The Royal Society of Ulster Architects (RSUA) is the professional body for architects in Northern Ireland and has a current membership of over 800 chartered architects. RSUA is the voice of architects in the region. RSUA is a charity which aims to deliver public benefit through the promotion of architecture.
RSUA welcomes the opportunity to comment on the Belfast Local Development Plan – Draft Plan Strategy and would like to thank Dermot O’Kane and his team at Belfast City Council for the meeting to discuss the Plan in early October 2018.
We also welcome the engagement with representatives of RSUA through the various working groups which have helped shape elements of the draft plan.
We support the vision as set out in the Belfast Agenda, as noted at 4.1.1 of the draft Plan Strategy document, and believe it is crucial that the city has a local development plan which actively helps to convert those fine words in to a tangible reality in our physical environment.
- 1. Support for high level aims
- RSUA supports the overall goals set out in the draft plan strategy. RSUA supports many of the specifics in the document too however we will focus our response on the elements of the draft plan where changes should be considered.
- 2. Deficit in Robust and Current Evidence
- RSUA is concerned that not all of the policies and plans have been developed on the basis of robust and current evidence.
Example 1: Tall building policy. There is no evidence presented in the Topic Paper: Urban Design and Built Heritage to say that there is a need for tall buildings in Belfast. Perhaps the evidence will make the case for tall buildings, conversely it may not. However, the information is not currently available to make an informed decision.
Example 2: The Technical Supplement no.6 ‘Urban Environment’ for draft BMAP is considerably out of date and cannot be relied upon for a current picture of the urban design of the city. It should, at least, have been the subject of a review as part of the current draft plan.
- 3. Specifics of Belfast
- RSUA is concerned that the plan does not sufficiently address the specifics of Belfast.
- For example, to what specific areas is the proposed population growth to be directed and do capacity studies support this growth in these areas? What are the priorities? What are the current blockages to increasing the population in the city and how will this new plan help remove those blockages?
- The challenge is to convert the broad desires in to specific actions that are actually deliverable in Belfast
- It would be useful to articulate more clearly how the vision can be realised with Council looking after planning but responsible for ‘project managing’ the inputs and deliverables from government departments responsible for housing, transport, regeneration, education etc.
- 4. Making the vision more tangible
- It would be very beneficial to demonstrate using 3D computer models or images what the desired vision for the city might look like in reality
- We would recommend the use of exemplars from other European cities to illustrate, in a manner easily comprehensible to both layman and professional alike, what the outworkings of the plan might mean
- We believe there is an increased chance of the plan being understood and delivered if there were readily understandable illustrations of the outcomes sought.
- 5. Clearer route from policy to practice
- There appears to be a missing link explaining how the strategic vision and four strategic aims and objectives translate into the future built form and the appearance of the city
For example: Policy SP5 – Positive Placemaking. The wording is aspirational and lacking in detail about what is meant by ‘good design’ and ‘positive placemaking’ in the context of Belfast, including how it might be delivered.
- The plan could be clearer and more explicit on: where we have come from; where we are now; where we want to be in the future, and; how we plan to get there.
- There is a need for the overall vision to be presented in a more tangible form so that it can be readily demonstrated how individual projects and developments contribute to the vision. This would also allow for rigorous interrogation and verification at each stage of development. Future sub-masterplans and key site requirements would also derive from this overall document
- We strongly support a masterplanning approach as proposed for major development but there is no overall strategic framework, either presented or proposed, into which these, and the myriad of other smaller projects and developments, would fit. It is therefore difficult to visualise how future development can be adequately controlled and directed to deliver the strategic vision for the city.
- 6. Prepared for change
- It is vitally important that it is widely understood that the plan will need to be responsive to changing circumstances politically, economically and in line with behavioral trends.
- 7. Design quality and place making
- The draft plan strategy strongly promotes design quality and placemaking and these are areas where Belfast City Council can have a significant degree of control. It is disappointing therefore to note that there is no definition of what these terms mean in the context of Belfast. There are no robust baseline evidence, indicators, targets or triggers with which to guide and monitor progress in these highly important areas, which have a cross cutting influence in all other areas of the plan, and which are essential to delivery of the vision for the city. These are serious omissions and thought needs to be given as to how to define and measure objectively what many see as largely subjective topics. However current exemplars exist in other areas of the UK, and elsewhere, and these should be investigated.
- A related area which requires consideration, though perhaps not as part of the plan strategy, regards the definition and assessment of design quality in general. Various approaches might be considered, such as:
– acquiring in house professional expertise
– appointing a city architect / urban designer
– engaging with the RSUA peer approved design quality panel
– engaging with other sources of external expertise, such as the Ministerial Advisory Group on Architecture and the Built Environment.
- 8. External peer review of the Plan Strategy
- We recommend review of the Preferred Options Paper and draft Plan Strategy documents, and supporting evidence base by experts acting in the role of critical friend, from other UK and European cities.
- 9. Importance of setting standards
- It is important to set out a plan for standards in of buildings in the city. The detail of this may come at the next stage but it having this requirement locked in to the strategy is critical.
- For example this could relate to inner city space standards for housing, required densities for housing, a policy on balconies. With regards to sustainability there are a range of measures that could be required but one obvious one which is often overlooked is requiring buildings to have a greater degree of permanence – accepting of course that the usage of that building will most likely change over 100 years.
- 10. Neighbourhood and Identity
- There is little detail on the aspirations to protect and enhance the identity of the differing neighbourhoods which make up the city outside of the inner core area. Detail, at a strategic level, is also needed of what measures are envisaged to break down barriers between areas, and promote connectivity and well-being.
- 11. Retail
- The draft plan implies that the inner core of the city will be promoted ahead of the neighbourhood and district centres and we see this as logical. However there is insufficient detail as to how this will be achieved or which areas of the inner city will be prioritised.
- Para 6.2.3 notes that as ‘… a major retail destination, it [the city centre] has a good representation of independent long established national and multi-national businesses offering convenience and comparison retailing and service uses.’ The term ‘independent’ is in conflict with the idea of ‘national’ and ‘multi-national’ retailers and it is difficult to comprehend the city centre as offering a good shopping experience, certainly not in the recent past. The desire ‘to attract major higher end aspirational retail anchor stores’ appears to ignore the growth of internet shopping and the demise of the traditional high street. An alternative strategy for the city centre should be considered.
- 12. Soundness
- Procedural Tests
Whilst the council has prepared a Preferred Options Paper the RSUA considers that, by presenting only a preferred option, this may fail to comply with:
– SPPS para 5.30 ‘ The Preferred Options Paper should contain a series of options for dealing with key issues in the plan area, …..’
– Development Plan Practice Note 5 (DPPN 5) para 8.1 ‘The POP should set out …… a series of options for dealing with key issues in the plan area and a council’s preferred option.’
– DPPN5 para 5.9 ‘The evidence base should therefore provide justification ….. to support the choices made …… . The preparation of the evidence base should therefore be regarded as a process with information being reviewed and kept up to date to ensure it remains reliable and relevant…. .’
– DPPN 5 para 8.5 ‘ As the evidence base will be used to test the ‘soundness’ of the development plan document, it is important to provide transparency in the process by linking the evidence used to justify the preferred option over the other alternatives considered in the POP and the subsequent policies and proposals contained in the Plan Strategy and Local Policies Plan.’
– SPPS para 5.4 ‘….. the SPPS requires planning authorities to focus on delivering spatial planning. ……… It should also be visionary in setting out a clear expression for how areas should look and function into the future.’
- Consistency Tests
– As above
- Coherence and Effectiveness Tests
– RSUA considers that the plan does not fully succeed in setting out a clear expression for the future development of the area, logically flowing from the Strategic Vision and leading to the Strategic Policies, as an incomplete and inaccurate picture of the current state of the city is presented and insufficient detail is provided to form a coherent view of the proposals in the unique context of Belfast.
– There are no clear mechanisms for implementing the plan.
– There are no proposals for monitoring Design Quality and Place Making. These are major components essential to plan delivery.
RSUA would welcome the opportunity to continue to engage in the Local Development Plan process. Please contact Ciarán Fox, Director, on firstname.lastname@example.org.