The Government has published its draft revision to the National Planning Policy Framework (NPPF). This consolidates a series of proposals that have been made over the last few years.
Prime Minister Theresa May’s wide ranging and lengthy speech at the launch of the draft revised NPPF, and the document itself, emphasises the importance the Government places on trying to resolve the housing crisis.
Theresa May has said:
‘The picture we see today is the result of many failures by many people over many years. Fixing it won’t happen overnight. But the size of the challenge is matched only by the strength of my ambition to tackle it.’
The launch of the draft revised NPPF has been accompanied by the release of a range of supporting documents, government responses, and further consultations; of particular note are the following:-
National Planning Policy Framework: consultation proposals and draft text;
Supporting housing delivery through developer contributions: consultation;
Draft planning practice guidance for viability;
Housing Delivery Test: draft measurement rule book;
Government responses to the Housing White Paper and the Planning for the Right Homes in the Right Places consultations; and
Section 106 planning obligations and the Community Infrastructure Levy in England, 2016 to 2017: report of study.
The former two consultations are both set to close on 10 May 2018. (https://www.gov.uk/government/consultations/draft-revised-national-planning-policy-framework)
The Design Review Panel has provided the below consultation response regarding Chapter 12 entitled 'Achieving well-designed places'. A copy of the below has also been sent to James Brokenshire, the newly appointed Secretary of State for Housing, Communities and Local Government:-
The Design Review Panel has deep concerns regarding the proposed revisions to the National Planning Policy Framework (NPPF) and the likely resultant detrimental impact upon the quality of the built environment.
The Design Review Panel (www.designreviewpanel.co.uk) continues to provide independent, constructive, cost effective, design review panel services without the need for any public funding/grants, which it is assumed was the Governments hope when the NPPF was first introduced. We currently provide regular design review panel services to applicants and local authorities across the south west, with regular meeting venues at Plymouth City Council, Exeter City Council, Taunton Deane Borough Council, in Swindon and Bath. Local authorities who sign post our services or have referred scheme to us include Plymouth City Council, Exeter City Council, East Devon District Council, Torridge District Council, West Somerset Council, North Somerset Council, Mendip, Taunton Deane Borough Council, Devon County Council, Mid Devon District Council, North Devon Council, Teignbridge District Council, Mendip District Council, Swindon, Bath & North East Somerset Council.
We believe that, with continued legislative support, this cost effective, privately funded model (not requiring public funding) may be replicated across the country, helping to create well designed, healthy and sustainable places and communities at no cost to the public purse.
However, there is a significant concern that the proposed changes to the NPPF may be prematurely abandoning or watering down the original aspirations regarding the need for independent design review panels. Not requiring local authorities to have to sign post and have access to all design review panel providers will threaten the viability of independent panels. This may have a significant detrimental impact upon the design quality of the built environment and undo the hard work that many have put into the running of independent design review, in response to the call to do so from Government (at both local and national level).
Due to the scale of the proposals that our Panel has been contributing towards, the projects we have reviewed are only now being constructed on site. Therefore, the benefit of the design review panel process may only be empirically seen in the coming 12 - 18 months. Furthermore, as with any new enterprise it can take several years for a new service model to effectively market itself, become known and widely used, this is only now just starting to happen. Therefore, it is far too early to abandon or water down the requirement for design review panels to be used by local authorities after such a short period of time; certainly, in the south west the design review panel process has been making a significant and valuable difference to the quality of the built environment.
If the proposed changes to the NPPF result in the independent and privately funded model of design review panel provision no longer being viable, this may then result in the effective reinstatement of CABE as the only provider and therefore effectively as a quango operating a monopoly.
If CABE were the only provider available, CABE and its regional network of sub -panels may then wish to make the case for needing ongoing government funding. In the current ongoing economic climate this may be unsustainable.
CABE and its regional sub-panels (despite being ‘not for profit organisations’) also charge significantly more than independent Panels, which may make the process inaccessible / cost prohibitive to many applicants & or local authorities. By contrast, our independent Design Review Panel currently only charges £1,800 for a 90-minute design review panel session of a major project with six multidisciplinary experts. We also review minor projects for only £950. We currently have a pool of over eighty multidisciplinary professionals and many of our Panel members also sit on the regional CABE backed Panel; so, it can be seen we provide at least the same level of expertise and service as our CABE backed regional competitor. The concern is that by CABE (and its regional network) charging nearly twice that of an independent Panel it may result in applicants choosing not to (or not being able to afford to) engage in the design review panel process, which will be to the detriment of the quality of the built environment.
As we have proved in the south west, since our launch in early 2014, accessible / cost effective, independent design review panels can be of significant assistance to local authorities who often no longer have a wide range of multidisciplinary expertise in house. As above, the proposed changes to the NPPF potentially harm the viability of independent design review panels and their ability to provide local authorities with access to this affordable multidisciplinary expertise.
No longer requiring local authorities to have access to local design review panels, and sign post all available design review panel providers, may also slow delivery of much needed development (in particular housing). We have found over the last few years that our Panel has been used as an enabling tool, helping to mediate between local authorities and applicants; de-risking the process for applicants / house builders whilst helping to raise the design standards of the housing schemes thus helping to assuage the fears of Councillors and residents. Early engagement with the design review panel process does not slow the planning process, but rather can de-risk and speed up the process. Therefore independent multidisciplinary design review panels may be seen to accord with the Governments aim to tackle the housing crisis.
It may be that the changes in the NPPF and refocusing on ‘Building For Life’ may be as a result of lobbying by CABE, their affiliated Design Network and the RIBA, who may be keen to see independent design review panel providers put out of business and replaced with legislation that may then require the input of CABE, The Design Network and RIBA in controlling the process, which in turn may result in a strong future argument for the need of future public funding for CABE, The Design Network and RIBA. It may be that some large house builders may also be keen to see ‘Building for Life’ given significant weight over the design review panel process, as it may be seen (incorrectly) by them as a quicker, cheaper, generic tick box exercise which they may feel they can standardise.
Mechanisms such as ‘Building for Life’ can be extremely useful tools and should sit below the design review panel process; that is to say such an assessment may form part of the material presented at a design review panel, helping applicants demonstrate that they are undertaking a structured design process that is considering all relevant aspects.
However, tick box, rigid, traffic light systems such as ‘Building for Life’ are not a replacement for an independent, multidisciplinary design review panel or the carefully considered, specific, bespoke feedback that results from a design review panel session. The concern is that if ‘Building for Life’ is used as a quicker alternative to the design review panel process that this will have a significantly detrimental impact upon the design quality of the built environment. We do not believe that tick box systems, such as ‘Building for Life’, will allow for the creation of places and new communities which result in unique, characterful and healthy places for future generation to live and work in; the design review panel process does help to facilitate this.
Ideally the new NPPF should say that all local authorities MUST (not should) signpost (in their literature and online) all available design review panel providers operating in their locality and MUST (not should) treat the feedback of the design review panel as a material consideration in the planning process.
Requiring all local authorities to signpost (in their literature and online) all available design review panel providers operating in their locality would allow private sector providers to offer independent and impartial design review panel services, on a competitive basis. This competitive environment would allow applicants and local authorities to choose to work with the highest quality providers and may ensure the price is determined by the market, not requiring inefficient expenditure of public money/grants. For example, our independent design review panel, aka ‘The Design Review Panel’ (www.designreviewpanel.co.uk), can offer its services, providing a larger pool of multidisciplinary experts and a larger panel of experts at each session, at around half the price of other regional ‘not for profit’ Panels.
We are very keen to ensure that the work of independent, private sector design review panel providers does not go unheard; by their very nature independent start up Panel providers unfortunately do not have the same lobbying ability / voice as national institutes such as CABE or the RIBA, who unfortunately in regard to the above cannot be seen to be impartial in their advice to the Government. Therefore if you agree with the above please make your feelings know by responding to the public consultation before the 10th May 2018 using the following link (https://www.gov.uk/government/consultations/draft-revised-national-planning-policy-framework)
by Jonathan Braddick - Chartered Architect and manager at The Design Review Panel (www.designreviewpanel.co.uk)
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