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SUSTAINABLE COMMUNITIES: AN URBAN DEVELOPMENT CORPORATION FOR THE LONDON THAMES GATEWAY
JOINT LIBERAL DEMOCRAT RESPONSE TO ODPM CONSULTATION PAPER
UDC or no UDC?
1 Liberal Democrats oppose the proposals to establish a Unitary Development Corporation (UDC) for the Thames Gateway. We do not welcome the centralisation of planning powers, which will mean less Borough control thereby substantially reducing local accountability and democracy. In addition with the work and projects already underway and the plethora of agencies operating in the Thames Gateway we detect the potential for overlap, confusion and a lack of transparency. There is a strong possibility that the UDC will only aggravate the existing fragmentation of organisation and direction.
2 In our view what is most required is a comprehensive set of measures to strengthen Borough planning capacity. In addition we suggest the selective use of Urban Regeneration Companies (URCs), an option rejected by the ODPM. Under Borough or LDA control these URCs could drive regeneration forward, by acting as delivery vehicles for major projects and calling upon staffing and knowledge from established Gateway agencies so that there is no proliferation of unnecessary bureaucracy. This framework, reinforced by effective strategic London government, would be both capable of and democratically accountable for delivering regeneration in the Thames Gateway.
3 However, we acknowledge the ODPM's apparent determination to proceed with a UDC and the fact that its eventual establishment is a foregone conclusion. Therefore, we frame our response to this consultation in terms of improving proposals that have been presented, recommending ways in which the level of democracy and local involvement can be enhanced.
Q1. The most appropriate boundary for the London Thames Gateway
4 Liberal Democrats are aware that each of the Boroughs affected by the ODPM's proposals have made representations with respect to UDC boundaries and specific pockets of land that they would like included or excluded. We wish to see utmost consideration and fulfilment of these local views, as the Boroughs themselves have a superior level of knowledge, experience and understanding of local communities and the particular needs and sensitivities of an area.
5 In general we have some concerns that the proposed UDC paid insufficient attention to the work carried out jointly by the Boroughs through the Thames Gateway London Partnership (TGLP). There seems to be no clear, identifiable rationale or set of criteria on which the boundaries were drawn up. Rather they have been arrived at fairly arbitrarily. It would be helpful, and improve transparency, if the logic behind the boundaries was laid out.
6 In addition, there is no detail on the specific reasons why parts of the London Thames Gateway require a UDC to fulfil regeneration objectives whilst for others the appropriate regional development agency is deemed sufficient to oversee strategy and implementation. Justification for this would also be useful.
Q2. Any other boundary options that should be considered
7 Liberal Democrats are not convinced of the wisdom or necessity of including the Lower Lea within the UDC boundaries This is an area on which a great deal of attention is already focused and where work is progressing with the involvement of a variety of agencies. The LDA has already commissioned a distinct and comprehensive masterplan for regeneration of area in view of the 2012 Olympic bid. Although the Lower Lea is a hugely significant part of the Thames Gateway, we are concerned about the potential for a conflict of interests and duplication of efforts if the UDC takes over strategic power. This begs the question of whether the Lower Lea region should be included within the UDC at all. It is very much a unique patch of the Thames Gateway and should be considered as such.
8 At the very least there must be far greater clarity as to how the existence and responsibilities of the UDC would affect the Lower Lea masterplan. Liberal Democrats recommend that the LDA should retain strategic control for the area so that planning, activities and progress can continue unhindered. Transferral of any responsibility risks disturbance of ongoing projects. The joint GLA-LDA-TfL response to this consultation suggests the establishment of a protocol or `agency agreement' between the UDC Board and the LDA, through which the Agency could be assured that it can continue to lead the land assembly and development in the Lower Lea. This is especially crucial given the need for consistency with regard to the Olympic Bid 2012 for which the LDA is a lead player. Such an arrangement should at least be instituted until the outcome of the Olympic bid in July 2005.
9 We do not, however, endorse the establishment of another, separate UDC with primary responsibility for the Lower Lea area. We consider that the LDA, organisations involved in the masterplan and the Olympic bid team are able to offer sufficient strategic direction. Adding another layer of bureaucracy to on top of this would only serve to complicate arrangements and cloud transparency further.
10 Finally with regard to the UDC's boundaries Liberal Democrats are very concerned about the consequences and implications for those areas that are not included. Presumably it is expected that benefits will be felt by those communities inside of the UDC borders. However, we are anxious about the risk for areas outside the UDC's boundaries and the possibility of them missing out on regeneration and renewal whilst attention and funding is dedicated for UDC purposes and projects. It is essential that proper consideration be given to excluded communities so that economic stagnation at the edge of the UDC boundaries is avoided. The proposals pay scant regard to this issue. Liberal Democrats want to see a demonstration of commitment to development of the Thames Gateway as a whole - not just the pockets in the UDC's remit. We call for clear proposals to prevent and mitigate against any detrimental effects that could be incurred by non-UDC communities.
Q3. The scope of an Order transferring planning powers to a UDC; as regards the area for which the UDC would be local planning authority and the development control functions that it ought to overtake
11 The UDC proposals do not provide nearly enough clarity about which planning powers are to become the responsibilities of the UDC and which are to be retained by the boroughs. This is a fundamental omission. This untidy split will only lead to planning difficulties and development delays in the future.
12 Liberal Democrats would like to see the planning roles and responsibilities of the UDC, GLA and the Boroughs distinctly resolved before the UDC comes into operation. We want strict limitations on the planning powers of the UDC, with the Boroughs retaining as much jurisdiction as possible. As the TGLP has suggested, this can be achieved through a process by which applications are taken through Borough planning systems prior to their consideration by the UDC so that local authorities can make recommendations. We also propose sub-contracting the administration of so-called strategic planning applications to the relevant boroughs so that they can directly handle them. Such a system should ensure that the planning process is more joined up and will enable community views and sensitivities to be heard and respected, with recommendations and delivery happening at a local level.
13 Liberal Democrats regard it as imperative that the safeguarding of local involvement and accountability must be written into the UDC plans. With its strategic remit, the UDC will not be sufficiently appreciative or aware of local circumstances. There must also be the establishment of formal and regularly used channels of communication to ensure continual local engagement in the planning process. Finally we would advocate a provision for public speaking rights during the planning process.
14 As well as clear planning protocols with the Boroughs, we also acknowledge the necessity for formal lines of planning responsibility to be drawn between the UDC and strategic powers of the Mayor of London. We insist upon the need for primacy of the London Plan and strongly support the London Assembly's right to scrutinise the UDC's exercise of planning functions to ensure that protocols are not broken.
Q4. How best the UDC and joint borough team could work together in the areas where the main Olympic facilities would be located.
15 With regards to the Olympic bid and the Lower Lea region in detail we have made comment under Q2.
16 In addition to these comments we would, once again, suggest the establishment of a protocol drawn up between the UDC and the joint borough team to ensure that borough views and representations guide development. This needs also to include the LDA, which has a key role in the Olympic bid.
Other Comments
17 Leadership and Co-ordination Issues
There is a plethora of boards, partnerships and organisations already in existence in the Thames Gateway. To name just a few - the Thames Gateway Strategic Partnership (TGSP), Thames Gateway Strategic Executive, Thames Gateway Steering Group, Thames Gateway London Partnership (TGLP). There are also public organisations with strategic responsibility in the Gateway, such as the ODPM's Sustainable Communities Delivery Unit, the GLA, the LDA, the SRA, the Housing Corporation, English Partnerships. We offer a strong warning about this multiplicity of agencies, which is creating layers of overlapping and potentially conflicting bureaucracy.
18 The specified role of the UDC's Board is to set a strategic vision for the UDC and take the decisions required to deliver that vision. It remains decidedly unclear how this is distinct from the roles of the other organisations already operating in the Thames Gateway. The Thames Gateway Strategic Partnership aims to develop and implement a pan-Gateway regeneration agenda, the London Thames Gateway Partnership Board has the objective to co-ordinate and oversee the activity of delivery agencies whilst the Thames Gateway Steering Group's purpose is to set and take forward the agenda. Then there is the LDA, which is also supposed to have strategic responsibility for regeneration. Not only is it not clear if and how the UDC will bring additional benefits but absolutely no consideration has been given to its working relationships with the myriad of organisations already in existence. This will inevitably lead to a lack of authoritative leadership and direction, duplication of efforts, conflicting objectives and confusion amongst participants. This is not to mention the lack of transparency that the absence of clearly demarcated lines of remit and responsibility will cause for the public and community; there will be no certainty about who and where to contact to get involved, express comments and ask queries. The proposals do not clearly deal with these issues and, in their present format, actively discourage public involvement.
19 Liberal Democrats want further clarification as to why this separate quango is really required. If the ODPM does believe that there will be specific added advantages from the UDC's establishment this needs to be clearly spelt out - at present there is no proper reason given as to why Boroughs in the Thames Gateway should have their planning powers usurped by a central body which seems remote from local communities and will add to the range of organisations already in operation.
20 Not only must there be an enhanced explanation of the reasons why a UDC is deemed necessary and the additional benefits it is likely to bring, but there must be detailed information about which organisations are going to be responsible for different projects and objectives together with specific proposals about the linkage and joint-working arrangements between the UDC and these other groups. It is imperative that the lines of responsibility are explicit if the UDC is going to achieve any success.
21 Funding
Liberal Democrats have severe concerns about the lack of detail within the proposals about funding of the UDC. The success of regeneration in the Thames Gateway is absolutely dependent on the availability of sustained financial commitment from central government. Far more details are required about the finances available over the lifespan of the project so that proper long-term planning is possible. What this funding can be spent upon also requires stipulating. For example, will the UDC be responsible for providing the associated community infrastructure in the Thames Gateway such as schools and hospitals? Such facilities are a pre-requisite, but information about their provision and the UDC's role in this is missing from the proposals.
22 Democracy and Accountability
Liberal Democrats have several concerns about the virtual absence of proper democratic safeguards and channels for representation built into the proposals. The UDC seems to be another Government quango, from which local accountability is severely lacking.
23 First, a point made very strongly by all of the Boroughs, is the inability for each local authority to have permanent representation on the UDC Management Board. With the ODPM having arbitrarily prescribed a formula for the Board to be made up of 13 appointed Members, it is very unlikely that all of the 8 affected Boroughs will have a seat. Unless this composition is altered communities without a member will feel effectively disenfranchised. This is unacceptable. The Liberal Democrats propose that the Board is increased in size to ensure that each Borough has a permanent representative.
24 We are also aware and concerned that no consideration seems to have been given to political representation. The usual practice is to ensure that planning committees are politically proportional so as to allow a broader and more representative input.
25 Finally, we are not convinced of the suitability or capability of a remote, unelected and unaccountable quango in handling the complex human (not just physical) challenges presented by the re-modelling of entire communities. It will not have sufficient knowledge of specific local dynamics, which is a serious concern. If it is to work constant and formalised communication channels with Boroughs are required. Proper forums and mechanisms for public consultation and engagement should also be written into the UDC's structure and procedures so that its democratic credentials can be improved. The principle of democratic accountability should be enshrined, not sidelined, in the UDC.
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Urban Development Corporation for the London Thames Gateway
Liberal Democrat Consultation Response
February 2004