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Is this house well designed?
CPRE planner Richard Thompson asks whether a welcome policy aspiration risks becoming just another developer-led tick-box exercise
Ask the public whether the above house is well designed and they are most likely to say yes, it is. Ask the same question to an architect, they are much more likely to dislike iti.
So who is right? What criteria should be applied in making this assessment? Are we just considering how the individual house looks, or how it relates to other houses? Could this design be considered locally distinctive in Kent? If not, why not and what is locally distinctive? Does what looks good in the centre of a town work equally well in the suburbs? If not, where should that line be drawn?
These are all questions that communities, local authorities and anyone else involved in the development industry will be grappling with over the coming months should proposed changes to the National Planning Policy Framework come to fruition.
Specifically, the proposed changes being consulted upon state that “development that is not well designed should be refused, especially where it fails to reflect local design policies and government guidance on designii.
To inform this, “all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code and which reflect local character and design preferences. These provide a local framework for creating beautiful and distinctive places with a consistent and high-quality standard of design”iii.
A proposed National Model Design Code is also being consulted on alongside the NPPF.
Importantly, “all guides and codes should be based on effective community engagement and reflect local aspirations for the development of their area”.
On the face of it, such proposals are welcome and it is heartening to see recognition of the role effective community engagement will have in this policy’s success. It is this engagement, and the local knowledge that comes with this, that will be key to grappling with the complexity posed by questions such as those above.
It is therefore extremely disappointing that there are no detailed guidance or proposals among the consultation documents as to how effective community engagement will work in practice.
Fundamental to this will be ensuring proper resource is provided to councils and local communities so they can effectively participate in the process. Without such resource, it will fall to those promoting sites and their consultants to demonstrate how they are creating “beautiful and distinctive places with a consistent and high-quality standard of design”.
If this is not properly resourced, an otherwise welcome aspiration risks becoming just another developer-led tick-box exercise, with the planning consultancy industry being handed yet another revenue stream.
- The consultation documents can be found here
ii Proposed Paragraph 133 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/961769/Draft_NPPF_for_consultation.pdf
iii Proposed Paragraph 133 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/961769/Draft_NPPF_for_consultation.pdf
Tuesday, March 9, 2021
- A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
- There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
- There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.
The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:
- There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
- A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
- Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
- Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.
Concerns about the rush to submit the plan
The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.
As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.
Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.
Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.
The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.
Further information
