Memorandum by the Royal Institute of British
Architects (UWP 98)
THE PROPOSED URBAN WHITE PAPER: 2000
INTRODUCTION
1. These notes comprise the brief response
of the RIBA to an invitation to make submissions to the Environment,
Transport and Regional Affairs Committee of the House of Commons
in respect of the Government's proposed Urban White Paper.
2. It is, of course, understood that at
this stage submissions are to be limited to six A4 pages but the
RIBA would be very grateful for an opportunity to expand on these
comments in oral evidence. Indeed, it should be emphasised that
there exists within the RIBA a body of expert knowledge of the
issues, and a particular range of experience in the development
field which would be helpful to the Committee. Architects work
not only for developer clients but they advise public authorities
and others, and have a special expertise in the creation of places
where people want to be which encourages both economic activity
and individual well-being. Moreover, Architects understand that
basic decisions about the broad location of development and the
parameters for construction projects have enormous consequences
for the character of the environment which is created. It must
be remembered that cities and towns attract people for reasons
which are sometimes unquantifiable, that the special qualities
of places where people want to live and work may be the result
of their character as a place rather than merely their place in
a statistical hierarchy and that well designed and desirable buildings
and environments generate a benevolent cycle of social and economic
improvement.
3. The RIBA has a Royal Charter which obliges
it to look to the public interest, the advancement of Architecture,
and should be involved in the process of setting the policy framework
for our urban areas. The RIBA would also wish to encourage the
Government itself as patron and not only as a regulator of the
urban scene.
THE REPORT
OF THE
URBAN TASK
FORCE
4. Many of the current concerns of the RIBA
are taken up in the Report of the Urban Task Force and much of
this submission flows from a commentary on that Report.
5. The main points of the Report must be
welcomed and the RIBA agrees with and supports its general thrust.
Indeed a recognition of the importance of the quality of the urban
environment is long overdue. It ought already to have been very
obvious that:
"Achieving an urban renaissance is not only
about numbers and percentages. It is about creating the quality
of life and vitality that makes urban living desirable."
6. The critical need is to encourage good
design, first in well-designed buildings and more widely in good
urban design. The Urban Task Force Report points out the need
for higher urban densities and the fact that "more than 90
per cent of the urban buildings and infrastructure that will exist
in 30 years time, has already been built". These factors
both give a special importance to design skills. Improvements
to existing complex urban frameworks, increasing the volume of
buildings and the range of activities for which they must cater,
demand special architectural design skills. It ought to be obvious
that architectural design is not merely a question of superficial
appearance but of responding to a huge range of (often conflicting)
design factors and integrating a range of skills.
Incidentally, that is why an Architect's training
takes seven years!
7. This basic message needs to be emphasised
and, perhaps more importantly, to be translated into specific
changes to policy and legislation which will encourage desirable
change. Some proposals in the Urban Task Force Report appear to
be too generalised and vague to have much real impact. Reference
to "a national campaign to improve urban design", for
example, recalls the Quality in Town and Country initiative which
seems to have had limited practical effect.
8. Therefore, these comments are intended
to focus on specific proposals for the planning system (and some
other areas of legislation).
9. Education of the public at large is necessary
and the RIBA especially welcomes the proposal to "Establish
Local Architecture Centres in each of our major cities".
Nevertheless, the education of national and local government is
much more important, especially in their roles as building owners.
Government design control functions have not been successful.
Planning control over design may have prevented some very poor
designs being built (perhaps), but it has signally failed to lift
basic expectations and if anything, has reinforced the apparent
presumption that new buildings should parody what has gone before.
That, of course, is in addition to the other main presumption
which in practice seems always to be presented to Architects designing
new buildings or extensions namely that the building should always
be reduced in size, no matter what the location or function.
10. In order to address these points, the
RIBA is preparing a proposal to amend Planning Policy Guidance
Note 1, to put Architecture back into the planning system.
11. The points made in the Urban Task Force
Report in relation to the need for "Recycling land and buildings"
are well made. Evidently "brownfield" land should be
used in preference to undeveloped land and contaminated land should
be properly dealt with and re-used, rather than simply being abandoned.
At the same time, of course, the needs for homes, jobs and so
on do have to be met because otherwise restrictive planning policies
do no more than put up land prices, incidentally causing greater
anomalies in the land market, due to speculation that prices might
rise further or that new opportunities might emerge.
12. The RIBA would like to emphasise the
need to consider a range of problems which arise through different
aspects of the regulatory systems, for example the Building Regulations.
As a matter of urgency, however, it should be possible to address
certain absurdities in the fiscal system which create undesirable
market distortions, especially in relation to VAT (as pointed
out by the Urban Task Force). Indeed, the RIBA will shortly be
submitting proposals for specific changes to the VAT system in
the hope that the Chancellor will take them up in the next Budget.
13. In the public domain the difficulties
inherent in even co-ordinating the various authorities responsible
for the ordinary street scene should not be under-estimated. The
highway authority, local council and various statutory undertakers
have little ability (and perhaps not much enthusiasm) for adopting
a coherent approach to the street scene and there is usually no
overall "town designer" to prepare and implement a design.
14. It is worth remembering Cerdas interpretation
of the street as an outdoor room for those who use it as such
as well as a traffic artery. The visual qualities of the street
are obviously important but it is also time to recognise that
in urban areas cars should expect to move very slowly indeed.
Thus it is that, allied with thoughtful visual improvement of
the street scene, there should be a radical review of traffic
calming measures on a consistent basis. The UTF Report suggestion
that councils should prepare "a single strategy for their
public realm and open space" fits in with the RIBA's approach
and could also take up the idea of Town Champions recently described
in an RIBA Publication.
However, in support of the idea that more could
be done to enhance visual quality (as well as highway safety)
the RIBA hopes shortly to be in a position to submit a specific
case study which will illustrate some of the issues.
15. Turning to the need for leadership the
RIBA must regretfully emphasise the need for more work to be done
to ensure probity in the planning system and perhaps in local
government generally, especially if more positive actions (including
the public acquisition of land) are to be encouraged. In general
terms the Government could do more to engender an instinct for
public service which has been eroded over the years but that will
not be enough. A strict requirement for all decisions to be taken
impartially now needs to be reinforced by additional powers of
the Local Government Ombudsman to investigate relationships which
are too close to be acceptable.
16. Finally, in this brief commentary on
the Urban Task Force Report, it is necessary to turn to the question
of traffic management. It seems obvious that we face a crisis
in traffic generation, part of a global crisis, but merely to
press for ill-considered and simplistic interventions, for example
by dramatically increasing petrol or diesel prices, will not produce
the desired solution for there cannot be one single solution.
It ought not to be necessary to observe that the crude social
engineering planning solutions of the 1950s have been discredited.
Planting a large engineering factory alongside a Council housing
estate does not create a population willing to cycle over to the
works, nor should it. For the economics of such a relationship
seem predicated on a subservient and ill-paid workforce, not one
which is anxious to find the best outlet for its educational advantages.
On the contrary the advantages of diverse and complex urban and
social structures must be recognised, not least the desirability
of ensuring that every member of society has the best opportunity
to use their particular skills to the full. In particular the
planning system should take account of the benefits of working
from home or in small groups. The Use Classes Order needs a thorough
reappraisal and the system's insistence on reducing development
(even room sizes in house extensions) needs a radical overhaul.
17. Much more important is the need to distinguish
those trips which could change from one mode to another. It is
now a commonplace to point out that a large number of car journeys
are "school runs", but it is also true that many other
regular journeys (not only commuter journeys) are the most adaptable
to other modes of transport than the car. For change to come about,
the alternative transport mode must not only be economical and
of good quality but must also be easy to use and reliable. Moreover,
the integrated transport plan for the country must recognise the
special advantages of different modes for different functions
and construct overall regional urban patterns based on railways,
tramways, bus routes and roads.
18. It is felt that by now the basic transport
issues are well understood, even though there has been a tendency
to seek grand and overly simplistic solutions. To make real progress,
therefore, the RIBA would hope to have an opportunity to take
part in and support a study project (based on existing research)
to review urban patterns specifically in the context of transport
requirements.
MAIN ACTION
POINTS FOR
THE PLANNING
SYSTEM
19. The RIBA is now anxious to take part
in a process of real change rather than another "talking
shop". The ideas which will be needed to regenerate our urban
areas already exist, what is needed is to put them into effect.
Indeed there can be no universal design ideas—for example
that every town and city should have some specified civic monument
or formulaic planning solution. Each of our towns and cities is
unique and each demands its own design solutions prepared in each
individual case by skilled Architects.
20. In reality, of course, the planning
system provides the framework for development which takes place
subject to the development control systems, the planning application
and appeal process. It is therefore essential to move the whole
process forward by introducing changes to the planning system,
both the legislation and the Planning Policy Guidance (which is,
in fact, somewhat legalistic in character). This opportunity is
therefore taken to put forward a shortlist of key proposals which
the RIBA would now like to see developed in addition to the matters
raised in the context of the Report of the Urban Task Force.
KEY PROPOSALS
BY THE
ROYAL INSTITUTE
OF BRITISH
ARCHITECTS
21. Design—The importance of
good design in our urban areas cannot be overstated and in an
urban context, good design is even more important and can be decisive
in establishing economic and practical viability as well as securing
a desirable environment. The planning system essentially imposes
a negative control, however, and current national guidance on
design control is contained primarily in PPG1. The position in
the UK can be contrasted with the position in much of continental
Europe, where the Architect's function is protected, since in
the UK it is generally accepted that such a system would be unduly
protectionist. However, it can be suggested that national guidance
should at least encourage the appointment of Architects for the
design of buildings (but obviously without imposing any formal
regulation to that effect). Hence the proposition that the guidance
on design in PPG1 should again be modified and augmented by a
new Circular on Design. The RIBA ought to be involved in the preparation
of such advice and could very well take the lead.
22. Streamlining the Plan Led System—The
planning system itself delays development and adds to costs. It
is felt that to counter this trend there is a need to clarify,
simply and harmonise policies in Development Plans (especially
in Local Plans and Part 2 Unitary Development Plans). Consideration
should therefore be given to removing the explanatory text from
all Development Plans. Additionally, consideration should be given
to publishing model planning policies for some subjects where
consistency and clarity are desirable and where local considerations
do not override those aims (subject to, for example, the inclusion
of a glossary of meanings).
23. Evolution of the Planning System—Inevitably,
however, new problems or anomalies are constantly being identified.
Indeed, the RIBA themselves have, from time to time, suggested
detailed changes to detailed aspects of the planning system, aimed
at keeping the system up to date and dealing with identified problems.
Nevertheless, the mechanisms needed to deal with such matters
are inadequate to keep up with the regular flow of, perhaps minor
but nonetheless, important injustices or anomalies. The RIBA (and
others) are convinced that consideration should be given to the
establishment of a permanent Commission or College of Experts
as a review mechanism for the planning system to help it to operate
more smoothly and consistently and also, in every sense, more
economically.
24. Urban Issues—Returning
to the main theme of these notes, it is pointed out that emphasis
on "brownfield" development makes it even more important
to focus on the inherent difficulties which act as constraints
to such schemes, problems of divided land ownership, complex servicing
and access requirements and other additional design constraints.
Consideration needs to be given to issues such as compulsory purchase,
taxation and land use reform but while a range of ideas have now
been suggested, it is now necessary to take these forward to a
more detailed analysis of specific proposals.
GOVERNMENT AS
PATRON
25. Finally, it should be remembered that
the Government does not only act as regulator of our urban areas,
through the planning system. In its different manifestations various
public authorities could be important patrons of buildings and
of other urban improvements.
26. The RIBA urges the Government to aim
for best value in its own developments, looking for quality and
long-term benefits and not merely for the cheapest price on tender
day. It is essential to establish a network of Architecture Centres
to encourage a "town championship" programme and, especially,
to promote Architectural Competitions for key developments that
are state sponsored in one way or another.
Royal Institute of British Architects
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