted plans and drawings are “clear and accurate” (para 140).
While any previously submitted plans and drawings should have been clear and comprehensible, the updated NPPF would make it possible that we will see references to para 140 and unclear or inaccurate plans listed within reasons for refusal.
Without clarification of what beauty actually is, we may see more LPAs use this as a delaying tactic, or an easy reason for refusal on the basis that beauty hasn’t been achieved.
However, I suspect we may see many of these refusals overturned at appeal with appropriate design evidence, a robust design process and demonstration of need, particularly for housing.
The trick for applicants, developers and promoters will be to make something subjective (like beauty), objective, by undertaking comprehensive character and context appraisals and demonstrate how design proposals are responsive to this.
It is anticipated that design assessment tools, including Building for a Healthy Life, will increasingly be used to support applications.
How can the NPPF be improved?
Overall, the NPPF update (from a design perspective) does include some additional paragraphs and wording amendments that will require greater thought and consideration to the design proposals and how they are presented.
This will require more comprehensive contextual analysis and more carefully considered presentation of design proposals to tell the design process story and demonstrate how the proposals are appropriate and responsive. All of this aligned should expedite the planning process and contribute to delivering higher quality new homes, communities and neighbourhoods.
Luke Hillson 
Design partner
Marrons
Tel: +44 (0)330 912 2670
