Memorandum by the London Planning Advisory
Committee (UWP 39)
PROPOSED URBAN WHITE PAPER
INTRODUCTION
As a national policy statement, the proposed
Urban White Paper must provide policy advice of relevance to all
urban areas. However, it should recognise that appropriate solutions
to urban problems will vary depending on the context and should
acknowledge, in particular, the scale and complexity characteristic
of London's physical, social and economic environment.
The proposed Urban White Paper must "add
value" to the range of existing national policy statements
relevant to urban areas. It can do this primarily by providing
an integrated policy framework, which draws together the agendas
of land use and transport planning, economic development, funding
of regeneration and public services and property taxation issues.
The White Paper should provide policy guidance on the importance
of developing integrated, cross-sectoral "spatial planning"
approaches within urban areas. In London, the Spatial Development
Strategy, to be prepared by the Mayor, will be based on an integrated
"spatial planning" approach, which may provide a model
for other urban areas.
The proposed White Paper should, for example,
provide guidance on integrated approaches to tackling social exclusion.
The Urban Task Force refers to the importance of tackling urban
social exclusion in bringing about an "urban renaissance",
although its importance does not seem to be reflected in the final
recommendations of the UTF. Furthermore, social exclusion is considered
by the UTF largely in terms of sub-standard housing, rather than
as the multi-faceted problem identified by the Government's Social
Exclusion Unit. The Urban White Paper could usefully draw together
policy advice in relation to all dimensions of social exclusion,
including homelessness, housing quality and affordability, discrimination,
adult education, child-care provision and so on.
The Urban White Paper should promote innovative
policy approaches to urban issues. For example, it should consider
new approaches to policy in relation to the development and management
of the public realm, the promotion of new forms of urban living
including the role of allotments, the role of incentive mechanisims
to promote development in urban areas, and the use of regional
housing targets to achieve the objectives of Circular 6/98 on
affordable housing.
URBAN TASK
FORCE RECOMMENDATIONS
The work of the Urban Task Force made a valuable
contribution to the urban regeneration debate. The Task Force
highlighted the many inter-connected issues which must be addressed
in bringing about an "urban renaissance" by changing
"urban attitudes so that towns and cities once again become
attractive places to live, work and socialise." Among the
many practical recommendations suggested by the Task Force, LPAC
suggests that the recommendations shown below (in italics) should
be progressed as a matter of priority in the proposed Urban White
Paper.
Land Use Planning
Establish clear procedures under the "plan
monitor manage" system; require planning authorities to carry
out urban capacity studies on a consistent basis; formally adopt
a sequential approach to the release of land and buildings for
housing, supported by a system of regional and sub-regional reconciliation
of housing needs and demand;
LPAC has pioneered many of the planning approaches
recommended by the Urban Task Force, particularly in relation
to "plan-monitor-manage" approaches to policy and the
use of urban capacity studies. LPAC's on-going capacity exercises
in relation to housing, industrial activity and open space provide
a strategic framework for London Boroughs and contribute directly
to completion of the wider Regional Planning Guidance for the
South East Region. They form part of LPAC's wider "plan-monitor-manage"
approach to policy. Periodic London-wide surveys of industrial
land demand and supply, office demand and supply, residential
development and open space provision also form part of this strategic
planning process.
While the Urban Task Force notes that many urban
capacity studies in the past have failed to consider alternatives
to existing planning policies and standards, LPAC has developed
innovative approaches based on the principles of sustainable development,
and recognising the linkages between related areas of urban policy.
LPAC's housing capacity exercise, for example, has considered
many forms of housing development and has made explicit the links
between housing capacity and urban design, transport access and
parking, town centre vitality, re-use of redundant offices and
large vacant sites. LPAC's work also recognises the important
contribution of open space to the quality of the urban environment.
In the light of policy seeking to promote urban development it
is vital that the protection and enhancement of urban open space,
as well as conservation and promotion of urban wildlife, are adequately
addressed in the Urban White Paper.
The Urban White Paper should provide national
guidance on the implementation of "plan-monitor- manage"
approaches to planning and the conduct of urban capacity studies.
Detailed guidance may, of course, be provided in separate "good
practice guides" produced by DETR. The role of the White
Paper should be to stress the importance of integrating such exercises
across sectors (housing, employment, open space), and ensuring
consistency with the principles of sustainable development. The
White Paper should, in particular, provide guidance on the use
of these techniques at the strategic (regional and sub-regional
level), and mechanisms to promote co-ordination between local
authorities, building on the good practice established by LPAC
in London.
Require local planning authorities to conduct
a review of all local rules, standards and procedures (including
residential density and car parking standards) to consider whether
they can be revised or removed to enhance urban development; amend
planning and funding guidance to improve the use of density standards;
The recommendation to review existing planning
standards is welcomed and accords well with LPAC's long-standing
position. LPAC has pioneered new approaches to planning in London,
particularly towards planning for sustainable development. LPAC's
work on Sustainable Residential Quality promoted higher density
development through a design-led approach, linked to public transport
provision, allowing good transport access to be combined with
reduced car parking provision. It demonstrated that careful design
of new residential development can result in a better quality
urban environment, more sustainable patterns of travel and increased
housing capacity. LPAC's SRQ work showed the potential for new
approaches to urban design, moving away from the traditional approach
of designing first for vehicular access and only subsequently
addressing building form and access for pedestrians and cyclists.
LPAC seeks to take these concepts further, linking them to wide
sustainable development issues, through a Sustainable Suburbs
Pilot Project. The Urban White Paper could promote such "new"
approaches to design, particularly in relation to the "Home
Zones" concept discussed below.
The Urban White Paper should also provide guidance
on securing social mix in new housing development, building on
the content of draft PPG3. This should relate, in particular,
to policies for affordable housing, and the importance of approaches
which allow flexibility in the form of affordable housing sought
in relation to different types of housing schemes.
Require local authorities to review designations
of employment sites in local development plans, accelerating the
release of land which is no longer needed for employment purposes,
for housing development;
The UTF report says relatively little about
the urban economy. Job-generating development contributes to the
urban economy both directly and through multiplier effects and
the continuing presence of jobs is essential for long-term urban
viability. In many urban areas, particularly in the northern conurbations,
but also in parts of London and the South East, lack of job opportunities
presents the greatest threat to urban renaissance. Moreover, forging
closer linkages between home and workplace is essential to achieving
more sustainable development. Future planning policy and economic
development initiatives should focus on making urban areas attractive
for modern commercial and industrial development, particularly
in growing sectors of the economy. The Urban White Paper must
address the issue of disparities in urban and regional economic
performance.
The Task Force rightly recommends that local
authorities should reconsider their land allocations for business
activity. Land allocations in development plans must be realistic
in the quantity and type of sites allocated for business development,
taking account of the needs of business and objectives of sustainable
development. Where employment sites are vacant for a considerable
period, authorities may need to be flexible towards other land
uses, although other uses such as housing, leisure or retail may
not be acceptable in light of national and local planning objectives.
It is particularly important that policy approaches are co-ordinated
between local authorities on a regional or sub-regional basis.
Such co-ordination is especially important between urban and neighbouring
suburban and rural authorities. The Urban White Paper and revisions
to PPG4 should provide further guidance on site allocations for
business, assessing genuinely redundant employment sites, and
on procedures and mechanisms for the regional and sub-regional
co-ordination of such policies, including co-ordination with the
efforts of the Regional Development Agencies.
Transport
Create Home Zones using tested street designs,
reduced speed limits and traffic-calming measures;
The concept of a "Home Zone" has much
to be commended, and the Urban White Paper could usefully provide
advice on their implementation. Designing streets around the needs
of pedestrians and cyclists, rather than the car is certainly
a step in the right direction and the Government's companion guide
to DB32 Places, Streets & Movement (September 1998)
provides examples of good practice. However, the concept does
raise two important and often overlooked issues. Firstly, highway
design must take account of the needs of bus-based public transport,
particularly modern, clean "hoppa"-style buses, which
are going to be critical for people making journeys longer than
a mile or so. Secondly, traffic calming measures such as chicanes
and speed humps can actually lead to localised air quality problems
as cars accelerate and decelerate. One way around this is to have
"car-free" or "Clear Zones" in areas where
development can be particularly well served by public transport.
Commit a minimum of 65 per cent of transport
public expenditure to walking, cycling and public transport over
the next 10 years;
The UTF recommendation to increase funding for
public transport, walking and cycling is welcomed. However, as
a general point, the UTF seem to fail to recognise that if we
are to discourage people from driving we will need a combination
of "sticks" and "carrots". The UTF emphasised
the role of "carrots" such as better public transport
and better conditions for pedestrians and cyclists. Whilst these
are undoubtedly important, all of the evidence to date suggests
that tough demand management measures such as road user charging
and a levy on private non-residential parking will be critical
to delivering reduced car use. In addition, these "sticks"
can provide significant new revenue streams for investment in
sustainable modes (particularly if there is 100 per cent hypothecation).
The Urban White Paper should provide guidance on the use of transport
demand management measures in achieving transport and other policy
objectives.
Set a maximum standard of one car parking
space per dwelling for all new urban residential development;
The recommendation to review existing planning
standards is welcomed and accords well with LPAC's long-standing
position. For several years LPAC has promoted restraint-based
car parking provision as an important element of a sustainable
transport strategy. However, the Urban White Paper should recognise
the need for flexibility in the application of parking standards.
For example, the UTF recommends setting a national maximum car
parking standard of one space per dwelling for all new urban residential
development. This seems unrealistic and inflexible. A more useful
approach would be to follow the very sensible guidance in the
Government's draft PPG3: Housing (March 1999) which seeks to relate
parking provision to the location and accessibility of potential
development sites by modes other than the car. It recommends that
"LPAs should revise their parking standards to allow significantly
lower levels of parking provision . . . Car parking provision
in any development should not exceed an average of 1.5-2 car parking
spaces per dwelling and should normally be less, often significantly
less" (para 42). This approach fits well with LPAC's
work on Sustainable Residential Quality, under which maximum residential
parking provision in London ranges from two spaces per dwelling
to zero. Depending on access to public transport and local services.
The Urban Task Force said relatively little
about the importance of concentrating retail and leisure development
in town centres to promote vitality, viability and sustainable
transport. The House of Commons Environment, Transport and Regional
Affairs Select Committee has already accepted the importance of
resisting further retail development away from town centres, including
expansion of existing facilities. These policies should be reiterated
and amplified in the Urban White Paper.
Property
Give local authorities a statutory duty to
maintain an empty property strategy with targets for vacancy;
LPAC's work has shown the potential significance
of empty homes to meeting housing demand in London, and highlighted
the need to make the best use of existing housing capacity. The
recommendation of the Urban Task Force to promote empty property
strategies is welcomed. The proposed Urban White Paper should
provide guidance on the development of such strategies, the implementation
of initiatives to bring empty homes back into use, and the importance
of local monitoring of vacancy rates, in light of the national
target of 3 per cent vacancy contained in the Housing White Paper.
The Urban White Paper should stress the importance of pro-active
approaches on the part of local authorities, integrating planning,
funding, property management and monitoring activities.
Facilitate the conversion of empty space over
shops by providing additional public assistance, including business
rate reductions; Harmonise VAT rates in respect of new building
and conversions/ refurbishments;
Changes to the tax system could play a part
in promoting urban regeneration, particularly if targeted towards
small landlords. LPAC's work on housing capacity in London identified
several sources of new homes, particularly redundant space above
shops, which should be promoted in the interests of urban vitality
and sustainable development. Research identified financial issues,
particularly VAT rates on refurbishment, as a significant impediment
to the refurbishment and conversion of such space to dwellings.
The Urban White Paper should indicate the potential for changes
in tax regimes to promote various aspects of urban regeneration.
Affordable Housing
Although much of the UTF's work related to urban
housing, their recommendations failed to adequately address the
issue of affordable housing, particularly the role of affordable
housing in promoting urban regeneration and objectives of sustainable
development. LPAC convened a joint Member level working party
with the Association of London Government on Affordable Housing,
Regeneration and Sustainable Development. This sought to take
a more holistic approach to affordable housing tackling social
exclusion, and embracing sustainable development and regeneration
(LPAC ADV58). The Urban White Paper and revision to PPG3 should
provide guidance on promoting socially mixed communities, tackling
social exclusion through affordable housing provision and ensuring
that development benefits existing as well as new communities.
The White Paper should promote practical and innovative approaches
to the funding of affordable housing, towards affordable housing
tenure, and in procedures for the assessment of affordable housing
need.
Area Regeneration
Create designated Urban Priority Areas, enabling
local authorities and regeneration partners, including local people,
to apply for special packages of powers and incentives to assist
neighbourhood renewal;
The Urban White Paper should consider further
the potential for some form of "Urban Priority Areas"
to promote comprehensive area renewal. However, the UPAs raise
several questions which need to be addressed in taking the concept
forward. The first relates to the criteria used to define such
areas. The UTF stresses the importance of a targeted approach
to urban regeneration, which is welcomed. It is important that
UPAs, if adopted, are closely targeted on the areas of greatest
need, which requires fine-grained analysis of deprivation at the
local area level. LPAC recently co-ordinated a mapping exercise
of the 1998 Index of Local Deprivation at enumeration district
in London, which provides a detailed picture of local area deprivation
in the capital. The local community-based approach to regeneration
proposed by LPAC for these areas is complemented by policy relating
to areas of development opportunity (often larger sites requiring
public regeneration intervention). Policy recognises the importance
of improving public transport linkages between areas of deprivation
and opportunity.
The second main issue raised by the "Urban
Priority Areas" relates to the powers and mechanisms available
within such areas. While measures to promote physical regeneration
through streamlined land assembly are welcomed, the UTF suggestion
to streamline the planning process in these areas should be treated
with caution.
The third key issue is the danger that UPAs
add to the proliferation of area-based regeneration initiatives.
If adopted, UPAs should be a mechanism to simplify and co-ordiante
the formulation and delivery of local area regeneration initiatives,
rather than simply another disparate form of intervention. This
reflects a wider issue which was somewhat neglected by the Task
Force: the importance of efficient and innovative approaches to
the provision of public services, in line with the principles
of Best Value. The quality of public services clearly has an important
influence on urban opportunities and quality of life. The Task
Force should have gone further in considering how public services
should be improved in a consistent and coherent way across urban
areas. The proliferation of area-based public sector programmes
is one aspect of this. The Urban White Paper should address the
wider issue of the co-ordination, and simplification, of public
sector service delivery in urban areas.
Land Remediation
Launch a national campaign with a target of
all contaminated land to be reused by 2030;
Ground contamination is a major factor inhibiting
the re-use of many brownfield sites in London and elsewhere. The
Urban Task Force proposal for a national "clean-up"
campaign is welcomed. Such a campaign should be linked to regional
targets for remediation, and include the prevention of future
contamination through pollution controls and use of enforcement
powers.
January 2000
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