REGIONAL   DEVELOPMENT   AGENCIES

 

                                                    A  DISASTER  IN  THE  MAKING ?

 

 

                                                                           OCTOBER 1997

                                                                         ( update  4.12.97 )

 

 

                                         An assessment by Steve Hawkins of Luton Friends of the Earth

 

 

                                Comprising:

 

                                A discussion paper on the problems RDAs will pose if adopted under the current

                                Planning System;

 

NB                          Measures which could be taken to reform the system and make it more accountable,

                                sustainable, and acceptable to the public;

 

                                An appended clarifying extract of text and graphs from our (Luton FoE) response to

                                the Bedfordshire Draft Structure Plan, of 1995;

 

NB                          Particular attention should be paid to the graphs of Household Growth and Population, which

make official projections of need look very odd.

 

 

 

                                25.8.97  (update: 28.10.97; 3.11.97; 4.12.97)

                                                                                                                               

 

 

                                Regional Development Agencies: a disaster in the making?

 

                                An assessment by Steve Hawkins. Luton FoE              

 

 

 

1           On 16.8.97 a regional workshop was held at Underwood Street for SE Regional  groups of Friends of the Earth to discuss housing issues and the government's plans to set up Regional Development Agencies (RDA).  An introductory discussion document had been prepared and circulated by Mike Birkin, Local Groups Development Officer SW, in response to the government paper.  Mike's paper had pointed out a number of serious failings in the concept of RDAs as planned (as had CPRE), but had stopped short of wholly rejecting the current plans.  There was therefore some debate as to whether FoE should ask for alterations to the government plans or reject them entirely and begin campaigning against them. 

 

2           I felt strongly that RDAs would be a disaster for FoE and affect most, if not all, of our other campaign areas and was surprised that the full threat did not seem to be appreciated by other members.  I was therefore asked to put some of my thoughts down in a paper for circulation to other delegates at the meeting.

 

3           The original paper seems to have provoked a more general interest than expected, so I now offer it in an updated, and more user-friendly, form for a wider audience.

 

4           There has been more coverage, in the media, of the issues surrounding RDAs since I compiled

             this report, and in considering the many responses to the consultation exercise, Mr Raynsford

             now says:

 

5               "There appears to be a strong view that the RDAs will need to operate within a clear strategic framework, perhaps provided by a strengthened form of regional planning guidance.  There are important accountability issues which we need to consider carefully."   (Speech to Town and Country Planning Summer School, Warwick University, 15.9.97)

 

6           This speech seems to adopt a more cautious tone than that which Mr Raynsford has previously presented, but the fundamental objections I raise remain largely unaddressed, and I hope that they may inspire others to question both the system, and the RDA plans, when the white paper is published.

 

7           Now that Mr Blair has sought to gag MEPs, by enforcing Party loyalty above responsibility to constituents, there are indeed very serious issues of accountability which need to be considered...

 

 

 

 

             Labour's original wider plans for the regions

 

 

8           Labour originally planned to introduce wider accountability to the regions by devolving power from the government to Regional Assemblies/Chambers.  These proposals were set out last year in a document entitled 'A new voice for England's regions', which seems to have passed largely unnoticed by the media.

 

 

9           The proposed assemblies would probably shadow the current Government Office Regions and would have some degree of influence in their running, though no precise details were given.  Initially members of these new assemblies would come from the existing local authorities, but once up and running direct election was proposed.  Referenda would first be held to be sure that the public supported the idea.  Though no mention was made of PR in the consultation document it had a generally positive theme of bringing democracy to bear on a system dominated by government-imposed quangos, such as the Regional Offices and Highways Agency.

 

 

             But is accountability likely?

 

10         Whilst this apparent nod in the direction of accountability seems fine, one should remember that Labour councils are themselves far from democratic:  they put party unity first and their loudest taunts at the Tories are accusations of 'lack of unity', as if reasoned debate was a crime. 

 

11         Luton FoE surveyed and found no local authority Labour candidates would say they would go against the whip on a strong environmental principle.  This is despite the National Code of Local  Government Conduct, by which they are bound, and which says:

 

                         "Whilst you may be strongly influenced by the views of others, and of your party in particular, it is your responsibility alone to decide what view to take on any question which councillors have to decide".

 

12         If their oath doesn't remind them who they represent, and they don't read Planning Guidance notes (PPG), or even their own Development Plan, because they can waive them as mere 'material considerations', how are they to be brought to account, and by whom?

 

 

             LAs have far too much power already -

 

13         Luton's unshakeably unified council already seems to hold too much power over the existing Government Office for the Region.

 

14         We have long fought to get the Government Office Eastern Region (GOER) to get Luton to follow planning guidance and even to honour its own development plan.  We have many times gone the rounds - council - Planning Inspectorate - Ombudsman - Sec of State - GOER - council.  GOER refuses to interfere with the 'democratic process':  and the Sec of State always sends complaints straight to GOER.  Catch 22.

 

15         Only once in 5 years does a sham of accountability occur when, without PR, we get to elect our next dictatorship (let's face it, we probably would with PR too, unless it was accompanied by some other controls on the party system).

 

16         This is the system that is to be given the combined resources of all the funding bodies and development lobbies in an entire Region AND funding from Europe to play with!

 

17         Let’s draw up the list of priorities for them shall we:  Cork to Moscow 'TERN' superhighway; South Coast Superhighway; East Coast Motorway; completion of the London Outer Orbital....It's amazing what you can achieve when everybody pulls together isn't it!  And no more inconvenient Transport Policy Packages (TPP) to negotiate each year...whoopee!

 

18         It is possible that a Nolan Committee (now Sir Patrick Neill cttee) - type body could be set up to oversee accountability, but would he (or we) be able to track all the plans of all the interests involved before it was too late?

 

19         The Ombudsman already handled some 15,525 complaints in 1994 alone, most of which related to planning and housing.  And he can only handle cases of 'maladministration' - which excludes most third party planning injustices.

 

20         Rest assured that, under the present system, important documents would be retained as the confidential property of the businesses in the various development partnerships and would not be available to us through 'right to know'.

 

21         So there are serious doubts as to the potential for accountability, even of elected assemblies as originally planned.  There are further horrors when the derivative plans for RDAs are looked at.  These were originally only to be one function of the Regional Assemblies.  This was bad enough:

 

                         "Successful regions will be those which can provide the infrastructure, investment and human resources to support the development of industrial clusters of small firms";

 

                         "What is needed are powerful, flexible, Regional Development Agencies which are responsible to local business needs".

 

22         And we always thought industry was for the benefit of people: now it seems New Labour thinks the reverse!

 

23         As a final point on the Regional Assembly idea itself we should remember that Labour has a vested interest in diminishing the power of the 'Tory shires'.  Were they seriously proposing 4 elected authorities - Local; County; Regional; and European: or might those troublesome shires prove to be 'unnecessary' and too 'expensive' for a new streamlined system?  A hint is given:

 

                "in general, regions will be expected to have moved to a predominantly unitary system of               local government before they introduce elected regional assemblies". 

 

             This sounds pretty-well equivalent to abolishing the shires, and with them much of the opposition to Labour rule.

 

 

             The document itself is not entirely open...

 

 

24         There is some concealment in the document itself:  RDAs were recommended as a result of an "independent regional policy commission, chaired by Bruce Millan, formerly EU Regional Policy Commissioner".  They neglect to say that Bruce Millan is also former Labour Scottish secretary!

 

25         However, even the 'independent' Mr Millan's "strong Regional Development Agencies" were to be "accountable to the regional chambers" - though undemocratic and unaccountable they themselves might prove to be.

 

26         Now, in Government with a massive majority, Labour, despite these pre-election overtures to accountability, has apparently dropped the Regional Assembly idea altogether but instead is going to set formidably powerful, and privately-led, new development juggernauts in motion at the earliest opportunity.  How many appeals to the High Court for 'review' can the environment movement finance or facilitate in trying to keep them in check?

 

 

            

 

             Some basic parameters that may be misunderstood -

 

 

27         It occurred to me that some of the debate at the meeting was down to different views of the concepts involved in 'development', and that some members may not have read the actual government paper on RDAs.

 

 

             Development: statutory definition of

 

NB   28         There is a general misunderstanding of the importance attached to this word in planning terms.  It must be understood that there is no benign 'World Development Movement type' use of this word in the UK planning system:  Development Plans are LAND USE plans.

 

29         Luton FoE was not even allowed to discuss population at the Beds' Structure Plan examination in public: this was not ruled to be 'a material consideration' for discussion in a land use plan, even though it should obviously be the basis for the whole thing!

 

NB   30         Statutorily,  'Development' means: "engineering, mining or other operations, or the making of any material change in the use of the land".

 

31         This definition must be changed before environment groups should have anything to do with 'Development Agencies', for, whilst it can apply to reuse of existing developed land, it cannot be made exclusively so.  And such exclusivity is required for Sustainability in the overdeveloped UK.

 

32         New-build on greenfield sites must first be tested for real need, and considered a serious matter, to be properly debated at a public inquiry as an 'exception', in a reformed planning system that has a presumption against unsustainable development. 

 

33         Having to develop a greenfield site means a sustainable development plan has failed.

 

 

             Presumption in favour of development

 

34         The present planning system has an overriding principle that development, as above, is good: the "presumption in favour of development".  This concept derives - like the planning system itself - from the real need to make good as quickly as possible, the damage done by the Second World War.  That obvious need is long gone yet this, all consuming, presumption still drives the system.  Environment groups must see an end this wicked presumption before we have anything to do with RDAs.

 

             [ Note:  Since writing this I have been reminded that a new version of PPG1 has ostensibly redirected the presumption - in favour of the development plan...  With the current definition of development and the attitude of government and most local authorities, this makes no difference:  the presumption in favour goes much deeper than any piece of paper can penetrate:  the planning system only exists to facilitate it.  Our planning ministry is also the Ministry for Construction!]

 

35         Regional Planning Guidance for the SE: RPG9 (1994) - much of which reads as a powerful document introducing sustainability principles - planned to redistribute the weight of development in Bedfordshire to the north.  However, the 'presumption in favour' led to Luton exceeding its housing allocation for the whole plan period by some 5000 'dwellings', within the first few years of the structure plan!

 

36         The new dwellings were filled by inmigration; the problems of local homelessness were compounded; social and affordable housing then had to be built on parks and important parts of wildlife corridors.  Luton still has an acute housing problem that can only get worse with this artificially increased population, and it has run out of land.

 

37         RPG9's good intentions were thus squashed, with dev going where the developer wanted instead of where intended.  And all because the council cannot, and will not, just say a firm 'no' to speculative development.  Like most councils, Luton considers an allocation for development in a 'sustainable development plan' to be a command to develop as soon as possible, and actively seeks developers to ensure that this happens!

 

38         The 'presumption in favour' is thus an anachronism that will wreck any gestures to sustainability that are put into the brief of the RDAs.  Such gestures will only be 'material considerations' that any Local Authority can overrule and any developer can successfully challenge.  We should be campaigning strongly to end this preposterous presumption before we should have anything to do with RDAs, or any other groupings of development lobbyists, whilst the current statutory definition of development exists.

 

 

             Economic Growth

 

39         Whilst social spin-offs may occur, as a result of this statutory type of development, these are 'material considerations' only:  the prime function of 'development' is, currently, to promote 'economic growth'.

 

40         'Economic growth' - is a flawed and dangerous concept which FoE is seeking to change, or redefine, through the work of its Sustainable Development Research Unit (SDRU).  RDAs are set to provide a concerted push for economic growth in England's regions by combining the resources of the many business, Local Government, and Quango bodies currently competing for the same pot of money.  This will set the regions off against each other and, no doubt, the richest will have the most success in promoting themselves.

 

 

             'Competition'

 

41         Is seen as essential for economic growth, and thus the proposed regions are being urged to compete: both with each other and with similar regions already set up in Europe.  Hence we read such nonsense as:

 

                "The economy in the South East is already one of the strongest in the UK, but ranks only                16th in the EU" (Evening Argus, Sussex, 5.8.97).

 

             SO WHAT!

 

42         With the current measures of 'growth' on which this 'success' is based, those at the top of the pile are doing the most damage to the world -in terms of consumption of resources and in exacerbating the inequalities that lead to further acceleration of environmental degradation in the '3rd World'.

             GDP could, indeed, be considered an 'inverse sustainability indicator'.

 

43         As RDAs are fundamentally designed to promote this race to be top of the GDP league, they are being set up in direct opposition to a major arm of environmental campaigning.  And they will have a lot more money to spend than environment groups do!

 

44         In the case of the South East, above, what is needed is a transfer of funds and resources from there to less fortunate parts of the UK (and, indeed, to the developing 3rd World)  In fact an 'anti development agency' is needed in the SE to see that funds and development pressure are transferred to the north of the country - which will in turn reduce the demand for housing in the south as the population becomes more evenly distributed.

 

45         Note that, overall, the UK population is set to begin declining from about the turn of the century, so that its redistribution, and a redistribution of resources is all that is required.  We should be planning for reduced population and need now: but, perversely, there is beginning a clamour to increase the birth-rate in order to promote further 'economic growth' and provide an excuse for the developers to go on developing!  ( Higher income taxes or rates in the SE could go a long way to restoring some of the inequalities between the regions, and be used to up the derisory level of British aid to the developing world.)

 

46         Rich nations like the UK should not be competing for 'Eurofunding' in any case.  It is routine in Bedfordshire, for example, to plead for Eurofunding for derelict sites at the same time as opening up ever more new land for industrial development, even though there has been a slow uptake of the land that is already available!  Developers must be made to use the land they have already degraded, not tempted to go elsewhere.

 

 

 

47         Consider this mindboggling gem from the Bedfordshire Structure Plan process:

 

                         Extra land was 'needed' to provide "quality sites to meet the needs of modern industry", yet 300 ha was already committed to industrial development though only 30ha, yes 30, had been taken up in the previous 7 years.  And to this gross excess of new land must be added the derelict land.  At the time, the Luton, Dunstable and Houghton Regis area contained 132ha of 'brownfield' sites - 7% of all such sites in the south of EEngland and, alone, enough to provide for 30 years of the actual demand of the whole county.  Since even this low level of demand is forced by grants and other incentives and inducements, one might conjecture that there was, in real need fulfilment terms, already an infinite supply of industrial land available before the new concessions were mooted.

 

48         Sceptics should need no more proof than the above that the development lobby is already far too powerful and the last thing in the world we need is Mr Millan's "powerful" new RDAs.

 

 

             Beware 'Greenfield site tax'!

 

49         Though a tax on greenfield sites sounds useful, it would not do - any more than the tax on cigarettes stops people from smoking.  It would simply open the way to promotion of more expensive and exclusive developments for the rich, with further 'ghettoisation' for the poor.  The tax would also become another 'planning gain' bribe, with local authorities offering up sites in order to get at the revenue!  The process must be legislated against:  UK will never develop its way out of trouble if it hasn't done so already in the 50 years since the planning system was created.

 

50         The SDRU, New Economics Foundation, and many others, have suggested viable alternatives to the current economic dogma, which could solve our, predominantly social and organisational, problems and get us off the GDP rollercoaster.  RDAs are intended to supercharge the rollercoaster!

 

51         ['full employment' - Labour's rallying call could sensibly be achieved, without development, by splitting the working week into two three day periods, with a common Sunday off.  This could greatly enhance everybody’s quality of life and spread the 'shopping' and 'weekend' traffic throughout the week - increasing the viability of shops - etc.  To those who counter that 3 days is not enough to earn a living, remember that one man's wage used to be sufficient to buy a house: now that partners both have paid employment it takes two wages to buy a house - prices move to reflect the money that is available.]

 

 

             'Need'

 

52         Another word to get everybody talking at crossed purposes, and it rarely fails!  In the original Brundtland definition of sustainability it means what most of us think it means: in 'Planning', business, and 'economics' it means DEMAND (in all but the rarest of cases).  Many a confused and blank look can be conjured in the face of the average planner or developer when one points out that the words mean different things!

 

53         The demands of developers and consumers, nurtured and encouraged by successive governments, and the 'presumption in favour', have long driven and distorted the planning system.

 

54         A case in point is the 4.4 million houses that are 'needed' to cater for 'the rate of new household formation due to the breakup of family units'.  What has actually happened is that at each round of County Structure Planning, developers have demanded, and been granted, higher housing allocations than even the planners intended.  At the last 10 year round of CSPs all the arguments centred around 'relative fertility rates between inmigrant and indigenous population'.  Now that's all forgotten and the excuse is 'household formation'.

 

55         Meanwhile the real population growth and household formation figures continue the same downward trend they have been following for the last 30 years.  The short term fluctuations that the developers make the basis of their 'need' projections do not show up in simple graphs of the concrete figures from the 10 yearly census (in Bedfordshire at least and I expect this is typical).   [See Appendix for extract from Luton FoE SP response showing graphs ]

 

56         With the imperative to develop, there is a rush to build all the housing allocation as soon as possible, coupled with government lobbying for people to become home owners, and to support the precious construction industry.  And lo!  The (short term) household formation graph rises more steeply than predicted!  So next time we'd better build more...etc.

 

57         As the demand is met by inmigration and increased commuting, and the land allocation - in the most popular regions - is quickly used up, developers point to this 'exceptional need' for more housing and demand more land-release ahead of the next plan period.  The Structure Plan is then 'reviewed' and 'altered' long before its ten year period has ended (It can be not long after the thing has even been adopted in fact!.  The last Bed's Plan was 'altered' 3 times!).

 

58         This process leads to some interesting anomalies when it is realised that meeting this demand actually helps to prevent real need being met.  In Luton  (which had already exceeded its estimated environmental capacity at 2001 by some 4278 'dwellings' at the time of last year's Local Plan Inquiry)

             a colossal 13,500 additional 'dwellings' were built between 1981 and 1991.  On census night 1991 4185 vacant properties were found.  Luton had then, and still has, a serious housing need problem.  Needy people do not buy houses.

 

59         The real housing need may be more easily addressed.  A recent Guardian article (Haunted by the Breadline, Malcolm Dean, 1.10.97) referred to targets set by Downing Street's 'Social Exclusion Unit' to deal with, amongst other things, "the 150,000 homeless families".  With empty house numbers typically running at around 5% of national stock - in excess of  800,000 - there would appear to be no need to build any new houses at all!

 

60         Are we really expected to believe that this government intends to build 4.4 million new homes entirely for single people with enough money to buy one on a single wage?  Are they intending to cut the prices in half?  Shouldn't they be trying to discourage this if they have any concept of sustainability and social cohesion?

 

61         For those who contend that the planning system should not get involved in social engineering just look at the 'Planning Commentary' from 'Town and Country Planning' magazine of Summer 1947 (quoted in the Sept 97 issue):

 

                         "There is good reason to think that if a bolder policy of decentralisation were adopted, a substantially larger proportion of people and industry would be willing and would desire to move." 

 

62         Surveys were carried out in Tottenham, Edmonton and West Ham to see if housing applicants would be willing to move to the New Towns (Harlow and Stevenage).  Figures from these surveys:

 

                "answer the most hackneyed arguments of opponents of decentralisation....the opportunity            to take advantage of this existing trend of opinion should not be missed by planners today.             It may never recur."        They certainly didn't miss it!

 

63         So now the true picture begins to emerge:  the planning system has been a massive experiment in social engineering all along.  Since 'the Act' 50 years ago that set it in motion the public have always been the pawns of the development industry.

 

64         Decentralisation was the name of the game and people were coerced into going along with it.  This policy is thus largely responsible for the mess we are now in!  Yet 50 years later we are still being coerced into going along with the decentralisation plans of the construction industry, espoused by its avowed champion - the DoE!

 

65         We are expected to jump to make room for 4.4 million extra houses nobody but the construction industry is calling for, while our elected representatives choose to ignore the near universal clamour from the public for an end to the despoliation of our countryside.  Did somebody say this was a democracy?

 

66         Meeting developer-led, speculative, demand squanders land needed for social housing, and compounds the problem for future generations.  It is, therefore, vital that this practice be stopped.

 

67         Similarly, there is said to be a 'need' for out of town 'science parks' etc. with the excuse that 'quality' developments are 'needed' to attract 'the right kind' of modern industry, and that there just isn't any way these could be fit on a measly few hectares of brownfield land in the grotty towns.

 

68         People flock to superstores.  In developer-speak, and Tony Blair speak :

 

                "We should recognise that certain patterns of behaviour will remain simply because people           want them to remain" (Hansard 4.6.97. 390)

 

             - this proves there is a need for them!

 

69         This kind of demand masquerading as need is one of the most destructive features of our times, yet it is actively encouraged and pursued by our Local Authorities in the name of 'sustainable development'.  And it is about to be boosted deliberately by the setting up of RDAs.

 

 

                                                                  ..............................................................

            

             Sustainability in the Guidance

 

70         Government planning guidance, surprisingly, has much good advice on the need to change from the status quo of demand-led 'development':

 

                         PPG12 6.11 advises us of:  "the pervasive changes in human behaviour that may be needed to limit and adapt to global warming".

 

71         SERPLAN's  'A Fresh Strategy for SE England', consultation document (RPC 3000 June 1996) - though it still put 'Economic Performance' as its number one 'Objective' - contained some promising principles.  Advised by 'a Sustainability Panel' they published a set of 5 sustainability principles:

 

                         "attention to the environment;

 

                          paying as much attention to future effects of actions as to immediate gain;

 

                         consideration of the environmental and other effects of development;

 

                         fairness in the distribution of benefits and costs;

 

                         and that participation rather than exclusion is the touchstone of development decisions about the future".

 

 

72         These 5 good principles were to be given effect through the following mechanisms:

 

                         "DEMAND MANAGEMENT;

 

                         the precautionary principle;

 

                         respect for carrying capacity;

 

                         conservation of natural resources;

 

                         maintenance of diversity;

 

                         attention to quality of life;

 

                         and reducing the 'footprints' of actions."

 

 

73         Needless to say, there is no sign of any of this in the consultation paper on RDAs: quite the opposite.

 

74         Demand management is, obviously, exactly what is needed.  However, in the consultation paper there are 21 clauses of "Role(s) and Functions" for the proposed RDAs.  There is not one mention of demand management.  'Promoting the environment and sustainable development' comes down at 17th.  Top of the list comes "acquisition of land and preparation of sites for development":  not sustainable development.  Most of the list is about financing and attracting 'investment' for this development, and of ensuring that 'the right infrastructure is in place' to attract it.

 

75         When the Government produces a list of priorities like these in spite of documents like Agenda 21 and the SERPLAN briefing, it clearly has no concept of the need for sustainability, and doesn't read or pay attention to its own planning guidance.  It intends to develop us all into further chaos and environmental destruction, under the delusion that it will solve the economic problems which have, in fact, been created by the very drive to 'economic growth' and 'competitiveness' that it is proposing to accelerate. 

 

             Sustainability is about slowing down: not speeding up!

 

                                                               ........................................................

 

 

 

             'Investment'

 

76         Another weasely word that has changed out of all recognition. It used to have the sense of 'giving', or 'clothing':  now it means 'setting up to exploit until a better deal is offered elsewhere - then getting out fast and leaving someone else to pick up the pieces'.  There must be a return to the old type of investment - necessary and freely given - otherwise it is short term gain which secures long term loss.

 

77         But, nowadays, even this exorbitant deal isn't enough.  They are to have their cake and eat it too!  The second of the proposed RDA's  'Perverse Agenda 21' considers:

 

                "the financing of third parties, through grant, loan, guarantee or other means, to carry out            land acquisition, assembly and site development; and the recouping of their investment;". 

 

             Are the developers expected to actually do anything themselves?

 

78         If all these mollycoddling bribes are required to force a development through, there clearly isn't any need or demand for it.  And it obviously isn't competitive or viable.

 

79         If the government has money and resources to throw away like this, it should channel them directly to the unemployed (saving a fortune in the process) by introducing a social wage, on which they could build their own flexible career without fear of destitution or persecution by the DSS whenever a modern, short term, job comes to an end.

 

 

             'Regeneration'

 

80         A term stolen from the sustainability stable, which now is simply another word for 'development' - as above.

 

81         In the purest sense regeneration would mean:

 

                the gradual evolution of the existing developed sites to meet the changing needs of society             through time. 

 

             This is the true nub of sustainable development.  Too bad the term has been tainted by association with the old 'development' junkies and now needs replacing.

 

 

                                                                   .....................................................

 

             The Real Need:  'Renewal Agencies'

 

 

82         CPRE hit on a better term in their own briefing on RDAs:  Renewal.  Perhaps we should write our own specifications for 'Renewal Agencies', and the environment which will enable them to succeed, and champion them?

 

83         Prerequisites for a Renewal Agency, which must be in place before any RDA-like bodies are set up (no doubt you can add some of your own ideas) would be:

 

             a)                An urgent Nolan (Neill) Committee investigation into the relationship between the               Department of the Environment and the construction industry, and the introduction of strong       instruments to remove the heavy influence of that industry from important decisions affecting                the environment.  The DoE cannot serve two masters and be both poacher and gamekeeper of    our environment.

 

             b)                Replace the absurd doctrine of  'free trade' with one of sustainable trade.  Wrest control of                the economy back from currency speculators, transnational corporations and the unelected            World Trade Organisation, and restore the bargaining power of governments given by       sensible use of  import controls, duties, and taxes;

 

             c)                Fully accountable Regional Assemblies elected by a fair system of  PR;

 

             d)                A ban on the antidemocratic practice of 'whipping' in local government (and preferably in                 national government as well);  [ - Mr Blair's latest imposition of a gagging Code on our     MEPs, for Party benefit, indicates that we are actually to get even less accountability than we           have at present, and that his version of  'PR' could give the traditional parties even more of a    stranglehold on 'democracy' than they have at the moment! - ]

 

             e)                Replacement of  'Development Plans' with 'Sustainability Plans';

 

             f) Planning Inspectors and Examination in Public Panel members to be properly trained and    briefed to be expert arbiters of sustainability: not facilitators of development;

 

             g)                A statutory duty on Local Authorities to honour their Local Sustainability Plan on behalf of              the public who have paid a huge amount of money for it  (NB this does not imply support for             the current 'Unsustainability Plans' with their ridiculous housing allocations!);

 

                [Mr Raynsford has already indicated that he is not in  favour of this - DoE News Release 213             1.6.97]

 

             h)                An end to the presumption in favour of development;

 

             i) An end to the process of projecting demand and proclaiming it as need;

 

             j) A removal of the word 'development' from the planning literature except under the special heading of 'Built Development';

 

             k)                A redefinition of the statutory purpose of Plans - to facilitate renewal and evolution            rather than 'economic growth' and competition;

 

             l) A full set of guiding sustainability indicators to replace the destructive and divisive notion of           GDP;

 

             [ There is some evidence that the government is considering a move in this direction:  DETR press release 18.9.97, -  Mr Meacher announced that a small number of 'high profile sustainable development indicators are to be developed which could be reported on the evening news'... But:  - "as are the key economic indicators".  As things stand, the two are mutually exclusive: the one based on restraint, the other on excess.  GDP has to go:  it was never meant to be used as a measure of 'success'.]

 

             m)               An automatic right of third parties to appeal against planning decisions - this is essential before any claim of democratic accountability can be believed.  Any departure from an                 agreed Plan must be given the same public scrutiny at inquiry as was given to the               original plan;

 

NB       n)                Currently a LA is the only arbiter of what constitutes a 'departure', and the first the public knows about it is when buildings start appearing in parks that they thought were protected.             There is nobody for the public to appeal to, at present, when this happens (and it happens in   Luton);

 

             o)                Consequently - an independent adjudicator system to be set up, with state finance, to          whom third parties could freely appeal within a 21 day 'cooling off' period after a LA       publishes its intention to pass a development application.  The adjudicator would weed out       spurious objections, and have the power to require public inquiries and conduct investigations into malpractice by the LA or developer;

 

             p)                Legal aid to be available for third parties, or a state financed service to help them in the    defence of sustainability principles;

 

                         [ It looks as though the movement is in the wrong direction on this one too, with the government announcing massive cuts in the Legal Aid budget - 4.10.97]

 

             q)                A presumption against built development on new land, and a requirement for proof of       need for built development on existing developed or brownfield sites.

 

                (This does not mean no development on new land, the presumption simply ensures that       such an application will be open to proper public scrutiny as a departure from the agreed                 Sustainability Plan);

 

             NB              (It is important to realise that a brownfield site is a valuable resource for sustainable      development.  Squandering these to speculative development, in a misguided drive to         'regenerate' them, means that unforeseen future need has to be met on greenfield sites)

 

             r) Currently, an allocation of greenfield sites is  'safeguarded' - as  'white land' - to be used

             NB              in times of unforeseen need.  Another good idea which has become abused - it is now          simply seen as land that will be developed next time around the plan process merry--go--            round.

 

                Brownfield land must be cleaned up under the polluter-pay principle and then      safeguarded in the original sense;

 

             s)                Planners to be removed from the business of built development promotion, and to be          independent, impartial, and independently financed.  They should be local guardians and       promoters of sustainability and their performance should in no way be judged by the income             the LA receives from processing planning applications;

 

             t) Planners should be guided by the overriding principles of demand management and           precaution;

 

             u)                Full statutory protection to all SSSIs and species and habitats currently protected (sic) under            the Wildlife and Countryside Act - at the moment, you or I commit a criminal offence if we so much as take pollen from a Red Data Book plant, but a LA can simply waive them aside                 as mere 'material considerations', subordinate to economic growth;

 

             v)                Similarly - full statutory protection, and a duty of care for, important archaeological              features and listed buildings;

 

             w)               A comprehensive and enforceable Freedom of Information Act;

 

             x)                Renewal Agencies should be financed by the state, from general taxation;

 

 

84                     [The government plan is for the proposed RDAs to be private -sector led, and they will have no additional government finance.

 

85                     Alarmingly, the government has also appointed a minister to pursue the Private Finance Initiative.  It is inevitable that this will lead to many more examples like the Birmingham North Relief Road (sic), where the £30 million spent privately in preparation was influential in the government's decision to go ahead with the road, even though they had previously opposed it and completion would mean spending ten times that amount.  The fear of having to pay compensation to developers, when plans prove unsustainable after private money has been spent, will prevent the Secretary of State acting properly in the interests of the environment.

 

86                     Remember: even ordinary development agencies have brought us horrors like the Cardiff Bay Barrage - again opposed by Labour when in opposition: but passed when in power.]

 

 

 

y)                Not a greenfield tax: but a wider 'Chaos Tax'

 

 

87         This could form a possible replacement for the rates and would be based on the amount of unnecessary travel created by any development - with a surprising number of positive knock-on effects.  There would be a basic car park tax, and a multiplier - the 'Chaos Factor'- for both existing and new developments.  These would both encourage new development in the sites where it is most sustainable - central locations with good public transport and local user populations - and encourage existing employers to make better use of their land than wasteful parking space.

 

88            (Luton's Vauxhall factory, for example, seems to be greatly made up of single-layer, ground-level car parks, but they have recently demanded, and been granted, permission to create another large car storage facility at a Green Belt site that has no possibility of rail access and will require replacement of an ancient winding country lane, on a prominent scarp, with a heavy duty road to take many vehicle trailer loads of cars per day.  Yet a railway runs right through the existing Vauxhall site and there is scope to open another!)

 

89         A swingeing car park tax should be imposed to make this absurd and destructive practice uneconomical.  The tax would be set so as to make out of town superstore shopping uneconomical and favour town centre shopping, around good public transport nodes, and neighbourhood shops within walking distance.  Similarly the tax would make other large out of town development uneconomical and would focus development back to the brownfield sites in towns where it is needed.

 

90         The 'Chaos Factor' :

 

             Would be a multiplier on the basic tax, based on the chaos imposed by travel-to-work practice.  It would be derived from the total length of journeys made by employees travelling to and from the work location each day.  The more employees and the further each has to travel, the greater the tax that would be paid.  Employers and potential employers - and hence developers - would then have to carefully judge their location so as to make best use of the indigenous population.  It would encourage them to seek out areas of high unemployment and - with the car park tax - places where there were good public transport possibilities.  These would invariably be the very regional black spots and 'town centre' sites that are the target of the various national and European regeneration funds.

 

91         The current practice of choosing a 'prestigious' greenfield site wherever the latest architects pipe dream can be fit and then expecting employees to find their own way there by car must be stopped: these taxes would be a powerful tool to encourage the change.  Already some of the prerequisites are in place: with firms such as Vauxhall,  Three Valleys Water, and BAA amongst those that are already beginning to analyse their employees travel to work patterns and look for improvements.

 

92         The Chaos Factor would have the form of:

 

                Total Employee Miles From Work

                            Total Employees,

 

             so that the bigger the ratio, the greater the chaos caused, the more the tax.  The exact journey mileage of each employee would not be needed.  Modern mapping programmes should be able to simply calculate the radial distance of each employee's home from its map reference or postcode; sum the total of radial distances of all employees (perhaps even of suppliers, to encourage local sourcing of materials and components), and divide it by the total workforce, to derive the factor for each company/location.  Both prospective employers and planners would find this technique useful in determining the degree of sustainability of their local economy:  it could be one of the new 'sustainability indicators'.

 

92a       Employers who managed to achieve high levels of non-car use would be eligible for rebates, but it must be remembered that all motorised journeys would best be reduced, so any such rebates should be weighted in favour of walking and cycling.

 

93         With the disincentive to long distance car commuting that would come with the imposition of this tax, the viability, and hence, attractiveness, of typical new greenfield housing development in the south would be reduced, and thus pressure decline.  Conversely the attractiveness of neglected northern towns with high unemployment would be increased, helping to reverse the trends in population and employment movement of the last fifty years.

 

94         When one looks at it there are innumerable positive spin offs from such a tax system, it could go a long way to correcting the social inequalities and planning and environmental nightmares that have resulted from allowing the car to dictate the pattern of development, not just in the UK but in all the developed world.

 

95         And, very usefully, this tax gets away from accusations of persecution of the motorist, by shifting the charges to the real villains:  those who by their actions make us use our cars.

 

 

 

             The Prospects?

 

 

96         So that's something of what the problems may be, and of what we actually need.  What are the signs that we might be lucky?  NOT GOOD.

 

97         Michael Meacher, Costing the Earth, Radio 4, 22.4.97:

 

                         "let me make it absolutely clear that the Labour Party will retain the veto over planning, water resources, energy, and green taxation"

 

                         ie. they are prepared to refuse to apply European legislation which they consider to be an unnecessary restriction on business freedom and economic growth.

 

98         In that same programme, Meacher again:

 

                         "we saw only last weekend that a bypass in Southern Ireland is going to damage a primary nature reserve.  That's precisely the kind of thing which we believe should not be allowed to happen and that the single market extension should not be allowed to force down environmental standards"

 

             Mr Meacher has since passed both Cardiff Bay Barrage and Birmingham North Relief Rd.

 

99         Prime Minister Blair has, in Prime Ministers Question Time, defended out of town shopping, saying that it accorded with what people wanted to do (Hansard as above).

 

             David Sainsbury, one of New Labour's prestigious backers, must have been pleased to hear this!

 

100       Mr Blair, himself, has reportedly been enjoying the holiday air at the Tuscan castle of, Treasury Paymaster General, Geoffrey Robinson - owner of 'The New Statesman'.   Mr Robinson has been given special responsibility to push the PFI.  He told 'Planning' magazine (9.5.97):

 

                "the PFI would allow schemes to go ahead when otherwise there would have been delay."

 

              Mr Robinson is a former chief executive of Jaguar.

 

101       In the same issue of 'Planning', Richard Caborn - Minister for regional affairs, regeneration and planning, is described as:

 

                "proposing the setting up of nine regional development agencies to give the same back-up             to the English regions as that enjoyed at present by the Welsh and Scottish corporations."

 

             More Cardiff Bay Barrages on the way then...

 

102       Whilst in opposition Labour produced a 'ten point plan' to end the destructive practice of open cast mining  ('Open Cast: Too High a Price?' 1992).  In its latest consultation on the practice the government has now dropped the presumption against open cast.  It has also refused to help the flagging RJB Mining - the main operator still using the, less damaging but more expensive, deep-mined coal process.

 

103       And, as if this wasn't bad enough, Welsh Secretary Ron Davies has now announced (15 Oct. Western Mail) the appointment of Bryan Riddleston to the council of The Countryside Council for Wales.  Mr Riddleston's first council meeting, will consider the denotification of what was a Site of Special Scientific Interest, in what is now the Selar open cast site operated by Celtic Energy.

 

              Mr Riddleston helped to create, and was executive director of... Celtic Energy!

104       This government seems to make a point of thus putting people with a history of anti-environmental activity in powerful positions where they will be able to do even more damage - 

 

105       Mr Blair has appointed Lord Simon, ex chairman of BP as 'Minister for Competitiveness in Europe', and a lot of flap about share ownership has provided a smoke-screen for the real issue.  BP is a major member of the 'European Roundtable of Industrialists', a powerful lobby of Trans-National Corporations whose principle goal is the removal of all barriers to free trade.  They successfully argued for the Channel Tunnel and Trans-European Networks (TERNs) (Colin Hines.'Might of the Round Table'. Guardian 20.8.97).  Lord Simon will now be lobbying the EU 'Committee of the Regions' to provide the Eurofunding for the pet projects of our own fledgling RDAs...  (and we'll be paying him!)

 

106       From the same article:  "the ERT's greatest and most environmentally threatening 'success' is getting governments - like New Labour - and the EU in general to institutionalise international competition as the primary objective of most policies".

 

107       The ERT was instrumental in a watering-down of the environmental provisions of the new version of the Maastrict treaty in the interests of free trade.  The result: "qualified majority voting would not be extended to environmental taxation, which means that the treaty will continue to allow such efforts to be vetoed by a single country" (ibid).  Which sheds light on Mr Meacher's statement above...

 

108       We are expected to believe that Lord Simon is not biased in any way!

 

109       'Nuclear Jack' Cunningham - ex consultant for Albright and Wilson and Hays Chemical  - Minister for Agriculture.  No conflict of interests there for sure!  Mr Cunningham has wasted no time in declaring organophosphate sheep-dips safe to use - he is an expert on them.

 

110       Interviewed on Radio 4's 'Food Programme' (19.5.97)  Mr Cunningham was asked what he thought about previous ministers who went straight from senior government positions to similar positions in the same industry.  He said:

 

                         "I think it's not only regrettable, but positively dangerous that that kind of process went on.  It will not happen under this administration."

 

111       However, Mr Cunningham sees nothing wrong with exactly  'that kind of process'  when it operates in the other direction!  Asked what he thought of FoE's opposition to his move to MAFF from the chemicals industry he said:

 

                         "I think it is curious.  I mean I thought it was rather a cheap shot frankly - petty - but I think it's curious that I'm a scientist [sic], that knowortsledge and expertise in an area disqualifies one from holding a job.  I thought knowledge was important in government.  Presumably so far as FoE are concerned, ignorance is bliss."

 

             ...and ambivalence is politics!

 

112       Graham Stringer - ex Chief Executive of Manchester Airport, and bane of extension protesters?  Now Labour MP for Blakely and sitting on the important Commons Transport Committee!

 

113       And then there's Nick Raynsford, Junior Minister to Richard Caborn.  We appear to have a serious problem in Mr Raynsford. He keeps coming out with very worrying statements:

 

114       Now given the disturbing epithet of  'Construction Minister' Mr Raynsford spoke of :

 

                "the increase in housing provision which is 'necessary' to meet the need for homes and to               avoid the problems of homelessness"  (Costing the Earth 6.8.97).

 

              As we have seen above, this is almost painfully naive.  And there's more...

 

115       Interviewed in 'Planning' (27 March 97) he caps the above by saying:

 

                "Alan Holmans, the former economic advisor to the DoE, has produced evidence that       household formation is not influenced by the availability of housing."  (!)

 

116       So why is he, and the rest of the development lobby, trying to con us that the 'new trend in household formation' is precisely the reason why we have to build 4.4 million new homes?!

 

117       Raynsford says he "will relax planning in villages to allow limited amounts of social housing".  He says:  "we need to make an exception to normal planning" to allow for this.  He doesn't seem to know that normal planning already allows for such exceptions, and this is why the government has previously asked for the word  'normally'  to be removed from Plans as unnecessary!  Any relaxation can only be for the worse, and deprive the public of the right to respond to such proposals, as exceptions, in the normal way.

 

118       In 'Housing - Labour's view' (Urban Focus. Winter 977).  Raynsford prepares to release greenfield sites in the south:

 

                         "Unfortunately the concentration of 'demand' is in the south, south-east, and south-west where there are not sufficient brownfield sites to meet the 'need'".  (!!!)  (A dictionary might help him!)

 

119       When these statements are taken together, it becomes apparent that Mr Raynsford is planning to weaken an already painfully weak (with respect to environmental protection) planning system, in preparation for a continuation of the 'rob Peter to pay Paul' method of social housing provision.

 

120       Irreplaceable open space, wildlife amenity and countryside will be needlessly sacrificed to the demands of speculative development on the (Section 106) condition that a small portion of it will be used for social housing.  'Planning gain', the demon of legalised bribery, is about to be unleashed with a new set of teeth.  Just sit back and watch those fields disappear!

 

121       Mr Raynsford obviously pays little heed to SERPLAN's sustainable development strategy, and does not believe in demand management.

 

122       In a press release (DoE 213 11 June 97) amusingly titled: 'Raynsford Backs People's Right To Be Heard', we find a statement on household projections:

 

                          "With regard to the household projections themselves, I understand that most responses to the [Green] Paper have not really taken issue with the projections methodology.....It follows from this that we see no case, as has been suggested by some authorities in the South-East, for revising downwards the housing allocation figures already in existing Regional Planning Guidance"

 

123       So it's business-as-usual, as far as housing is concerned: but coupled with a new strategic weakening of the planning guidance to make our lives that much more difficult.

 

124       And Mr Raynsford does not just have strong views on housing provision.  In the same press release he shoots down our prerequisite for accountability. Mr Raynsford had:

 

                         'decided not to take forward the proposal that the recommendations in the report on the public local inquiry into a plan should be made binding on the local authority.'

 

125       Thus Mr Raynsford backs our right to be heard yet also backs the council's right to ignore the findings of the public inquiries at which we speak!

 

 

126       And, if one needs any further convincing of the disasters in store for us under Mr Raynsford, the press release goes on:

 

                         "Mr Raynsford made clear that in addition to the existing initiatives to speed up the development plans and appeals procedures, the government was looking at ways to simplify and speed up the planning process for major infrastructure projects of national importance such as major road, rail links, new or extended airports, reservoirs and large waste incinerators." (!!!)

 

             Need I say more?   This government firmly believes that massive opposition to a project is a sign that it needs to be rushed through rather than seriously reconsidered.  Thousands of people objecting to a development plan is taken as a fault of the consultation process rather than a sign that the plan is ill conceived and unpopular!

 

127       As Construction Minister, Mr Raynsford will presumably head The Construction Directorate.  As pointed out by George Monbiot in 'The Land is Ours' newsletter no 8, this, little  heard of, government agency is the only one :

 

                "dedicated to promoting the interests of a single industry.  Senior figures from the             construction industry are seconded into it, and swing enormous influence within the         department." 

 

             As Monbiot says: "Countryside?  What countryside?"

 

128       [ Mr Monbiot has since reminded me of another article in which he pointed out that the DoE's annual report states that it: 

 

                         "aims to help all sectors of the UK construction industry...succeed in their domestic, European and international markets.  It is the advocate within Government and the European Union for these industries. ...It also acts as the focal point within Government for the property industry". 

 

                         At this rate the DoE might aptly be called the 'Countricide Department'! ]

 

129       Mr Raynsford is, of course, entirely unbiased.

 

 

 

             And lastly, a mention of some other interesting players in this destruction derby:

 

 

130       Tim Cordy - was director of the Town and Country Planning Association when he came up with this gem:

                          "There is no way a tax on greenfield sites will persuade builders to build on brownfield sites.  There is a 200-year tradition in this country that to get on is to get out".  The TCPA "counts many large building companies among its members, and offers the opportunity to influence...important planning and environmental policies" through "excellent contacts with senior politicians".  (Simon Jones 'Blighting of Blighty'. Guardian 28.5.97)

 

131       Interestingly, the Guardian later reported (30.7.97) that Mr Cordy has indeed been given the opportunity to 'get on and get out'.  It was reported that he has been:  "forced to resign amid talk of vote-rigging."

 

132       And there's Paul Dimoldenberg, lobbyist with Good Relations, part of Sir Tim Bell's - Lowe Bell.  'Luton Bedfordshire on Sunday' informs us (2.2.97):

 

                          "Lowe Bell/Good Relations was paid £60,000 to fight for a road programme for North Bedfordshire, in particular an A1/M1 link.  The cost was to have been shared between the borough, the county and the Bedfordshire Business Forum.  In the event the borough paid half the cost.";

 

                         "Charles Rose, chairman of the Chamber of Trade, said: 'They did a lot of work and, as a result, we got the southern bypass.";

 

                         "Dimoldenberg said:  'We didn't get the A1-M1 link, but we did get the southern bypass during a period of government cutbacks.".

 

133      Paul Dimoldenberg was formerly Labour leader on Westminster Council and was Labour candidate for South Bedfordshire in 1987.

 

 

                                                                      .................................................                        

 

 

 

134       So, not exactly in a nutshell, but I hope that sets the scene for RDAs, and introduces some of the more visible players.  There are countless many more, and they are all champing at the bit ready for the 'off!'.  Can we do anything to hold them back?  Can anybody?

 

 

 

 

 

 

             Summing up...

 

135       Without third party rights of appeal, and the ability to freely challenge an authority over 'rationality', 'consistency' (PPG1), compliance with planning guidance or adherence to the 'Local Plan', the whole planning system is a colossal sham which operates primarily to provide jobs for planners and lawyers, and fodder for speculative developers and international manipulators.

 

136       The last thing the environment needs is a new-power- charged, government-sanctioned-but-private-sector-led, development juggernaut rampaging through what is left of our countryside!

 

 

 

 

 

                                                                                       R.D.A

 

                                                      RAPID  DESTRUCTION  ASSURED

 

 

 

 

 

 

                                                       Appendix. Extract from:

 

 

 

 

                                BEDFORDSHIRE  COUNTY  STRUCTURE  PLAN

 

                                        DEPOSIT  DRAFT MARCH 1995

 

 

 

 

                                       LUTON  FRIENDS  OF THE  EARTH  RESPONSE

 

 

 

 

 

 

                                      (originally)

                                      Comprising: 

 

                                      67 Printed pages.

                                      3   Figures - pages 4a, 4b, 4c.

                                      7   Photocopied references - pages 68-74.

 

 

 

Note:  December 1997

 

                There follows an edited version of our original ‘proof of evidence’ presented to the Bedfordshire Structure Plan Examination in Public.  I have primarily included it to show how the properly redrawn graphs belie the 'need' for new development land, either for housing or employment:  this 'need' is entirely developer demand and planner/establishment adherence to a doctrine of  'develop come what may'.

 

I have retained some of the structure of the proof in the event that it might be of use to those preparing such statements of their own.  However,  it will be obvious to those reading the quotes from the various instances of good planning guidance and comparing these statements with their own knowledge of planning decisions in the real world, that they are not worth the slightest fraction of the cost of the paper they are printed on!  Whilst I would urge that readers, nevertheless, do put in an appearance and make their considered protest at EIPs and Public Inquiries, I most strongly urge that they put their maximum effort into campaigning for the urgent reform of the system itself along the lines I have suggested in the body of the main RDA report.

 

 

Steve Hawkins   7 December  1997

 

 

                Bedfordshire County Structure Plan. (Deposit Draft).  March 1995

 

                                                Friends of the Earth - Luton - response.

 

 

 

Policy 1:   SUSTAINABLE DEVELOPMENT

 

This policy should not suggest that sustainable development means 'sustained' development in the current manner. Too much uncontrolled development has been permitted. The first priority in considering any development should be the POPULATION'S NEED for it, not the 'need' of the developer. 'Development' should be redefined from the often assumed meaning of  'expansion and growth' to 'evolution and change which is beneficial to all'.  This sentiment is not represented in Policy 1, and must appear.

 

     [A cassette recording of a BBC Radio 4 'Analysis' programme (26.3.95) outlining some of the modern thinking on growth, the new economics and sustainability was enclosed with this account.]

 

We see every reason to ask for a clear statement that this authority is really taking the bull by the horns over sustainability and the question of need, and therefore that the list of clauses begin with the Brundtland statement, and its complementary statement from IUCN, UNEP and WWF.  Thus:

 

"sustainable development in Bedfordshire means:

 

i)   'development that meets the needs of the present without compromising the ability of future generations to meet their own needs; improving the quality of life while living within the carrying capacity of supporting ecosystems.' 

 

This opening sets a much more timely and appropriate theme for a policy headed  'SUSTAINABLE DEVELOPMENT'.

 

 

[Note:  Statutory definition of development.

 

It is unfortunate that the statutory definition of development (mentioned in Draft PPG2 3.10) has the theme of:

 

                "engineering , mining or other operations, or the making of any material change in the use of the land".

 

This emphasis on inherently unsustainable consumption of land is a fundamental flaw in the planning system and the result is that in planning terms sustaining development is in fact unsustainable in the 'Brundtland' sense!  There is therefore an urgent need to change this definition to one based on evolution rather than 'growth', or to remove the term from local plans altogether except under the special and separate heading of 'Built Development'.]

 

 

 Remaining clauses should be renumbered and we suggest some alterations:

 

 i)  We appreciate the aim of this statement but as it stands it could lead to increased pressure to develop on parks and amenity spaces within towns, and to the loss of garden space etcetera.  Talk of ‘maximising development potential’ is for speculators, and suggests exploitation of resources rather than their conservation and sensible use to fulfil genuine need.  The consultation draft policy which related development potential to opportunities to use public transport and reduce distances travelled, reducing energy consumption (important: add 'and minimising pollution') could be defined as a sustainable policy.  The altered policy (i) while concise, is not so clear:

we suggest instead:

 

                ‘Necessary development should be directed to existing centres'

 

 vii)         The term 'infrastructure' should be preceded by 'environmentally supportable'.

 

viii)         Add:  'with particular regard to the encouragement of small businesses'.

 

 

Add new clause:

 

 xii)          'The authority will seek to retain and extend local services including retail, health, leisure,   education and social facilities to ensure that they are within reasonable walking distance (800 metres) of all residential areas.’

 

 

 

 

 

Policy 2  DEVELOPMENT STRATEGY

 

 

I)  After 'sites of nature conservation value' add:

 

                'natural beauty and amenity,'.

 

 This is because PPG 12 5.4 and the 1990 Act specifically require:

 

                "the conservation of the natural beauty and amenity of the land"

 

We are also concerned that as Luton has less than half the urban greenspace recommended by the National Playing Fields Association what remains needs strong protection.

 

 

POPULATION:  the need for control.

 

The acceptance of population growth announced by clause ii) is not what is required for sustainability. The national population is not growing very rapidly, yet the imbalance of job opportunity and local population densities (often in part generated by developer-led planning) is getting steadily worse.  Despite high acreages of new housebuilding in Luton, with corresponding increase in population, we are still the number one unemployment blackspot and have numbers of homeless people begging in the streets.

 

Our town is largely a dormitory for commuters who could not afford to live anywhere more pleasant.  No doubt Luton could 'accommodate' a substantial increase in population as could Bedfordshire as a whole: but at what cost to the environment and amenity of those already resident, especially in high unemployment areas where new residents would have to commute elsewhere to work?  These sentiments are expressed in your context statements in para 1.4 page 15; and you also recognise that growth does not nowadays go with job creation in 1.24-1.26 page 4.  Knowing these facts,  passively deciding to accommodate population  growth as suggested is not a very proactive stance to take for the 21st century.

 

 

 

Misleading Population and Household Graphs

 

 

We notice that the block 'graphs' on page 6 depicting population and household growth for the county from Office of Population and Census Statistics show a declining trend and have redrawn them so that this can be more easily appreciated (see Figs 1-3).  The trend of urbanisation, intriguingly shows a similar downward path.  The trend seems to bear out what is described in SERPLAN, and is for imminent negative growth in population closely followed by decline in household formation. The implication is that the tide is beginning to turn towards sustainability.  Unfortunately, by planning for a sudden reversal of these 30 year trends, this Structure Plan, if accepted will, actually be very likely to precipitate further inmigration and commuting, with further competition for vanishing local jobs as well! This puts development firmly back on the path to eventual environmental catastrophe.  There is clear evidence that a carefully constructed plan can take Bedfordshire well down the road to a sustainable 21st century. This will not happen while the tail is allowed to wag the dog. Population must be carefully steered to sustainable (which sensibly does mean much lower) levels.

 

The trend of population growth depicted in your Figs 1&2 seems to be understood (if not actually capitalized upon) in regional planning guidance:

 

                RPG9 3.9 states that "the workforce is not expected to grow significantly" over the plan period.

 

Since it is the workforce that also produces the new native population we can therefore assume that indigenous population growth for the region as a whole will also be insignificant.

 

                RPG9 5.4: "overall there has been a small net outflow (of population) to other regions from           the South East in recent years.  This is expected to continue as policies designed to   regenerate the cities and provide employment in the Midlands and the North tend to reduce    migration from those areas to the South East and people continue to move out of the Region          to retire, or in response to economic opportunities in areas adjoining."

 

Planning for the 21st century should therefore concentrate on restoring the balance of population and its needs within the Region while allowing for net outmigration and minimal growth from within.

 

 

The authority should also pursue a social policy for reducing the local birth rate to globally sustainable levels as it has a duty to consider the environment "in the widest sense".  Can this be a stated policy of a structure plan?  It should be one:

 

                PPG 12 5.51  suggests  that authorities may have "wider social considerations in mind in               taking a view about how they hope to see the social pattern of their communities develop"...                 so long as these "social considerations are relevant to land-use policies."

 

Population  distribution and the potential for its redistribution to lessen problems of environmental, amenity, and infrastructural overload can and should, therefore, be tackled through planning.

 

 

The current weak and unsustainable sentiments of this clause should therefore be replaced with a strong statement reflecting the urgent need for pervasive changes referred to in PPG12 6.11.  We suggest:

 

                'to minimise  population growth in the county with a target of achieving environmentally    sustainable levels by 2011.'

 

INSERT PAGE OF BLOCK GRAPHS FROM COUNTY STRUCTURE PLAN HERE

INSERT FIG 1 REDRAWN POPULATION GRAPHS HERE

INSERT FIG 2 REDRAWN HOUSEHOLD FORMATION GRAPHS HERE

INSERT FIG 3 REDRAWN URBANISATION GRAPHS HERE

This can be done by:

 

      *       putting an end to speculative housebuilding and large scale employment developments that             attract commuters and encourage inward migration;

 

      *       minimising housebuilding in areas of high unemployment and ensuring that such house-                                   building that does occur is for local need only, to discourage commuters from moving into                             places where housing is cheap because of a depressed local economy;

 

      *       ensuring that new businesses are directed to those areas of high unemployment and that they                          are of a scale and type that can use indigenous population rather than commuters;

 

      *       buying up unused and negative equity private housing stock for use as affordable council                                accommodation.  Numbers of people are unable to move because of the depressed housing                              market.  Councils could introduce mobility by breaking 'chains' in this manner;

 

      *       by ensuring that the local workforce is adequately trained to take up employment or to pursue                          jobs by migration to other Regions where financial assistance is being provided for                                  revitalisation ( since many of our towns are becoming degraded and unpleasant through                                    pollution, it should not be difficult to help those who can do so, to move elsewhere );

 

      *       instead of going begging to Europe for 'redevelopment' grants that we know are unlikely to                               result in significant new job formation (page 4 para 1.24), the county should be campaigning                         for changes in social policy that will lead to a better sharing of the national workload, and a                         removal of the stigma from 'unemployment'.  For instance, the week could be split into two                 three-day working parts.  This would double the number of jobs and free people to engage in                            social and economic activity for four days instead of two.  Thus boosting the local economy,                                 and reducing stress in both the underworked and the overworked.  Similarly a 'social wage'                        would free the unemployed from the impossible requirement of being 'actively seeking work'                       among a dwindling number of employers who are themselves striving to be 'efficient' by                                     laying off staff!  With the support of a social wage the workforce will be able to continuously                         retrain and reskill to take on the short term jobs that are likely to be the norm in future, or to                           start up the small businesses that are desirable for local sustainability.  The unemployed are a                        wasted resource that can be effectively brought back into use to make life better for everyone.                          Only our dinosaur 'economic' system prevents it!

 

      *       by  pursuing a vigorous birth control strategy through education and social policy:

 

‘Western' excesses mean that each new birth here puts many more times the load on the world's resources than is created by a birth in an 'undeveloped' nation.  Our current population is very unlikely to prove to be a sustainable one and we must therefore set an example to the developing world and adjust it accordingly.

 

Imaginative use of the authority's planning, social, and administrative powers must act together to reduce the burden of the Bedfordshire population both on local and world resources.  This is the attitude that  must spread  rapidly to all the world's decision makers if there is to be an inhabitable Earth for mankind in the year 2111.

 

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Development Strategy ctd.

 

 iii)  Replace with:

 

                'to direct necessary development to existing urban areas.  Only when the problems of inner                city dereliction have been addressed will development be considered elsewhere.'

 

In a survey of E.C companies ('Integrated Planning and the Grants of Permits in the E.C.'  HMSO 1994) it was found that:

 

                "although planning systems were a consideration for two thirds of them in their choice of               location, these were generally not a determining factor.  Of greater significance were              proximity to markets, the availability of favourable infrastructure, and high quality land."       (quoted from planning Monthly Bulletin Feb 94)

 

Thus developers must be directed to where they are needed: they will not go there while 'high quality land' is made available to them elsewhere.

 

Opening up new development zones in 'strategic corridors' or anywhere else will seriously compromise the chances of achieving the regeneration of existing sites which is a key principle of sustainable development and is demanded by planning guidance. Ready availability of land depresses its price.  No one will pay to redevelop an old site while a cheaper greenfield site exists!  Missions to the EEC for regeneration funding are a complete waste of time and public money while release of greenfield sites is permitted.

 

PPG 12 5.20:

 

                "redundant, derelict or underused sites represent an important resource; the plan            should ensure that such sites can be used in preference to greenfield sites wherever      possible."

 

5.21 of  this PPG states:

 

                “should have particular regard to the conservation of finite or non-renewable resources                such as land and energy"

 

 

REMEMBER 7% OF ALL THE DERELICT LAND IN SOUTH EAST ENGLAND IS IN LUTON DUNSTABLE AND HOUGHTON REGIS. 132 HECTARE!  THIS WILL NOT GET DEVELOPED WHILE MORE ATTRACTIVE SITES ARE PROVIDED BY LOCAL PLANS!

 

 

The principle of phasing - appears in PPG12  (5.38-42).  New centres of development should be phased as an emergency-only provision.  ('Corridor' development is simply ribbon development by a different name.)

 

If such emergency land provision is to be described at all in the structure plan it should be made quite clear that this is SAFEGUARDED land, and is not available for development either in the plan period or in the foreseeable future (Draft PPG2  94 Annex B).  Presently such land seems to be treated as safeguarded for development when SAFEGUARDING is to protect land from development!

 

 

Implementation of out of centre development zones will signify that the plan for sustainability has failed. 

 

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Development -  the urgent need to redefine.

 

 Attention is drawn elsewhere in PPG12 to the:

 

                 "pervasive changes in human behaviour that may be needed to limit and adapt to global               warming" (6.11)

The E.C Fifth Environmental Action Plan:  "Towards Sustainability":  proposes setting targets explicitly to "break current trends".  Such trend-breach planning recognises the existence of environmental constraints to development.

 

As an example of a current trend that must be broken consider CO2 emissions: a greater than 60% cut in CO2 emissions is required to stabilise the atmospheric concentration and limit global warming. However, per capita emissions in the developed world are estimated to be 7 times higher than in the 'developing' nations.  To achieve the overall target reduction in CO2 emissions therefore requires an 80% cut per capita in Western Europe!  Traditional development with its emphasis on high consumption is the driving force behind global warming.

 

                [ref: 'Planning  For The Planet', Friends  of the Earth 1994 (national);  see also 'Climate   treaty heads for trouble', New Scientist 18.3.95, and 'Price of life sends temperatures               soaring', New Scientist 1.4.95 ]

 

It is obvious that the current human behaviour of 'growth', by 'economic expansion' and by continuous consumption of irreplaceable resources - particularly in the form of new land for 'development' - is grossly unsustainable. The natural form of development is by evolutionary change as species adapt to new constraints.  Traditional development is putting an impossible burden on both local and global environments and is undermining the social fabric of nations.  It is long overdue for planning authorities to provide a proper framework for facilitating the "pervasive changes in human behaviour" acknowledged as necessary in PPG12, and to lead a movement to real sustainable growth by evolution of existing development sites rather than continually demanding new ones.

 

The Structure Plan should ideally contain some bold statements to signify that there is an urgent need for change in the development status quo, and that Bedfordshire intends to be in the vanguard of the forces for sustainability.  The intention to open up new 'strategic corridors' for speculators in Marston Vale and along the already overloaded A1 shows that this county intends instead to  be in the guard's-van, a long way behind!

 

Development should be by evolution and change within the existing framework.  Luton, Dunstable and Houghton Regis are already both grossly overdeveloped and, perversely, at the same time national centres of dereliction!  Planning Guidance is replete with clauses devoted to the need to protect the urban environment and greenspace:

 

RPG9 4.7 - 4.11 for example, and specifically:

 

                7.28   "The emphasis on economic restructuring and regeneration in Luton and Dunstable              needs to take maximum advantage of recycling and re-using land already in urban use by         close co-operation within the public and private sectors."

 

It is clear from the RPG that this restructuring does not entail development on greenspace, and it is significant that the guidance does not talk of the need for 'economic development' in Luton and Dunstable, but for restructuring of what we already have.

 

It is also  clear that any unnecessary development in the Luton Dunstable and Houghton Regis area will compromise the aims of the RPG to move the weight of new development to the north of the county.  Long term strategy begins now: not at some indefinite point in the future.

 

 

Green Belts

 

vii)          Change 'a Green Belt' to 'the Green Belts', and remove 'south of the County' (we know they                 are in the county!).  Change 'green wedges' to 'new Green Belt wedges'.

 

The elastic green belt implied by the use of  'a'  would permit unlimited expansion and does not reflect planning guidance.

PPG12 6.5  speaks of:  "defending Green Belts to check urban sprawl"

 

RPG 9 has a key principle 1.10 (v):

 

                "Firm protection will be maintained over Metropolitan Open Land, Green Belts,  Areas of              Outstanding Natural Beauty, wildlife sites, Sites of Special Scientific Interest, Heritage         Coasts, the built heritage and the best and most versatile agricultural land." 

 

[WHAT A SHAME NOBODY TAKES A BLIND BIT OF NOTICE OF THIS 'FIRM PROTECTION'!]

 

 

RPG9 also states the broad objectives for the Region derived from "This Common Inheritance":

 

                "to maintain Green Belts, to protect areas of natural beauty (note; not just AONBs) and to            maintain and enhance wildlife habitats."

 

Draft PPG2 1.4:  Intentions of  GB Policy:

 

                "to assist in urban regeneration by encouraging the recycling of derelict and other urban              land".

 

Example - Tony Burton C.P.R.E:

 

                "In Newcastle-upon-Tyne for example the tight boundary round the town is helping         regeneration of the inner city." [Telegraph 22.2.94]

 

Draft PPG2  2.1:

 

                "The essential characteristic of Green Belts is their permanence.  Their protection must be            maintained as far as can be seen ahead."

 

It is clear from this guidance that THE Green Belt in the south of the County and all other Green Belts that may exist or be created in the County must be maintained, under firm protection.  The non-statutory term 'green wedges'  [apparently this has now become accepted as a statutory term but it could still be confused in common language - ed Dec 97] would not give adequate protection between settlements.  Proper Green Belt extensions or designations should be established if coalescence is to be prevented.

 

                                                ..............................................................

 

ix)  Delete everything after 'urban areas'.  'Strategic corridors' refer to ribbon development, which is both undesirable and unsustainable.

 

x)  Requires clarification. Suggest: 'to facilitate local sustainable employment, new housing should be designed for local people, and employment provision should be complementary so as to reduce the need for travel.'

 

 

Sustainability is not about promoting development: it is about promoting a responsible attitude to land use and minimising the need to go on developing (in the statutory 'development' sense at least).  The planning system must control development and only promote it in areas where it is essential.

 

 

 

 

 

An extra clause should be added to the strategy:

 

xvii)         'to recognise that there are limits to the traditional concept of economic growth and that there           is an urgent need for a "pervasive change" in this globally damaging human behaviour.' [PPG12 6.11]

 

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Comments on the Development Strategy:

 

 

In 1.27 page 4 of the introduction you say:

 

                "The likelihood of a low level of economic growth would suggest that the County should                avoid planning for levels of population and household growth which are out of step with the           ability of the local economy to provide jobs."

 

The current level of population ( let alone any growth ) is way above the ability of the present economy to provide jobs.  You admit in 1.24-1.26 that the economy is not likely to reduce unemployment even if there is substantial 'growth'.  Then you plan for levels of both population and household growth that act to reverse what appears to be a steady downward trend towards the very levels you desire!  Clauses ii) and iii) in particular will ensure that you do not achieve your avowed aim.

 

Paragraph 1.30 on page 4 shows that one of the key principles of the County Economic Development Strategy is begging:!

 

          *    "to raise awareness by the UK government and Europe of the problems of all parts of the

                  County"

 

          *    "obtaining funds from both sources to the benefit of the local economy"

 

 

Bedfordshire must be one of the most  developed and affluent places in the world and yet we have the cheek to pass the buck to Europe to solve our problems for us.  But this is still not embarrassing enough for us:  as well as asking for help we also continue with policies that make regeneration ever more difficult.  To ask for funds for regenerating the AWD site for example, whilst simultaneously releasing many hectares of  Green Belt for new development at Sundon Park simply beggars belief!  Bedfordshire really must take responsibility for its own future if it wants to be sustainable.  With such policy clauses and 'economic strategies' as these, it never can be.

 

 

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