Better Places? Into the Matrix

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Policy Exchange's "A Matrix for Measuring & Delivering Placemaking Quality" was published last week with an endorsement from none other than Michael Gove. As Simon Ricketts pointed out in his excellent blog, this means we should probably give it some consideration. 

I've therefore repurposed some thoughts on the matter:

Conflicts of interest 

I'll be honest,  I'm not a fully impartial commentator:

1. I work for an organisation has an evidence based framework setting out the key ingredients (physical and non-physical) that help support quality of life at a neighbourhood level.

2. I helped develop and write the National Model Design Code with colleagues and national government at my previous job. 

Let's get into it

Ok, that being said, here are my thoughts on the matrix:

1. Lack of clarity on process/use

Intended scorer and process
I can’t get a clear sense of who the intended “scorer” is (developer “marking their own work” or LPA) and how it is to be used - some of the questions are a level that you wouldn’t necessarily know at pre-planning stage, especially for outline. 

It feels like the scores would be ripe for argument and legal dispute. There's also the question of resources and capacity for undertaking this exercise. It would be useful to see a more detailed example of a user journey.

Usefulness of case studies 
The case studies at the end apply the scoring to built development, but the main body of the report is proposing it be used at pre-planning. The report suggests that although scoring at pre-planning would be imperfect, it could be made to work, but I'm not so sure.

2. Concerns re legitimacy of scoring

Place scoring in principle 
I have concerns around the idea of developing universal numerical scoring of places, for reasons acknowledged in the report itself.

They write: “Inevitably, as with all qualitative assessment systems particularly those based on empirical evidence, it will be impossible to fully eliminate subjectivity and preference and the personal, emotive nature of placemaking outcomes makes such variation more rather than less likely to occur.”

The matrix in its current form is highly subjective. The report aspires for it to have the same weight as the OFSTED ratings applied to schools, and we know how much influence those have. 

Nowhere-ville?
The matrix does not feel responsive to the nuances of different contexts. Urban designers rail against the idea that everywhere will end up looking the same, but this risks precisely that. It also doesn't acknowledge the way design decisions might need to be balanced with other factors, especially viability and housing need. 

Mixing principles with details 
I don’t understand how, as an example, a broad principle consideration like the integration with non-car transport modes should be scored alongside something very detailed like the presence or otherwise of stone sets.

Evidence base
Who has decided what should receive a positive score and what shouldn’t? What is the evidence base that underpins the matrix? This feels like it rewards a very particular aesthetic and character, without sufficient justification as to why. 

3. Implementation/alignment with current policy landscape:

10 Characteristics of Well Designed Places
The 2019 National Design Guide established the 10 principles of well designed places. We took care to reflect this structure when we wrote the National Model Design Code. I’m unsure as to why such a matrix wouldn’t follow the same broad framing. The fact that it doesn’t will make the work of local planning authorities harder, not easier.

I understand the aspiration to bring non-physical elements into the assessment, and the report does suggest that the approaches are complimentary, but I'm not seeing much alignment in the current iteration. 

Isn’t this the purpose of a local design code? 
Local codes would be able to do roughly the same job in a way that was much easier to measure and, most importantly, rules would be tailored to fit a local context both in terms of design and viability. The non- physical elements can be captured in elements of the NMDC like "Lifespan" and "Identity" as well as being picked up in Local Plan policies. 

The NMDC can already be used in this way
The National Model Design Code content can be used as a checklist (albeit non-scored) at pre-planning, even in the absence of a local code. The purpose is to sense-check that all the aspects of well-designed places have been considered in the design process and provide structure to pre-app conversations around design. Para 129 of the NPPF explains this. 

Conclusion

I want to be supportive of something that is aspiring to deliver better placemaking quality, but I worry this is not the right way to go about it. 



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