Why don't we abolish planning?

You remember the first episodes of the 15th season of South Park- in which Kyle, agreeing to the user terms of an application without reading it, gets kindapted (the rest of the story is completely irrelevant to this text, but very, very scary)? What on earth does South Park have to do with planning??? Well, the fine print in the documents that shape our individual and collective lives can produce a lot of harmful things if we miss them, and someone is always keeping their fingers crossed that this happens. It is a similar story with the Plan of General Regulation of the City of Belgrade and the effects of only one paragraph (in the plan of a total of 1174 pages) on the plans that are currently happening to us. 

Why is that General Regulation Plan so important to us?

The General Regulation Plan (GRP) is an operational urban plan that is adopted either for the entire territory of a local self-government unit (city or municipality) or for a part of it, that is, a specific spatial entity. Like detailed regulation plans (PDR), the PGR serves as a planning basis for issuing location conditions and building permits. It is logical to ask why we need a PGR at all, if we can produce a planning basis by creating a PDR. However, the purpose of urban planning does not lie only in the mere production of the planning basis. Through the PGR, wider spatial development should be designed and regulated in terms of land use and land management (with a special focus on public land), typology of buildings, regulation, capacity of infrastructure and public services, as well as their spatial distribution, measures to protect the environment and cultural assets. The purpose of the PGR, therefore, should be reflected in the reflection of the overall urban regulation in a certain area, on the basis of which the PDR will be made further, which will include a specific block or a smaller spatial entity. 

However, as construction is currently the most profitable business, any kind of restriction and regulation, even through plans, can be a hindrance. Unfortunately, instead of being a counterweight that represents the interests of all citizens who share the same space, the state agrees to flexibilize regulations in order to reduce resistance to private interests. Flexibility is thus reflected both in terms of quick production of plans (without redundant procedures) and in terms of urban regulations. 

The PGR of the construction area of ​​the city of Belgrade was adopted in 2016. Despite the fact that this plan prescribes the overall urban regulations on the territory of the city on 1174 pages, during the preparation of the PDR, only one paragraph tells us that all those written pages are just a dead letter on paper. This provision states that “When creating a detailed regulation plan, regardless of the zone in which it is being worked on, the provisions, conditions and rules of this Plan are considered orientation and do not require a formal amendment to this Plan. Also, … [planned purposes] they can be changed, through the development of a detailed regulation plan, in cooperation with the competent institutions.” (Official Gazette of the City of Belgrade No. 20/2016, p. 607). Therefore, the city has adopted a regulation, which is not applied at the level of detailed planning and does not actually regulate spatial planning. 

In addition to the fact that the PGR can be implemented through the development of the PDR, another way to implement the provisions of the PGR is through direct implementation. Thus, one part of the sites in the city is planned to be elaborated through the preparation of the PDR, and the other part of the site can be built directly on the basis of the PGR. Okay, so that means that the PGR and its rules only apply to those locations marked for immediate enforcement? Well, not quite. In the chapter related to immediate implementation, it is emphasized that it is possible to create detailed regulation plans for these areas as well. Then follows the provision: "If a detailed regulation plan is being developed in an area that is implemented by direct application of the rules of the general regulation plan (including elements of detailed elaboration), all the provisions from Chapter 2. Areas for which the preparation of detailed regulation plans is mandatory shall be applied." (Official Gazette of the City of Belgrade No. 20/2016, p. 608). Here it is important to remember that in "all the provisions of Chapter 2." includes the provision that the entire PGR is only indicative and not binding.

The question that begs and goes unanswered is what is the point of a higher order plan if it is not mandatory for any location it covers?

Where does housing come from here, when it is not written in the PGR? Or why we need to read small letters when we sign terms of use or do we react to plans

Land uses (housing, public services, green areas, etc.), defined by the General Regulation Plan, which should be further elaborated through a detailed regulation plan or by direct application in the project itself, refer to predominant purpose in that area. Npleasant it also determines construction parameters (such as the maximum number of floors of buildings), as well as whether it is a public or other purpose. Thus, the distribution of uses provided by the PGR, really reflects a complex system of interrelationships between different entities in the city. However, considering the "non-binding" character of the entire PGR, through detailed regulation plans, the initially intended purposes can obviously be completely ignored, as we witness in the most recent plans that are currently on early public and public inspection. 

Take, for example, Detailed regulation plan for Block 66 in New Belgrade – a block surrounded by the railway, the Belville settlement, the new bus station and the commercial zone of block 66a. Currently, a public city transport depot is organized on that area, but the PGR also stipulates that it will remain a public infrastructure and retain its traffic purpose. However, as the PGR is not a binding plan, the initial purposes can be changed through the PDR with the consent of the institution. Considering that they are both the client and the developer of the public service plan, we can only trust them that the Secretariat for Public Transport really voluntarily submitted the initiative to change the purpose of the block (although we did not see the initiative, because it was not attached to the concept plan documentation). Be that as it may, in the proposed solution, the traffic purpose has completely disappeared, and it has been replaced, you guessed it, mostly by zones of mixed centers (combination of profit housing and commercial contents - investors are smiling), although there is also an area for public services and one public green area.

We have a similar case with Detailed regulation plan for the zone of commercial contents north of the Dobanovačko road in Zemun. In the draft plan itself, it is stated that, according to the PGR, it is planned that in addition to public purposes (traffic and infrastructure), there will be other uses - other green areas. But alas, the authors of this PDR read the fine print and neglected the other green areas as the intended predominant purpose and on 32ha provided the economic zone as the only function.

Turn-turn, everything is possible!

In the case of these two specific plans, it is not primarily to open a debate on whether the initial or new purpose is better or worse, but to illustrate how arbitrary the application of the provision on orientation character of the "provisions, conditions and rules of the PGR". Tomorrow, who guarantees that the uses will not change more aggressively and radically, so that they provide even more opportunities for private investments, and even less for public infrastructure?

Unfortunately, it does not end here. The identical disputed provision that we mentioned was added in 2019 through an amendment to the Plan for the General Regulation of the Green Areas System of the City of Belgrade, thus completely rendering this plan meaningless. We are left with the question in which other important plans will he find his place?