Amendments to the general regulation plan (GPR) - when urban planning becomes an instrument of space privatization

Amendments to the General Regulation Plan (GRP) of Belgrade represent another step in the long-term process in which urban planning is moving away from the general interest and becoming an instrument that primarily serves private actors. Although these interventions are formally presented as technical corrections, they essentially introduce a structural change in the spatial management regime and enable the further seizure of public goods in the city. The fact that changes and additions to this plan have been ongoing for six years clearly indicates a systematic approach to destabilizing the planning system, through a series of partial and arbitrary interventions.

Key change - Introduction of "flexibility" in the protection of public spaces and facilities 

The core of the current proposed changes relates to the part of the plan that defines "Compatibility of uses". The following provision is proposed: "Conversion of areas for public purposes (traffic areas, areas for infrastructural facilities and complexes, communal areas, public green areas and forests, facilities and complexes of public services and areas for sports facilities and complexes) into areas for other purposes is allowed only by drawing up a detailed regulation plan, with the consent of the competent institutions." 

The proposed provision would enable any public purpose (which includes schools, kindergartens, health centers, hospitals, universities, institutes, social welfare services, public green areas, forests, traffic areas, communal infrastructure and its accompanying facilities, etc.) to be changed to any other commercial (private) purpose (such as housing, commercial facilities, economic zones, etc.) by drawing up a detailed regulation plan (PDR), only with the consent of the competent institutions. 

Although this formulation is presented as a technical detail, it represents a radical instrument of planning deregulation, because it abolishes a kind of protection against the privatization of public purposes and spaces in the planning system. 

Also, deciding on the purpose (and then the ownership status) of the land is moved from a higher level of planning that looks at the whole city, to a lower level of planning, that is, to detailed regulation plans that partially look at the space. In this way, space is opened for ad hoc decisions and reshaping of the city in accordance with the short-term interests of investors.
In essence, this footnote introduces a permanent exception to the rule - the possibility for any public space to be repurposed, without clear criteria, standards or analysis. It is a form of "flexibility" that suits private actors and that renders the existence of a spatial planning system meaningless. 

Public land and facilities at risk - what can be privatized

All public purposes are directly threatened - educational facilities (kindergartens, schools, faculties...), health care facilities (ambulances, health centers, hospitals), social protection facilities (homes for neglected children, drop-in centers, centers for social work...), cultural facilities, traffic infrastructure, communal infrastructure facilities, sports fields and public sports centers, public green areas (parks, riverbanks, greenery in residential blocks, etc.), as well as city forests. 

By abolishing the protection of public purposes in the PGR, it is possible to legally prepare public land, which cannot be sold as long as it is defined as a public purpose, for privatization by drawing up a detailed regulation plan. Conversion precedes sale, and sale opens space for the construction of contents that bring the greatest profit, regardless of the needs of the local population or the development priorities of the city.

After the proposed amendments to the PGR would be adopted, hundreds of investors would have the wind behind them to initiate the conversion of all the above-mentioned public purposes in their plans, followed by the intention to buy those plots from the city afterwards. All that is needed for the conversion to take place is the approval of the City of Belgrade Planning Commission, which is not a stranger to such decisions, nor does it hesitate about them. And that's why, when the question is asked "what is at risk of conversion and privatization" - the answer is everything. 

Every piece of land in the city's public property, whether it already has a public facility or represents land on which a public facility should be built, as well as every piece of public greenery in the city, including city forests. 

It is unacceptable that the city has a general regulation plan, which, instead of regulating construction and protecting and improving public spaces and facilities for the needs of its residents, actually represents a kind of catalog for the sale of public land and facilities! 

Consequences - what kind of city will we live in then

The consequences of the free repurposing of public purposes with detailed regulation plans are extremely serious, dangerous and long-term! Belgrade already has only 9% of public green areas, which is far below the recommendations for cities of this size and density. With the further repurposing of public green areas and forests, which is made possible by these changes to the PGR, and which would intensify the already present trend of rapid reduction of public green areas in the city, Belgrade could very quickly drop to smaller percentages. The scenario in which Belgrade has 3% of public green areas and forests, although it sounds apocalyptic, becomes very certain if the abolition of all forms of planning regulation and space protection were to continue. 

Also, if the city sells off the remaining reserves of public land, it will become impossible to provide new schools, kindergartens, health facilities and other public services. Thus, the basic capacity and resource of the city, necessary for planning its development and for enabling its inhabitants to achieve and fulfill their basic needs, disappears. If there is no more public land for public health and education facilities, then complete privatization of health and education is a certain scenario.

A city where decisions are made ad hoc, through fragmented and investor-initiated plans, land is privatized, and greenery disappears completely, becomes a city of permanent spatial inequality and institutional weakness, but also a city full of risks to public health and citizens' well-being. In such a city, all the harmful consequences are suffered by the inhabitants, while a handful of individuals profit. 

We must not consider such an urbanization scenario as some accidental deviation, but understand it as a direct consequence of the long-term and thorough establishment of a neoliberal-authoritarian planning regime in which "planning flexibility" serves as a mechanism for dismantling the public interest and facilitating privatization, i.e. grabbing public land. According to this planning logic, which is further strengthened by these changes, Belgrade will become a city where there is no place for people, an extremely hostile environment for life, in which some of us will survive, and some will not even be able to do that. 

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What we protest and fight against refers to the idea that the development of the city should be based on the complete privatization of public land and public buildings within the coupling of economic and political elites that crush the institutional and legal systems under themselves - and then also to the attempt to legitimize such spatial policies with proposed changes to the plan. 

Therefore, the request to reject the proposed amendments to the PGR is also a request to establish a planning system in which public purposes are permanently protected, strategic planning becomes binding, and decisions on the use of space are based on analytical criteria — instead of ad hoc interventions. 

It is a request to establish a planning system in which decisions on the use of space are made through transparent procedures, with mandatory analyzes of public needs, availability of data, limiting the discretionary powers of the Planning Commission and mandatory involvement of the professional and local community in the early stages of the process. As well as that space management guarantees the long-term availability of public services in all parts of Belgrade. 

The current plan of general regulation cannot meet these requirements, much less the proposed changes. That is why it is necessary to reject them and develop a plan that is not flexible towards investors and rigid towards the needs of citizens, but vice versa.