Spatial Planning Systems of Britain and France

A Comparative Analysis

Philip Booth, Michelle Breuillard, Charles Fraser, Didier Paris

• Publisher: Routledge
• Year: 2007
• ISBN:
  9781134086832
• Edition: 1
• Topic: Architecture
• Subtopic: Urban Planning & Landscaping

Spatial Planning Systems of Britain and France brings together a wide selection of comparative essays to highlight the fundamental similarities and differences between the spatial planning in Great Britain and France: two countries that are near neighbours and yet have developed very different modes of planning in terms of their structure, practical application and underlying philosophies.

Drawing on the outcomes of the Franco-British Planning Study Group and with a foreword by Vincent Renard of the Ecole Polytechnique in Paris, the book offers a comparative investigation of the basic contexts for planning in both countries, including its administrative, economic, financial and legal implications, and then move on to illustrate themes such as urban policy and transport planning through detailed analysis and case studies.

From these investigations the book brings together planning concepts from both a national and European perspective, looking particularly at two current issues: the effects of urban growth on small market towns and the use of Public-Private partnerships to implement development projects.

Spatial Planning Systems of Britain and France will prove invaluable to policy makers and practitioners in both countries at a time when national policy is beginning to look towards practice in other countries.

The book is published simultaneously in English and French opening up a wider debate between the English-speaking and francophone worlds.

Chapter 1
The purpose and process of comparing British and French planning

Michèle Breuillard and Charles Fraser

Context and objectives

Even if Goethe thought that ‘comparing is just an easy way for the ignorant to avoid making decisions’, most French and British academics as well as other European colleagues would consider that there is an urgent need for improving mutual knowledge through comparison. Thus although there are apparently comparable problems in both countries and considerable exchange of information about them and the methods of dealing with them in a western democratic environment, there are still continuing debates about their nature and the differing legal and institutional frameworks within which the two societies operate to manage and resolve such problems.

However, the many debates which have occurred, both within the Franco-British Planning Study Group and in a wider policy context, have highlighted the fact that although much is written and spoken about each other there is a dearth of analytical literature comparing the two countries, ways of managing their environments and a lack of really detailed analysis of the similarities and differences in practice across a range of aspects of this process. What has been produced to date has been useful and basic, more often than not merely descriptive but in certain areas, particularly the analysis of structures and practices, more fundamental theoretical questions have begun to emerge going beyond the procedures of the system and its contextual frameworks to the social theories (McConnel 1976) which underpin the workings of each. In essence there is a lack of a theoretical framework within which a comparison can be conducted.

There is therefore a need to clarify several issues before plunging into the specific topic comparisons:

• What are the objectives of comparative work generally and what can be achieved by this comparative work in particular?
• What do French and British planners already know about each other? What has been written and when and how well have we used the methodology of comparative analysis to enhance the mutual comprehension of the two systems and to use this knowledge as a policy and practice enhancement tool?
• What are the main issues for theoretical debate which have emerged from this historic work and how and in what areas can this volume further the process of mutual comprehension of our planning systems and beyond this improve practice and policy efficiency?

The comparative analysis objectives

It would add little to the volume to rehearse the nature of comparative theory and to point to its many difficulties and to its considerable theoretical and practical advantages. These are well documented with respect to planning in Breakell (1975), Masser and Williams (1998) and Couch et al. (2003). There is an even more structured and thought-through methodology for comparative work in respect of comparative politics in Ashford (1982) and several other disciplines, such as housing (see Power 1993; Kleinmann 1996). In France comparative method is also a well-used intellectual tool but it has essentially been restricted to the study of law and government and not to more practical areas such as urban planning and policy. The accent has been on using comparison to draw out universal principles which occur in all contexts: ‘Comparative law allows one to discover the sense of the Universal in the legal sciences’ (Rodière 1972). There is evidence that in recent years a more practically oriented interest has begun to emerge, i.e. Green and Trache’s work on public-private partnerships in the UK for the Caisse des Dépôts et Consignations (Green and Trache 2003).

The many problems of comparative work, language and terminology confusions, statistical non-equivalence, incompatibility of structures, competences etc., are familiar to all who attempt comparative work and have been encountered in all the seminars held by the group and by every chapter editor. However, what is more important for this volume is which of the policy objectives of comparison have been addressed by this work and to what extent has any contribution to knowledge been achieved as a result of it. Faludi and Hamnett (1975) identify three basic objectives for comparative work:

• the advancement of theory in planning;
• the improvement of planning practice;
• the harmonisation of planning systems.

These can be placed in any order and their priority is usually defi ned by the needs and objectives of the researcher. Thus Faludi and Hamnett give precedence to the advancement of theory over the improvement of planning practice and the removal of barriers to the integration of systems. To the technical administrator the second of these objectives might be the more important while to the Eurocrat attempting to harmonise European urban policy, planning or land tenure the last of the three might be the more interesting. Bertinget et al. (1979), working in the social sciences, adds two more important uses of comparative research: to explain and interpret social phenomena to assist the understanding of social reality and, through policy evaluation to lead to policy development (an extension of Faludi and Hamnett’s, ‘improvement of practice’). Implicit in all of these objectives is the almost subliminal product of comparative analysis which is to make the analyst more aware of the nature of their own system and to question its practices and values; this is a prerequisite of any attempt to evaluate and improve practice and policy as well as to understand the theoretical frameworks and social theories underpinning the system in any given country. As Robert Burns eloquently puts it:

O would some power the gift would gie us,

To see ourselves as others see us

Comparative analysis may provide some of that power.

A final important element in all such comparison is the illumination of the processes which are going on in each country and how the dynamics of not only the social but the economic and political ‘reality’ in each country are driving the evolution of each system. Are the two becoming more similar in the face of emerging similarity in the challenges of the modern world or less similar as different approaches from these are attempted?

Thus in writing the various chapters of this volume, and in particular bringing their conclusions together, the purpose will be to review where and how the following wider objectives might be met:

• Do we have a better understanding of the nature of ‘social reality’ in the two countries?
• Can the conclusions assist those attempting to evaluate and improve planning practice or policy development? The question ‘Which is best?’ might remain unanswered, but a better comprehension of the potential of a different approach might be more clearly articulated.
• Can the work assist, if not in the integration of the two systems, in the development of common approaches to problems which touch both countries?
• Can theoretical analysis and comparative methodology at the various levels, as articulated by McConnel, be advanced by reflection on their structure and purpose?

What do we know about each other?

It could be presumed that the literature available to the student of French planning in the UK or British planning in France is copious and sufficient to provide the basis for mutual comprehension. In effect this is so far, far from the case and although there is a constant series of articles, these are in no way linked in to any cohesive programme of national analysis or comparison.

To begin to build up a comprehensive picture of the French planning system the British reader would find a lack of books in English on the subject and would have to indulge in some eclectic reading to do so. There is almost a dearth of any truly comparative work. Even enormously useful papers such as the analysis of urban policy and the Délégation Interministérielle à la Ville (DIV) by Parkinson and Le Galès (1994) and the South Bank University Occasional Paper by Sebastian Loew (1978), now sadly dated, struggled to answer the comparative questions they posed.

There is thus a rich literature describing the practices in each country for a readership in the other, beginning with the again outdated, Urban France by Ian Scargill (1983). The EU Compendium of Planning Systems (EU 1999), again out of date, has volumes on each member state in all official languages, thus permitting French readers to acquaint themselves with the principles of British planning in French (Nadin) and for UK readers to similarly find a description of the French system (Marcou). Several British books in the field have chapters on French examples, namely Berry and McGreal have a chapter on the Paris property market; Farthing et al. have a chapter on the western regions in both countries in the context of the EU Atlantic Arc; Fraser and Baert have a chapter on the regeneration history of Lille in Urban Regeneration in Europe, Couch et al. (2003), and Le Galès and Mawson (1994) have produced a study of the Contrat de Ville for the Local Government Management Board.

There is an abundance of articles in British journals, particularly European planning studies, with many different contributors on aspects of French planning, but the professional journal of the RTPI seldom features any work of an international nature, the essay on development control systems by Devereux (2002) being an exception.

Much of the practical comparison has emerged from projects within the framework of the EU Inter-Regional programme, from Ia to IIIb, but these usually have a wider multinational context, e.g. Living in Towns (Fraser et al.) Urban Regeneration Network (Agence de Développement de Lille Métropole).

There is a considerable literature in the field of housing where the nature of the French system is often compared with that of the UK or good descriptions in English of the French system for British readers can be obtained. The works by Klienmann (1996), Ball et al. (1988), McCrone and Stephens (1995) and Power (1993), etc. all give good material which contributes to better understanding of housing management in the French system and how it varies from that of the UK. Wilmott and Murie (1988) provided one of the first real comparative efforts with their study of Polarisation and Social Housing: The British and French Experience, a study still of contemporary relevance.

For the French reader there is equally an eclectic collection of essays on various topics. Over the years the Association des Études Foncières (ADEF) in Paris has conducted a series of seminars and published the results of these, as well as other pieces of research, most of which contain some description of British practice and reflection from a French point of view upon it. A major work is that of Vincent Renard and Thierry Vilmin (1990), who examine British land law in the series Politiques Foncières Comparées – Grande Bretagne. A further volume on land availability contains a chapter by Barry Redding and Sebastian Loew, on planning gain. A major comparison is that by Le Galès on urban policy (1993) and a recent major work by Breuillard focuses on local administration (2000). Other notable works are by Grive (1998) looking at a specific local planning system in Shepway, Kent and by the Faculty of Law at the University of Dijon (Fromont 1996). A study of the transport system in the UK has also been undertaken by CETUR, the Centre d’Études de Transports Urbains in Paris.

What conclusions have been derived from this considerable body of literature? The recipients of the information can be divided into two camps, those in planning practice and those engaged in academic analysis or some other form of theoretical analysis for its own sake. From the above it can be seen that most of the work is derived from academic study and very little from practitioners seeking new practice or policy initiatives. Only Wilmott and Murie in the housing field had an effect directly into British practice in that their review of the HLM system was a direct contributor to the shift of the housing management model in the UK from ‘council’ housing to the current mix of housing associations and companies. In France, the analysis of British housing policy is notable by its absence, chapters in twin volumes on the housing systems of the, then, 15 EU member states by Ghékiere (1991) being the outstanding exception.

From this selection it can be seen that the literature relating to planning, as we have tried to define it, is restricted and the reader seeking enlightenment must delve into the fields of law, government, housing and European policy to extend their knowledge. There do not appear to be any resoundingly conclusive works and therefore there remains a great deal still to be examined if useful progress is to be made in furthering mutual comprehension. This work is not therefore the last word in Franco-British comparative studies but in reality the first word as it sets out for the fi rst time to knit together a series of essays which each attempt to compare an aspect of the two systems of planning and land management.

Issues to be examined

Many of the authors contributing to this volume have contributed to this body of literature but consider that there is still some way to go if a profound comprehension is to be achieved; other contributors are beginning their careers and need a more defined context within which their work can be fitted if it is to enhance wider understanding and not merely be yet more eclectic articles, theses or book chapters.

The issues discussed in a more profound way in this volume arise from the interests and concerns of the authors and the Franco-British Planning Study Group (FBPSG) in general. As a result of the diversity of that membership and its widespread geographic distribution this makes for a very comprehensive coverage of contemporary concerns. However a major objective of the volume must be to ensure that there is some focus to the work and that it helps establish a framework for further research and analysis and moves beyond being a collection of eclectic essays.

The first question which presents itself is defining what the ‘social reality’ is in both countries and how the contemporary evolution of society, demographic, social and geographic varies, or does not vary, between the two. The impact of these changes allied to the evolution of the domestic economies of both countries has a profound impact on the objectives and processes of their planning systems as they grapple with new problems from social alienation at a local level to the effects of economic ‘globalisation’ at the national. Whilst the debates on planning tend in both countries to be urban oriented it is clear that the profound changes in the agricultural sector and in the use and purpose of the ‘countryside’ pose a grave threat to the rural economy and to rural society and are an equal constituent of the contemporary ‘social reality’. The nature of these phenomena in both countries will be explored in Chapter 2 by Stuart Farthing and Jean-Paul Carrière.

A primary point of comparison is the discussion of the legitimacy, the legal justification for public intervention in the rights in land of individuals; the fundamental legal foundation upon which the planning system in both countries is based. The balance of private and public rights is the stuff of planning law debates and a critical comparison is intended to take the reader into the differences between the clearly legal codes of the French judicial system and the more evolutionary pragmatic processes of the UK: in essence to one country where constitutional underpinning is the norm for everything and one where such encoded rigidities are viewed as brakes to social and economic evolution. These issues were debated at one of the group seminars in Lille and the issues raised there are the foundation for Chapter 3 which deals with specific aspects of the two systems by Matthieu Galey and Philip Booth.

Clearly the many changes in the social and economic structures have influenced the two systems and this has been reflected in significant recent amendments to their planning systems. The enactment of the Loi 2000 relative à la Solidarité et au Renouvellement Urbains, SRU 2000 in France is paralleled by the Planning and Compensation Act 2004 in England and Wales. A major debate which has been engendered is whether these developments signal a turning point, in the evolution of planning, taking them in a common direction in both countries. To British readers does this signify that planning is no longer at the crossroads but has at last struck out in a clear new direction from it? The d...

Table of contents

• Cover Page
• Spatial Planning Systems of Britain and France
• Title Page
• Copyright Page
• Contributors
• Foreword
• Preface
• Abbreviations and acronyms
• Chapter 1: The purpose and process of comparing British and French planning
• Chapter 2: Contemporary urban and regional changes and policy problems
• Chapter 3: Land law, land markets and planning
• Chapter 4: Institutional frameworks and planning processes
• Chapter 5: Actors and instruments in the planning systems
• Chapter 6: Strategic spatial planning at the metropolitan level: The cases of Manchester and Lyon
• Chapter 7: Examining the relationship between transnational and national spatial planning: French and British spatial planning and the European spatial development perspective
• Chapter 8: Policy for small towns in rural areas
• Chapter 9: The evolution of urban policy
• Chapter 10: The financing of development
• Chapter 11: Public-private partnership in urban regeneration
• Chapter 12: Public transport in cities and regions: Facing an uncertain future?
• Chapter 13: So near, yet so far