National Model Design Code (NMDC) Pilot Programme Phase 1: Monitoring & evaluation - executive summary
Published 20 June 2022
Applies to England
1. Executive summary
1.1 The pilot programme, its monitoring and evaluation
In January 2021, the government proposed to test the application of the National Model Design Code (NMDC). The NMDC provides detailed guidance on the production of local design codes, guides and policies that lead to well-designed places. It provides advice to local planning authorities on the process for producing codes, the design parameters and issues that need to be considered and tailored to their own context. It includes methods to capture and reflect the views of the local community throughout the process.
Expressions of interest were sought from local planning authorities in England to test aspects of the process and content of the NMDC, demonstrating how it can be applied to different contexts. Each applicant was required to present a proposal that responded to specific questions addressing baseline information, deliverability and objectives.
Through a rigorous assessment process, 16 local authorities were selected to partake in the pilot programme (Table 1). The local authorities represented a mix of proposals from different locations and contexts and a geographic spread representing the nine English regions. They had different development aspirations, addressed various stages of the NMDC process, and began with varying levels of pre-existing experience and in-house design resources. Because one pilot team consisted of three local authorities and one local authority split their funding across two independent testing programmes, the testing programme funded 15 pilot teams.
Table 1: 15 local authorities funded through the pilot programme
Local authority | Region |
---|---|
Buckinghamshire Council | South East |
Colchester Borough Council (with Tendring & Essex) | East of England |
Dacorum Borough Council | South East |
Essex County Council (with Colchester and Tendring) | East of England |
Guildford Borough Council | South East |
Herefordshire Council | West Midlands |
Hyndburn Borough Council | North West |
Leeds City Council | Yorkshire & Humber |
Mid Devon District Council | South West |
Newcastle City Council | North East |
North West District Leicestershire | East Midlands |
Nuneaton and Bedworth Borough Council | West Midlands |
Portsmouth City Council (two pilot teams) | South East |
Sefton Council | North West |
Southwark Council | London |
Tendring District Council (with Colchester & Essex) | East of England |
The testing programme formally began in April 2021 and final outputs were submitted in September. During the six-month testing programme, all the testing teams participated in collective roundtable sessions, individual roundtable sessions with members of the specific testing team, offered optional one-to-one monthly discussion sessions and were able to attend a range of topic-based workshops.
During this period a team led by Prof Matthew Carmona at UCL conducted an independent monitoring and evaluation of the work of the 15 pilot teams and this report is the result of that research. The research was conducted over two phases based on extensive interviewing of the pilot teams. A framework for analysis was utilised to structure the work which covered: inputs to coding, the coding process, outputs from coding, and anticipated impacts.
The pilot teams were all starting from different places with different trajectories. Some already had guides or codes in place, some had pre-existing analysis or engagement to draw upon, or existing urban design capacity and skills in-house to utilise. Others were starting from scratch and had little experience of coding. The pilots also intended to test design coding at different scales, some at the authority-wide scale, others focussed on particular defined areas with multiple sites, and others on a single development and its site.
Adding to the complexity, not all of the pilot teams began with the intention of producing design codes. Some focussed their work on producing local guidance to eventually guide others to produce codes (e.g. neighbourhood groups) or on one aspect of the anticipated coding process only (e.g. area types analysis). As a result, teams followed very different processes and produced widely varying outputs from the programme, including eight actual design codes. The content of these was analysed and fed into the evaluation.
Despite the very different pathways to coding, it was possible to identify a broad range of detailed lessons generated from across the pilot team experiences – 21 spanning the design coding process. Some issues raised by the Phase one pilots will be subject to further testing during the Phase two pilot programme which commenced in March 2022 and the findings in this report should not be taken as a definitive judgment on all design coding processes.
1.2 Inputs to coding
1. Reinforcing design quality expectations across the scales
Design codes represent a tangible demonstration of commitment to design quality:
- Site-specific design coding is used to optimise the responsiveness of development to local conditions and character. Authorities largely looked to code at this scale as this was where they could have most impact and where, they perceived, the real problems lay.
- Area-based coding (e.g. at the neighbourhood scale) can capture multiple smaller sites with an area of uniform character that can benefit from a shared set of design parameters.
- Authority-wide coding can tackle common authority-wide design problems, help to coordinate area-based and site-specific codes, and is of value in the absence of capacity to take a site-specific approach.
2. Vision defining and vision delivery tools
Design codes have for decades been viewed as ‘vision delivery’ tools, being prepared following and in order to implement a masterplan. Preparing design codes in advance of such an agreed site-based vision, as was the case in many pilots, places design codes in a new ‘vision defining’ role. This creates challenges as well as opportunities and tends to result in more strategic design codes, focussing on key design principles rather than their detailed implementation.
3. It takes time, skills, resources and leadership
A steep learning curve is required to produce design codes and to use the new methodology in the NMDC, and with a few exceptions local authorities were not set up to deliver design coding in-house. Key skills gaps include urban design, graphic communication, viability assessment and digital engagement. This often lead to the commissioning of external specialist assistance that ranged amongst the pilots between 60 and 200 days of external professional input. Overcoming, skills, capacity, and organisational barriers to preparing design codes in-house will be a necessary investment for authorities who don’t wish to rely on developers to produce design codes.
In order to achieve a more proactive approach, rather than waiting until developers are in place, requires strong place making leadership from chief executive, director and political levels. It can unlock the skills and resources issues.
4. Getting those hooks into policy
Coding is no fool-proof solution to delivering design quality. Instead, codes are seen as fitting within a policy hierarchy which cascades from more general policy in the local plan to the more detailed design parameters contained in design codes. Providing policy hooks in the local plan for coding gives them status whether, ultimately, they are formally adopted as part of the development plan or as SPD or submitted with a planning application.
5. Getting those hooks into highways
Highways design remains a challenging issue for many planning authorities, with some highways authorities seemingly reluctant to engage with design coding and some planning authorities reluctant to challenge this. Without highways firmly onboard and committed to improved placemaking, coding is unlikely to be successful.
1.3 The process of coding
6. Some places are more challenging to code, and all places are complex
There is no single one-size-fits-all coding process and pilot teams have been able to successfully adapt NMDC processes to local circumstances. Nevertheless, some locations are inherently more complex to code than others given different delivery constraints (e.g. low market values) and there is a need to be realistic whilst remaining positive and ambitious about design quality.
7. The role of area-types and characterisation
The phase one pilots conducted design coding across different scales. This revealed that the use of area-types is not always appropriate, notably in relation to coding conducted for areas of unified or negative quality, for site-specific coding, and in relation to authority-wide guides dealing with generic principles. Authorities planning authority-wide coding, first, need to determine if they wish to create area types at a very detailed level, or if they will opt for higher-level, more flexible guidance, or coding for only strategic design issues such as location and proportion of green space, transport links, and so forth. Those producing authority-wide guidance during the Phase One pilots opted to produce more flexible guidance that covered their entire area.
Whether leading to the definition of area types, or not, an analysis of existing character will always be appropriate. The scale at which to conduct this seems to be the scale at which design coding can most usefully be conducted and used, typically the site or defined area (e.g. neighbourhood) scale. Pilots struggled with areas types and most did not apply this aspect of the NMDC.
8. Understanding viability is key to coding
Authorities are keen for coding to raise the design quality bar prior to development interest in sites, but understand that viability represents a major constraint on the mix of uses that can be supported and the mix of housing typologies the market will support. Handling developer pressure on these issues was a key concern amongst pilots leading to a sense that it is better to engage developers early in the coding process rather than afterwards.
9. Engagement is a journey
The pilots showed the value of early engagement with communities, but also that this is a time-consuming process during which trust is gradually built with communities that may have been intrinsically opposed to development. It goes beyond simply asking what people like or dislike and at its best is a journey of education (in both directions) from analysis, to vision, to coding and testing of design codes. Communities were primarily interested in whether codes would have teeth, and their future trust in the process is likely to be dependent on that.
10. Mixing methods of engagement to be more proactive
When there was over-reliance on single forms of passive engagement during the Phase one pilots it led to lower response rates and to more basic (less informed) insights on community preferences. By contrast, combining traditional and technological means of interactive engagement around issues of genuine public interest tended to facilitate wider and more inclusive community engagement. Communities, for example, were more interested in the overall design vision for places rather than on technical design and delivery concerns.
In this process the value of existing local networks as a means to tap into local knowledge can be invaluable. Also, the critical role of professional expertise to guide and interpret community preferences should not be underestimated given that constraints and opportunities may not always be apparent to communities. The need is to balance local knowledge and professional support.
11. The potential for staged coding
There is a clear hierarchy from the fundamental design qualities relating to the form, layout and use of new development that need to be prioritised early as they impact on viability, to those that are more concerned with detailed delivery and can be dealt with later. This might imply a staged process for large sites or for area-based coding where detailed codes for different phases of development build upon and develop the principles contained in a more strategic overarching code for the place (or perhaps the authority) as a whole.
1.4 Outputs from coding
12. Character areas / area types can be complex and overlap
A wide range of analysis can feed into identifying area types or (at a smaller scale) character areas, but this needs to capture the fine-grained complexity, variation and constraints that characterise many urban areas. The qualities of areas may overlap and mix, and more sophisticated approaches may use different overlapping layers of character (e.g. through GIS) rather than defining self-contained and bounded areas across the board.
13. Balancing certainty with flexibility and creativity
The balance between prescription and flexibility depended on what was being coded and the context. Issues seen as critical e.g. heights, quantum (density), uses, parking including parking ratios vs. front garden space, dimensions for bin access, and access for pedestrians and cyclists tended to be more rigidly coded whilst aesthetic issues were treated with greater flexibility, particularly where variety and the creative interpretation of context was favoured as a design outcome.
Some qualities are more amenable to expression as more certain target metrics than others. Examples include: density ranges / movement targets / land use mixes / plot and grain / street patterns / open space / landscape and nature quantums / boundary treatments / energy use.
14. Prioritise character as a holistic concern
Local character is a fundamental concern for local communities and needs to be captured in coding in order for councillors to embrace this more systemised, rather than negotiated, approach to decision-making. In defining their response to character, Pilots tended to prioritise tangible issues such as landscape, density, height and building line as the enduring qualities of places and avoided being too prescriptive on purely aesthetic concerns or on what they perceived as less tangible concepts such as beauty. This will be further tested during the Phase two pilots.
15. Code for ‘process’ as well as ‘product’
It is possible to code for desirable and rigorous design process as well as for desirable design product, for example that sites should be subject to character analysis and community engagement prior to development proposals being made. Doing so can give development managers the confidence to encourage such activities at an early – pre-application – stage in the development process.
16. Different audiences are often compatible
Codes focussed on both community and professional audiences are compatible. They each benefit from digestible, readable, precisely worded and attractive design codes, avoiding overly long explanations whilst containing enough detail to support decision-making and graphically emphasising ‘must’ have design principles.
17. Using consistent language, graphic protocols and slimming codes down
Clear language and graphics protocols help readers to understand the relative importance of different elements within codes. Critical issues should be expressed as ‘must’ haves, meaning they are mandatory whilst ‘should’ haves are expected not advisory and ‘could’ haves are optional. The delivery of ‘must’ haves can be usefully caveated with ‘shoulds’ or ‘coulds’ but should be prioritised and not crowded out with detailed discussion. However expressed, the qualities being requested should be clear and unambiguous so it is clear to all users of the code how they should be interpreted and delivered in any given circumstance.
At the site-specific scale ‘must haves’ can be beneficially brought together and reflected in a framework or regulatory plan to make their application and significance crystal clear and to reduce code volume.
18. Adding weight through adoption
Adoption can occur as informal design guidance or formally as a Supplementary Planning Document or Development Plan Document. With each step the status of the resulting code increases but at the expense of the time, resources and risk required to get through the process and the ease with which codes can later be revised.
Design codes are typically seen as planning documents to be adopted for planning purposes and highways guidance and standards are seen as related but separate, and too often conflicting. It is, however, possible to jointly adopt and implement design codes if the will and agreement is the
1.5 Anticipated impacts
19. Turning development management into active place shaping
Design codes, it is believed, give development managers the tools to become active place shapers, allowing their work from the pre-application conversations to the formal assessment of proposals to be informed by a clear vision of design expectations. Compliance checklists, performance targets (against the code) and process guidance can help development managers to challenge poor schemes and evaluate proposals in a proactive, timely and objective fashion.
Development managers will need the skills to administer the new codes and to take on a more proactive role. In many circumstances they could be assisted by those with specialist design skills either inside or outside local authorities and also by design review. This will be particularly so in relation to those elements of design codes and guidance around which greater flexibility is maintained.
20. Building in review protocols
Changing external circumstances and the experience of using design codes and determining what works and what doesn’t, should lead to periodic review processes. This will be particularly important for authority-wide codes or those covering large sites or areas where development will spread over many years. This may involve formal review processes (every two to five years) or the adoption of a staged approach to coding.
21. Meeting aspirations, so far
Pilot teams, community representatives and development stakeholders who had been involved in the design code production largely proclaimed satisfaction with the tools and / or processes that had been put in place and with their potential to deliver a more certain, streamlined and quality focussed development process. Unanimously they would choose to use design coding again – resources allowing.
1.6 Many paths to coding
The coding pilots demonstrated that there are many paths to design coding and that design codes are not a single tool or process. These diverse ends are inevitable because there are many beginnings, with local authorities all at different stages in the development of their design governance infrastructure. More important than the exact form coding took seemed to be the journey coding teams and communities embarked on to get there, and the raising commitment to quality that represented.
Moving forward there was a sense that the momentum needed to be maintained, not least by being clear in policy when design codes would be expected, where other forms of tool might be more appropriate, and who will be responsible for producing codes in the future.