Huge interest currently focuses on the use and utility of design codes, both here and around the world. But codes of one sort or another are nothing new. In the UK, they were arguably first seen following the Great Fire of London in the form of standards to re-build the City in a manner that would be less susceptible to fire, plague and a host of other hazards. Today, although the hazards are rarely so dramatic, development standards exist to control almost every aspect of the built environment:
- National building regulations dictate the internal and (to some degree) the external design of buildings
- Highway standards (national and local) control a good part of the public realm through their impact on road and footpath design and layout (often disastrously)
- Planning standards (national and local) dictate density levels, space between buildings, parking requirements, open space requirements, and so forth
- Police secured by design criteria determine lines of sight, permeability, access points, etc.
- Emergency service access requirements dictate distances between buildings and points of access
- Health and safety standards are increasingly pervasive, right across the built environment.
This reality was brought home to me on a recent visit to Erith in the Thames Gateway. There, the main shopping street (Pier Road) includes along one side a car park on the site of an old street market. Recently, when the car park was laid out, the local police liaison officer argued that one entrance was safer because (in theory) criminals could only escape in one direction from the car park (this despite the fact that the car park is open on all four sides to streets and surrounded by a very low railing over which any able bodied person could hop). The result is that criminals can still escape in any direction, whilst the elderly and disabled (who can’t hop) are often forced to exit and double back on themselves to get where they intended to go in the first place. Nevertheless, that standard was met and the box was ticked.
To make matters worse, the attempts by the local planners to re-introduce market stalls in the shopping street itself have been frustrated by the insertion of brass studs all down the street by the local fire brigade, between which no obstructions are allowed. The intention is to allow for the free access of fire appliances at any time of the day or night. Unfortunately, this effectively leaves no space for market stalls, whilst the standard is applied despite the fact that access in the case of emergencies can anyway be gained to the street at both ends and in the centre, and for much of the time the street is deserted. Again, the box is ticked, and the consequences seem to be someone else’s (or in fact no-one’s) problem.
All this is reinforced in Eran Ben-Joseph’s[1] new book in which he traces the evolution of these hidden codes that dictate so much of the form and function of urban space around the world. In doing so he argues that often the original purpose and value of many standards are forgotten, as the bureaucracies put in place to implement them do so in a manner that has little regard to their actual rationale, and even less to the knock-on effects of their existence.
In the UK, debates about the use and utility of standards are central to the future of planning for housing, because, in multiple ways, they help to determine both the quantity and quality of new housing, as well as (as we have seen in Erith) the relative desirability of the places to which housing is being directed. In this regard, a quick comparison of responses to the consultation exercise held on draft PPS3 is instructive.
Picking five organisations representing different stakeholder views (CABE, RIBA, TCPA, RTPI and HBF), all were supportive of the emphasis on achieving higher quality design, with the HBF (so often in the past resistant to planning engaging in such issues) arguing “our members are committed to achieving high quality development in terms of design and build quality”, and, we have been supportive of emerging tools such as design codes”. For their part, whilst admitting that “the majority of new housing in the UK – particularly greenfield housing – is built without any input from architects”, and accepting that codes can help to fill this skills gap, the RIBA argued that such approaches “must be flexible and able to develop over time”.
The comment reveals a tension that goes to the heart of administrative systems such as planning, to what Reade[2] describes as regulation versus discretion. In this regard public services can be categorised on a continuum from pure rule of law to pure administrative discretion. In the former, there are very clear regulations and a clear divide between what is allowed and what is not (i.e. the building regulations). Thus although a high level of expertise is required to put the system in place and to monitor its relative success, it does not require a high level of expertise amongst those charged with administering the controls. Pure administrative discretion, on the other hand (i.e. much British land use planning prior to 1991), describes a system where there is no obligation to provide a policy framework and each case is determined on its merits. Such a system would (ideally) require considerable expertise to operate it day to day and puts significant power in the hands of those charged with its administration.
The use of standards (as opposed to discretionary policy) tends towards the regulatory end of the continuum, as standards establish required levels of quality, and as such are not open to interpretation. However, as soon as flexibility is introduced, the nature and operation of the whole regulatory process changes, and the means of control encompassed in setting standards in the first place may cease to exist. In the UK, the use of standards (or codes) in an otherwise still discretionary planning process represents a departure in practice, but may be particularly beneficial to deliver key policy objectives, or in areas where skills (i.e. design skills) are lacking.
Other ‘standards’ related responses to draft PPS3 dealt with density, parking, life-time homes, and eco-standards. On the question of density, CABE counselled “one unintended consequence of the national density minimum has been a detrimental impact on the quality and character of many developments in suburban and edge of settlement areas”. They, like the RTPI, argued for locally defined density standards based on a proper assessment of the locality, although the RTPI also called for “a ‘default’ minimum density for a plan area”. For their part, the TCPA admitted that density standards are inevitably crude, and suggested that there “maybe a case for working to an average density minimum – say across a region”. By contrast, the HBF were implacably opposed to any density standards, other than those devised through careful analysis of local areas.
The dropping of national parking standards from the draft guidance was widely welcomed, with CABE arguing “we believe that the objective for parking should not simply be quantitative but qualitative”. Here, the RTPI recognised that “tight parking restrictions can also lead to unintended consequences through the displacement of parking to the close vicinity, with adverse impacts on amenity”. They warned, however, that a loosening of parking restrictions could result in a less effective use of land. On the question of lifetime homes and eco-standards, CABE and the TCPA were particularly keen that tighter national standards be adopted. Perhaps unsurprisingly, the HBF argued for voluntary codes, and were concerned that “many authorities appear to want to take into planning considerations issues that are more appropriately dealt with via the building regulations”.
The various responses suggest a further dilemma. Standards can be powerful tools to achieve policy goals, but their unthinking imposition on areas can bring with them unintended, and usually negative, knock-on impacts. Indeed, the larger the scale from which standards are imposed – area-specific to borough-wide to regional to national – the greater both the impact of the standard, but also the degree of collateral damage caused. Furthermore, the larger the scale of application – buildings to urban space to urban form – the greater the impact (positive or negative) on the public, as opposed to the private realm.
Ben-Joseph takes a historical view of the use and impact of standards, tracing their evolution and use, and focusing in particular on how they have shaped the residential landscape in the US. He argues that although standards will continue to be used, they must be used in a more flexible manner that contributes to the creation of real places, with principles of sustainability, place, and community at their heart. Not therefore on the basis of myopic unthinking application, as so often seems to be the case in the UK (i.e. Erith).
In the UK, where codes are increasingly being seen as the answer to delivering sustainable communities, we would be wise to fully consider the lessons from history, and the pros and cons of the tools we are adopting. If we understand the lessons, and use such tools intelligently, the evidence suggests that they can be very powerful tools indeed[3]. This will require:
- A move from nationally defined to locally defined standards for anything over the scale of the individual building
- A requirement that flexibility in interpreting standards be matched by design skills to ensure appropriate application to context
- A review of the administrative systems through which standards (and by implication codes) are implemented, in order that their application – and any unintended consequences – are viewed as part of a holistic view of the environment that has at its core the desire to deliver quality.
Matthew Carmona
Professor of Planning & Urban Design
The Bartlett School of Planning, UCL
March 2006
[1] Ben-Joseph E (2005) The Code of the City: Standards and the Hidden Language of Place Making, Cambridge Mass., MIT Press
[2] Reade E (1987) British Town and Country Planning, Milton Keynes, Open University Press
[3] Carmona M & Dann (2006) Design Coding in Practice, An Evaluation, London, Department for Communities and Local Government
Matthew Carmona 