Memorandum by BG Holdings Ltd (UWP 70)
PROPOSED URBAN WHITE PAPER
1. INTRODUCTION
1.1 This Memorandum of Evidence is being
submitted by BG Property Holdings Ltd. (BGPH) a wholly owned subsidiary
of BG Group plc. As a major landowner, the Group welcomes the
opportunity to comment on the provisions which should be contained
in the proposed Urban White Paper. Phil Kirby, an employee of
BGPH, was a member of the Urban Task Force in his personal capacity.
BGPH is concerned to ensure that emerging legislation and urban
policy implements certain of the Task Force's recommendations,
whilst recognising that there are potential issues arising from
others—particularly those relating to movement and land
use planning policy and advice.
1.2 The following sections of this Memorandum
relate directly to those issues listed in the Press Notice for
the Inquiry which are relevant to BGPH's interests. The sections
are therefore as follows:
2. The recommendations of the report of the
Urban Task Force which should be a priority for implementation.
3. The integration of policies for employment,
competitiveness, housing, transport and public services, to foster
urban regeneration.
4. The encouragement of local authorities
to release brownfield sites and foster creative urban designs.
5. The "added value" of a Government
White Paper on urban policy.
2. THE RECOMMENDATIONS
OF THE
REPORT OF
THE URBAN
TASK FORCE
2.1 The recommendations of the Report of
the Urban Task Force which should be a priority for implementation
are considered to be as follows (using the same numbering as the
Report):
(i) The re-use of previously developed land
"(56) Formally adopt a sequential approach
to the release of land and buildings, supported by a system of
regional and sub-regional reconciliation of needs and demand.
(57) Set ambitious targets for the proportion
of new housing to be developed on recycled land in urban areas
where there is a significant amount of previously developed land
available and housing demand is currently low.
(72) Resolve conflicts and inconsistencies
between the different environmental regulation systems, by instigating
a single regeneration licence, covering contaminated land, water
and waste at the first legislative opportunity. Site owners should
only have one set of standards to work to when resolving problems
of site contamination.
(74) Give landowners greater assurances that
the regulators are unlikely to take future action over contaminated
sites once remediation schemes have been carried out to an agreed
standard.
(75) Establish a national framework for identifying,
managing and communicating the risks that arise throughout the
assessment, treatment and after-care of contaminated and previously
contaminated sites.
(76) Pilot standardised Land Condition Statements,
to provide more certainty and consistency in the management and
sale of contaminated and previously contaminated sites.
(91) Introduce a package of tax measures,
providing incentives for developers, investors, small landlords,
owner occupiers and tenants to contribute to the regeneration
of urban sites and buildings that would not otherwise be developed."
"(3) Revise planning and funding guidance
to:
— discourage local authorities from
using "density" and "over-development" as
reasons for refusing planning permission;
— create a planning presumption against
excessively low density urban development; and
— provide advice on use of density
standards linked to design quality."
(iii) Planning policy and advice
"(43) Simplify local development plans,
with a stronger emphasis on strategy to create a more flexible
uses basis for planning. The plans should avoid including detailed
site-level policies.
(48) Review, at a regional level, the designations
of employment sites in local development plans, taking into account
economic needs, but avoiding over-provision, and accelerating
the release of land for housing development."
(iv) Recycling the Buildings
Harmonise VAT rates at a zero rate in respect
of new buildings and conversions and refurbishments. Additionally,
redevelopment of brownland should be exempt from Stamp Duty since
it becomes a further burden on urban regeneration.
3. THE INTEGRATION
OF POLICES
FOR EMPLOYMENT,
COMPETITIVENESS, HOUSING,
TRANSPORT AND
PUBLIC SERVICES
TO FOSTER
URBAN REGENERATION
3.1 BGPH generally welcomes the recommendations
of the Urban Task Force Report, and the advice of draft revised
PPG3, "Housing", where the re-use of previously developed
land for housing is promoted, in preference to the use of greenfield
sites. The recognition in both documents that land reserved for
employment use should be reviewed and consideration given to whether
it may be better used for housing is also welcomed.
3.2 However, there is a need in the White
Paper or any "daughter" documents to provide clear guidance
on the relationship between the different sequential approaches
to the location of different land uses, such as town centre-type
uses and housing. Advice in existing and emerging policy guidance
needs to be reconciled and coordinated, to make locating housing
in or near to city, town and district centres subservient to the
greater need to focus major generators of travel demand near to
major public transport interchanges and to city and town centres.
Linked trips can then take place.
3.3 There is also a need to provide advice
on how the sequential approach can be reconciled with guidance
requiring development to be accessible by public transport. Brownfield
sites are not necessarily accessible in these terms but there
may be the potential to improve the infrastructure available and
make such a location acceptable for development.
3.4 Also with reference to the sequential
approach, and in the context of the physical constraints on the
development of brownfield land, such constraints need to be seen
in the context of the wider benefits of redeveloping previously
used sites.
3.5 Finally, on this issue, it is as yet
unclear how the sequential test is to relate to allocated greenfield
sites in approved and adopted development plans. If the sequential
approach is to be effective, it should also apply to proposals
coming forward on such allocated sites.
3.6 The relationship between transport and
urban regeneration is similarly complex and requires transport
and land use policies at the national level to be fully integrated
with fiscal measures. A balanced approach to public and private
means of transport, cycling and walking has to be taken. To alter
modes of travel to encourage more public transport use, cycling
and walking, attractive alternatives to the car must be in place.
Thus, for example, the revenues raised from road user charging
and workplace parking charges being applied to provide better
public transport is supported. Improvements to public transport
should however be in place, before further restrictions on the
use of the car are applied significantly. It is therefore essential
that land use policies to foster urban regeneration balance the
objectives of limiting car use and encouraging public transport.
Public education will also have to play a critical role in the
implementation of integrated transport policy and as an element
of urban regeneration objectives, with it being recognised as
taking up to 20 years to achieve any significant change in travel
attitudes.
3.7 Finally on this issue, land use planning
should not be used in the Urban White Paper as a means for achieving
the Government's non-land use planning objectives. Thus by way
of example, the current provisions for planning obligations should
remain, with environmental impact fees provided on smaller scale
sites or schemes only and as explained/itemised in development
plans.
3.8 The role of RDA's should be strengthened
to ensure that there is co-ordination of planning policies on
a region-wide basis, especially relating to integrated transport
and housing demand.
4. THE ENCOURAGEMENT
OF LOCAL
AUTHORITIES TO
RELEASE BROWNFIELD
SITES AND
FOSTER CREATIVE
URBAN DESIGNS
4.1 We have already commented above on the
issue of brownfield sites allocated for employment use in development
plans and their review for housing being favoured.
4.2 The Urban Task Force Report also recommended
other measures which would hasten local authority release of brownfield
sites, and the fostering of creative urban design. In particular,
the Urban White Paper should provide for:
— The promotion of the use of integrated
spatial master plans for major sites/areas (supported by "upfront"
public finance).
— The introduction of a series of best
practice design guidelines.
— Planning policy guidance (PPG) on
urban regeneration, supported by complementary policies in Regional
Planning Guidance, development plans and implemented by planning
decisions (providing that any PPG was consistent with advice already
in place).
— The streamlining and consolidation
of Compulsory Purchase Order (CPO) legislation, in Urban Regeneration
Zones with good practice guidance being provided, to assist the
wider land assembly process.
5. THE "ADDED
VALUE" OF
A GOVERNMENT
WHITE PAPER
ON URBAN
POLICY
5.1 As stated above, the proposed White
Paper on urban policy must be consistent and coordinated with
current Government guidance and advice, eg on town centres, housing
and integrated transport, so as to ensure continuing openness,
fairness, clarity and certainty in the process of development
of land. Such coordination would be assisted by awarding land
use planning greater emphasis at national, regional and local
government levels.
5.2 The coordination of policies for the
urban environment, to achieve investment, eg in promoting the
re-use of brownfield sites and in better public transport in the
short to medium term, would be an appropriate course for Government
to follow, rather than having to fund social welfare provisions
and regeneration initiatives in the longer term.
5.3 The proposed White Paper should ensure
that Local Authorities adopt current Government guidance as a
priority notwithstanding, it is not incorporated within their
Development Plans. Only then will there be meaningful changes
in policies to give priority to the re-use of previously developed
sites.
January 2000
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