Paragraph 79 update: Size Matters

In 2018, we undertook the most comprehensive study into the National policy known as Paragraph 79 to date. Coinciding with the revision of national planning policy, we published as our online map and research article. The research remains the most complete picture of applications to date, and is proving to be a valuable resource for our clients as well as other architects working in this field.

Paragraph 79 changed in little but number (it was previously Para 55), but our latest analysis highlights a missed opportunity to make sustainability an explicit requirement.

Below are Studio Bark’s three propositions which we think could upgrade the Paragraph 79 policy, propelling it forward as an environmentally responsible flagship piece of legislation.

The context: Growing concern / climate emergency

In May last year, Studio Bark were among the now 960 (and counting) practices who made the Architect’s Declare pledge.

Two of the 11 points that we have committed to under the declaration are as follows:

– Establish climate and biodiversity mitigation principles as the key measure of our industry’s success: demonstrated through awards, prizes and listings.
– Evaluate all new projects against the aspiration to contribute positively to mitigating climate breakdown, and encourage our clients to adopt this approach.

After having made the declaration, we made the decision to not to submit any award entries in 2020. We decided Paragraph 79 – as a core focus of practice – should be subject to this same scrutiny.

Proposition 1, on requirement for homes to be Environmentally Outstanding

Sustainability is the central principle written into the National Planning Policy Framework.

Somewhat surprisingly therefore, the wording of Paragraph 79 doesn’t require these new houses to be environmentally high performing, despite raising the bar on a number of other counts. In the context of the climate emergency, we think it is appropriate that the wording should be changed to:

the design is of exceptional quality, in that it:
– is truly environmentally [added] outstanding and innovative, reflecting the highest standards in architecture, and would help to raise standards of design more generally in rural areas; and
– would significantly enhance its immediate setting, and be sensitive to the defining characteristics of the local area.

Proposition 2, on Size

Size is a potential point of contention when looking at environmental performance in the high-end housing sector. Paragraph 79 makes no mention of the size a building can be, and so we have seen an increasing trend of larger and larger Paragraph 79.

Size is a multiplier of energy use: a smaller home with an efficient layout is likely to have a smaller environmental impact than a larger counterpart, no matter what the construction method or quality. Is it really correct that the policy should be able to cover a 1400m2 house?

We can, and do, have conversations with clients around the relationship between size and impact, but equally wonder whether the policy could take a clearer line to reward Paragraph 79 houses that are more modest in size. A well designed, efficient plan will reduce impact on the client’s pocket as well as the planet, so this is hopefully a win-win for all.

Proposition 3, on Isolation

Between urban settings and isolated sites in the open countryside, there is a potential geographic middle ground available for high quality, innovative homes. When we are trying to reduce the use of the private transport and travel distances, sites closer to certain facilities are clearly more sustainable.

However, there appears to be a policy black spot for proposals on sites which are not deemed isolated as a result of the Braintree ruling (see below), but still within land designated as open countryside.These sites fall outside of national and local planning policy despite their potential easier access to communities and facilities, and are thus excluded from development.

Presumably, the writers of National Policy haven’t intended to make it more difficult to build rural homes in sustainable locations – close to infrastructure, services and amenities – than in isolated open countryside, yet this is the current state of play.


As professionals working in a specific policy area, architects (and others working in built environment sectors) can consider ourselves the experts on policy, thus critiquing areas that are failing to reflect the environment and climate crisis is a reasonable course. Our own aim is to ensure Paragraph 79 can stand the test of time and not be made irrelevant as environmental concerns gain traction.The sign of the times appears to be direct action.

So what next? We will raise these policy propositions with Steve Quartermain CBE, the Chief Planner at the Ministry of Housing. Whether our propositions will be successful is unknown. This is unchartered territory for us, and we will be interested to see the result – if our proactive steps achieve a change, it perhaps follows that, collectively, we may be able to gain considerable momentum towards policy change more generally.

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