In his first column for BD, New York-based Chris Fogarty assesses the relative merits of the US and UK planning systems

Chris Fogarty Headshot_cropped

Chris Fogarty

Recently, I was traveling with an old college friend who owns an architecture firm in London. After finishing a long and frustrating call with a local planning officer regarding a new housing project, he vented that the UK planning process has led to a general lack of respect for the architectural profession.

When I mentioned that New York has no formal design review process at all for new buildings, he was blown away. It made me wonder: How did we come to have completely different systems for our city planning, and is one better than the other?

In the UK, the 1947 Town and Planning Act nationalised the right to develop land. Planning authorities oversee local development plans which serve as guidelines and inform decision-making in relation to scale and visual impact. Applications are reviewed by the Planning Officer and approved by a Planning Committee.

The US, however, relies on localised zoning, essentially a legal text uniquely written for each town, defining the parameters for development. The first real city zoning started in New York in 1916 and led to the tiered skyscrapers of the Chrysler and Empire State buildings.

Known as single-use zoning, US land use is regulated by type, such as residential, commercial or industrial, and by a prescriptive set of massing criteria, including maximum floor area, bulk, height, setbacks, lot coverage, and density. Unfortunately, the States’ complicated past (and present) with segregation means that zoning restrictions have a long history associated with exclusion, restricting uses to single-family homes and large lots to divide neighborhoods.


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The first real city zoning started in New York in 1916 and led to tiered skyscrapers such as the Empire State building

New York City’s Zoning Resolution is a vast legal document. Within its 4,000 pages, the text (with virtually no illustrations) covers all aspects of the city’s development from single-family homes on Staten Island to the supertall towers of Midtown Manhattan. Obtaining variances for large buildings is all but impossible, so few attempts are made.

Occasionally, landowners can apply to rewrite the zoning text - i.e. changing from industrial to residential use - but the process can take between two to five years with no guarantee of success. Instead, large-scale rezoning is generally led by the city’s planning department.

How does the absence of a review process impact New York’s built environment? Repeat “architect offenders” win projects by undercutting fees and constructing cheap, poorly designed buildings, especially in lower-income neighborhoods. The city is rife with shoddy work, but every now and then, a gem of a building raises the bar for us all.

The quality of the architecture here though really does depend on the architect and the client

Though buildings conform to similar heights and setbacks along a street, they can be wildly different in terms of materials, color, and attention to detail. All that said, somehow in New York, it mostly works. As a functional gridded city, where the whole is greater than its parts, New York seems to revel in its brutal discordance.

In the absence of a formal planning review process, our clients have the final say as to whether a design can move forward. Here, the zoning process allows them to know exactly what can be built on any site before they purchase the land, and from our perspective, planning for the project with respect to its schedule, fees, and staffing is relatively easy to determine. Having a client who values good design and respects their architect is essential.


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Suburban sprawl in Colorado

Does the US system create better architecture than the UK’s? Probably not; it certainly does not result in better-planned cities or towns. No one who has seen the suburban sprawl and its endless creep into rural communities across America can say that the US system yields a better result than the unified planning strategies of the UK.

The quality of the architecture here though really does depend on the architect and the client. Do we get more respect? Maybe. But only when we get it right.

>> Also read: Want to work in the US? The difference is more than just feet and inches