The urban architect Víctor García Gil, representing AUG-ARQUITECTOS, SLP, has delivered to the City Council of Buñol (Valencia) Modification number 13 and Modification number 14 of the Subsidiary Norms (NNSS) so that the environmental and territorial evaluation of both instruments can begin. Modification 13 has a structural scope and will be evaluated and approved by the autonomous bodies, while Modification 14 only affects the detailed planning of urban and developable land and will be evaluated and approved by the same city council. Both instruments are complementary and compatible, but completely independent and when they are approved they will mean a radical change of scenario, as far as urban planning in Buñol is concerned.
In its preparation, the Consolidated Text of the planning of Buñol, prepared by AUG-ARQUITECTOS, SLP in 2023 on a highly precise digitalised basis and in accordance with the criteria established in the Instruction for the drafting of CONSOLIDATED TEXTS of general planning approved by the General Directorate of Urban Planning and referred to in ORDER 1/2023, of 13 September, of the Ministry of Environment, Water, Infrastructure and Territory, has been taken as a basis.
Although with the modifications introduced in the Consolidated Text of the Law on Territorial Planning, Urban Planning and Landscape (TRLOTUP), approved by Legislative Decree 1/2021 in recent years, an attempt was made to simplify the processing and final approval of planning modifications, the truth is that any urban planning procedure is still a complex process, especially if the resolution of the evaluation and the final approval are resolved by autonomous bodies, as is the case. This complexity, which entails tensions and an added workload for those responsible for the town hall and for the Administration as a whole, which has to examine a complex instrument and issue a large number of reports, makes it advisable to take advantage of the same urban planning procedure to address different issues. That is, for a question of economy and as long as there is no specific justification that may require processing a Specific Modification of the general planning with a single objective, it is preferable to wait as long as necessary and accumulate a set of corrections, to process them simultaneously. This has been the spirit with which Modification No.13 and Modification No.14 of the NNSS of Buñol began to be addressed from 2022 and these are the reasons that explain the accumulation of several objectives in these two instruments.
This accumulation of objectives therefore responds to a strategy of optimizing public resources, has a perfect legal fit and requires, of course, an orderly presentation of the objectives of each Modification.
On the other hand, it should be noted that, together with the strategic objectives of Modification 13, other collateral objectives have appeared, apparently less important, but with a utility and justification no less notable. These secondary objectives are a direct consequence of the transfer of urban planning determinations to a different and much more precise digital medium than the one used in 1987, when the NNSS were approved. They also respond to an attempt to take advantage of the process to correct deficiencies that were not initially identified, when the city council decided to promote this file, but that have been emerging during the drafting of the M13. We refer to:
In compliance with national and regional planning legislation, a detailed analysis has been made of the degree of urbanisation of the land and the real situation of all the land classified as urban in the NNSS, in order to assign to certain areas a classification more in line with their real situation, that is, changing them from (supposedly) urban land to developable land, articulating for this purpose an urban planning model that resolves the corresponding transfers without compromising the public treasury. This resource is not only inexcusable in a document such as this, but it also corrects an important error that can lead the local Administration to a delicate situation when managing its planning, since this (the current NNSS) orders supposedly urban land, without delimiting areas subject to programming, which leaves public land pending acquisition without an urban planning figure that facilitates this acquisition at no cost to the Administration.
Despite the update and precision improvements introduced in the plans and the transversal scope of this Modification, it has not been intended to adapt all its content (because in that case we would be dealing with another type of instrument), so the changes are still limited in scope, especially as regards the innovations in the Urban Planning Standards.
Modification 13 of the NNSS of Buñol corrects and/or complements the following:
Regarding Modification 14, along with the strategic objectives of the Modification, other collateral objectives have appeared, apparently less important, but with a utility and justification no less notable. These secondary objectives are a direct consequence of the transfer of urban planning determinations to a different and much more precise digital medium than the one used in 1987, when the NNSS were approved. They also respond to an attempt to take advantage of the process to correct deficiencies that were not initially identified when the city council decided to promote this file, but which have been emerging during the drafting of the Modification. We refer to:
Despite the update and precision improvements introduced in the plans and the transversal scope of this Modification, it has not been intended to adapt all its content (because in that case we would be dealing with another type of instrument), so the changes are still limited in scope, especially as regards the innovations in the Urban Planning Standards.
Modification 14 of the NNSS of Buñol corrects and/or complements the following: