"Should Seoul Step Back From Redevelopment of 500-Unit Complexes? The Ultimate Desk-Bound Policy" Urban Scholar Offers Sharp Criticism

[Financial News] There is a very simple way to evaluate a policy: ask where its key number came from. Opinions are divided over the ruling party and the government’s proposal announced on the 23rd to transfer permitting authority for redevelopment and reconstruction projects with 500 units or fewer to district governments. In particular, questions continue to arise over whether the figure 500 has any reasonable basis and whether district governments currently have the capacity to handle such work.
Professor Ma Kang-rae of the Department of Urban Planning and Real Estate at CAU recently posted his views on Facebook, saying, "I am someone who wants this administration to succeed." He described the measure as "the ultimate desk-bound policy." The criticism may sound harsh, but much of the basis he cited can be verified in existing laws and regulations.

Ma said that building an apartment complex with 400 units requires coordination across urban planning, architecture, transportation, landscape, environment, education, and disaster prevention. He questioned whether it would be possible to build such a system in 25 district offices. In fact, the Act on the Improvement of Urban Areas and Residential Environments lists eight categories for integrated review of project implementation plans: construction of buildings and designation of special architectural zones, landscape review under the Landscape Act, education environment assessment, urban and county management planning, traffic impact assessment, fire performance-based design review, disaster impact assessment, and environmental impact assessment. The actual law requires even more than the seven items Ma listed.
Ma also explained that it would be difficult to recruit experts to carry out such work. The law requires the integrated review committee to have at least 24 and no more than 150 members, including the chair and vice chair, and it also sets minimum staffing levels for each participating subcommittee. If all 25 district governments were to form separate committees, the arithmetic suggests that about 600 experts would be needed. Of course, members can serve on multiple committees, so the actual number required could be smaller. Still, Ma pointed to this issue as a concern.
What he was especially worried about was whether 25 such bodies could actually be created. Ma criticized the plan, saying, "Even Seoul Metropolitan Government struggles to gather experts, and those experts are being called to various committees two or three times a week while giving up their livelihoods." He added, "If this difficulty is overcome and the policy is actually implemented, the standards for redevelopment projects will differ from one district to another, and redevelopment work in Seoul will become a complete mess." Ma currently serves as an outside member of the Seoul Metropolitan Government Urban Planning Committee.
In fact, the Seoul Metropolitan Government Urban Planning Committee, the Urban Architecture Joint Committee, and the Architecture Committee all meet twice a month by principle. Separate expert committees on structural safety, excavation, and landscape are convened when needed, and the redevelopment project integrated review committee also meets twice a month.

What he warned about even more strongly was fragmentation. He said, "If five more sites each with 400 units are added, the total quickly exceeds 2,000 units." He added, "But because of this fragmentation, it will become difficult to secure roads, parks, and schools properly."
A report titled "Implementation Status and Improvement Tasks of Seoul’s New Town Project," published by The Seoul Institute in 2008 in connection with past New Town projects, said that the redevelopment of existing residential areas had been carried out as small-scale, private-sector-led individual projects. The report noted that this created limits in linking development with neighboring areas and securing infrastructure, and that this concern formed part of the background for introducing the New Town project.
The concerns raised 18 years ago are closely aligned with Ma’s current argument. For the ruling party and the government’s latest policy to have legitimacy, they also need to explain how they will address the problems that arose in past small-scale, individual redevelopment projects. Ma added, "Once you try it and it does not work well, it is hard to roll it back."
The laws and regulations that must be reviewed for the transfer of authority are not limited to the urban redevelopment law alone. Traffic impact assessments and environmental impact assessments, both of which are subject to integrated review, are operated under separate laws and Seoul Metropolitan Government ordinances. The scope of review that district governments will ultimately handle will depend on future revisions to the law and on how related laws and ordinances are reorganized.

The logic behind the push is speed. The ruling bloc believes that review of small-scale projects has piled up at Seoul Metropolitan Government, creating a bottleneck. Seoul Metropolitan Government, however, says that of the nine permitting powers related to redevelopment projects, district governments already hold seven, while the city handles only two: the review for district designation and the integrated review for project implementation.
Seoul Metropolitan Government says the two review processes take about four months, or roughly 2.7% of the total redevelopment project period of about 12 years. Of the 193 redevelopment projects involving 500 units or fewer, 31 are still at the district designation stage, the city said, accounting for 16%. There are limits to this calculation because it comes from Seoul Metropolitan Government itself. However, the government and ruling party have not publicly presented specific figures to counter it. For the policy to be convincing, it needs numbers showing where bottlenecks occur, how severe they are, and how much time the transfer of authority would actually save.
Of course, not all of Ma’s claims can be fully verified. He argued that "district offices do not have a system in place for this kind of integrated administration in the first place," but district governments also have related committees such as urban planning committees and hold meetings by appointing outside experts. It would be hard to say there is no expert pool at all. Still, whether district governments have the capacity to independently operate a system like the redevelopment project integrated review currently run by Seoul Metropolitan Government is a separate question.
[email protected] An Seung-hyun Reporter