Memorandum by the Wildlife Trusts and
The Urban Wildlife Partnership (UWP 22)
PROPOSED URBAN WHITE PAPER
INTRODUCTION
1. The proposed White Paper provides the
perfect opportunity for the Government to begin putting sustainable
development into practice in the UK's towns and cities. It should
take into account its own statements (especially "A Better
Quality of Life" the new strategy for sustainable development),
the work of the Urban Task Force, the Round Table on Sustainable
Development, the UK's international obligations and commitments
in this field (especially the International Convention on Biodiversity
and the requirements of Agenda 21) and the forthcoming Local Government
Bill (especially the new power for local authorities to promote
the economic, social and environmental wellbeing of those who
live, work and visit the local area).
2. Taking a lead from "Best Value",
the thrust of the White Paper should be to promote qualitative
measures, such as continuous improvement in people's quality of
life, as essential components of an urban strategy. Integrating
economic, social and environmental policies should be at its heart.
Achieving the urban renaissance called for by the Urban Task Force
requires vision and leadership: if it is to happen it will take
time, instant change may be politically desirable but is unlikely
to be sustainable.
3. Perhaps the most radical thing the White
Paper could contain would be an acknowledgement that towns and
cities need to be managed by engaging a wider sphere of expertise
and with broader objectives than at present. As well as the traditional
skills in such fields as engineering, construction, transport,
health care, business and commerce, society now needs urban ecologists,
environmentalists and sustainable development practitioners. These
should not be seen as luxuries or optional extras, but as vital
to our understanding of why cities are as they are and how their
dynamism and attractiveness may be sustained.
4. These skills need to be exercised at
the most appropriate level within towns and cities. The principles
of subsidiarity should be combined with participative democratic
processes, such as Local Agenda 21, to ensure that the many and
varied communities which make up towns and cities are effectively
engaged in the decisions which affect them most. For example transport
infrastructure will normally be tackled at a strategic level within
a city or a conurbation, but decisions about open space planning
and management should be at least partly made within the communities
or neighbourhoods where the open spaces are.
5. It will also be helpful for the White
Paper to offer an ecologically sound definition of "urban
renaissance". The Task Force's own report acknowledges that
". . . cities themselves are extremely vulnerable organisms,
. . . protecting existing natural environments from damage is
one of the greatest challenges of the next century. Nowhere is
the implementation of sustainable products and services more important
than within cities." (The Ecological Imperative, page 28.)
Attention must be paid to conserving and enhancing biodiversity,
people's access to semi-natural open spaces (see page 6 of this
Memorandum), air and water quality, resource use, waste management,
energy use and supply, and transport systems.
6. In the rest of this memorandum we will
be focusing upon land-use issues within the context of some of
the points the Committee wishes to examine.
THE URBAN
TASK FORCE'S
RECOMMENDATIONS
Recommendation 1
Require local authorities to prepare a single
strategy for their public realm and open space, dealing with provision,
design, management, funding and maintenance.
7. In principle this is a welcome recommendation,
although the vision and long-term thinking needed to bring such
a strategy forward will be difficult to achieve because of short-term
political considerations. As well as the suggested "combination
of nationally agreed standards and guidelines and a careful interpretation
of local need" mentioned immediately before this recommendation,
a note about thinking in 50 or 100 year time scales would have
been helpful. If, as stated elsewhere, "more than 90 per
cent of our urban fabric of 30 years times already exists",
then there is little room for manoeuvre in the short to medium
term.
8. We have some concerns about putting "the
public realm" and "open space" together here, as,
in the context of the report, the former seems to relate to the
smaller spaces of the built and designed environment and the latter
to the generally larger spaces of the semi-natural environment.
Our suggestions for standards for access to urban green space
referred to below are relevant here.
Recommendation 21
Provide above-inflation increase in central
resources allocated to local authorities for managing and maintaining
the urban environment in each of the next seven years.
9. This is a very welcome recommendation.
It is apparent that in recent years the resources devoted to the
management and maintenance of open spaces of every sort have diminished
in comparison to both earlier years and other services and functions.
It might have been expected that money saved through the contracting
out of land management could have been invested in such things
as ranger services, interpretation, regular ecological surveys
and sensitive ecological management of prime nature conservation
sites. This would have led to greater access and accessibility,
greater confidence amongst the public to use and enjoy open spaces
and greater understanding of nature. This would ultimately have
lead to better value for the resources devoted to open space management.
More resources now would give an opportunity for the situation
to be reversed.
Recommendation 22
Assign a strategic role to local authorities
in ensuring management of the whole urban environment, with powers
to ensure that other property owners, including public utilities
and agencies, maintain their land and premises to acceptable standards.
10. This recommendation has obvious affinities
with recommendation no 1, being intended, perhaps, as one of the
mechanisms for implementing it. It begs the questions as to what
"acceptable standards" are, how they are defined in
different circumstances and who sets them. Our concerns would
be that overtidyness, misguided efforts to "improve"
the inherent informality of nature and lack of ecological expertise
on the part of regulators and others could lead to damage to valuable
wildlife sites and threats to biodiversity.
Recommendation 31
Create designated Urban Priority Areas, enabling
local authorities and their partners in regeneration, including
local people, to apply for special packages of powers and incentives
to assist neighbourhood renewal.
11. This recommendation needs to be looked
at very carefully. It has echoes of previous flawed initiatives,
especially Enterprise Zones. These may have achieved some of their
objectives, but in some cases were used by the private sector
to circumvent planning and other restrictions. This lead to, for
example, the creation of the massive Merry Hill Shopping Centre
in the West Midlands, an activity and land-use not envisaged by
those who framed the regulations.
12. If this recommendation is acted upon
we would seek very strong safeguards for nature conservation and
biodiversity interests, and would expect the strategic considerations
contained in other recommendations, such as those above, to figure
prominently. It has taken much effort to achieve even the minimal
protection currently given to statutory nature conservation sites,
and to have non-statutory Wildlife Sites included in nature conservation
strategies and other planning documents. This effort should not
be wasted by a relaxation of planning constraints where it is
inappropriate to do so.
Recommendation 34
Make it easier for regeneration bodies to endow
cash and assets to local trusts and community organisations.
13. Being an organisation rooted in local
action for the environment we warmly welcome this recommendation.
One of the recurring problems of regeneration schemes has been
the parachuting into communities of human, physical and financial
resources, followed by their withdrawal. Properly planned succession
strategies, coupled with effective engagement of local people,
will do much to protect investment in the urban renaissance.
14. Linking this recommendation with others
relating to local authority powers and duties, and, outside the
report, the UK Strategy for Sustainable Development and the themes
and programmes of the National Lottery distributors would provide
a powerful and integrated approach to community development. Within
any such approach we see many opportunities for integrating the
economic, social and environmental aspects of regeneration.
Recommendation 39
Develop a network of Regional Resource Centres
for Urban Development, promoting regional innovation and good
practice, coordinating urban development training and encouraging
community involvement in the regeneration process.
15. The Task Force's report envisages that
such centres would serve the planning, design, surveying, construction
and engineering professions. Their value to both sustainable development
and the urban renaissance would be greatly enhanced if they also
incorporated urban ecology, environmental management and biodiversity
skills. Indeed if they do not then they will never be able to
fulfil their potential. Continuing to develop our towns and cities
whilst ignoring the natural features, forces and resources which
ultimately dictate our success or failure is last century's method:
the 21st century demands a more sophisticated and holistic approach.
Recommendation 46
Require local planning authorities to conduct
a review of all local rules, standards and procedures to consider
whether they can be revised or removed to enhance urban development.
16. Whilst appreciating that any set of
rules and standards should be reviewed and revised over time we
feel that it is dangerous to do so with such a narrow end in view.
Rather the review should be to test the rules and standards against
the original purposes and, in this context, to consider whether
their revision can contribute to the called for urban renaissance,
of which development is but one part. Too much concentration on
urban development per se is likely to result in the loss of the
strategic vision implicit in other parts of the report. To return
for a moment to the question of standards, consideration should
be given to the introduction of new standards where appropriate,
not just the revision and removal of existing ones.
Recommendation 59
Retain the general presumption against development
on designated Green Belt. Review whether there is a case for designating
valuable urban green space in a similar way.
17. We very much welcome this proposal,
although the two types of land are entirely different: Green Belt
designation is related to the location rather than the quality
of land, whilst "valuable urban green space" implies
a qualitative assessment of the land concerned.
18. Introducing such a designation would,
however, go some way to allaying some of our concerns as outlined
in other parts of this response. This could be an integral part
of new planning mechanisms, so that even in, for example, Urban
Priority Areas, such designations could be made to protect land
against development. This would be in keeping with the comments
above about introducing as well as revising and removing existing
standards.
Recommendation 61
Introduce a statutory duty for public bodies
and utilities with significant urban landholdings to release redundant
land and buildings for regeneration.
19. If the phrase "for the achievement
of the urban renaissance" had been used then this recommendation
would be more welcome and appropriate. We believe that greater
clarity is needed: for example how would "redundant"
and "regeneration" be defined, would valuable but informal
open space owned by a public body be at risk of being "released",
if so at whose behest and to whom?
20. It is easy to see that land for building
houses would be released to a developer, but what about land contributing
in other ways to regeneration—for instance land with biodiversity,
amenity or recreation values? Would this have to be disposed of,
and if so would this not work against other recommendations seeking
an enhanced strategic role for local authorities? (The report
implies that local authorities are included in "public bodies"
in this context.) We note that an associated recommendation (62)
is that the land be transferred to Regional Development Agencies.
This could be appropriate if they manage/dispose of it in pursuance
of their duties to further sustainable development, and not just
to further economic development.
Recommendation 86
Establish a ten year national programme—The
Renaissance Fund—to help repair our towns, whereby community
groups and voluntary organisations can access the resources needed
to tackle derelict buildings and other eyesores that are spoiling
their neighbourhood.
21. This recommendation is very welcome.
It reflects and acknowledges the enormous contribution made to
environmental improvement and protection by community and voluntary
groups throughout the land. Such a fund would complement and build
on existing initiatives, both in the private sector (such as Shell
Better Britain and Barclays Site Savers) and in the public sector
(such as the recently successful Rural Action for the Environment
and the Environmental Action Fund). The work of ourselves, Groundwork
Trusts, the British Trust for Conservation Volunteers, the Civic
Trust and many others would be enhanced and strengthened.
OTHER POINTS
Building on Greenfield or Brownfield Sites
22. It has always been our belief that the
concentration on the proportion of new development on brownfield
sites distorts the process of urban regeneration. For an urban
renaissance to be successful we are strongly of the opinion that
the open space resources of any town or city need to be assessed
together with its buildings and infrastructure, and not be seen
merely as a series of potential building sites. The actual and
potential values and functions of the open spaces need to be taken
into account when planning development. What the open spaces are
called (eg brownfield, greenfield, derelict, waste, urban commons,
park) is of less importance than the functions and services they
provide, and their importance to the neighbourhoods and communities
within which they lie.
23. That local authorities should give priority
to the re-use of previously-developed land seems to us to be more
helpful than setting targets of putting X per cent of new houses
on such land. Establishing a priority which can then be interpreted
according to local needs and circumstances is surely better than
expecting an arbitrary target to be met. It is our contention
that the allocation of land for housing should be done on a site
by site basis taking into account the existing biodiversity value
of the site concerned, whether or not it is a "brownfield"
or a "greenfield" site, and whether or not it is in
town or country.
24. The UK-MAB Urban Forum has similarly
called for every site proposed for development or redevelopment
to be treated on its merits in respect of its wildlife and natural
features. Their value needs to be judged against appropriate environmental
and social criteria. Such an approach would need to draw on the
ideas of valuing natural capital and ecosystem services and has
been used in Durban in terms of the cash-benefits derived from
the services provided by its metropolitan open space system.
25. The White Paper would do well to recognise
these factors, and to endorse the Government's proposed definition
of brownfield sites ("previously developed land") in
the draft new PPG 3 Housing. This does acknowledge the virtues
of some brownfield sites by excluding from the definition "land
that was previously developed but where the remains of any structure
or activity have blended into the landscape in the process of
time (to the extent that it can reasonably be considered as part
of the natural surroundings), or has subsequently been put to
an amenity use and cannot be regarded as requiring redevelopment".
The Role of Parks and Open Spaces
26. In the quest to regenerate urban areas
there is an acute need to incorporate all the elements of town
and city life that improve people's quality of life, facilitate
effective and economic management and protect the local environment.
Parks and open spaces have a fundamental place in these processes.
Compact settlements should not mean town cramming, greenspace
should be both created and protected within such settlements,
and this should be seen as an important contribution to improving
the quality of life. Every opportunity needs to be taken to do
this, and not just by allocating new areas of semi-natural open
space, important as this is. Developers, architects, planners
and public agencies should be actively seeking ways of linking
new housing (and other development) to the systems and cycles
which support us, and which are traditionally ignored.
27. There is much in the Committee's own
Report into Town and Country Parks which should inform the preparation
of the White Paper. In particular we urge that the recommended
"Urban Parks and Greenspaces Agency" be included. Combining
this with the standards below, the ideas in the Urban Task Force's
recommendation no 59 to consider extending Green belt provisions
to valuable urban green space, the proposed definition of previously
developed land (below) and the recommended duty of care on land
owners and managers, would provide a rational and integrated approach
to the protection, use and management of open spaces of all sorts
in our towns and cities.
28. One way to ensure proper provision is
to introduce standards for access to semi-natural open spaces
in urban areas. English Nature and ourselves believe that the
following standards should be adopted, the White Paper gives the
opportunity to do so.
— "An urban resident should be
able to enter an urban greenspace of at least 2 ha within 0.5
kilometres of their home.
— Provision should be made for Local
Nature Reserves in every urban area at the minimum level of 1
ha per 1,000 population.
In addition there should be:
— 1 x 20 ha site within 2 kilometres
of all residents;
— 1 x 100 ha site within 5 kilometres
of all residents;
— 1 x 500 ha site within 10 kilometres
of all residents."
29. We also endorse the recommendation from
the UK Round Table on Sustainable Development, in its report on
housing and urban capacity, that the Government should issue new
national planning policy guidance in respect of urban revitalisation
and development on previously used land. In particular, we support
the rider added by the UK Round Table that this new guidance ".
. . should also provide strong support for the protection and
enhancement of urban green space." Such an approach has much
to commend it and reflects the existing national planning advice
that in seeking to make maximum use of vacant urban land for housing
there is a need to distinguish between sites which need to be
retained for recreation, amenity or nature conservation and sites
which are genuinely suitable for development.
30. In this connection the Special Report
produced on 15 December 1999 by the Parliamentary Joint Committee
under Lord Shaw of Northstead, considering the City of Stoke-on-Trent
Tunstall Northern Bypass Local Government Act Compulsory Purchase
Order 1997 is of interest. In ordering extra land to be made available
in exchange for the loss of Public Open Space, they said: "The
City Council is expecting to improve the formal recreational facilities
available . . . But we would urge the Council—and similar
planning authorities throughout the country—to bear in mind
the need for uninterrupted open space, accessible to all, including
people with disabilities and pushchair users, where people can
simply let off steam."
Policies Relevant to Towns and Suburbs as well
as Cities
31. We recommend that a duty of care in
respect of wildlife, landscape and natural features should be
placed on owners and managers of developed and undeveloped land
in urban areas. Such a duty has been recommended to Government
by the UK Round Table on Sustainable Development with regard to
agricultural and undeveloped land in rural areas. This would provide
a uniform basic level of obligations—a level playing field—to
which local initiatives could be added. There is, of course, the
question of what are the obligations in respect of this duty of
care and who enforces them. But a first step in this direction
could bring significant environmental and community benefits.
January 2000
| 
