If the GLA were serious about impact they would have started their analysis right at the beginning of making the plan. Then the assessments could alert them to bad policies with likely poor outcomes and could test improvements. In fact this Impact Assessment has yet to start and plan making is well under way.
The GLA has been consulting on the scope and design of the Integrated Impact Assessment (IIA) and we find it to be weak in many respects and biased in ways which would make it blind to the downsides of many controversial policies. Policies will gain plus points for growth and plus points for almost all extra density. How can density policy and tall building policy be evaluated if increases in density are the measuring rod for success?
Another weakness of the approach is the lack of analysis of why earlier plans have failed – especially failed over 25 years to produce anything like enough low-rent social housing. The need for it is unchallenged but the backlog of unmet need mounts. Without much better monitoring, evaluation and explanation it will be next to impossible for the Assessment to point towards better policies.
Many of the criticisms of the London development process come down to the effects of prioritising developer and land owner profits in the assessment of projects, captured in the phrase ‘subject to viability’ and its application to everything in the plan.
Is there no alternative? The regulations require a strategic assessment of the plan against reasonable alternatives which have been explicitly or implicitly rejected. Just Space is working on an Alternative Plan for London which differs radically from the Mayor’s and the GLA has no excuse for not exploring some of the main alternatives that Londoners call for: less pressure for growth, a more polycentric metropolitan region with less need to travel, more care and support for existing enterprise.
Read our consultation response in detail. Download here. It has been prepared by a group of JustSpace members and others have been consulted on drafts. Particularly valuable inputs have come from the Southwark Law Centre.
For the previous London Plan City Hall planners got the IIA seriously wrong and were required to go back and do a lot of extra work. Earlier posts have the details.
