UDG responds to the National Model Design Code and Guidance Notes
Following a series of public events attended by nearly 400 practitioners from engineering, design, planning, landscape, architecture and development sectors, and extensive workshop sessions, the UDG has made a number of suggestions to Government for improving the effectiveness of the draft guidance on the production of design codes.
IMPROVEMENTS TO STRUCTURE AND PRESENTATION
- A single document - combine the National Model Design Code and Guidance Notes into one single document to eliminate duplication and avoid confusion. As it is a guidance on producing design codes, it should be called Guidance.
- Signposting - The Design Code Guidance should signpost supporting technical guidance and standards rather establishing its own independent set of technical requirements.
IMPROVING THE FRAMEWORK IN WHICH DESIGN CODES WILL OPERATE
1. Consistent policy and guidance
Government should work to ensure that there is consistent and coordinated policy, planning and design guidance, and technical guidance across the built environment sector, using common terminology. The same current best practice guidance should appear in all documents. For example, best practice in street design should be reflected in guidance on traffic signs or planning design guidance; best practice on drainage and suds, should be reflected in street design guidance. Currently this is not the case, with technical guidance retaining out of date practices drawn from other specialisms.
2. A clear and transparent mechanism for securing good design through the planning system is needed using frameworks, masterplans, guides and codes.
- Precise and legally sound definitions of the different types of masterplan and design code that can be produced should be established, so that they can be formally and robustly included within planning documents
- A vision for each town - there should be a vision for each town or neighbourhood created with the community. It is more valuable to involve people in the shaping of their town or community: where development should go, where green and blue space should be protected or enhanced, where amenities should be provided and so on, rather than in matters of detailed design, such as the colour of street furniture or the detailing of doors, roofs and windows.
- Effectiveness of a Code - there are concerns over the ability of a scheme promoter to overturn a design code that has been agreed with the community. The government is invited to address this issue, and come to a public position on how this question is to be resolved, and the trust of communities honoured and respected.
3. A reformed approach to development site location
Design Codes cannot rectify the fundamental problems created by unsustainable site location created through the current call-for-sites driven planning system. This approach is wholly incompatible with the duty under Section 19 in the Planning and Compulsory Purchase Act “to secure that the development and use of land in the local planning authority's area contribute to the mitigation of, and adaptation to, climate change”, and the meeting of the 2050 net Zero carbon reduction target.
Government should be aware of the resources required to create quality design codes. It is unrealistic to base a new planning system on design codes when Local Planning Authorities are under resourced and under skilled. The production and process of a competent and well considered design code takes a lot of different skills and is time consuming.
Resources are also required to ensure compliance with a code, with effective remedies and sanctions for non-compliance.
The Urban Design Group has commissioned a skills survey which will report later in the year.
The Guidance should be based on a landscape and people-centred approach to design, in accordance with the duties on climate change adaptation and mitigation and duties in the Equalities Act: Section 1 Public sector duty regarding socio-economic inequalities and the Section 148 Public Sector Equality duty relating to advancing equality of opportunity among people with protected characteristics including age, gender, race, religion and disability. Climate responsive design be embodied in the Guidance.
Design Codes should be written so as to enable innovation - including new technologies and built form such as that that will achieve net Zero Carbon.
Additional guidance on coding is needed for rural areas. The guidance at present focuses on metropolitan areas.
Further detailed comments are contained in the comprehensive response.
With many thanks to UDG members and other industry professionals who contributed to the working group and two online events:
Adriana Bonilla | Rob Cowan | Roger Evans | Helen Flage | Sue Illman | Sue James | Phil Jones | Martina Juvara | Tony Mulhall | Colin Pullan | Barry Sellers | Kenji Shermer | Katja Stille