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Writing about design as if people spoke and thought in English

23th October 2013

By Rob Cowan


The CLG’s National Planning Practice Guidance, explaining the National Planning Policy Framework, has gone through a period of public testing and comment, and is currently being revised. The draft guidance material is still available online. The CLG’s existing guidance will not be cancelled until the new planning practice guidance is published in its final form.

The good news is that the draft guidance, like the NPPF, does cover the essential elements of design. And the latest planning appeal decisions show that, despite the government’s desperate attempts to get some housing built, design has not completely gone out of the window as an issue to be taken into account in determining what development will be allowed. As ever, local authorities’ refusals of planning permission on the grounds of design will stand up at appeal only if they are based on solid, up-to-date policy and guidance, and if the council can show evidence that its councillors and officers know what they are talking about.

Unfortunately in its present form a great deal of the National Planning Practice Guidance will be absolutely impenetrable to much of its target audience. That audience includes not just planners (to many of whom the role of design in planning is still a mystery, 13 years after By Design and contrary to what is sometimes said); the target audience also includes many types of other built environment professionals, councillors, developers, planning applicants, members of community and neighbourhood organisations, and many more.

It is easy for us, who eat, drink and sleep this stuff, to welcome the draft guidance’s discussion about design. We recognise all the concepts and know pretty much what most of the sentences are trying to say. But we are not the target audience.

The biggest problem is that the guidance seems to be about some weird thing called ‘design’, which will seem to ordinary people to be, in its language and concepts, very different from planning. The new guidance says, as PPS1 did, that ‘Good planning is indivisible from good design.’ But the rest of the guidance certainly does not give that impression.

Design and its role in the planning system are complex matters. But the essentials can be simply explained. Planning has an impact in two ways. One is through a development’s use. The other is through the development’s physical form. The physical form of the development is everything that you would need to know about if you were to draw a picture of it: the layout, height, materials and so on.

Twenty years ago planning focused on use, and paid little attention to physical form. A great deal of unsuccessful development convinced us that this approach was wrong. In the last 20 years there has been general agreement that successful planning depends on considering the use of a development and the physical form of the development together. Consideration of the physical form of development tends to gets called ‘design’. But in this context it is also planning, so we must be careful not to think of design and planning as being two separate things.  

The guidance mentions a number of concepts that are not explained clearly in their context. They include (to use the guidance’s own words) appropriateness, architecture (as distinct from design), blight, community safety, complementarity, contemporary design, context-specific design, crime reduction-based planning measures, crude local development standards, design quality, design standards, designing in community safety, detailing, distinctiveness, diversity, designing out crime, evolutionary local design, flexibility (as distinct from adaptability), formlessness, good design, inclusive design, inclusive environments, innovative new design, integration, land form, legibility, local distinctiveness, natural surveillance, outstanding or innovative designs, permeability, planning of internal space integrally with external space, poor design, resilience, responsible innovation, sense of identity, sense of place, servicing, sprawl, sustainability, sustainable communities, the joins between elements, the design stage, uniqueness, urban design, vibrancy, visual amenity and visual prioritisation.

Many of these are highly complex issues. The draft guidance discusses them without explaining many of them, in text that is very loosely and carelessly written. Unless this is remedied, any attempts to restructure the guidance will go some way towards satisfying us specialists, but the guidance will be of almost no help to its target audience. And it will cause endless confusion at planning inquiries.

The good news is that many of these undefined terms and abstract concepts do not have to be used in this sort of guidance at all. Guidance is needed to help people plan development whose physical form contributes to making successful places. Such guidance can be written in everyday language, with a few additional terms that we can introduce, explain and illustrate.

The process of drafting the guidance that the CLG has gone through so far has been useful in determining to content and structure of the guidance. Let’s hope that the CLG is revising it in the light of the many useful comments it has received, and that the final draft will reflect how normal people think and talk.    

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