Memorandum by the Berkley Group (UWP 57)
URBAN WHITE PAPER
In reviewing the points raised by the committee,
I find myself needing to step back one pace, to ask whether from
my perspective the right questions are being asked to promote
an Urban Renaissance.
From a presumption that the requirements of
countryside protection and sustainable transport naturally lead
one to prioritise sites in existing urban areas the aim must surely
be to identify those actions that are likely to accelerate and
facilitate development within the existing towns.
To understand the Urban Task Force's approach,
I set out their key proposals:
(1) Rewriting best practice guidance over
five years.
(2) Delaying projects until spatial masterplans
are produced.
(3) Improving city management.
(4) Developing the concept of urban priority
areas.
(5) Preparing policies for neighbourhood
regeneration.
(6) Rewriting policy guidance with full public
participation.
(7) Adopt sequential approach for land release.
(8) Remove some greenfield housing allocations.
(10) National framework for contaminated
sites.
These almost all require firstly the carrying
out of research, secondly the writing of policies and thirdly
a round of public participation to ensure acceptability. Against
my criteria, none will speed or ease urban renewal in either the
short or medium term and experience shows that by the long term,
priorities and policies will have changed making most of the complex
preparation obsolete.
However, among the supporting proposals, there
are some which deserve consideration against the facilitate and
accelerate philosophy.
Defining Density Policy 3—gives a rational
base to understanding density and framing simple policies to approach
the density/transportation car provision equation.
Mixing Uses (page 65)—indicates a rational
explanation of some advantages of mixed use developments.
Mixing Households (page 65)—offers the
more flexible approach to varieties of social support and may
provide a key to improving the social affordable framework.
Reducing Car Use (page 101)—reducing the
school run and introduction of orbital public transport routes
are areas which will make the suburbs more sustainable—this
provides helpful sustainable ideas.
Parking (page 105)—The standard of one
space per dwelling enables higher densities to be achieved. The
further extension into car free is pursuing theory too far—solutions
must be practical. We are not expecting public transport to do
away with the car.
Set Targets for Public transport (page 97):
This page explains how bus networks should be provided in suburbs,
pointing out that low density and lack of neighbourhood centres
deters people from using buses. Policy 13 advises that distances
to bus stops should be set out in Transport Plans.
Adequacy of Existing Planning System—Chapter
8 identifies the major faults and points out that the planning
system:
— Does not adequately recognise the
special needs of urban areas.
— Is not attuned to the complexity
of site assembly.
— Is stultified taking too long to
plan and make decisions.
— Too focused on controlling.
All these criticisms are completely justified
within my experience.
Having listed all the different types of plans
which control planning the task force report goes on to complicate
issues ever further by recommending an overall planning guidance
document incorporating all the others explaining how the policies
should be interpreted to support Urban Renaissance. This is complex
and confusing.
The report explains that prospects for Urban
Regeneration are weakened when the planning system is unable to
create or revise development plans within a reasonable period
of time. It points to seven years as a period taken to prepare
a local plan, going on to explain how it is often out of date
before it is adopted. It also points out that in marginal areas
this time delay can make the critical difference causing no development
to proceed. The recommendation "to simplify local development
plans with a stronger emphasis on strategy avoiding site level
policies" (policy 43) is to be supported.
The sections on streamlining planning decisions
set out the difficulties laying much of the blame for delay on
the planning system itself, lack of resources and attitude and
approach of planning authorities where no priority status exists.
It states that serious attempts at regeneration
should not be undermined by poor planning performance on behalf
of the planning authority.
The recommendation "to review all local
rules, standards and procedures to consider whether they can be
revised or removed to enhance urban development" (policy
43) should be pursued as density standards, restrictions on change
of use and mixing of uses, strictly numerical rules on distances
between properties arbitrary height restriction, minimum car parking
standards and over generous standards on the scale of roads and
road junctions are all restrictive.
On 106 agreements only policies 50 and 51 should
be pursued which:
(a) Establish independent fast-track processes
which can be triggered by either party.
(b) Replace 106 agreements with a standard
format for impact fees on smaller projects (to base it on finished
values is arbitrary—floorspace more sensible).
On social housing the proposals only scrape
the surface of the issues and only the suggestion that shared
equity be part of the proposals deserves supporting because this
is an essential part of keeping the centre of a large city going—many
of those employed in central city services require some support
otherwise urban regeneration would fail through key personnel
being unable to afford the inner city costs.
The current interpretation on social housing
being pursued by most inner London authorities simply prevents
development occurring, promoting as it often does accommodation
only for the poorest in projects designed for the richest. The
whole concept of mixed households requires a grading to achieve
a progressive mix, currently this aim is not being supported by
local authorities. Projects are being shelved and no housing is
being provided, whether social or not. Policy 80 would help these
issues.
The policies relating to contaminated land set
out in 72 and 74 aimed at simplifying and unifying conflicts in
legislation and licensing are to be supported.
Restoring old buildings to provide conversions
to flats is subject to VAT at 17 per cent. When planning gain
issues for social housing on site and education payments are added,
this creates a situation in which a building is often more valuable
in its existing use. The number of new dwellings which come forward
this way results from a combination of VAT and how greedy local
authorities try to be on other planning gain issues. Zero rating
of VAT would certainly help urban regeneration by aiding the conversion
of existing buildings.
The recommendations of the Urban Task Force
on the one hand, demonstrate a professional approach to many of
the issues, however it is in my belief, the pursuance of them
all would become such a burden of preparation and so complex in
its application that it would be more likely to delay urban renaissance
in practice than promote it.
I believe that I have identified above those
policies which could be pursued individually to make urban regeneration
more likely to occur. These favoured policies will only nibble
at the edge of the aim to facilitate and accelerate Urban Regeneration
and as explained in previous paragraphs the whole Urban Task Force
report contains so much research and needs so many further approvals,
I fear that it would not get off the ground.
In stepping one pace back from this complex
scenario, I wonder how much of a hindrance our current planning
system is to urban regeneration. It controls to the last line
of each of the local plan policy and the last sentence of each
aspect of supplementary guidance and then to the precise percentages
on the last line of site briefs.
The Urban Task Force also questioned this aspect
and try to move it forward with "Urban Priority Areas".
These however appear to serve best the areas of deprivation comprised
in the poorer housing estates to maintain the level of these and
improve the living environment by management and re-investment.
There are areas of the country where this approach is right.
It will not in my view, approach the issues
required for new urban development designed to be sustainable
in terms of reducing car dependence or those needed to create
the appropriate higher densities in towns necessary to achieve
these aims.
To promote higher densities with good transport
connections to ensure pursuance of this policy needs a simple
understandable framework aimed at achieving a specific and understandable
answer to the issues. This does not require rocket scientist abilities,
it requires local men of vision and competent planning professionals
working with simple tools.
In the early 1960's at Walton-on-Thames in Surrey,
a need for smaller dwellings was identified as a planning requirement.
Opposite the station entrance were some 11 Victorian houses, each
with several acres of land. An amendment was proposed to the local
plan identifying this area as one of high density (approx 170
hrh). This land extended to adjoin an area of existing shops.
An area was identified appropriate for housing associations to
provide houses for rent. The remainder was private flats and housing.
Opposite, adjoining the station a new office block was constructed
by Birds-eye foods which is now a listed building. All the residential
developments were different and the generally well tree'd appearance
remained. The developments were mostly completed within 10 years
provided new schemes of small dwellings (including social housing),
most of which was within walking distance of shops, bus stop,
station and junior school. All of these projects were carried
out without any local authority ownership or involvement other
than as a planning authority.
This concept can, I believe be applied to local
plans reasonably easily. Firstly, transport nodes are identified
which incorporate a shopping parade nearby. Distance assumptions
from the Urban Task Force or Llewelyn Davies reports defining
pedestrian distances are utilised and the accepted radius is drawn
from an existing station. This defines an area which is sustainable
in transport terms for high density development again as suggested
by Llewelyn Davies and the government projection for smaller dwellings
highlights this type of provision as suitable for the need or
demand. Nearer to city centres it may be that some transport nodes
are already fully developed but those located further out are
often not.
Central government needs to produce, as part
of its policy statement a small document setting the distance
criteria and promoting the high density overview policies and
stating that they will support applications which comply with
these broad policies. Encouragement to local authorities to use
compulsory powers to enable access or enable land to be efficiently
assembled or alternatively the proposal as set out in the Urban
Task Force document to increase CPO powers within the defined
area and include an ability for land assemblers to request local
authorities to use their powers of CPO to facilitate development
within these areas.
Once an area is identified, it should not be
fettered by a planning brief but left open to those with imagination
to propose schemes of merit. Quality control on design should
be a matter for planning officers and client and should include
a recognition that a project which has visual identity in the
town may offer a good answer. Perhaps a matter of civic pride
in the most imaginative results.
These simple requirements will identify locations
where employment, housing and transport can be integrated. The
role of Government departments, Government Agencies and RDA's
should be to champion this new concept by public announcement
planning advice and accelerated procedures within all relevant
government offices dealing with the planning applications or appeals.
Greenfield site developments only need to be
released if special circumstances need addressing, such as inadequate
brownfield or transport based sites being available to satisfy
the housing markets or employment needs.
Brownfield sites should be identified on local
plans with no other notation covering them—This will leave
judgements at the local level avoiding the prejudice which erroneous
Metropolitan open land or Green Belt designations can inflict
on urban brownfield sites—The definition already set out
in PPG3 draft, should be used. This will enable proper decisions
in their re-use to be examined within the policy framework necessary
to create an urban renaissance.
With respect to design, one mans chalk is another
mans cheese, this should be a combination of market preference
and civic aims and a pleasant environment does not have to embrace
extreme Architecture.
The above suggested policies prioritise suitable
sites in city, town and suburbs—edge of town is only affected
in special cases for instance if a station is on the edge of town.
It is particularly relevant in suburbs where
the loss of local facilities, such as local shops is occurring,
making the suburbs less sustainable—the introduction of
new high density living and working areas around the local station
will revitalise the local shops and services.
An Urban White Paper if produced should incorporate
the following points
(1) confirmation of sustainable approach
to an Urban Renaissance
(2) Framework to promote the policy outlined
above
(3) Introduction of a sequential approach
to dealing with planning applications.
Applications which are sufficiently large to
affect the local economy should be prioritised at every stage
and reported to committee within two months of submission aiming
to issue a decision within three months.
(A threshold of say 5,000 square metres floorspace
should govern this and separate records should be kept by the
Government indicating what percentage of these receive a decision
within three months).
This would automatically include those important
to urban regeneration and give a measure of how long it took to
get a scheme through the procedures.
In conclusion, I submit that the proposals put
forward would:-
— Rapidly identify sites with sustainable
locational characteristics for development within the urban area.
— Require the minimum of legislative
and research time to put in place.
— Prioritise Brownfield sites.
— Create a speedy planning application
procedure.
— Provide the monitoring tools necessary
to gauge success.
I believe them to be capable of facilitating
and accelerating the Urban Renaissance in a simple and understandable
way and hope that the brief explanation here, aids your thoughts
on promoting an Urban White Paper.
B N Salmon Dip TP MRTPI
14 January 2000
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