PPG7 3.21: Is this the clause to fight for?

Architects Journal June 2003
Practical planning advice # 78 (uncut version)


We all love a bit of campaigning journalism, but that’s for the front end of the mag. Back here we are supposed to be a bit more analytical Ð so here goes! LetÕs briefly touch on the facts. In BOX 1 I quote extracts from the Planning and Policy Guidance Note 7 (The Countryside, Environmental Quality and Economic and Social Development) clause 3.21. Starting at the beginning, should architects be keen on government guidance saying: ÒNew house building and other new development in the open countryside … should be strictly controlledÓ? The clause within the clause which John Gummer, much to his credit, added-in : ÒAn isolated new house in the countryside may also exceptionally be justified if it is clearly of the highest quality…Ó. This is of course the focus of the AJ campaign and the reason the ÔBig names add weightÕ to it (AJ headline 29 May).
So itÕs not the clause we want to keep but the exception? OK. For the few of you who havenÕt kept a copy of my column of ?? February 2001 next to your Macs, I repeat extracts in BOX 2. This demonstrates how the exception has fulfilled GummerÕs purpose. It has allowed planning inspectors to allow one or two (some say up to 15 since 1997, but the ODPM doesnÕt know the number) exceptionally well conceived, designed and landscaped new country houses on exceptional sites to go ahead. I say Inspectors, because by their very nature, exceptions tend to come up against the generality of the over-riding prohibition contained in the guidance which itself is generally also the local plan policy.
Under the White Paper planning reforms due to be enacted by November, these PPGs are to be replaced by PPSs (Planning Policy Statements). The G for Guidance will be dropped and the new notes are to be shorter, concise statements of strategic policy free of prescriptive guidance. Thus a clause such as the one the subject of this campaign will have no place in any case. The intention is to give more room for local policy in the new frameworks which are to replace turgid development plans. Come July the ODPM will have published the new draft PPS7 for consultation. This will give a second wind to the AJ campaign and will allow it to refocus on an achievable target. ItÕs hard to object in anticipation of the unknown. The main concern should be to influence the PPS policy in such a way that it does allow flexibility at the local level.
But the nub of the issue is the concern we architects might share that, in general, an exceptionally good design might make acceptable something which would otherwise not be. And the place to do this will be in the long-overdue replacement for PPG1 which is the umbrella government policy note. In the original PPG1 the involvement of an architect was itself a material consideration in a planning decision, but was dropped in the current version. Reviving the campaign to reinstate this position may seem a bit retrograde, but times and the climate have moved in our direction with the Task Force, the Urban and Rural White Papers and the successful establishment of CABE. In reviewing the imminent PPS7 we might be well advised to seek CABEÕs support to lobby for just this.

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Early in the year a new draft PPG1, the planning policy guidance from DETR which embraces all the rest, is promised. It is understood that, having dropped specific reference to the role of architects in the preparation of planning applications in the current (second) version of PPG1, a new emphasis will refer to the importance of design and urban design skills being available to applicants and authorities alike. It is to be hoped, as the Association of Consultant Architects has long urged, that the involvement of a qualified designer, most probably an architect, will again become a material consideration where design matters are at issue in a planning application. Two very recent appeal decisions demonstrate how this new emphasis might work more frequently in future. Architect Robert Adam has designed a large country house in undeveloped countryside in HampshireÕs Test Valley. The inspector ruled that consistency in the design and all its elements is the best pointer to truly outstanding architecture and resisted the authorities’ reliance on PPG7 (The Countryside, Environmental Quality and Economic and Social Development) whose main thrust is to stop new housing being built away from established settlements. However it does provide for the exceptional case: Òthe opportunity to add to the tradition of the country house, which has done so much to enhance the English countrysideÓ… provided that such a house is of the Òhighest-qualityÓ and Òtruly outstanding in terms of its architectureÓ. Whilst the objectors argued that AdamÕs classical design was not of its time and therefore not good architecture, Adam called two experts with different stylistic predilections: arch-modernist Michael Manser and architectural historian David Watkin. Both told the inquiry that the design fulfils the test being of the highest quality. The inspector came to the view that the architecture of the house and its landscaping is outstanding. His reasons included that the design has evolved under the direction of a skilled architect and a that the design is based on sound principles of composition, proportion, space and style and will be both attractive and enduring. This will become important precedent for PPG7, being the first case where the exception clause has succeeded since its introduction in 1997. More broadly it indicates how the Planning Inspectorate will address the integrity of the design as distinct from the integrity of the style in future appeals.

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PPG7 clause 3.21 New house building and other new development in the open countryside, away from established settlements or from areas allocated for development in development plans, should be strictly controlled. The fact that a single house on a particular site would be unobtrusive is not by itself a good argument; it could be repeated too often. Isolated new houses in the countryside require special justification Ð for example, where they are essential to enable farm or forestry workers to live or near their place of work. Advice on the special considerations which may arise in relation to agricultural and forestry dwellings is given in Annex 1. An isolated new house in the countryside may also exceptionally be justified if it is clearly of the highest quality, is truly outstanding in terms of its architecture and landscape design, and would significantly enhance its immediate setting and wider surroundings. Proposals for such development would need to demonstrate that proper account had been taken of the defining characteristics of the local area, including local or regional building traditions and materials. This means that each generation would have the opportunity to add to the tradition of the Country House which has done so much to enhance the English countryside. Sensitive infilling of small gaps within small groups of houses or minor extensions to groups may also be acceptable though much would depend on the character of the surroundings and the number of such groups in the area.

Brian Waters is principal of The Boisot Waters Cohen Partnership, brian@bwcp.co.uk/ www.bwcp.co.uk