London Plan: damage limitation

On 1 February Just Space wrote to the GLA calling for urgent steps to reduce the negative impacts of the latest changes to the Plan.

From Just Space to Jules Pipe, Deputy Mayor (planning)

Cc to Tom Copley, Deputy Mayor (housing), Members of the London Assembly, London Plan Team, London Councils

Dear Mr Pipe and colleagues

New London Plan: mitigation of adverse impacts

Now that the new London Plan is cleared for printing and London is, in effect, stuck with it for a few years, we are writing to urge you to launch an urgent study of how the negative impacts of the Plan can be mitigated through any of the GLA’s powers or the powers of boroughs or other bodies and to collaborate with community groups in doing so.

Many community and grassroots organisations, and others, struggled long and hard through the last five years of consultation & planning to make the London Plan a more equitable and powerful instrument to achieve the inspiring egalitarian ambitions held by the Mayor and captured in his City for All Londoners, in his preface to the London Plan and in the Good Growth Policies. Both the process and the outcome have been a tremendous disappointment at successive stages. The interventions from the SoS have made matters worse.

The consultation draft of the Plan as amended prior to the EiP was subject to very strong criticism for failing to provide for the low-rent social housing which the SHMAA showed was London’s overwhelming need; its protections for industrial land, other workspace and local services – while an improvement on earlier plans – were heavily criticised for not going far enough. The lack of resources for infrastructure meant that inroads were made into the prospective S106 resources to support social housing and further intensified densities beyond what could be supported by social infrastructure or community consent. The entire logic of the plan was to further increase centralisation of jobs, depending on heavy investment in radial railways to create capacity and lengthen commutes. What we needed instead was more distributed employment (existing as well as new) and a strong emphasis on better inter-suburban transport, alongside walking and cycling. On this, and other environmental issues, the Plan was criticised for lacking staged milestones and targets ambitious enough to match the global warming and biodiversity emergencies. A year ago we urged the Assembly to reject it (our 2020 letter was attached.).

Many of the deficiencies of the Plan would disproportionately impact low income Londoners and one or more of the groups with protected characteristics. We were proud that our evidence and determination persuaded the Panel of Inspectors to require the GLA to do a lot of extra work on the Equality aspects of the IIA and were not surprised to see that the resulting GLA report NLP/EX/33c Impact of policies on each ‘protected’ group acknowledged the plan’s discriminatory impacts, especially on housing. 

The changes which the GLA has been required to accept during the last year’s exchanges with the SoS produce further negative effects and we would like urgently to meet with you and the planning team to consider the scope for mitigation. In particular:

  • Affordable housing: the wording which encouraged Boroughs to seek affordable housing contributions from small sites has been deleted. (Direction 3, Policy H2). Although this is a small change it comes on top of the plan’s failure to ensure that enough affordable —and particularly low-rent— housing can be secured. Community groups are gravely concerned and are not satisfied that the mayor is doing everything in his power to improve prospects, even in the housing emergency revealed by Covid19.
  • Density and Opportunity Area expansion: (Direction 2, Policy D3) where the pressure further to densify already-dense parts of London would tend to overload social infrastructure with adverse effects on many protected groups and the addition of power to extend OA boundaries would amplify the democratic deficit already endemic in OAs.
  • Industry and employment: (Direction 4, Policies 4,5,7) substantially weaken the protections the plan offers for employment space, threatening damage to the output and employment of diverse sectors and disproportionately likely to affect working class, including BAME, Londoners. At a time when Covid19 has brought London severe growth in unemployment levels, especially of young people, and an awareness of the value of jobs close to homes, this SoS intervention needs urgent mitigation.
  • Gypsies and Travellers (Direction 7, Policy H14). Community organisations had supported much of the Mayor’s approach and are shocked by the SoS weakening of the plan. The best possible mitigation would surely be for the GLA to press forward with the London-wide Gypsy and Traveller Accommodation Needs Assessment.

We look forward to hearing from you on the mitigation issues. We shall be writing soon about the larger, longer term, prospects for starting work on the next London Plan in an altogether more participatory way, piloting and devising a Mayoral SCI as we go along.

End of letter. (To download a Word copy, click below)

Both the web version and the download have typos corrected and links repaired 5 Feb.