Select Committee on Environment, Transport and Regional Affairs Memoranda


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.

    (9)  Improve CPO powers.

    (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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