Design codes: intentions and reality

The principles and parameters in design guides and codes will raise design quality only if they are properly understood by those responsible for determining planning applications.

A figure from the National Model Design Code.

1 Introduction
2 Historic context
3 Current practice
4 Conclusions
5 Related articles on Designing Buildings

[edit] Introduction

In June 2021 the Ministry of Housing, Communities and Local Government (MHCLG) published a National Model Design Code (Part 1 The Coding Process and Part 2 Guidance Notes). According to the successor Department for Levelling Up, Housing and Communities (DLUHC) website, the National Model Design Code ‘sets out clear design parameters to help local authorities and communities decide what good quality design looks like in their area’. Prior to that, in 2019, the MHCLG had published a National Design Guide: planning practice guidance for beautiful, enduring and successful places.

The National Design Guide sets out 10 characteristics of well-designed places, the first of which is ‘context’. This is reinforced by the second, ‘identity’, which acknowledges the importance of local character, although the lack of specific reference to conservation area character appraisals is disappointing. The document is well illustrated with carefully selected examples of well-designed development, much of which is located in historic places.

The National Model Design Code builds on the 10 characteristics, and sets out a seven-step coding process largely based on dividing the area covered by the code into a set of typical ‘area types’. The guidance for the various area types is based on well-established urban design principles, and includes prescriptive detail on such matters as height/width ratios. While the broad-brush approach advocated should be helpful in routine situations, it is unlikely to be sufficient in relation to design proposals that impact on listed buildings and conservation areas, which invariably display unique characteristics and require a tailored approach. The copious illustrations in the National Model Design Code include isometric, axonometric and two-dimensional drawn diagrams. For some, the sheer volume of information could be overwhelming.

Local planning authorities (in England) are expected to prepare local design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, which should reflect local character and design preferences.

[edit] Historic context

The design of new development has always been a material planning consideration. In the past there was generally a reasonable amount of design expertise in planning authorities. Many chief planning officers were ‘architect-planners’, the larger authorities mostly had architects’ departments, many of the first phase of conservation officers were architects, and design was traditionally a key theme in most planning courses. However, in the early years of planning there was little in the way of design policy beyond platitudes that poor design should be refused.

Some planning authorities sought to fill the policy lacuna with design guides, which first appeared in the early 1970s. The seminal Essex Design Guide (1973) was denounced by architects as a rulebook. Its critics tended to ignore the fact that it set out fundamental principles of spatial arrangement that were rarely applied in housebuilding at the time. Similar design guides were provided by such authorities as Cheshire County Council and the Peak Park Planning Board, but few managed to match the depth and impact of the Essex guide. A large number of locally produced design guides evolved in the following decades, often having regard to specific subjects, such as house extensions, shopfronts, conversion of traditional farm buildings and development in conservation areas. While there has always been some hostility to design guides, there can be little doubt that those which have been influential over long periods, such as the North Norfolk Design Guide, have reinforced local distinctiveness and character. Design codes evolved, distinct from design guides, in that they usually set out a more precise template for appropriate development in a specific place.

National design policy eventually embraced urban design and townscape. However, the changes ushered in by PPS5 in 2010 and the NPPF in 2012 saw references to urban design largely expunged, replaced with a short set of design policies that encouraged design codes, but repeated previous warnings that design policies should not attempt to impose architectural styles or particular tastes, nor should they stifle innovation, originality or initiative. At the same time the one-size-fits-all policies for the different heritage designations saw the eradication of a townscape approach to conservation areas.

[edit] Current practice

The government’s current interest in good design was signalled in late 2018 with the establishment of the Building Better, Building Beautiful Commission. This was tasked with championing beauty in the built environment and advising the government on the reforms needed to ensure that new homes were built to much higher, locally popular design standards, and reflected local character and preferences. In addition to the publication of the National Design Guide and the National Model Design Code, the government has reinforced the NPPF design policies and associated online Planning Practice Guidance (PPG) to put a greater emphasis on design. In the words of the then secretary of state Robert Jenrick, who made the changes, ‘for the first time in the modern planning system, beauty and placemaking will be a strategic policy in their own right… this will put an emphasis on granting permission for well-designed buildings and refusing it for poor-quality schemes’. If only it were that simple.

Most English local authorities are yet to produce their own design guide or design code, and it is too soon to evaluate the impact of the government’s aim to achieve design quality through such documents. However, it is clear that the production of design guides and codes needs considerable specialist input if they are to be effective. Unfortunately, most local authorities no longer have architectural departments and most modern planners are not trained in design. While some authorities employ urban designers, the conservation and design officers of the past have often given way to more specialist conservation officers, who do not necessarily have design skills. While conservation and design stalwarts continue to fly the flag for design in some authorities, there is considerable concern that local government as a whole does not have the skills or capacity to produce the sort of design guides and codes that the government envisages. Design codes could be procured from the private sector, but they will be of little use if those involved in making decisions in the planning authorities do not have the knowledge and understanding to apply the principles espoused. Government advice stresses the need for community involvement in the production of design codes, but effective involvement needs to be facilitated by people who are in commend of the relevant design issues.

The design skills shortage in local government has been highlighted by the PLACE Alliance, the Urban Design Group and the Design Council in a joint research report entitled The Design Deficit (July 2021). This showed that of 235 English local authorities, three quarters employed no architectural advisers. Furthermore, the research found that many authorities that had ambitions to enhance their design capacity had been frustrated by funding difficulties and the inability to compete with the private sector. Less than a quarter of authorities were found to use a design review panel regularly and, while the use of design codes was seen to be increasing, a third of authorities did not know how they would produce or fund the production of codes, particularly if they needed to cover whole authority areas. With regard to upskilling, the research found that while the majority of non-design officers in planning authorities had access to some form of ongoing design training, this was typically focussed on raising awareness about design rather than on developing design skills. Consequently, it would seem that the shortage of design skills in local government could well fetter the realisation of the government’s ambitions with regard to improving the design of new development.

A further concern has been highlighted in a research report by the West of England Combined Authority and UWE Bristol entitled Design – the whittling away of wonderful ideas: post-consent and the diminution of design quality (April 2021). This found that the way in which post-consent planning processes unfolded could allow for a significant decline in the overall quality of a delivered scheme. Outline permissions were shown to be particularly problematic for ensuring design quality; planning conditions did not necessarily provide a quality safeguard; and the report found that non-material and minor-material amendments were being increasingly used by developers to chip away at the original design intent of schemes. Those with design skills in local government are less likely to get involved with amendments to approved schemes or enforcement. Clearly, the best-framed design code will be undone if its principles are not upheld throughout the whole development process.

[edit] Conclusions

The National Design Guide and National Model Design Code are impressive and thorough documents which, with the strengthened design policies and guidance in the NPPF and PPG, provide the strongest policy and guidance basis for good design that the planning system in England has ever known. However, that does not automatically translate into well-designed development. The Achilles heel in the government’s claim that the documents ‘will lead to beautiful and distinctive places with a consistent and high-quality standard of design’ would seem to be the lack of design skills and capacity in local government. If the design principles, parameters and requirements contained in design guides and codes are not properly understood by those responsible for determining planning applications, they will not raise design quality.

The government’s PPG promotes the use of design review panels to assist authorities. While these can be helpful, they rely on voluntary effort, have only patchy coverage across the country, and architects on such panels can be reluctant to criticise the work of other architects or to alienate potential clients. In addition to the need for upskilling, if design quality is to be achieved on the ground, planning authorities must ensure that approved schemes are not debased by post-consent amendments and failures to enforce implementation of approved plans. With respect to conservation of the built environment, the broad-brush nature of the content of the National Design Guide and National Model Design Code is unlikely to be sufficient to address the unique nature and design subtleties of many heritage design issues relating to listed building and conservation areas, which will inevitably require a more finely grained approach.

The IHBC has made a start on addressing the design skills shortage by publication of a Guidance Note on Design Sources for developing skills in design with specific regard to design in the historic environment. This is intended to provide a starting point for applicants and members wanting to upskill.

This article originally appeared as: ‘Design codes: intentions and reality’ in the Institute of Historic Building Conservation’s (IHBC’s) Context 172, published in June 2022. It was written by Roy Lewis, a former conservation officer, educationalist and planning and heritage consultant, who has been the IHBC policy secretary since 2016.

--Institute of Historic Building Conservation