For many years this blog has tracked the twists and turns of national policy on design quality. The recurring theme has been frustration over the persistent inability on the part of Government to set out a clear and confident national ambition for design without over‑complicating it, hedging it with caveats, or introducing contradictions that ultimately undermine its effectiveness.
That frustration is understandable. Advocates of high design quality are always met by the familiar chorus of objections: that decent standards will somehow impede development, or that design is just too subjective. These arguments are simply wrong, as our recent research Tackling Inequality in Housing Design Quality once again demonstrated. So against that backdrop, it was with genuine surprise – and some delight – that I read the latest proposed revisions to the design paragraphs of the National Planning Policy Framework (NPPF). They exhibit a clarity of ambition and structure rarely seen.
It is worth looking at them closely.
How to judge the changes?
First, like a good academic, I need some criteria to judge the changes against. To find them, we can look back to September 2024 when the design paragraphs were last amended, on that occasion rolling back the final edits made under Michael Gove when Secretary of State, notably the liberal insertion of the words beauty and beautiful throughout the design paragraphs. Frustrated by the constant tinkering and the inconsistencies it produced, I proposed my own redrafting of the then eleven design paragraphs in Blog 105. The principles underpinning the redrafting were simple and can be used now to judge the latest changes.
First, the design section of the NPPF should address three fundamentals:
- To establish unequivocally a high‑level national ambition for design quality
- To set out clearly how that ambition should be operationalised through the planning system
- To cross‑reference and empower national guidance that provides a more detailed design framework
A structured framework
In one important respect, the new NPPF is different from its predecessors. It now sets out explicit National decision‑making policies, structured in a way that feels closer to the sorts of policies found in local plans. At the same time these policies remain non‑statutory material considerations, with Government stepping back from the statutory National Development Management Policies envisaged in the Levelling Up and Regeneration Act 2023.
Even so, the new structure matters. Instead of a continuous narrative, the document is organised into distinct policies. In Chapter 14, Achieving well‑designed places, this results in four policies:
- DP1: A strategy for design
- DP2: Local design guides, local design codes and masterplans
- DP3: Key principles for well‑designed places
- DP4: The design process
As elsewhere in the proposed framework, plan‑making comes first (DP1 and DP2), followed by decision‑making (DP3 and DP4). Taken together they do a good job of addressing the second and third fundamentals – operationalising design and empowering guidance – while the first – setting out a clear national ambition – is less convincingly addressed. Let’s take them in reverse order.
A single national design framework
One of the most welcome changes is the simplification of national design policy and guidance. The National Design Guide, the National Model Design Code (Parts 1 and 2), and the Design Process and Tools Planning Practice Guidance are to be consolidated into a single Design and Placemaking Planning Practice Guidance, due to be published in the new year.
At its core will be seven Features of well‑designed places, which will now also sit at the heart of the NPPF design chapter. Crucially, the framework states that these principles should be used in the absence of locally produced design policies, guides, codes or masterplans. Together, this creates a coherent and consistent set of principles and a national backstop in cases where nothing else exists.
Making design expectations work in practice
The revised framework is also far clearer about how design ambitions are meant to be delivered through the planning system. It sets out a logical sequence:
- establishing a local design policy framework;
- articulating expectations for key sites through tools such as design codes and masterplans;
- addressing design quality holistically through the seven features; and
- applying these expectations consistently in decision‑making, including through design review.
Community engagement remains important, but its emphasis has shifted upstream, towards the preparation of guides, codes and masterplans, rather than being overly concentrated at the application stage. This makes sense. Early engagement is far more effective in shaping an agreed design vision and delivering it efficiently.
The missing statement of ambition
Which brings us to the all-important question of national ambition for design.
The good news is that the proposed policies avoid the mealy‑mouthed contradictions of earlier incarnations, which would extol the virtues of good design in one paragraph only to constrain its meaning in the next. The less good news is that they lack a single, powerful opening statement of intent.
The current NPPF begins with a clear declaration: “The creation of high quality, beautiful and sustainable buildings and places is fundamental to what the planning and development process should achieve. Good design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities.” That unequivocal statement is absent here. One might argue that it is implicit in the more formal, testable policy language and the new guidance. But in a field long plagued by uncertainty and inconsistency, explicit ambition still matters. A strong opening statement would go a long way to ensure that a strong national design ambition is beyond doubt.
What is still missing
In Blog 105 I also identified several omissions so, second, the current changes should remedy these. Not all have been resolved.
Beauty and place quality
Following a period in which beauty became a politicised and controversial priority, references to it have now been almost entirely removed from the design paragraphs, surviving only in the broader statement of the planning system’s purpose at the start of the proposed NPPF. This is unfortunate. Research, including my own, shows that the emphasis on beauty helped raise design ambition nationally.
While there is a danger in fixating on the aesthetic dimension of design, there is also a danger of under emphasising what is for most of us the primary means of understanding and interpreting the qualities of places. The new guidance talks about the need to “create visually attractive, distinctive and characterful development”, but as research that I have yet to publish will show, there is something uniquely powerful about the desire for beauty and having reclaimed the term, it seems a shame to abandon it now.
The Nationally Described Space Standard
The Nationally Describes Space Standard represents a critical resource and in the proposed framework has been promoted from a footnote into the main text, although only tentatively. Authorities are warned that they should not seek to adopt standards that cover matters relating to the internal layout of buildings unless they are to implement the nationally described space standard. In other words, it is acceptable to adopt the standard, but it is not mandatory or even necessarily encouraged. In a policy framework that goes a long way to bring health centre stage in planning policy (including in design), this remains a glaring omission.
Planning versus highways
Perhaps the most persistent obstacle to placemaking is the disconnect between planning and highways. Despite positive language in the new policy – particularly TR4, which promotes safe, inclusive and attractive streets – highways authorities remain under no obligation to comply. Reference to Manual for Streets is a welcome first, but without stronger alignment, car‑dominated environments will continue to undermine place quality.
That said, the framework’s firmer stance on density may force change. For the first time, a recommended density appears: 40 dwellings per hectare near rail stations, rising to 50 where connectivity is good. This is a major step forward, though still too timid. We know, for example, that development of less than 40 dph is unlikely to support even a regular bus service, so these densities should – by default – be the minimum. Any less is simply unsustainable and therefore against the very purpose of the planning system as set out at the start of the proposed framework and against its drive to deal more convincingly with climate change.
Design quality as a universal requirement
Finally, design expectations still risk being treated as optional when the so‑called tilted balance applies. While the new framework states that poorly designed development should be refused, experience suggests that housing shortfalls often override this. An explicit statement that design standards apply always and to all development – not as a discretionary extra – would finally resolve this long‑running problem. Perhaps as part of the high-level statement of ambition discussed earlier.
A big tick
The design section of the NPPF is short – just over 1,000 words (down from 1,333 currently) – but its influence will continue to be immense and will increase further when supported by the new and internally consistent Design and Placemaking Planning Practice Guidance.
A final slight worry, however, is new advice that “All plan-makers should, in preparing plans … Not duplicate, substantively restate or modify the content of national decision-making policies unless directed by other policies in this Framework” (PM6c). While the design paragraphs encourage the setting out of locally specific design policies, standards, guides and codes, this will be difficult without also covering the sorts of fundamentals contained in the national policy and guidance. A nutty challenge for policy-writers, but one that I am sure can be overcome.
Overall, despite some reservations, this latest iteration of the NPPF represents a significant step forward. It is clearer, more coherent, and more confident than anything that has gone before. On the long and winding road that is national policy on design, it marks genuine progress towards clarity – and for that, it deserves a big tick.
Matthew Carmona
Professor of Planning & Urban Design
The Bartlett School of Planning, UCL
Matthew Carmona 