Select Committee on Environment, Transport and Regional Affairs Memoranda


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


 
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