Chris Rogers  |  Writer on architecture and visual culture

Transparency and beauty: Planning to fail?

By Chris Rogers, Aug 10 2020 11:08AM

No one could doubt Boris Johnson’s intentions for England’s “outdated and ineffective planning system”, as he describes it, which he sets out in this week’s consultation on its reform. Scrapping individual site and scheme applications, pre-approved developments that cannot be stopped in principle, American-style zoning, less paperwork… It’s certainly radical. Media coverage has concentrated on the implications for housing but I’d like to focus on two other areas the white paper addresses: public access to planning information, and notions of ‘beauty’ in buildings. ..

The degree to which people are aware of, understand and contribute to any planning application is a major element of the proposals. The current system, Johnson says, is a “relic” that means the nation’s “potential is being artificially constrained.” In an introduction that uses – in rather laboured fashion – the metaphor of an aged and ramshackle building to clear the ground (sorry) for what follows, he also says we need a way forward “that gives you a greater say over what gets built in your community” and concludes that we need to “make the system work for all of us.”

In his foreword Johnson’s secretary of state, Robert Jenrick, initially sounds calmer with the acknowledgement that “longstanding issues in our development and planning system have come to the fore”, but any suggestion that this might lead to a dispassionate examination of those very ‘issues’ is quickly abandoned when he proceeds to ignore the ones that matter and distorting some of the others that, arguably, don’t.

The disingenuity that stalks the planning world as well as the political one appears immediately with two misleading assertions. The first is that “We are moving away from notices on lampposts to an interactive and accessible map-based online system” whereby “local democracy and accountability will now be enhanced by technology and transparency.” The second is that planning is ‘discretionary’, whereby each case is considered on its merits. Both do not reflect the actual position.

Jenrick’s slating of notices on lampposts, repeated twice later in the document (“Residents should not have to rely on planning notices attached to lamp posts, printed in newspapers or posted in libraries”), not only misses one obvious point – that this is a perfectly valid way of bringing applications to the notice of a wide cross section of locally-involved people – but conveniently ignores another; that currently every planning authority is also obliged to make each planning document publicly available online, as part of the application process. Indeed, the document calls for the “harnessing [of] digital technology to make it much easier to access and understand information about specific planning proposals” even though this is exactly what happens now. It also wants “a digital template for planning notices” but, again, these already exist.

Already available - a local authority planning portal entry

Online access is one of the most powerful tools there is for engaging with possible changes to the built environment, and planning portals allow anyone to examine plans, descriptions and historical material relating to any site and scheme, even those going back some years and regardless of whether they were approved or rejected. The go-to item for each is always the design and access statement, which sets out in simple form the entire development. It is true that they can be “hundreds of pages long” for large developments and uploaded as multiple (but easy to read) pdf files where this is the case, but viewing that as a problem is akin to suggesting a recipe should leave out half its steps. In repeating an aspiration for ‘data not documents’, the consultation appears to shy away from the very accessibility and transparency that it demands since not every piece of important information can be presented as a number.

These planning application documents or the developer’s or architect’s own websites already include other material the consultation mentions as being vital, including timely, sourced information and high-quality virtual simulation in the form of verified views, computer-generated imagery, studies of daylight angles and more.

If public comments on planning applications are really “dominated by the few willing and able to navigate the process” today, then that is surely true of any field, including that of voting in general elections – the Conservatives remained in office last year notwithstanding 4 in 10 voters didn’t bother to cast their ballot. If, too, young people do not take part in a procedure that is already fully digital and accessible, it is hard to envisage any improvements that will alter that; caution must accompany the document’s vague but also repeated ambition for the public to “feed in their views […] through social networks and via their phones”– should major planning decisions be reduced to a Facebook ‘like’ or a swipe left or right?

Yes, there is one weak link in the chain between a site and its application documents at present – you need to know the address of the former to locate the latter on the web portal. This is where the trust lamppost is helpful, but all applications have to be published in local newspapers and many of these have online editions, including the Evening Standard where the City of London publicises its own applications each Tuesday. Many planning authorities already provide a map-based search facility online, and some automatically alert subscribers to new applications in their neighbourhood.

Democratic deficit is a useful phrase. Although the consultation document claims to address this it contains sweeping statements that conflate and elide with dexterity. This has already been seen in that obsession with ‘popular voting’, which idea appears in the document to relate to individual development plans but will actually only be for those local plans – no further public involvement will be possible. It pops up again with the statement that “Communities will be able to trust the planning system again as their voice will be heard from the beginning of the process” whereas in reality, that will be the ONLY point at which their voice will be heard since there will no site applications left to scrutinise under the new approach.

On that ‘discretion’ point, there are in fact “clear rules for what can and cannot be done”, found in both statute and government policy and guidance. Additional support is derived from case law, societally fundamental in England & Wales, so it is curious that this is criticised as being “exceptional internationally” when applied to planning given the government repeatedly praises this same legal system in other contexts.

Ironically for a consultation that is not only about what things look like but which seeks to encourage clarity, there isn’t a single flowchart or diagram to explain the relationship between the various elements of the new system, which include local plans, zoning decisions, design codes, development orders, neighbourhood plans and existing national planning policy guidance and use classes, both of which will be retained.

And what of beauty? The consultation talks of the need for authorities to consider “empirical evidence of what is popular and characteristic in the local area” in order to wave through any scheme that accords with those findings, with little realisation that ‘popular’ does not axiomatically equate to ‘good’. It also champions “gentle intensification” without noting that any encroachment on England’s green and pleasant land even when that is brown and in a city centre has always been fiercely resisted or that this can most easily be equated currently with crude upward extensions along suburban shopping parades or clunky attic storey conversions in residential streets.

Things to avoid... From 'Distinctively Local'

Attracting much coverage in the architectural press is the suggestion of design codes or – even more prescriptive – pattern books, schemes in compliance with which will speed through to construction. In truth these are not described in any detail at all let alone illustrated. The new system envisages “a limited set of form-based development types that [would] allow the redevelopment of existing residential buildings where the relevant conditions are satisfied – enabling increased densities while maintaining visual harmony in a range of common development settings (such as semi-detached suburban development). These would benefit from permitted development rights relating to the settings in which they apply.” Unfortunately it is those very PDRs – themselves recently relaxed yet again – that have allowed the aforementioned suburban crassness, and so using them to drive more building work with the justification of local support that is in actuality likely to come only from ‘those who take part’ seems unlikely to achieve beauty and will certainly remove the ability of neighbours or others to oppose further schemes.

The recent Building Better, Building Beautiful Commission report is mentioned approvingly in the consultation but in truth that well-intentioned document says much but contains relatively little. It stresses the need for housing to look like it is of ‘somewhere, not anywhere’, champions use of local materials and rightly marks the importance of re-using heritage structures and ongoing stewardship of buildings. It also addresses the long-standing, discriminatory practice of VAT being chargeable on refurbishment but not on new build, which awkward fact is not even mentioned in the new consultation. Yet it struggles to actually define standards for beauty or explain how they will be achieved, and the images used to support such conclusions as it does come to are themselves as biased as the

consulta tion's language.

Quite beautiful....

...quite plain?

Thus one photograph of a new housing development does indeed seem to reflect many people’s ideas of a homely neighbourhood, but my own search for pictures of the same scheme reveals rather less flattering examples. It pulls the same trick in reverse with 20 Fenchurch Street, aka the Walkie Talkie, presenting an awkward camera angle and blunt caption as proof of its unattractiveness rather than an opinion as to that.

With no evidence, let alone the kind of objective criteria that Johnson and Jenrick claim will do the job easily, it is of limited value but does inadvertently signpost readers to a far richer and more practical guide, the ‘Distinctively Local’ report produced by four architectural firms who actually build residential schemes. By no means (only) a free plug for their work and covering everything from the small but important issue of avoiding the utility meter boxes that disfigure the fronts of many new developments to the possibility for a degree of customisation at the point of sale for new-build homes, this handy guide also contains a warning that “Design codes cannot by themselves produce excellence - they are not a substitute for talented designers.” Practical aspects of the creation of new houses that also affect its appearance are also addressed, such as a recognition that young people no longer recognise the traditional home where there is one phone, one television and one living room and the helpful observation that “physical conditions on [a typical building] site are uncomfortable and the culture is seen as ‘laddish’” by potential young entrants to the industry. Its range of case studies to illustrate its recommendations show variety and specific details.

Other potential mechanisms for producing beauty are considered by the consultation. Promisingly, “In Growth areas, we would also want to allow sub-areas to be created specifically for self and custom-build homes”, and authorities are encouraged to appoint a chief officer for design and place-making. The document is silent on the exact function of this role, however, just as it is on the true potential for off-site manufacture (which would also greatly assist in extending customer choice), the need for a dramatic reduction in the slow, waste-generating ‘wet’ trades still plied on those intimidating building sites and the potential for good that reinstatement of design reviews might bring.

Worryingly, even existing, accepted icons of beauty may not be safe under these proposals. There are brief mentions of allowing “sympathetic changes” to listed heritage assets more often, as well as a disturbing suggestion wondering if “suitably experienced architectural specialists can have earned autonomy from routine listed building consents”.

Predictably, house builders and surveyors have welcomed the consultation ideas, whilst town planners and local authorities have not. New London Architecture summarises the views of its professional panel, which are helpful and broad-ranging.

In one respect at least the consultation is consistent. Everything in it is about cutting: scrutiny, pages, input, time, information, objections. Jenrick himself accepts that the public will lose the right to object to individual developments. Will he and Johnson succeed?

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Chris's first book examines the career and works of British architect Michael Pearson, the third generation to head the practice founded by his grandfather in 1904. Pearson's presidency of the Architectural Association and his pioneering and prescient Burne House building are covered.


"Throws light on significant achievements" 


 Patrick Duerden, Practice Director, Donald Insall  



Black Dog Publishing, 2010  


ISBN  978 1 906155 73 5

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Become an architectural detective with Chris's second book, investigating the styles of a thousand years of building in the world's most visited city from the middle ages to the present day. Illustrated and with photographs, maps and addresses, also included are a list of resources and a two-part introduction.


"A little gem"


Terry Philpot, Tablet


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ISBN 978 1 78240 406 4  


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"Rather wonderful"


  – Don Brown, The London Society


Ivy Press, 2017  


ISBN 978 1 782404 52 1  

final cover L

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Ivy Press, 2018  


ISBN 978 1 782405 44 3  

Portfolio - cover BSMC

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"I really like both the research behind it, and its clarity and accessibility"


Susan Acland-Hood, Chief Executive, Her  

   Majesty's Courts & Tribunals Service  


Private press, 2006        


The Twentieth Century Society’s new peer-reviewed Journal on commercial architecture in Britain since the 1920s includes Chris’s piece on Fitzroy Robinson's pioneering atrium buildings in the City of London. The piece is founded in original research including archive imagery, interviews and site visits.


Twentieth Century Society, 2020


ISBN 978 0 955668 76 0