Planning for a Step Change in Design
August 2018 Issue
Reading the Ministry of Housing Communities and Local Government’s (MHCLG’s) press release about the new NPPF Revision 2 (try saying all that out loud), they’re keen to draw our attention to the following:
• Promoting high quality design of new homes and places
• Stronger protection for the environment
• Building the right number of homes in the right places
• Greater responsibility and accountability for housing delivery from councils and developers
In particular they refer to their ‘commitment …to promote and deliver a step change in the design quality of new development.’ There’s much to like in these strong words that bring a welcome emphasis on design.
So in simple terms the government should be applauded for that – which I’m sure is what they’re after.
We’re all happy – Hurrah! – and probably the housing crisis is solved too - Yay!
As usual however there’s a little more to things than that – which is why it’s worth reading the actual NPPF Rev 2, rather than just the press release about it.
In fairness there’s a lot of good stuff in it – though it’s more a refinement of the previous document than a radical departure from it – but most importantly the government must really be committed to the NPPF if it’s to have a significant impact on design – or anything else for that matter.
And there’s the rub.
Regrettably the MHCLG is just not a part of government one associates with commitment - and that’s an issue exemplified by its leadership. The current minister, Kit Malthouse, is the eighth in eight years – which doesn’t make the role look like one government much cares about. There’s definitely a larger timing thing going on here too. The election cycle is just too short for an incumbent government to be able to take credit (or blame) for the effects of its housing policy – and it’s too easy for government to find other people to blame, be they foreign investors or big bad developers – when problems do occur.
Perhaps this is picked up in their last point – about there being ‘greater responsibility and accountability from councils’ – but talk of responsibilities is only fine words unless those councils are given the resources to fulfil their responsibilities. The accountability bit I’m more cynical about because one of the major tools that’s being put in place from November this year, to measure progress, will be the ‘Housing Delivery Test’. This will record how many homes are actually built rather than just given permission for. It’s tricky to see how the blame for any shortfall in that number will be directed at anyone other than the developers doing the building. Time will tell.
Going back up through the other points it’s difficult to argue with the focus on ‘building the right number of homes in the right places’ and the NPPF’s methodologies and forms of measurement have been tweaked in this area – though it’s disappointing to see in Paragraph 68 that the percentage of new housing to be achieved on ‘small’ sites has been reduced from 20% to 10%. Disappointing because it leaves less room for the delivery of housing by smaller housebuilders and developers – a part of the housing industry government has previously made noises about being much more supportive of.
‘Stronger protection for the environment’ is generally always to be welcomed and I’m very pleased that the UN’s encapsulation of Sustainability as ‘meeting the needs of the present without compromising the ability of future generations to meet their own needs’ remains the opening statement of intent for the whole document (Paragraph 7). It would have been refreshing to have seen a more detailed interrogation of the Green Belt policy however. For the most part I’m a big fan of the Green Belt as an idea – it’s just that the existing boundaries need reviewing – too much of the Green Belt is simply not that green. Oh and I see that the Country House clause, Paragraph 55, has sneaked through under a new number – expect to hear a lot more about Paragraph 79e houses instead.
So at last we come to the first point – promotion of the ‘high quality design of new homes and places’. This is encouraging, and fortunately the direction of travel towards good design is positive for numerous other reasons as well.
Mostly, as always, money.
For example new forms of tenure, be they PRS or shared equity, are forcing long term investors to think very seriously about demanding higher quality, more durable, more loved, homes and communities - that retain a higher value over a longer period of time.
There remains a tricky issue about subjectivity however – which is made slightly more tricky by the inconsistent use of the word ‘design’ in Paragraph 130 which suggests that provided a design meets the basic criteria captured in local policies (be it for example the space guidance of the London Plan, or a local material design code) – then it should be given approval even if it’s not a very good design in terms of its subjective appearance – a bit of a ‘low bar’ approach – though I appreciate the bar has to be set somewhere. I’ll just have to hope that Local Authorities will have the confidence to turn down applications when the designs are horrible.
Regrettably many innovative architects and housebuilders could be on the wrong side of a planning decision anyway – simply because their design is not what the planning authority ‘likes’ or ‘knows’. The thing about innovation is that it tends to be different to what came before, which can make it difficult to understand and visualise.
The more optimistic side of me takes comfort from the NPPF’s encouragement for the use of ‘new visual tools’ however – so we can all actually understand what we’re looking at. I’m not a huge fan of VR (Virtual Reality) as a presentation tool yet – the kit remains bulky and difficult to experience collectively, but AR (Augmented Reality), 3D printing and CGIs are ever easier to produce and have all transformed our ability to communicate how a design will be experienced.
Let’s hope this lead to new homes across the country that Local Authorities and Communities don’t just seek to control but learn to love. That really would be a step change.