My response to the new Design Planning Policy Practice Guidance

Soon after the publication of the draft Design Planning Policy Practice Guidance (DPPPF) in January I got an email from Graham Smith asking where the boulevards had gone?

For those of you who don’t know him, Graham is an academic and practitioner and, back in 1985, was one of the authors of Responsive Environments, which is really the foundational text for urban design in the UK. It was the first publication to codify the principles that have been repeated in every subsequent piece of design guidance from By Design in the 1990s right the way through to the latest guidance, which was published for consultation in January.

His point about boulevards was that they were in the National Model Design Code (NMDC) but are missing from this new guidance. It made me realise that the DPPPG which, on the surface, is a useful bringing-together of four existing policy documents into something more succinct and accessible, needed a closer reading to see what had been lost in the edit.

The documents in question are the National Design Guide, the Design: Process and Tools guidance and the National Model Design Code Part 1: The Coding Process and Part 2: Guidance notes. I should declare that I have skin in the game as one of the authors of the two NMDC documents.

Anyone writing a code could do worse than just go through this guidance and write a rule for each bullet point

In simple terms, the first part of the new DPPPG guidance is an update of the National Design Guide, the middle section combines the Design: Process and Tools guidance and NMDC Part 1, while the final section is an update of the NMDC Part 2.

It might be worth starting with that final section because it is really good. It is a comprehensive list of all the things that should be in a design code. Anyone writing a code could do worse than just go through this guidance and write a rule for each bullet point.

Unlike the earlier documents there is no indication of what the rules should say, which is a shame. It sets out, for example, how to code for density but does not say what appropriate densities might be for different types of development. But still, it is a very useful tool for creating a code.

Going back to the first part of the DPPPG, we find a restatement of principles that are widely accepted. The 10 elements of the National Design Guide are reduced to seven by treating “context” as an overriding principle, and combining three other categories into a new “livability” section – which all makes sense.

But… (I think you could feel that coming).

My first quibble is with the language that is infuriatingly vague. Ground floor “active uses” become ground floors “occupied successfully and appropriately”. In a similar vein “a clear separation” becomes “a good relationship” between public and private space.

There are lots of instances of “appropriate”, “could include”, “relate well to” and “as accessible as possible”. Nothing that you could object to – who wants inappropriate development? But everything has been nuanced to cover every eventuality until it becomes shorn of any real meaning.

Having said that, the point was made at a recent Urban Design Group event that the purpose of this guidance is not to teach anyone about good design; if people don’t know now, they never will. The purpose is to provide wording that can be raked over by barristers at appeal and maybe therefore the civil service wording is necessary?

Other issues such as urban blocks, building lines and heights are mentioned, but only as a subsection of urban grain, which seems strange

There are however elements that have been lost in the edit. As Graham Smith points out, the street hierarchy is now solely within “movement” whereas in the NMDC it was in “public space” and the idea of a boulevard as a way of dealing with a high traffic street through an urban area has gone. Other issues such as urban blocks, building lines and heights are mentioned, but only as a subsection of urban grain, which seems strange.

The middle section of the draft guidance ties in with the draft NPPF, which was out for consultation at the same time. Back in 2023 the NPPF specified that all authorities should have design codes and these should cover the whole of their area. By 2025 this had been watered down. It still required everyone to have a code, but it could be a guide and it did not need to cover the whole of their area.

The new draft NPPF is completely rewritten and the phrase “design codes, design guides and master plans” is repeated as a mantra. The DPPPG sets out how these design codes, design guides and master plans should be produced and used. But, while it includes guidance on preparing codes and masterplans, despite their equal billing there is no guidance on design guides – which is telling.

The coding methodology is largely the same as in the NMDC and retains the concept of “area types”, although these are an optional extra rather than a central organising element of a code. It also, I believe, gives an incorrect definition of “character areas”.

The question is: will any of this make a difference? In research we did on the application of the NMDC last year, we found that most of the codes that have been produced had not followed the NMDC methodology and many were guides rather than codes.

There are two ways you could respond to this: You could double-down and make the guidance more specific and mandatory, or you could step back and allow authorities to do their own thing. In our discretionary planning system, you can guess which option is taken.

It still encourages the sort of prescriptive coding that I have been advocating, but it does not require it. Over the past few years I have reluctantly come to the conclusion that that is probably the best we can do.