Memorandum by Wandsworth Green Party (PGP
PLANNING: DELIVERING A FUNDAMENTAL CHANGE
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
whether the Government's proposals
will simultaneously increase certainty, public participation and
faster decisions, particularly for business; and
planning's contribution to the urban
Over a period of 1012 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
againstincluding going to judicial review to contest decisions
granting planning permissionhave been granted planning
permission, and are now in various stages of construction.
In summary, our experience is considerableat
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
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
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 standis 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
Councilwho 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 decisionsall 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 landhaving granted planning permissionthus 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 involvementin a power
effective wayin 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
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 communitiesthe
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 inputsworking
on a consensus basisfrom 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 askas
any such possible factors will continue to bear effect on land
use, whatever the final outcome of this proposed reform of the
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
changeconnecting the local with the strategicso
as to shape a quality of living environment for all who live and
work here. Such transition will be difficult, and will not occur
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 cityand 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
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 LDFswith implied lowering of environmental
standards and profile of community concern/objection, the proposalstaken
collectivelygive 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
We would hope the Select Committee pays particular
attention to this question of the implied democratic deficit of
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
CommunitiesThe 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 groupsin
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 andappropriatelyChanging 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.
for Wandsworth Green Party