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Design
& Access Statements
New
requirement
for planning and listed building consent applications
Chris
Burford-Bradshaw
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| New
flats and historic warehouse conversions at Gloucester Docks |
Earlier this
year the Department for Culture Media and Sport introduced various
changes to the existing development control system. Possibly the
most far reaching of these is the need for most planning applications
and for applications for listed building consent, to be accompanied
by a design and access statement. This requirement came into force
in England on 10 August 2006.
Design and
access statements, or DASs as they are already inevitably being
labelled, have been introduced as part of the government’s response
to the level of criticism attracted by development, and as part
of its wider policy of ‘inclusivity’. DASs are intended to explain
the design process, taking into account the local context of the
building or site, and otherwise to justify the proposed scheme.
A DAS will form part of an application, and will therefore be
sent to all of the consultees.
DASs are
required to accompany both full and outline planning applications
except where applications relate to the following:
- Changes of use (where no building alterations are involved
- Engineering operations
- Mining operations
- Developments incidental to existing residential uses, including
extensions, provided that they are outside conservation areas
and other ‘designated’ areas – that is to say, Areas of Outstanding
Natural Beauty, National Parks, Sites of Special Scientific
Interest, The Broads and World Heritage Sites
- Adverts
- Tree preservation order consents
- Hazardous substances consents. Where both a planning application
and an application for listed building consent are being submitted
in respect of a proposal, only a single DAS is required.
IMPROVING
DESIGN OR IMPROVING PAPERWORK?
The Church
of England already has a requirement for statements of significance
and need to accompany petitions to alter a listed church building,
and in the secular world designers accustomed to dealing with
large development schemes may also be familiar with preparing
and submitting design statements as part of planning applications.
Indeed, the latter have already met with criticism from architects
who see them as unnecessary and unhelpful. The government’s view
is that DASs are simply formalising what is being done anyway.
In some cases this is clearly true, but in many others, and especially
in smaller schemes, the driving force behind the design may well
be issues other than those which the DAS initiative attempts to
promote: well developed, appropriate design that takes account
of its local context.
The requirement
begs the question whether ‘good design’ can really be defined
and, if so, who should be the judge? Clearly there are many subjective
issues involved. The government’s intention seems to be to encourage
designers to undertake a more structured thought process and to
engage in more constructive dialogue with local communities and
other interested parties. Such aims seem utopian, and it will
be interesting to consider whether the general perception of design
and development has changed significantly in a few years time.
LISTED
BUILDINGS
DASs submitted
as part of listed building consent (LBC) applications will replace
the ‘justification statements’ currently used to accompany some
LBC applications. Generally they should be similar to those prepared
for planning applications, except that DASs for LBC applications
will not need to include information on the use of the building
or the proposed landscaping. They should, however, include reference
to how the requirements of PPG15, paragraph 3.5 have been satisfied.
This is the paragraph which outlines the general issues relevant
to the consideration of all LBC applications, including the importance
of the building and its setting, and the extent to which the proposal
would benefit the community through regeneration or the enhancement
of its environment.
PREPARING A DAS
Little guidance
regarding the preparation of DASs is currently available. Different
local authorities will no doubt be developing their own guidance,
quality criteria and check lists. Significant variations between
authorities are therefore entirely likely. However, right or wrong,
the requirement for a DAS is now upon us, and it is worth noting
that applications will not be registered unless accompanied by
a properly prepared DAS. The preparation of these documents may
well have significant implications on projects both in terms of
timescale and cost. The jury is still out on the effect on quality.
FURTHER
READING
Design and
access statements: How to write, read and use them. CABE, London
2006 – available on-line at: www.cabe.org.uk/publications/design-and-access-statements
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