The latest draft of the National Planning Policy Framework marks a meaningful shift in how design quality and land efficiency are expected to be delivered across the planning system. For years, previous versions of the NPPF have sent mixed messages, planning for growth and new development while simultaneously urging the preservation of character and lower densities. The new draft takes steps to resolve these tensions through clearer definitions and stronger design principles.
One particularly welcome feature is the more explicit description of what constitutes a well-designed place. The rewritten ‘Achieving well-designed places’ chapter offers a more coherent framework that should remove ambiguity for plan-makers and applicants alike. Importantly, the Draft NPPF acknowledges that existing character should not automatically preclude development that makes the best use of a site, an important and pragmatic shift reflected in Policies L2, L3 and DP3.
Below are several areas of the design-related amendments that merit closer attention.
- Making Effective Use of Land (Chapter 12)
The ambition to use land more effectively, particularly in highly connected locations, is laudable. Policy L3 introduces minimum density standards in these areas, with a direction that proposals failing to make efficient use of land should be refused.
While the intention is sound, the current drafting is arguably too rigid. Housing needs and market demand vary over time and between different parts of the country. In some locations, the need for larger family homes may make achieving a prescribed minimum density unrealistic. Without sufficient flexibility, the risk is that density standards could inadvertently constrain housing delivery rather than support it.
A more nuanced policy would allow professional judgement to accommodate local circumstances and medium- to long-term changes in housing need and market conditions.
- A New Emphasis on Refusing “Poorly Designed” Development (Policy DP3(2))
A notable change in the new draft is the strengthened wording around refusing planning permission for proposals that are not well designed. Policy D3(2) states:
“Development proposals that are not well designed should be refused, when assessed against this policy and local design policies, guides, codes and masterplans set out in the development plan. Substantial weight should be given to compliance with these policies when assessing the design quality of proposals.”
This is a clearer, more directive statement than found in previous NPPFs, and it raises an important question: does this create a greater risk of refusal on design grounds, particuarly at outline application stage?
Potentially, yes.
Outline applications typically fix land use, access and broad parameters but leave detailed design, such as layout, form, scale, architectural treatment and landscaping, to later reserved matters stages. However, Local Planning Authorities may expect outline submissions to demonstrate stronger alignment with local design policies, design codes or masterplans that are already in place.
While outline applications are still intended to establish principles rather than final design, the stronger direction in Policy D3(2) means applicants may face:
· Higher expectations of design justification at outline stage
· Even greater scrutiny of parameter plans and design rationales
· Increased risk of refusal where a proposal is perceived not to align with design codes or local design policies, even at a the outline stage
This underscores the importance of a strong design rationale at an early stage. This does not mean creating a detailed design submission at the outline application stage, but a proposal underpinned by strong masterplan design principles will be even more essential.
- Tree-Lined Streets and Deliverability (Chapter 19)
Policy N3(1a), a rewriting of paragraph 136 of the current NPPF, appears to imply that all streets should be tree-lined. While the aspiration is understandable, green streets deliver visual, ecological and climatic benefits, a blanket requirement is very rarely practical.
Street trees require adequate soil volume, long-term maintenance, and coordination with utilities. Not all street types or neighbourhood contexts allow for this. A more proportionate policy, one that requires the main tree-lined street (or streets in larger developments), would ensure good design without undermining scheme viability or deliverability.
- Net Developable Area: Ensuring Consistency (Glossary B)
The new definition of net developable area is a welcome addition, but the draft text incorrectly includes incidental open space and children’s play areas. These areas typically sit within public open space and are not counted as net developable land, particularly because some play areas require substantial buffer zones to protect residential amenity.
Including them would distort density calculations and complicate plan-making evidence.
This issue is made more complex by the Draft Design and Placemaking PPG, which includes a diagram showing that open space should be excluded from the net developable area, directly contradicting the NPPF. Ensuring the two documents align is essential.
Final Thoughts: A Stronger NPPF, With Some Refinements Needed
Overall, the design-related amendments in the Draft NPPF represent a positive evolution. They provide clearer expectations, reduce the contradictions of earlier versions and strengthen the tools available to secure better-designed development.
But clarity is still needed in several areas:
· Policy L3 should be more flexible in recognising varied housing needs.
· Policy D3(2) should be applied proportionately at the outline stage to avoid stifling housing delivery.
· Policies on tree-lined streets must remain deliverable and context-aware.
· Net developable area definitions must be corrected and aligned across guidance.
With these refinements, the NPPF would provide a much more robust and practical foundation for delivering high-quality places across England