Grave weaknesses in the London Plan

Today 25 February has been a momentous one for the London Plan, challenged for its entire approach to “affordable” housing and now described as ‘unlawful’ for failing to discharge the Mayor’s duties under the equalities act. Policies which discriminate against poor people, many ethnic groups, disabled people, women… are being air-brushed as positive or neutral.

A surprisingly wide range of organisations, ranging from Just Space, the London Tenants Federation and 35% Campaign to the Council for the Preservation of Rural England and the Highbury Group made independent critiques of the very weak “affordable” housing proposals in the draft Plan, proposals which would fail to meet even the needs identified by the Mayor —overwhelmingly for council housing (low-rent housing)— and would further boost an over-emphasis on housing which few Londoners can afford. Some details are in this afternoon’s tweets @JustSpace7 and a blog post will follow here.

Part of the challenge from Just Space is that the housing proposals fail to satisfy the GLA’s obligations under the Public Sector Equalities Duty. This failure is just one aspect of the systematic failure of the entire plan. After Just Space raised these issues on day 1 of the Examination, the panel of inspectors ordered the release by the GLA and Arups of supplementary tables which had been prepared but not published. These did appear and  participants were given until yesterday to comment. Just Space Written Statement 2019 Mayor’s Additional Equalities Evidence  is detailed and careful, concluding:

  1. The effect of the Mayor’s flawed approach has been to produce a Panglossian EqIA (as part of its IIA) which bleaches out any negative effects arising from the policies because it fails to ask the right questions, namely, what is the likely differential impact of X policy on persons with protected characteristics and to inquire after the right sort of information on which to base such an analysis.
  2. The Mayor, the Panel and the Secretary of State need to take into account equalities impacts prior to adopting the NLP. However, the flawed approach taken in the IIA is only underscored by the assessment tables which have now been published. These do not correct the deficiencies of the IIA and taken together, the total information provided does not come close to discharging the PSED. Were the plan to proceed on the basis of the current IIA it would do so unlawfully.

The Panel announced this evening that it would now read the submissions and give careful consideration to them. The GLA staff, asked to comment, said that they were satisfied that the IIA was a proportionate and robust exercise. “The Public Sector Equality Duty is at the heart of everything we do, every day.”

The panel’s response is awaited. When further submissions are available we’ll post the links. Later (9 March): six more submissions have been made and are available at https://www.london.gov.uk/what-we-do/planning/london-plan/new-london-plan/examination-public-draft-new-london-plan/written-statements/supplementary-written-statement-matter-2  It is not yet clear when these will be discussed. Without exception these submissions reinforce the detailed statement from Just Space summarised here.