Interview: David Burney & Nancy Levinson
An Interview with David Burney: On New York and the 21st-Century City-State
David Burney [Image courtesy of NYC Department of Design and Construction]
In 2004 David Burney was appointed Commissioner of the New York City Department of Design and Construction in New York City. In that capacity he oversees a staff of almost 1,200, charged with managing capital projects for multiple city agencies and cultural institutions in all five boroughs; in 2006, to ensure the quality of municipal public works, he launched the DDC's Design and Construction Excellence Initiative. Previously Burney was director of design at the NYC Housing Authority, and before that, he practiced architecture with the firm Davis Brody Bond. Born in Liverpool and educated in London and Edinburgh, Burney arrived in New York City in 1982, in retrospect a dramatically different era, when the city was still emerging from the fiscal calamities of the 1970s and struggling with rising crime and declining population. As a public servant in his adopted city, Burney has received many honors, including the Thomas Jefferson Award for Public Architecture, from the AIA, and a Sloane Public Service Award, from the Fund for New York City. As the city prepares for a new administration — this November New York will elect a new mayor to succeed Michael Bloomberg — Places Editor Nancy Levinson interviewed Burney about the urban design record of the Bloomberg years, focusing especially on PlaNYC and the ongoing post-Sandy recovery effort — and on the potential for cities to take the lead in 21st-century sustainability planning. Nancy Levinson:
As an urban designer who has worked for years in the public sector in New York City — and as a Brit who is now a U.S. citizen — what is your assessment of the current political scene? What are the key challenges for cities in these tumultuous times? David Burney
: There's a growing consensus that this is one of the most dysfunctional eras ever in American politics, and I'd have to agree. The federal government seems paralyzed not only by the impasse between Democrats and Republicans but still more by the internal politics of the GOP. The anti-government ideologues have hijacked the legislative process to the point where it's hard to expect leadership from Washington — and certainly not on much-needed investment in the country's declining infrastructure. At the state level it doesn't seem much better. So increasingly it's been our cities that have taken the lead on critical issues, from gun control to immigration reform to economic stimulus to climate change.
Given the migration of people into cities worldwide, this trend is sure to continue. We might even be in a de facto transition to a society dominated by economically and politically powerful cities — a contemporary version of the great city-states that arose in the 13th century and ruled Europe until the consolidation of modern nation-states a few centuries later.
Here in the United States, the federal government remains strong, but its authority is being eroded by the polarization of the political parties, and also by an extremely unproductive debate about taxation. It's an old story: we hate paying taxes but we value the services that taxes support. But the real issue goes deeper — it's no exaggeration to say that civilization depends on the proposition that we all do much better when we work not just individually but also collectively, and that we need to balance personal freedom with common interest. In other words, if we all contribute to the common good — the commonwealth
— then it will be there for us when we need it, whether in the extreme case of post-disaster assistance or the more everyday matters of affordable housing and healthcare and reliable civic infrastructure. New York City [Image: Penn State University]
This idea of common good is the basis of the modern concept of progressive taxation, in which each citizen contributes according to his or her ability, and our elected leaders determine the best collective use for the revenue. What's more, it is the most technologically and culturally advanced societies that adhere most strongly to this concept of collective revenue and spending. Think about Scandinavia and what's come to be called the Nordic model
, in which high government investment in education, health care and social services has helped to produce national stability and prosperity for decades.
Of course, the United States of America continues to resist this model. Maybe this is because America is still, after all, a relatively young country, born in reaction to the oppressive constraints of its European colonizer-ruler — which accounts, I think, for the libertarian tendencies that inform the U.S. Constitution and persist in the national psyche. Live Free Or Die
. Don't Tread On Me
: These slogans date back to the Revolutionary War, and they're still rallying cries! The original Tea Party was an act of resistance to a British tax in 1773. But the disparity between the U.S. and Europe is also a legacy of World War II: the devastation of Europe was so profound that recovery could only be financed and executed by strong national governments, entrusted with the power to borrow huge sums and marshal the necessary resources. In the postwar decades, European nations invested in major housing programs, in single-payer healthcare systems, in social security plans that protected the poor.
The U.S. has never confronted the need for such massive reconstruction. The closest parallel remains the Great Depression, which produced the New Deal programs of the 1930s, which in turn inspired the Great Society of the '60s; and today those legacies — the monumental public works of the WPA, the protections of Social Security, Medicare, Medicaid, et al. — are being steadily dismantled in the wake of the Reagan Revolution and the 21st-century Tea Party. From a European perspective, and from my personal perspective as a Brit who has lived in New York for three decades, this trend seems absurdly retrograde. But I do think that we have now arrived — as we realize with increasing urgency
— at a moment when our politics must change if the U.S. is to retain its status as a democratic role model and if we are to solve the problems that confront us in the 21st Century. Top: NYC Mayor Michael R. Bloomberg, addressing the UN General Assembly, February 2008. [Image courtesy of the United Nations] Bottom: Promotion for Climate Week NYC, 2011. [Image courtesy of climateweeknyc2011.org]
: What do you think is driving this new sense of urgency? David Burney
: I think it's arising from three large-scale phenomena. First, there is the aging infrastructure
that supports our prosperity and needs significant reinvestment; then there are the multiplying effects of climate change that threaten our environment and ultimately our survival; and finally there is the increasing migration to cities and the need to ensure the quality of life that cities can provide. The only entity that can respond effectively to these unstoppable forces is government. Repairing transportation, water and power systems; adapting cities to rising seas or persistent drought; ensuring access to housing
and services for rapidly rising populations — all these require such intensive and sustained capital investment, and affect the lives of so many people, that they cannot be left to the volatile forces of the market.
In Europe, attempts to privatize infrastructure have been notably unsuccessful. In England, for instance, the de-nationalization of railway agencies
and water supply
has resulted in poor service and loss of public confidence. Here in the U.S. the much-vaunted "public-private partnership" method of financing civic infrastructure often proves more costly to the taxpayer than direct government investment; which isn't surprising, since the profit for the private financier is always structured into the partnership
And again, at the federal level, there seems a real lack of will to address these issues — to face the political challenges and fight for what's needed, for initiatives equal in scale and vision to the New Deal. It's been more than a quarter century since James Hansen testified to Congress about the threat of climate change, but we have yet to craft a coherent or vigorous response. Look at the U.S. refusal to sign the Kyoto Protocol, back in the '90s, or to take decisive action in Copenhagen, early in Obama's first term; and it's still not clear whether the re-elected president will summon the political will to stop the Keystone-XL Pipeline
So it is cities that have taken up the challenge. To be sure, cities have real advantages. With respect to climate change, for instance, urban densities allow for efficient land use
and extensive public transit; as a result, urbanites use less energy
and account for less CO2 than their suburban counterparts. And many cities enjoy the benefits of robust governance, with more direct executive administration than is possible in the broader sphere of national politics. More generally, I think the loss of confidence in national leadership was bound to spur local action. And to some extent this might also a reaction to globalization, which can erode local control if it's not balanced by strong efforts at the city level. PlaNYC documents. [Cover images courtesy of nyc.gov]
: Let's focus on climate change, which in the aftermath of superstorm Sandy, a week before the presidential election, roared back onto the political agenda. In 2007 New York City adopted PlaNYC 2030, an ambitious effort "to prepare the city for one million more residents, strengthen our economy, combat climate change, and enhance the quality of life for all New Yorkers
." To what extent was the city motivated by the lack of national policy or action? David Burney
: Mayor Bloomberg launched PlaNYC
on Earth Day, April 2007 — and yes, right from the start it was intended to establish the city as a global leader in sustainability planning
. It's not surprising, when you recall that Michael Bloomberg built his private sector career in information management; Bloomberg L.P. is a data and media company, and from the beginning, his city administration was driven by data. So given the projection that New York City will add one million new residents over the next three decades, and given the need to maintain the quality of urban life in order to retain and attract talented people and remain a world leader, then the challenges were clear. PlaNYC, with its many initiatives, was largely a response to the question: how can the city plan for growth?
PlaNYC considered the fact that all cities depend crucially upon infrastructure, and that construction and maintenance of infrastructure is a big driver of standards and policies. More specifically, we see urban infrastructure in terms of hard
infrastructure — systems for water, energy, waste and transportation, and networks of buildings, parks and open spaces — and soft
infrastructure — institutions and programs that promote education, culture and recreation, and influence quality-of-life issues such as crime rates, health factors, and so on.
New York is fortunate to have relatively reliable hard infrastructure. There is a mature legacy of good buildings and landscapes that's being replenished with new architecture and parks. There is an extensive system of roads and mass transit, including the subway and bus networks. The freshwater catchment areas north and west of the city — including the Croton Reservoir, which dates to the mid 19th century — provide an abundant and stable water supply, although this system is now under threat from land development and, possibly, from natural gas exploration — fracking
— near the watersheds. Despite occasional brownouts in the thick of summer, municipal energy production has kept pace with consumption. And the city's waste-treatment system functions adequately, at least in dry weather; unfortunately during big rainstorms it overloads and dumps sewage into the rivers.
But a city with only hard infrastructure would be an empty city. Soft infrastructures are fundamental to quality of life — to low crime rates and safe streets, to accessible health options, to high-performing schools, to cultural and recreational opportunities like museums, symphonies, professional sports, etc.
For some cities the challenge is to build and provide these hard and soft infrastructures. For New York the challenge is to maintain and improve them — and in the process make a more sustainable city. So PlaNYC is the result of this basic recognition. The original 156-page document comprised 127 policy initiatives designed to shape the future of the city by 2030, and to allow for the population to increase from 8 to 9 million; the 2011 update added a few more initiatives. The initiatives were grouped into categories that broadly parallel the hard infrastructure types: housing, open space, brownfields, water quality, water network, congestion, energy, air quality and climate change. Times Squares, Manhattan, before and after implementation of the NYC DOT Plaza Program. [Image courtesy of NYC Department of Transportation]
: PlaNYC sets really big goals — to build affordable housing and public parks, protect watersheds, remediate brownfields, achieve "the cleanest air" of any big U.S. city, reduce greenhouse gas emissions 30 percent by 2030, to note just a few. How would you assess the progress to date? David Burney
: Yes, the goals are big! They are also often long-range, so there's no simple way to answer the question about progress to date. But you can track the progress in some detail on the PlaNYC website
In my view, one important achievement has been the steady transformation of public space both in the streets and on the waterfront. For a long time New York has been associated with the skyscraper, and with the sheer density of its population. Yet public space was something of an afterthought — usually just the space left over between buildings — and the street grid was dominated by the car. In fact, most of the space of city streets — 89 percent — was devoted to the car. There wasn't much left for pedestrians, and cyclists were hardly in the picture at all. So during the past decade, the Department of Transportation, under Commissioner Janette Sadik-Khan, has implemented a “Complete Streets” policy, with the goal of giving the pedestrian and the cyclist equal rights with motor vehicles. By expanding the width of sidewalks and creating new plazas, and by creating an extensive network of bike lanes, the NYC DOT has made the streets more walkable and bikeable; the city is a more enjoyable experience. You can see this in Times Square, where closing Broadway to automobile traffic from 42nd Street to 47th Street produced five new public plazas, which immediately filled with people. The traffic closure has been temporary; this year it will be made permanent, with a new design by the design firm Snøhetta
The transformation of the waterfront has been equally significant. Historically the waterfronts were working zones — the industrial doorstep to the city — but now these old uses are giving way. One of PlaNYC's goals is to create a contiguous and publicly accessible waterfront along the Hudson and East Rivers and the harbor. This is, of course, a very
long-term project, much of which will not be seen in my lifetime. But lately there has been measurable progress along the riverfronts; I'm thinking, for instance, of the East River Park Esplanade and the Hudson River Park. The new Brooklyn Bridge Park
has transformed the industrial waterfront from Brooklyn Bridge to Atlantic Avenue. Top left: East River Esplanade. [Image: courtesy of Reimagine the Waterfront]. Top right: Hudson River Park [Image: courtesy of Hudson River Park]. Bottom: New bicycle lanes in Manhattan, looking north across Canal Street. [Photograph by Gnarly, courtesy of Wikimedia Commons]
These are major initiatives and highly visible — and often controversial! Just look at the battle over the bike lanes
. But many PlaNYC goals are less visible. For instance, to ensure the long-term viability of our water supply, the NYC Department of Environmental Protection has spent several decades building a new water tunnel — the third, and first to be constructed since the 1930s — that will bring water from the Croton Reservoir and allow one of the two existing tunnels to be taken offline and repaired. It's a huge work of infrastructure: The new "Tunnel 3
" is some 600 feet below street level and will stretch 60 miles. This spring the distribution mains that bring water to the surface and carry it to individual buildings were completed, and the tunnel will be put into service this summer. All of this infrastructure will be largely invisible
to most New Yorkers, but its importance cannot be overestimated.
And then there are small-scale projects, such as the “Million Trees
” campaign. Ultimately this involves every neighborhood in all five boroughs, and will take many years to implement (at last count we've planted around 660,000 new trees). The goal here — besides the beauty of urban greenery — is to contribute to better air quality and reduce the heat index.
But beyond the individual initiatives, what's been critical to the success of PlaNYC is the governance framework of the city. New York has a “strong mayor” system, which means that significant executive authority resides with the Mayor’s Office, and in my view that has made the crucial difference. Many PlaNYC projects are challenging not only professionally but bureaucratically: they are large, systemic environmental and building projects that require the coordinated efforts of multiple city agencies and jurisdictions and sometimes also of external, private entities.
Here's an example. Stormwater management isn't the sexiest city infrastructure — bike lanes and urban agriculture are a lot more photogenic — but it's vital to urban health, as we saw last fall, during Sandy. New York's stormwater management functions as a "combined" system: rainwater drainage combines with blackwater sewers and both then lead to water treatment plants. But the treatment plants cannot manage the volume of water generated during heavy — or even moderate — rainfall; so to prevent overload at the plants, there are overflow mechanisms that allow the rainwater/blackwater to flow into the rivers during a storm. But these so-called “combined-sewer-overflows" can raise the bacterial content of the rivers to levels that endanger public health. To address this, the city has rehabilitated an existing detention tank, at Spring Creek, and built new facilities at Flushing Bay and Alley Creek, in Queens, and at Paerdegat Basin, in Brooklyn
. Still, the cost and logistics are prodigious, and even with adequate funding, it is politically difficult to site treatment plants, and construction takes years. So another solution is to separate the systems and let the rainwater flow directly into the rivers. Which sounds great; but with thousands of miles of rainwater sewers this, too, turns out to be a long-term proposition.
In response, PlaNYC envisions a more “upstream” approach: preventing rainwater from entering the drainage system in the first place, rather than on handling it at the treatment plants. There are various ways to do this. At the scale of architecture, you can mandate that buildings feature rainwater-retention systems. At the scale of landscape, you can construct bioswales and tree-pits that absorb rainwater, retrofit parking lots with permeable pavement, and increase the city's "bluebelt" network of coastal wetlands, just to name a few. (You can read more in the city's Sustainable Stormwater Management Plan
.) In other words, PlaNYC proposes a range of green infrastructure that together optimize the grey infrastructure of the sewage and treatment systems. Top: Paerdegat Basin CSO Facility. [Photograph courtesy of NYC Department of Environmental Protection] Middle: New York City Water Tunnel No. 3. [Photograph: courtesy of NYC Department of Environmental Protection] Bottom: Bluebelt, Staten Island [Photograph: courtesy of NYC Department of Environmental Protection]
Now as you can imagine, the implementation is complicated. It requires coordinating the policies and actions of the Department of Environmental Protection, which manages the waste and water systems; the Department of Transportation, which manages the roads and sidewalks; the Parks Department, which manages the trees and bioswales; and the Department of Buildings, which ensures new construction complies with water retention requirements. Usually it is the Department of Design and Construction (DDC) that designs and builds all the systems, and to do this we've got to reconcile the budgets of collaborating agencies in order to fund and obtain approvals for construction plans. And then, of course, all the agencies remain involved throughout construction and beyond.
And that's just for the stormwater goal! But no matter the system, what makes a huge difference is that the agency heads all report to the same boss — the mayor. Without a strong mayor system, PlaNYC would have been a great document, but implementing it would have been extremely difficult.
Not surprisingly, the organizational chart of New York City
is complex. In fact, Mayor Bloomberg created a special agency — the Office of Long-term Planning and Sustainability — in order to create PlaNYC and coordinate its implementation. But as the org chart shows, the mayor has direct control over the agencies and the 300,000 city employees responsible for the plan. There is a legislative body, the City Council, and each of the five boroughs has its own president. Nonetheless, real power resides with the executive branch. Contrast New York with Los Angeles, which has a “weak mayor” system in which planning authority is distributed among the counties, with relatively little central planning or control. It's much harder to make things happen. Nancy Levinson
: But can the goals of PlaNYC be achieved if the projects do not take in the regional scale? Isn't that one of the hard lessons of Sandy? In other words, can New York become a truly sustainable city in the midst of an unsustainable region or nation? David Burney
: That's a very real concern. Large as it is, the city is only the city. It's estimated that the immediate repair costs of superstorm Sandy will reach $60 billion
, which is equal to the entire annual budget of New York City. Clearly the infrastructural challenges demand engagement across sectors, at the state and federal as well as municipal levels.
Given the political atmosphere — earlier this year we saw Congressional stalemate lead to the automatic sequester cuts —it's tempting to look to public-private partnerships. But even if private capital could be secured — and setting aside the problems of such partnerships, which I noted above — the question of governance remains crucial.
Here's a recent example of flawed multi-jurisdictional governance in New York. In 2008, New York City proposed congestion pricing for Manhattan's business districts. By charging vehicles a fee — and thus reducing the numbers of cars— the measure was intended to ease traffic, improve air quality, promote public transit and generate revenue. It seemed like a win-win; it's been used successfully in London since 2003, and it requires very little public investment. But — because of arcane rules that give the state jurisdiction over some city streets — it did require approval from the New York State Assembly. And as it happened, the Assembly wasn't even able to bring it up for a vote, providing yet more evidence that it is one of the world's most dysfunctional bodies.
Another and even more dramatic example involved the cancellation of the Trans-Hudson Passenger Rail Tunnel
by New Jersey Governor Chris Christie. Here's a project that was widely acknowledged as essential infrastructure for the entire region. It had been in the works for two decades, billions of dollars had been committed, ground had been broken in 2009. But in the fall of 2010 Christie summarily stopped the project, citing the possibility of cost overruns; which not surprisingly, proved to be unfounded
. Brooklyn Bridge Park, master plan/composite aerial, Michael Van Valkenburgh Associates. [Image: Courtesy of Michael Van Valkenburgh Associates]
In contrast, two New York City park projects — Brooklyn Bridge Park and Governor's Island — have proceeded smoothly largely as a result of being wrested away from the jurisdiction of New York State. The first parts of Brooklyn Bridge Park, on a formerly industrial waterfront, opened in 2010, and construction of the park on Governors Island
, which had been stalled for years, has actually started.
Not that New York City’s governance is perfect. The Bloomberg administration prides itself on bringing a managerial mentality to municipal bureaucracy, but there remain obstacles to organizational efficiency and timely decision-making. With respect to infrastructure and public works, for instance, the subdivision of responsibilities — which you see codified in that org chart — can cause conflicts. For example, the Department of Environmental Protection is responsible for city water and sewer. The Department of Transportation is responsible for upkeep of city roads. Each department has its own budget and does its own capital planning, and each replaces its infrastructure roughly on the basis of age and condition. But there's a problem here: the water and sewer mains run underneath the roads — and the two systems deteriorate at very different rates. Which meant that the DEP often needed to dig up the DOT's perfectly good city streets to replace aging pipes. It was this kind of internal contradiction that led to the creation of the DDC, back in 1996.
Since then the situation has improved, but even now city government can be unwieldy, with too little coordination among the City Planning, Transportation and Parks Departments, and too little interaction between the Department of Design and Construction and either the Office of Long-term Planning and Sustainability (again, responsible for PlaNYC) or the Office of Capital Project Development (which expedites projects favored by the Mayor's Office). And so on. Some city think tanks have proposed the creation of a Deputy Mayor for Infrastructure as a way to centralize these various activities.
Nevertheless, it seems clear that cities with strong mayor systems are much better at getting projects done, that decision-making at the city level is less complicated and politically fraught than at either the state or federal level. Recently, at a panel sponsored by the Forum for Urban Design
, former Mayors Richard Daley, of Chicago, and Manny Diaz, of Miami expounded on the advantages of greater authority for cities. They didn't broach home rule, in a legal sense, but they emphasized their accomplishments at the urban level. Diaz has just published a book that does the same
. One can imagine a network of contemporary city-states that together might accomplish a great deal. Cities could collaborate on a range of issues and combine their collective economic strength, along the lines of the medieval Hanseatic League. Look at the C40 Cities Climate Leadership Group
, a global consortium of major cities which for more than half a dozen years has been not only advocating for progressive climate change policies but also setting standards to guide the way. Since 2010 Michael Bloomberg has been chair. Nancy Levinson
: Superstorm Sandy revealed how much remains to be done to make New York — and the metro region — truly sustainable. What are the next big challenges of PlaNYC? And given the likelihood of more big storms, and rising sea levels, what are the most significant initiatives being evaluated? Which seem likely to be realized? David Burney
: In the past few months several studies and reports have appeared that address this very question of policy, post-Sandy. New York State published a preliminary Bi-Partisan Task Force Report
; the New York Chapter of the AIA has published its own initiative
; New York City has just issued its "After Action
" report and recommendations. Other city organizations, including the Municipal Arts Society and the Regional Plan Association, are expected to produce their own assessments.
This flood (if that’s the right metaphor) of documents is by necessity fairly high level; there simply hasn’t been time to study every affected area in detail. The recommendations can be roughly divided into two types: a) deciding where it makes sense to rebuild and where it doesn’t; and b) how rebuilding should be done to ensure resilience. Recently FEMA published new flood maps
that provide some guidance in the aftermath of Sandy, where inundation far exceeded the levels shown on earlier FEMA flood maps.
One result of the new mapping is a dramatic increase in the cost of flood insurance within the so-called “V” zones, which will experience "high velocity wave action," or storm surges. In response, it's likely that city building and zoning regulations will be modified to require higher building elevations in high-risk areas. Together the expensive flood insurance and the new construction standards are likely to deter rebuilding in the V-zones areas; they might also encourage owners of damaged property to accept government buyouts. Which in turn would make it possible to treat these areas — mostly along the shoreline — as defensive barriers, rebuilding them as dunes or as vegetated wetlands that would help absorb the energy of storm surges. U.S. Coast Guard supervising the removal of debris from the New York City coastline in the aftermath of Hurricane Sandy. [Photograph: courtesy of U.S. Coast Guard]
But some shoreline communities are determined to remain, and the Mayor has stated publicly that these communities will not be abandoned. In these areas — the Far Rockaways in Queens, for example — new construction can be built above flood elevations with water-sensitive equipment — such as electrical panels and boilers — located on upper floors rather than in basements. A design competition has been jointly sponsored by the NYC Department of Housing Preservation and Development and the AIA NY Chapter to explore strategies for a resilient and sustainable development on an 80-acre site in the Rockaway Peninsula
. The city is rebuilding lifeguard and comfort stations at the major public beaches
, with the goal of resisting future storm surges. In fact, some of the newer housing in Far Rockaway fared far better during Sandy because it was already designed with those principles. The city, along with FEMA and the Army Corp of Engineers, is looking into constructing dunes as storm barriers. In parts of Long Island where they were already built, these proved effective during Sandy.
Perhaps the most difficult problem to solve is how to make existing
buildings and infrastructure more resilient. Clearly in the areas that were most affected by the storm, mechanical and electrical equipment needs to be relocated from basements to higher levels above flood elevations. Power stations, waste treatment plants, subway tunnels, hospitals — all need to be reinforced to survive the anticipated flood levels. Nancy Levinson
: Given that Mayor Bloomberg is in his final few months, are you concerned about the future of PlaNYC? David Burney
: Yes, the uncertainties of a new administration are always a cause for concern — especially in a strong mayor system where change can be sudden and broad. This may be even more pronounced given the continuity of Michael Bloomberg's three terms. On the other hand, to the extent that the Bloomberg policies have been successful, I don’t expect to see a new mayor rush to make changes. If there is a concern among the planning and design community, it's that the Bloomberg focus on the quality of urban life might not be sustained. With Patti Harris as First Deputy Mayor, the city government placed great emphasis on urban issues, and several agencies — notably the City Planning Department, the Landmark Preservation Commission, the Department of Design and Construction and the Public Design Commission — were all concerned with the design quality of public works. Some city policy groups, including the AIA and the Municipal Arts Society, are already lobbying mayoral candidates in the hope of securing commitments to continue this approach.
My own feeling, which might be optimistic, is that heightened public
awareness of urban design issues will carry over into any new administration and help sustain the momentum. We may not all agree about where to put the bike lanes — but at least we've all got opinions! And ultimately that is healthy for urban design and planning.