Design coding, what’s next?
The National Planning Policy Framework consultation has brought design codes back into focus for us at the Quality of Life Foundation. Vicky Payne, our Strategy Research and Engagement Lead, worked on the 2021 National Model Design Code (NMDC). She explains the basics of design coding, the background to the NMDC and the current policy direction.
What are design codes?
A design code is a set of clear, measurable rules that control the design of a place.
They differ from design guides in that they enable binary decision making; yes the code has been followed, or no it has not.
A design guide might say “heights of new buildings should be in keeping with the surrounding area”. A design code might say “heights of new buildings should be between 3–5 storeys”.
Codes can be made flexible by having wider acceptable ranges or fewer rules.
The 2019–2021 design agenda
The Government published the National Model Design Code in 2021, and made accompanying changes to the National Planning Policy Framework. This sought to give design coding a greater role in the planning system.
Its development was influenced by the Building Better Building Beautiful Commission (BBBBC 2019–2020) the National Design Guide (2019) and the Planning White Paper (2020) which explored the idea of a zonal system.
Design coding had been used on individual sites up to that point, but the 2021 changes formally required local planning authorities to produce codes and introduced the possibility of setting design rules for a wider area.
A pilot programme in 2021 gave 15 teams £50,000 each to test the coding process. Then the “Pathfinders” programme in March 2022 awarded £3 million to 25 teams to demonstrate best practice. The updated NPPF wording emphasising the importance of design seemed to be filtering through into decision making.
‘Well-designed’ vs ‘beautiful’
Although the policy direction behind the NMDC was propelled by the BBBBC, it’s intended to be stylistically neutral.
A well-designed place can be beautiful, but beautiful buildings are not required for good urban design.
There are a set of principles that, although they do not have to be used all the time in every situation, tend to result in better outcomes when they are considered in the design process.
What’s next for design coding?
Discourse on design coding seems to have hit a lull since the launch of the Pathfinders in March 2022. But the progress of the Levelling Up and Regeneration Bill (LURB) and the NPPF Consultation has brought it back into focus.
The LURB seems to require codes to be produced for the whole local authority (page 305), whereas the NMDC and 2021 NPPF allowed for flexibility about how much of a local authority the code covered. The proposed NPPF text from the December 2022 consultation seems to assume the widespread presence of codes to determine appropriate character (footnote 8, page 6).
This feels like a shift in policy that has not been significantly publicised, and one which local authorities may not be prepared for: the Pilot authorities found the full coverage approach to coding one of the more challenging aspects to grasp, according to a UCL evaluation; the Pathfinders programme has not yet shared outputs; and local authorities are struggling to find the resources to maintain current performance, without the requirement to produce comprehensive codes.
The picture is made more complicated by a number of factors.
Firstly, the renewed focus on beauty rather than design. We reflected on the problems thrown up by integrating a word like beauty into a national policy document previously. One of which is the uncertainty about what constitutes a beautiful (and therefore policy compliant) code.
Secondly, in the decidedly anti-housing consultation draft of the NPPF, one of the many ways in which an authority could avoid meeting housing need is if doing so would mean building at densities “significantly out of character with the existing area”. Codes are the suggested means of determining this. The absence of codes may make this difficult to ascertain and the policy change may motivate “NIMBY codes” that set inappropriately low densities.
Finally, the future of supplementary planning documents and the complexity of new style plan making timetables creates uncertainty about how adopted design codes will be given weight as development plan documents.
In conclusion
Design codes can be a useful tool for raising standards of design and maintaining clear standards through the development process.
Going forward we would love to see:
- A refocus away from beauty and towards principles of good design
- Clarity from the government about their expectations for local authority code production
- A general increase in funding for local authorities, as well as specific funding to provide the skills and resources needed for full coverage codes, if that is the intended policy direction.
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