Memorandum by Beazer Group (UWP 86)
THE PROPOSED URBAN WHITE PAPER
1. URBAN TASK
FORCE (UTF) RECOMMENDATIONS
Urban Priority Areas
Priority should be given to those proposals,
which simplify delivery and improve implementation of projects
in urban areas. Beazer Group recognises the need to identify priorities
for action and therefore we support the concept of designating
Urban Priority Areas (Recommendation No 31) and the associated
measures which to with them namely, introducing special local
authority regeneration committees (Recommendation No 37), devolving
planning policies for neighbourhood regeneration (Recommendation
No 47), supporting a more streamlined planning process (Recommendation
No 45), assisting with land assembly process through simplified
CPO powers (Recommendation No 70) together with the clear indication
that many of the fiscal measures set out in the report will be
concentrated in Urban Priority Areas. The failure of special designations
in the past (eg SPZs) should not be used as a reason for rejecting
this approach again. However we consider the White Paper should
to further than the UTF and give some commitment to applying these
principles outside the designated areas.
Compulsory Purchase Orders
Recommendations relating to compulsory purchase
should be given considerable priority. Recommendations 67-69 and
71, which apply generally are important in providing a potential
key to unlocking sites. Although we accept the Government through
the Modernising Planning Programme has started out on a programme
of reviewing CPO powers our view is this needs to be done and
completed quicker.
Contamination
Another positive range of measures which are
clearly advantageous and achievable deal with contamination. These
include a requirement for one set of standards to work to when
resolving problems of site contamination (Recommendation 72),
establishing an Environment Agency "one-stop shop" service
for regulatory and licensing requirements, moving to a single
regeneration licence covering all requirements for cleaning up
a site (Recommendation 73), giving land owners greater assurances
that the regulators are unlikely to take future action over contaminated
sites once they have been remedied (Recommendation 74) and piloting
standardised land condition statements (Recommendation 76). In
addition Recommendation 77 suggests specific targets are set.
This is one area where the Government has failed to act in the
past but where the UTF sets out a clear programme for implementation.
Tax and Fiscal Measures
There are a large number of tax and fiscal measures
concentrated in two chapters, chapter 12 "Attracting Private
Investment" (Recommendations 87-91) and chapter 13 "The
Role of Public Investment" (Recommendations 92-105). It is
likely that most of these measures would have a positive impact
but the UTF did not set out a fully costed programme and if new
spending proposals would have to be absorbed in existing programmes,
resulting in a re-distribution of existing monies within existing
spending limits, rather than an increase in resources, the effects
will be much more limited and even potentially damaging. So, if
additional resources are not to be forthcoming what needs to be
considered carefully is what is likely to be hit in order to concentrate
priorities in urban areas.
Planning
There are some useful recommendations in the
report, which would improve the speed and efficiency of the planning
system but in our view these would be negated by another series
of recommendations, which increase the emphasis given to design.
Clearly we would support simplifying development plans (Recommendation
43) but not if it meant deferring detailed decisions on sites
to an additional level beyond the end of the local plan which
would only delay rather than increase the speed of the planning
system. Equally a review of all local rules standards and procedures
(46) and reviewing designations of employment sites should be
undertaken as a matter of course although we suggest that a review
of employment sites (48) would be more effective if it was to
take place at local plan rather than regional level. In our view
the concept of reviewing designations should also apply in the
case of Recommendation 58 rather than the much more onerous suggestion
that green field allocations which do not meet planning policies
should be removed from plans.
In respect of forward planning, the report recommends
the establishment of clear procedures under the proposed Plan
Monitor Manage system to ensure the early correction of an emerging
under supply or over supply of housing (Recommendation 54). Unfortunately
the UTF does not set out any procedure by which this could be
achieved. There is an existing mechanism in place which enables
land supply to be measured, namely the 5 Year Land Supply Calculations,
which through PPG3 Review the Government proposes to delete. In
our view that mechanism should remain in place. Equally, in the
interests of efficiency it is important that managing under supply
does not require a full review of the plan before additional sites
come forward. There is no reason why the concept of reserve sites
in plans which could be released by committee resolution if monitoring
identified a shortfall, could not be brought in.
Planning Gain
We support proposed changes to planning agreements
set out in Recommendations 49 and 50, which will provide much
more certainty than exists at present without the need to consider
introducing standard impact fees, which would not work due to
the wide range of land values on brownfield sites, which have
to be considered on their merits. In some instances the development
of the site is the only achievable gain.
2. INTEGRATION
OF POLICIES
TO FOSTER
URBAN REGENERATION
(i) The problem of the planning system putting
planning policies in separate compartments and considering individual
land uses in isolation reduces the opportunities for integration
policies.
(ii) Again, overly rigid policies can be
a problem—urban regeneration will not be achieved by setting
out rigid land uses in plans. Some degree of flexibility has to
be allowed.
(iii) In our view the planning system does
not at present address competitiveness in any way. The response
of the planning system to the Competitiveness White Paper has
been negligible
(iv) The role of Government Departments—if
the planning system is to be at the centre of the delivery of
urban regeneration, Government departments and agencies will have
to actively participate in the planning system both at the forward
planning and development control level. In our view currently
the level of resources the Government Offices for the Regions
devotes to this activity is insufficient.
(v) The role of the RDAs—RDAs do have
a role in integration of policies to foster urban regeneration
firstly as facilitators, secondly as arbitrators in disputes between
local authorities and applicants/promoters and thirdly they have
to be involved if they are to deliver their own strategies, where
urban regeneration is central to the achievement of the strategy.
3. URBAN AREAS
SUFFERING LOW
DEMAND FOR
HOUSING AND
SOCIAL DECLINE
As a single house builder we take the view that
we can only have a limited positive effect in areas suffering
from low demand for housing particularly if left to tackle the
issue on a site-by-site basis. Therefore is some attraction in
the clearance approach floated by the Hallam Study for Housing
Corporation. However, Government needs to establish the framework
to enable such an approach to take place which will provide the
land whereby individual house builders can have a positive effect.
If the Government is serious about reducing the amount of housing
to be built on Greenfield land this option has to be looked at.
In addition it gives the opportunity to adopt an urban design
and masterplan approach which will reflect current thinking and
give the area the new identify that a piecemeal approach cannot
achieve.
4. CONSEQUENCES
FOR URBAN
RENAISSANCE OF
GREENFIELD DEVELOPMENT
(i) Within the context of a national strategy
which seeks to make better use of urban land it is important to
recognise that some development has to go on Greenfield sites
and that there is still a necessity to provide a package of development
sites to meet different needs.
(ii) Urban renaissance should not be about
town cramming and Greenfield development should be recognised
within the overall strategy for the positive effect it can have
on promoting urban renaissance. Urban renaissance should ensure
that the urban areas retain a network of quality open spaces and
that not every site in the urban area is built on simply to avoid
developing on Greenfield sites. The planning system should be
able to identify the best and most sustainable Greenfield options
which both consolidate the edge of the urban area and which is
supported by an urban design/masterplan strategy which deals with
inner urban and edge of urban sites comprehensively.
(iii) Achieving a balance of uses and recognising
the needs of the market is still an important consideration. It
is too simplistic to say that all Greenfield development is bad
and all brownfield development is good or adopt an approach which
appears to be prevalent in some authorities whereby all housing
is forced onto brownfield sites and this results in an increased
demand for use of Greenfield sites for business development. This
will have the effect of creating reverse commuting not reducing
commuting, which a balanced approach ensuring that sufficient
development is provided on both brownfield and Greenfield sites
would give.
(iv) It is more important to concentrate
on ensuring sufficient numbers of brownfield sites can be delivered
which will by definition reduce the requirement for greenfield
sites.
5. SPEEDY RELEASE
OF BROWNFIELD
SITES AND
FOSTERING CREATIVE
URBAN DESIGN
In our view speedier release of brownfield sites
requires greater flexibility in the application of planning policies
by local authorities. Too often individual sites are prevented
from coming forward by employment land protection policies, prematurity
arguments pending a review of the next plan, unrealistic affordable
housing and planning gain policies and supplementary planning
guidance more onerous or in conflict with other plans. Secondly,
local authorities need to play a much more positive role in the
relocation of existing uses on sites and there is a need for assistance
in providing land in the next round of plans to allocate alternative
sites for existing industrial uses which need to be relocated
and particularly for small low value industrial users.
We would question whether local authorities
are able to foster creative urban design, partly due to lack of
officer expertise but more likely down to the fact that the ultimate
decision rests with politicians and in our view decisions on urban
design issues should not be political and should not be made by
committee.
6. POLICIES RELEVANT
TO TOWNS
AND SUBURBS,
INCLUDING THEIR
BOUNDARIES
Firstly in respect of the suburbs we fundamentally
disagree with the UTF approach which seems to concentrate on inner
urban areas to the potential detriment of the suburb. Unless issues
in the suburbs are positively addressed there will be a need for
a suburban task force in 20 years time. Suburbs must be protected
for what they are, retaining their character and encouraging investment
which makes them more sustainable by providing suitable shopping,
social and cultural facilities, together with improved public
transport. The suburbs have an important role to play in the regeneration
of whole urban areas rather than a concentration on inner urban
areas. It is important this is recognised in the Urban White Paper
which could introduce the concept of "Suburban villages"
to produce similar strategies for specific suburban areas as the
urban village concept does in inner urban areas.
Secondly in respect of towns they also provide
a sustainable solution but the inflexibility of the planning system
probably means that in most cases the most sustainable solution
is not being delivered. We would suggest a series of criteria
based policies relating to provision of different land uses in
or on the edge of towns without specifying particular land uses
on particular sites. The plan would need to review the delivery
of different uses (ie there would be a clear purpose in carrying
out regular monitoring) and as sites come forward it is likely
that later stages of the monitoring process will require more
specific uses to be specified for particular sites in order to
achieve a sustainable balance of uses.
7. THE ROLE
OF HISTORIC
PARKS AND
BUILDINGS IN
URBAN REGENERATION
(NO COMMENT)
8. WHAT ADDED
VALUE A
GOVERNMENT WHITE
PAPER SHOULD
PROVIDE
We would look for two clear commitments from
the Government in a White Paper which have not been seen elsewhere.
In our view Government needs to demonstrate commitment to urban
regeneration through establishing clear sanctions for the Secretary
of State's intervention, because one reason the rest of the planning
system does not work is that there is no enforcer other than the
legal system. The Secretary of State has sanctions but chooses
not to use them. The White Paper needs to set out how the Secretary
of State would use sanctions to ensure its measures are met. This
clearly needs to be backed up by additional financial support.
There is a need for greater consideration of existing funding
provided by local authorities, Government Departments and other
agencies, rather than relying on redistribution of existing resources,
which may be to the detriment of other interests, and in particular
the rural areas. Gap funding needs to be more readily available
on the basis of specific tests rather than through competitive
tendering.
9. OTHER MATTERS
(i) It is important the Urban White Paper
is wide-ranging, embracing more than just planning issues including
proper coverage of social, cultural, education and crime issues
which the UTF report did not address.
(ii) In our view the UTF report takes an
unrealistic moral stance suggesting that if people do not want
to live in urban areas we can educate them into accepting it.
It is important that the Urban White Paper properly examines causes
of why there is little demand for housing in particular areas
and properly considers housing market and economic considerations
in seeking a wide-ranging solution to the problem, which embraces
economic, employment, environmental, social and education issues
rather than relying on a housing and planning-led urban renaissance.
(iii) Planning does not just occur in cities,
it occurs everywhere and it is important that the measures in
the UTF report relating to the improvements in the planning system
are applied more generally, resulting in improvements in the planning
system as a whole, but giving particular priority to urban regeneration
and brownfield sites.
(iv) Treatment of affordable housing in urban
regeneration merits particular consideration. Local authorities
often assume that there is a need for as much affordable housing
as possible in inner city areas. The UTF report recognises that
this may not be the case and in establishing mixed communities
it is equally important to start from the top of the market and
work down as to start from the bottom of the market and work up.
It is important that proper consideration is given to providing
housing at the highest point the market can stand in any particular
area and also ensure that housing for sale at appropriate levels
for those in the middle of the market like teachers, nurses and
providers of essential services is available.
Paul Davis
Group Planning Director
14 January 2000
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