Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by Wandsworth Green Party (PGP 41)


  Some of our members are involved with the local Wandsworth Environmental Forum, and a small input has been made by WEF to the wider Green Paper consultation process. This covered many, if not all, of the main points we would wish to make on the Green Paper proposals. This note seeks to cover four of Committee's expressed points of interest as follows:

    —  the effectiveness of the system of local plans and the Government's proposals to replace them;

    —  the role of regional planning bodies (London context);

    —  whether the Government's proposals will simultaneously increase certainty, public participation and faster decisions, particularly for business; and

    —  planning's contribution to the urban renaissance.


  Over a period of 10—12 years, we have been involved in local land use/planning issues from the community/environmental perspective, campaigning for development that accords with real local needs, social/economic/environmental; that incorporates fine design and juxtapositional balance/harmony; and that includes genuine participation in the decision making process. We have not always been successful in the campaigns we have taken part in. Many of the specific site development proposals (mostly luxury residential schemes along the Thames riverfront) we campaigned against—including going to judicial review to contest decisions granting planning permission—have been granted planning permission, and are now in various stages of construction.

  In summary, our experience is considerable—at the grassroots, and urban (London) based. Though much of what we say here has specific London resonance, significant points re a wider contextual framework for land-user/planning procedures might apply to urban environments generally, with some input (though probably crossover relevance is limited) for rural communities and development.


  The DTLR press release (12 December 2001) on the Green Paper stated, in the words of the Mr Byers, that: "This is a radical change in the way we look at planning. Instead of being led by plans we will lead by people. We want a planning system in which the values of the whole community are allowed to prosper and develop". The concluding quote frames our deep concerns concerning the efficacy of these proposals: "Our proposals have been characterised as being good for business. That is true. But they are good for the rest of the community too".

  This last quote can legitimately, we feel, be described as understatement, specifically it's description of the proposals as being good for business. These proposals, if enacted unchanged, would be superlatively good for business interests and developers. The real fear is that the necessary balance of view regarding land use decisions would be lost, with the concomitant democratic deficit enabling incremental or swift, sudden erosion of environmental, community, conservation safeguards that have been qualitatively developed through decades of dedicated effort by many people/groups since 1947.

  If, as is stated at paragraph 1.4 in chapter one of the Green Paper, that "(the planning system) has a critical part to play in achieving the Government's commitment to sustainable development", several points clearly follow:

    1.  Sustainability is the overall context for all development.

    2.  The criteria of sustainability re all aspects of development need careful and precise delineation, thus to form an agreed, principled and non-negotiable foundation for all sectors/groups/interests across the "development spectrum". In our view, we live in critical times, ecologically as economically, locally as globally, and our transition to sustainable ways of living, contributing to security/stability/quality of life for all, is an essential component of our individual/collective responsibility as local/global citizens.

    3.  Patterns of development that reflect these principles can only be determined through co-operative consensus processes. If the Government is sincere in its commitment to development that is sustainable, the Green paper proposals need clear modification in order to guarantee that the future pattern of development, relating to urban, sub-urban, rural, wilderness environments, conforms to such principles/criteria/process.


  Without doubt, the process of determining Unitary Development Plans (UDP)—as they now stand—is protracted, complex and often cumbersome. The strengths of the process include the guaranteed right of participation by people/groups in the local community, thus ensuring some semblance of participatory democracy in determination of the UDP.

  The group which worked on inputs for the Wandsworth UDP Review (for Wandsworth Environmental Forum) met regularly over an 18 month period, putting together some 150 comments (a quarter of these were comments of support, the remainder were objections; of these objections, the Council took action on five). Following the Public Inquiry, which ran for three months last summer, the imminent publication of the Inspectors' report will see the report's recommendations duly considered by Wandsworth Council—who are under no obligation to accept such recommendations. The subsequent Council report will be open for comment by local people/groups, though it is not seriously considered that, at this late stage, any such inputs will make the slightest difference to the Council's views.

  As regards our inputs concerning specific site development proposals, our involvement with a local community group (over a period of six years) seeking a balanced development of mixed economic/community/environmental uses for a significant riverfront site by Wandsworth Bridge (Gargoyle Wharf)—this included public meetings, lobbying Councillors and MPs, letters to Government Office for London, a community "Planning for Real" exercise in which 150 people took part (the subsequent plan was totally rejected by the developers of the site), plus two judicial reviews of planning consent decisions—all now, it would seem, to no avail. Planning permission has finally been granted, and presumably initial decontamination work on the site will shortly commence (or possibly the developer will now sell the land—having granted planning permission—thus securing the benefit of the land's enhanced value). For the scheme as stands, we did secure 25 per cent social housing.

  We give this detail to clearly demonstrate the various factors that come into play when urban development is inevitably confrontational, between the developers needs/wishes, the local community's needs/wishes; with the local authority somewhere in between? This kind of situation is repeated with many sites, involving various developer groups, and many, many community/environmental/amenity/residential groups. From the community point of view, there have been some gains, but too many losses, with large single use developments in many areas negating the opportunities for the kind of compact, mixed use developments that would best exemplify sustainable community development. And this is with the current UDP system operative, a system which, supposedly, guarantees participation by the local community. All too often, the developers interests have been upheld, with perhaps some minor ameliorative environmental add-on extras secured through Section 106 agreements.

  If this is the situation that pertains with the strictures of the UDP in place, then a possible abolition of the UDP (or local/structure plan) and replacement with a looser, unmapped Local Development Framework would seem to open the gates for all manner of inappropriate schemes to unravel, with LDFs providing too much scope for speculation.

  For Local Development Frameworks to be successful, in real terms, for the local authority, the commercial sector, developers, and all groups in the community, there would have to be something of a statutorily supported shift towards genuine power-sharing between the local authority and other interests within the community.

  The proposals state (at paragraph 4.21, page 17)—under the heading, "Engaging the Community", "We shall encourage all local authorities to work with Local Strategic Partnerships to establish effective mechanisms for community involvement, building on their work preparing Community Strategies". Such language is almost transparently inadequate, if, that is, there does exist a real commitment to render these proposals as totally supportive of local community involvement—in a power effective way—in the decision making processes for land use planning for the urban built/natural environment, that will serve to shape and affect the quality of living for people in local neighbourhoods/streets/areas.

  Measures like the Statement of Core Principles, the Community Strategies, community action plans, maps for areas of change and existing designations (such as conservation areas), implementation measures/schedules, progress reports to local communities—the language is indeed alluring. But without the requisite shift in the power equation, then in all probability, the LDF proposals will be (as I heard them described recently by an experienced politician) just so much flannel.

  In principle, we like the essential ideas relating to LDFs, but it is their contextual application which elicits our deep concern.

  We consider a viable solution (possibly) might be a judicious blend of UDP/local plan framework and the main component elements of the proposed LDF. If local participation were guaranteed, in a real sense, then area master plans, neighbourhood/urban village plans, design statements, site development briefs, could all be incorporated into that process, with inputs—working on a consensus basis—from business/commercial, amenity, environmental, residential, special interest groups, designers, ecologists, working with planners and councillors from the local authority. A genuinely democratic exercise in land use determination. Some UDPs have already taken some steps in this direction, with the inclusion of urban village/sustainable neighbourhood considerations in UDP Review.

    Question: Would local authorities be willing/have the capacity to share power thus?

    Question: Would developers use the looseness of proposed LDFs to push through contentious schemes, disguising the business-as-usual approach with greenwash jargon?

    Question: If business/commercial development applications were fast-tracked as proposed, without any clearly delineated sustainability/community context (with criteria, principles, policies in place), would environmental/conservation standards be diminished, or upheld?

    Question: Are there any underlying factors that affect the power balance re land use procedures? If so, what are they, and how might they be addressed so as to neutralise their effect on the quality and sustainability of urban land use?

  (Though this last question goes beyond the remit of the Green Paper, we still think it relevant to ask—as any such possible factors will continue to bear effect on land use, whatever the final outcome of this proposed reform of the planning system).

  Other questions could be asked, and many further points made, but let brevity suffice.


  London's circumstance is specific, with a large population spread through 33 Boroughs. Given that these are critical times, the case for the transition to London as a truly sustainable city renders complexities of strategy that inevitably need an overall strategic authority. While the GLC was far from perfect, since it's demise, our city has suffered a consequence of discoordinated approaches re various aspects of development and investment. Now, with the GLA, there is the dawning opportunity to render positive change—connecting the local with the strategic—so as to shape a quality of living environment for all who live and work here. Such transition will be difficult, and will not occur overnight—no surprise!

  With the next draft of the Mayor's Spatial Development Strategy due for publication in April (we think), with Wandsworth's UDP awaiting the PI report before the formal adoption of the Plan probably later this year, plus the Green paper proposals for the reform of the planning system, the coordination of local with strategic plans is indeed complex.

  It has been, and is of huge benefit to have three Green Party representatives serving on the GLA (NB elected under a system of PR). For us at local level, as well as for the city overall, qualitative environmental and economic inputs have ensured a spreading influence around our city—and hopefully such influence will only increase.

  As with any strategic body, there are concerns at bureaucratic barriers that might hinder the Green commitment to devolved strategies and communications. At this stage however, we wish to add little more here; the difficult complexities of coordinating GLA strategies with those at the local level will doubtless emerge through the months ahead.

  London provides a clear example of the essential nature of strategic policies, and with transition to a sustainable city in mind, it will be interesting to see just how the GLA maintains an issues-led stance, rather than divisive party political considerations being prioritised.


  Many of the proposals for fast-tracking applications, lessening the time taken to process applications, and the introduction of shorter time scales on call-in and appeal procedures would, if introduced, allow faster decisions. And the business/developer section would undoubtedly benefit hugely from such implementation.

  The main question here is what qualitative costs will have to be born with regard to environmental standards, genuine public involvement in the decision-making process, and the level of anger that would be incurred if some of the major proposals for fast-tracking are introduced as they stand.

  With regard to major infrastructure projects, the introduction of Business Planning Zones (requiring no planning consent), the diminution of scope of Public Inquiries, the very looseness of LDFs—with implied lowering of environmental standards and profile of community concern/objection, the proposals—taken collectively—give rise to a disturbing democratic deficit, which we find impossible to reconcile with the stated aims of sustainable development, engaging the community voice, and creating better places in which people can live and work.

  The overwhelming priority seems to be inclined towards the business sector, without due regard towards necessary constraints. Indeed, in an article in the Guardian (18/12/2001), Ros Coward put it clearly: "Reform ought to be an opportunity for a government which claims it wants `to put the environment at its heart'. But there is virtually no mention of environmental protection, nature conservation or green belt. The focus is on the frustrations of developers, not on the question of how planning should be used to protect and enhance local quality of life".

  We have not had the chance to consider the documents on Planning Obligations and Compulsory Purchase, or the detail of the proposals for major infrastructure projects. However, to even suggest that such projects should be determined in principle by Parliamentary scrutiny (half day or half hour debate?), with such "scrutiny" subject to the whipping procedure, is almost beyond democratic belief. People in our localities must have the guaranteed right to involvement in the decision-making process where the determination of quarrying/petro-chemical/major roads/opencast coal mine/port/nuclear power plant project proposals are concerned.

  We would hope the Select Committee pays particular attention to this question of the implied democratic deficit of these proposals.

  And while appreciating the need for decisions to be made as fast as possible, the necessary adjunct regarding assured quality of decisions within the true sustainability context mentioned earlier is that decisions be as slow as necessary.

  As to the question of certainty, the vagueness of the proposed LDFs and accompanying "community engagement" would seem to promise more uncertainty as to maintained standards, and the disempowerment of people in communities in all environments, particularly with regard to the potential intrusion of the business sector, with schemes that lack quality and would tend to minimise on social equity and environmental protection.

  If the urban renaissance is to be one of quality, peace of mind, security, happiness and enjoyment of the built/natural environment that comprise people's surroundings, these proposals need considerable and careful rethinking.


  The nature and pattern of permitted development, including the range of criteria and policies employed in such determination, can serve to shape urban/suburban environments that enhance people's real quality of life as much as they can serve to detract from such potential quality.

  In London during the last few decades, pressure for commercial development in many areas has seen loss of treasured open spaces, a proliferation, most recently, of luxury residential developments, often dreary public sector housing estates, and quantities of large-scale single use developments. While at urban edge, the sprawl of development has continued its intrusion into the Green Belt.

  Now though, there is a clear opportunity of evolving a fully integrated approach to our urban planning, so as to deliver land use strategies that make the most of compactness, with close proximity of services, housing, employment opportunities, leisure/recreation facilities and open spaces. Such mixed use planning can serve to create living environments in which quality of living is enjoyed, in which sense of belonging is endemic, and in which beauty might form a practical component. It would be tragic if this opportunity were to be wasted through lack of vision, understanding and determined commitment on the part of politicians, planners and developers alike.

  From a considerable range and wealth of material substantiating the case for integrated mixed use planning for community, two titles are worth a mention, both of which refer to components of land use strategy that are sustainable within the urban/suburban context, and have quality of living as the ultimate arbiter of successful development.

  The first is Compact sustainable communities, published by CPRE London Branch, 2001, with subtitle, "Meeting London's housing needs while improving quality of life, increasing economic vitality, protecting environmental assets and reducing the need to travel". This pamphlet of some 30 A4 pages outlines specific components of qualitative higher density development, that are well designed, with the focus on inner London, on town and other local centres, along with the benefits of compact communities.

  The second is a 300 page book, Sustainable Communities—The Potential for Eco-Neighbourhoods, edited by Hugh Barton, published by Earthscan, 2000 (reprinted 2002). It succinctly examines the practicalities of creating/planning for neighbourhoods, covering the ground in consummate detail, challenging planners, politicians and professional/voluntary groups—in short, all those with a dedicated interest in shaping the communities we need in our inner cities, our suburbs and elsewhere. On pp 249-251, in the chapter headed 'Towards Sustainable Communities', three vital areas are summarised- Shifting Hearts and Minds, Reorientating the Planning System and—appropriately—Changing Government Policy. We can do no better than to quote from the initial paragraph of this last section re government policy:

    "It has been obvious throughout the discussion that government holds the key to the move towards more sustainable neighbourhoods. The DTLR has in the mid/late 1990s comprehensively overhauled planning guidance, and the rhetoric of sustainability is beginning to be matched by action through the plan approval and planning appeals systems. Some related areas of government are also showing signs of embracing the new local approach, particularly in relation to health and urban regeneration. However, there are fundamentals of government fiscal and regulatory policy that need to shift if moves towards localisation, neighbourhoods and greater subsidiarity are to be generally successful".

  A further paragraph commences thus: "More specific to the development process is the issue of the way the market for land inhibits reallocation from high to low value uses (eg from housing land to open space within the urban green network), while giving no benefit to the public purse when the reverse happens (eg through intensification policies)".


  Much more could be said on these and other related issues, but we'll close this brief input with a quote from Richard Rogers in his Cities for a Small Planet: London is at a turning point in its history, and our generation has the opportunity of transforming it into one of the most habitable and civilised cities in the world".

  With this, we concur. We hope these few pages are of use to your deliberations re the Green Paper, and fervently wish that our collective opportunity will not be wasted to commercial selfishness and greed. Thank you.

Bruce Mackenzie

for Wandsworth Green Party

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