Response to the Department for
Communities and Local Government consultation
Urban Development Corporations’ Quinquennial Review
The Environment Agency welcome the opportunity to respond to the consultation
Urban Development Corporations’ Quinquennial review.
Our main points are:
London Thames (LTGDC)and Thurrock Thames (TTGDC) Gateway
• We have a good working relationship with LTGDC and TTGDC since their
formation, and believe they have been quite successful in directly and
indirectly delivering regeneration in their areas.
• They have also been fairly successful at assembling land and preparing sites
for development, encouraging existing and new industry and commerce as
well as creating attractive environments that encourage people to live in the
• There is a need for improved clarity on the different roles, responsibilities,
funding programmes and budgets, as well as joined up working between
LTGDC and HCA.
• We support development of a formal relationship between LTGDC and the
Olympic Legacy Committee.
West Northamptonshire Development Corporation.
• WNDC’s additional role of determining planning applications has been a
considerable challenge for them. However, they are now addressing this and
undertaking the necessary strategic environmental and other studies to enable
applications to be determined.
• Recently approved Regional Spatial Strategies growth targets may be unrealistic
without compromising sustainability standards contained in the relevant planning
policies, making it difficult for WNDC (and others) to meet expectations.
• We have a reasonable extent of engagement with WNDC since their formation
and feel they have made good progress in securing the regeneration of the
• They have been fairly successful, given the difficulties in funding of
infrastructure. In particular the settlement of Section 106 agreements has
proved to be very time consuming, though this has been the case in all growth
areas, probably because the expectations are higher. We believe they need
firm strategic planning and timing for the delivery of infrastructure when
assembling land and preparing sites for development.
• We believe there is an opportunity to review the geographic boundary and
threshold (size) of responsibility in WNDC.
1.1 As the leading public organisation for protecting and improving the
environment in England and Wales, the Environment Agency welcomes the
opportunity to respond to this consultation on the three Urban Development
Corporations (UDCs). We work with each of them, and provide advice on the
environmental aspects of their work, both at the strategic planning level, and
as a statutory consultee in the process. Some specific activities they
undertake, for example in respect of contaminated land and work on rivers,
may require our consent.
1.2 London Thames and Thurrock Thames Gateway Development Corporations
(LTGDC and TTGDC) lie within the Environment Agency Thames Region, and
West Northamptonshire Development Corporation (WNDC) falls within the
Anglian Region. The main contact between the Environment Agency and the
three UDCs is through the Milton Keynes South Midlands (MKSM), and
Thames Gateway Sustainable Development (TGSD) teams.
Our Work with the Development Corporations.
1.3 The TGSD team influence sub-regional policies, strategies and master-plans
that determine development and regeneration in the Thames Gateway. Both
the Thames Gateway Development Corporations are therefore strategic
organisations for us to work with. We sit on the Lower Lee and London
Riverside Management groups, set up by the LTGDC to assist them in
deciding how pooled financial contributions should be used, and to assist in
reviewing their Planning Obligations Community Benefits strategy.
1.4 WNDC lead engagement with the delivery vehicles to promote our aims and
objectives. With the transfer of planning determination powers from the
District/Borough Councils our local Planning Liaison team have engaged with
WNDC officers from the outset.
1.5 For each of the UDCs, we have provided, where appropriate, general
comments and responses to the specific questions raised in the consultation
document. These are in Annexes 1- 3.
1.6 We have focussed on those questions and issues most relevant to our
environmental remit. We consider maintaining and enhancing the environment
to be an integral part of regeneration, and in assessing the success of these
organisations, have factored in their performance on environmental matters.
1.7 We do not offer a view on the possible delivery options, but emphasise that
whatever option is selected, it should not detract from their ability to deliver
environmentally sustainable development and regeneration, or the effective
working arrangements we have developed with them.
2. FURTHER INFORMATION
Further information or background to this response can be obtained from Kim
Dowsett , Sustainable Development Policy Officer, Kings Meadow House, Kings
Meadow Road, Reading, RG1 8DQ, 0118 953 5112, kim.dowsett@environment-
LONDON THAMES GATEWAY DEVELOPMENT CORPORATION
Q1. How successful has LTGDC been in securing the regeneration of its area?
1. LTGDC has been successful in driving a number of strategic master-plans within
its London Riverside area, for example River Roding in Barking and Rainham
Village, which we contributed to. These provide parameters for the next stages of
detailed planning and development, and are prepared outside of the local planning
process. This enables them to influence individual planning applications much
quicker. We have been advising the LTGDC on the environmental content of a
number of master-plans as they progress from early concept to final documents
and consider this joint working to be a welcome step in securing regeneration with
positive environmental outcomes.
2. Because these master-plans are not statutory documents within the local planning
process, we recommend that wherever possible they are signed off at an
appropriate level by strategic stakeholder organisations. This would help ensure
that the master-plans (and associated contribution from strategic stakeholders in
their preparation) are referenced by local planning authorities considering
individual planning applications.
3. LTGDC aim to work with developers prior to submissions, to influence planning
applications within the wider master-plan area, and to encourage submissions that
reflect parameters of the master-plan. They have facilitated our input into early
discussions with a number of developers, resulting in schemes that we fully
supported at formal consultation stage. The challenge now will be to ensure that
development which proceeds to construction phase remains aligned with the
environmental parameters of LTGDC led visions and master-plans.
4. In the Lower Lee area, the LTGDC has led on producing an ambitious vision and
plan for a Lee River Park, south of the Olympic Park, which we support. It has
secured funding for some early projects. However to date there has been no
significant scale project delivery on the ground.
Q2. How successful has LTGDC been in assembling land and preparing sites for
5. Overall, we consider that they have been quite successful. In the Lower Lee there
are several examples of land secured in partnership with others, for example the
former St Andrews Hospital site at Bromley by Bow. In London Riverside, the
LTGDC is currently assembling land around Dagenham Dock, a strategic location
within East London to be promoted as a Sustainable Industries Park. This
assembly of land will hopefully result in a more effective master planning process
and provide improved opportunities to deliver environmental infrastructure across
the whole site. In Rainham Village they have acquired a number of individual sites
for new development to help revitalise the area.
6. We endorse LTGDC’s approach of commissioning investigations on a number of
its sites, as a necessary early phase of site preparation. This means any
environmental issues such as land contamination can be addressed as an integral
part of the development.
Q4. How successful has LTGDC been in encouraging existing and new industry
and commerce, creating attractive environment and ensuring social facilities to
encourage people to live in the area?
7. In the Lower Lee the LTGDC has successfully worked to relocate existing
businesses from the Olympic Park. They have also worked in partnership with the
Olympics Development Agency and British Waterways London on the new lock on
the Lower Lee River which improves the navigation of the channel for larger
vessels. This provides opportunities for both social and economic benefits.
8. In the London Riverside area, the Corporation is driving the delivery of a vision for
a Sustainable Industries Park at Dagenham Dock. An Energy from Waste facility is
earmarked for the location as a result of the Corporation’s work, subject to
9. The LTGDC is a significant supporting partner of Wildspace, a large green space
in east London that includes the Inner Marshes Sites of Special Scientific Interest.
The LTGDC’s financial support to local delivery partners has provided match-
funding for significant external grants. Some first phase projects to enhance the
area are already complete. Future projects will primarily focus on improved
accessibility of the marshland for local communities.
Q8. Are the arrangements already made to ensure alignment of the work of
LTGDC and HCA in London sufficient? if not, what further arrangements should
be put in place?
10. It is early days to answer this. There are a range of public bodies all with a
regeneration remit and an interest in East London, including HCA, the Olympic
Delivery Authority (ODA), LTGDC, the Olympic Park Legacy Committee (OPLC),
CLG Thames Gateway and Olympic Directorate, London Development Agency,
plus the London Boroughs. We believe that the HCA needs to have a clear
relationship with all of the others to ensure alignment. There is a need for
improved clarity on the different roles, responsibilities, funding programmes and
budgets, as well as joined up working.
Q9. Should the LTGDC have a formal relationship with the Olympic Park Legacy
Company (OPLC)? if yes, is a Memorandum of Understanding the best way to
establish such a relationship?
11. As much of OPLC work is strategic planning for regeneration in the Lower Lee
Valley they should be encouraged to develop a formal relationship with LTGDC.
They will need to work closely with them to ensure there is a coherent plan for, and
delivery of, a sustainable legacy for the Olympic Park, its fringe, and the wider
Lower Lee Valley. How they best do that is for them to decide.
THURROCK THAMES GATEWAY DEVELOPMENT CORPORATION
Q 10. How successful has TTGDC been in securing the regeneration of its area?
1. TTGDC have successfully produced a number of master plans for their regeneration
areas within Thurrock. These have been prepared by different consultants so the
level and focus of these documents varies slightly. These documents are not statutory
but are signed off by TTGDC board, containing members from Thurrock Borough
Council (TBC), and do have material planning consideration.
2. There can be differing priorities within the area between TTGDC and TBC. However,
the majority of the time the planning applications are to be determined by TTGDC with
TBC as a consultee, and therefore TTGDC are able to guide developers to follow the
master plans. Through pre-development discussions we assist with promoting the
parameters or guidance within the master plans.
3. To date there has been no significant scale project delivery on the ground, but we
hope that the parameters of the master plan will be followed through as these come
Q 11. How successful has TTGDC been in assembling land and preparing sites for
4. TTGDC have successfully purchased a number of sites for development, the most
significant being Fiddlers Reach. Some of these sites have constraints that we are
working with TTGDC to resolve.
Q13. How successful has TTGDC been in encouraging existing and new industry
and commerce, creating an attractive environment and ensuring social facilities to
encourage people to live in the area?
5. As examples of its success in encouraging commercial development, and creating an
attractive environment, Thurrock will be housing the new ‘London Gateway Port’ and
business park and this should act as a draw for a number of other businesses. Master
plans focus on the commercial and industrial development of areas as well as meeting
employment needs. Thurrock also houses two ‘Parklands’ projects in Thurrock
Thameside Nature Park which were part funded by TTGDC.
WEST NORTHAMPTONSHIRE DEVELOPMENT CORPORATION
1. WNDC’s additional role of determining planning applications has been a considerable
challenge for them. We are very aware that they inherited a large amount of difficult
and contentious applications from Northampton Borough Council, and this has
hampered progress in delivering growth. Most of these applications had not
progressed for good reasons. For example, we raised concerns relating to flood risk
and water infrastructure, both of which have required major assessments to
demonstrate compliance with Planning Guidance. It has taken a considerable effort
from all stakeholders to get these studies to their current state of nearing completion.
Because overall growth requirements are spatially distributed across all the growth
areas, this situation is replicated many times. This has stretched and fragmented the
available skills and resources of the various stakeholders and suppliers involved.
2. We have active liaison with planning applications and in the majority of cases our
comments are given due attention. However, recently approved RSS growth targets
may be unrealistic without compromising sustainability standards contained in the
relevant planning policies, and without the infrastructure funding that will be
necessary. This would appear to place WNDC (and others) in a very difficult position,
compounded by their short lifespan.
3. We feel there are some lessons to be learnt from the arrangements in North
Northamptonshire where there has been a more inclusive approach from various
organisations. We are pleased that after a long period there does seem to be a
coherent Joint Planning Unit in place for West Northamptonshire and we look forward
to this providing firmer direction to any future organisational arrangements.
Q17. How successful has WNDC been in securing the regeneration of its area?
4. WNDC inherited an ambitious programme of regeneration in Northampton. Although
progress on the development has been patchy, they have supported a strategic
approach to flood risk management by conditioning planning applications. This has
facilitated a new major flood balancing area incorporating a country park.
Q18. How successful has WNDC been in assembling land and preparing sites for
5. They have been fairly successful, given the difficulties in funding of infrastructure. In
particular the settlement of Section 106 agreements has proved to be very time
consuming, though this has been the case in all growth areas, probably because the
expectations are higher.
Q19. How successful has WNDC been in creating private sector confidence and
maximising private sector investment?
6. It is possible that the large scale involvement of HCA masks WNDC’s role, and
creating public sector confidence is difficult under current market conditions. A
significant amount of time has been spent in trying to secure sufficient funds for
environmental infrastructure by all stakeholders through Growth Area Funding. This,
however, is restricted and has left the only route to funding being through planning
agreements/ Section 106 agreements. In the current market this is a very difficult
position for WNDC.
Q20. How successful has WNDC been in encouraging existing and new industry
and commerce, creating an attractive environment and ensuring social facilities to
encourage people to live in the area?
7. We are unable to comment. As the Joint Core Strategy emerges we would like to see
a green infrastructure strategy for the area, to ensure an attractive natural
environment is created.
Q.23. Is the assumption that WNDC should have a ten year lifespan still correct?
8. This needs to be considered in the context of the emerging Joint Core Strategy. We do
not anticipate this being in place until 2011 after which there may be greater clarity of
land assembly and infrastructure requirements. It may be worth targeting any changes
in WNDC’s lifespan towards this horizon. See also Q24 below.
Q24. Do WNDC’s planning powers need to be modified (in so far as the current law
allows) in the light of experience? If so in what ways(s)?
9. Currently the Joint Planning Unit covers all of West Northamptonshire whereas
WNDC powers only extend to parts of the area. We envisage that all significant
development in West Northants could be served through a strategic approach.
This could be achieved by strengthening the role of the West Northants Joint
Planning Unit, or suitable policies in the Core Strategy to ensure that an ad-hoc
approach is avoided.