Category: Housing

Just Space comment on draft City Fringe OAPF

On 2 March 2015 JustSpace submitted the following short comment in response to the Mayor’s consultation draft City Fringe Opportunity Area Planning Framework.
http://www.london.gov.uk/priorities/planning/consultations/city-fringe-opportunity-area-planning-framework

For a proper consideration of its content, strategies and proposals, there is a need to have knowledge of: the array of Masterplans, Local Plans, Action Area Plans… (vide para 5.55, p. 58). To gain an appreciation of these is made more difficult and time consuming because of the 3 boroughs involved;and the the functional and geographical areas, the localities and neighbourhoods – and this would mean all of the OA, rather than the ‘local patch’ knowledge that individual amenity/community groups would have, for various reasons.

This Framework has a Vision (para 1.54, p.12) to enable business growth that has spatial/land use consequences for all of the OA. It seeks to ensure a consistent approach across the 3 boroughs (Strategy 1, para 1.57,p.12) and its primary aim (para 2.2, p. 16) is to create a positive environment for employment growth in the City Fringe.
For local communities to marshall their resources during the consultation has proved impractical, particularly as no evidence has been brought forward to demonstrate that communities have been involved, unlike those mentioned as part of the wider stakeholder group (para 1.3, p. 2). Given the hetrogeneity of the OA, consistency of approach is an inappropriate strategy. However, a coordinated approach would better fulfill the purpose of the OAPF to elaborate and guide development plan policies . This is not simply a matter of semantics as this goes to the heart of the intent and purpose of the Planning Framework which, given the nature, characters, scales and extent of the OA, should enable a variety of locally appropriate responses to flourish. Consistency of approach conveys something entirely different.

Recognition of the need to protect and support the distinctive economic clusters and provide for a variety of space typologies and affordable workspace is encouraging. Although it should be noted that existing models of affordable workspace have been criticised for not actually delivering the intended products useful to micro and small enterprises (research by Dr J Ferm, UCL, 2014, http://www.sciencedirect.com/science/article/pii/S0305900614000361 )

The resulting Strategy 3 (para 3.7, p28) begins with the stated need for development to facilitate economic growth without the necessary qualification and recognition that sustainable development is the goal of the planning system and that the achievement of this should frame this facilitation.

Given that the OAPF is to be delivered in partnership with the local boroughs (p.viii), the cited Implementation Chapter 6 is relatively underdeveloped and does not articulate much more than a listing of funding streams. More should be said on the mechanisms for cooperation, monitoring and review, as promised on p.viii (“in detail”), together with an explanation of more effective and continuing community engagement. This chapter is crucial to the OAPF but it has been inadequately and carelessly attended to as at para 6.20 (p.90) with its reference to LBE and at paras 6.37 & 6.38 to Ealing and Southall. This evidence of cut and paste from another OAPF undermines the credibility and standing of the City Fringe document.

The Implementation paragraphs of the Executive Summary describe the Framework as “the plan”. If it is a plan and it does have maps clearly setting out spatial expressions, (including the identification of sites) of its content, then it should be subject to the formal procedures of plan-making with examination in public to form part of the development plan for London. Consideration should be applied to the need to subject this plan to a SEA having regard to its environmental impact.

Correction is also needed to Chapter 1’s Fig 1.3 ‘Material Weight of the Framework’ which incorrectly depicts the planning hierarchy and material weights. Neighbourhood Plan is not on the same level nor does not have the equivalent weight of SPG or OAPF; it is actually at a higher level/has greater weight because a “Neighbourhood Plan forms part of the development plan and sits alongside the Local Plan prepared by the Local Planning Authority.” (National Planning Guidance ref 41-003-20140306). It should be in the diagram’s box ‘The Statutory Development Plan’.

END

Additional comment from Robin Brown of Just Space: It seems to me that the GLA are attempting to counter the voracious demands of residential led development, as amplified by the 2013 permitted development rights for office to residential conversion, to protect the supply of employment land supported by their commissioned demand side appraisal. And that their draft policy at paras 2.16 & 2.17 detail the requirements on incorporating affordable workspace (in the core growth areas – map 2.3- roughly approximate to the permitted development exemption area).

03/03/2015
Demolish or refurbish? new evidence

Just Space and the London Tenants Federation are collaborating with the new Engineering Exchange at UCL where researchers have produced fact sheets and surveys of evidence for community use. This is a pioneering attempt by academics to focus their research on hot topics in the metropolitan community and has led to some first publications and to evidence to the London Assembly Housing Committee from Dr Sarah Bell and Dr Charlotte Johnson. More at http://www.engineering.ucl.ac.uk/engineering-exchange/ … (dead link)

Prof Muki Haclay and Prof Sarah Bell with Richard Lee (Just Space) and Sharon Hayward (LTF) at the launch on 27 October 2014

The report is here

Page checked (and new live link added) M Edwards 21 07 2025

28/10/2014
Staying Put: An Anti-Gentrification Handbook for Council Estates in London

Download ‘Staying Put’ low resolution here.

Download ‘Staying Put’ high resolution here.

This handbook explains why the regeneration of council estates often results in established communities being broken up and moved away, and housing becoming more expensive. It is designed to help local communities learn about gentrification and the alternatives they can fight for. Through the experiences of council tenants, leaseholders and the wider community in London, it contains ideas, stories, tools and resources.

Staying Put is free to use by any individuals, community or amenity groups and campaigns, TRAs, students, researchers and all. We have included two download links above to enable the booklet to be circulated as far and wide as possible. There is a high resolution PDF also if anyone is able to print further copies for community based campaigns.

We are currently working out how we will distribute the printed copies around London. Do get in touch if you are from a council estate or community campaign and would like some copies. We printed 1000 but this will not go round everyone so we ask people to be strategic. Thanks

CONTENTS:
1: What’s going on?
   • Council estates under threat
   • What is ‘gentrification’?
   • When is ‘regeneration’ gentrification?
   • The ‘consultation’ con
   • The ‘affordable housing’ con
   • What is displacement?

2: What can you do about it?
    • Finding out what’s going on!
   • Public resources and Freedom of Information
   • More than just you! Getting together
   • Tenants and Residents Associations
   • Organising a local group
   • Telling your story
   • The consultation game
   • A word about the law

3: Alternatives to fight for
    • Community planning
   • Neighbourhood Planning
   • Lifetime Neighbourhoods
   • Community Land Trusts
   • Co-operative housing
   • Community Housing Associations
   • Refurbishment
   • Community-led Self Build

It is a collaboration between four groups and individuals:

London Tenants Federation
Federation of organisations of tenants of social housing providers at borough level and at London level. LTF provides information and research on London’s housing issues through accessible policy briefings and newsletters. It facilitates networking and information exchange at local and regional events, linking tenants and other community and voluntary groups. www.londontenants.org

Loretta Lees
Professor Loretta Lees is a London-based urban geographer. She is an international expert on gentrification and the policies and practices associated with it. She is working to persuade policy makers and communities that there are alternatives.

Just Space
Just Space is a London wide network of voluntary and community groups operating at the regional, borough and neighbourhood levels. It came together to influence the strategic plan for Greater London – the London Plan – and counter the domination of the planning process by developers and public bodies, the latter often heavily influenced by development interests. www.justspace.org.uk

Southwark Notes Archive Group
Local people opposing and writing about the regeneration &
gentrification of the North Southwark area that has happened over the last 20 years. www.southwarknotes.wordpress.com

Checked M Edwards 1707 2025. (Note that LTF web site is under repair)

See also the 2023 Alternative Good Practice Guide to Estate Regeneration (in publications)

19/06/2014
Communities ‘Open the Book’ for Viability Assessments

Viability Assessments submitted in support of proposed developments have been widely criticised by community groups for justifying lower levels of affordable housing and/or other forms of planning gain than that required by planning policy. In consequence, several groups have sought to challenge the assumptions that underpin them, but have faced the refusal of local authorities and developers for an ‘open book’ on the grounds of an overriding need to protect commerical confidentiality, notwithstanding the public interest issues raised by these developments. Refusals of Freedom of Information requests for disclosure of critical parts of Viability Assessments have been referred by groups to the Information Commissioner’s Office for determination, and recently, they have been meeting with success. On 10 May 2014, the 35 Per Cent Campaign announced a positive result: see ” Heygate FOI appeal decision – Tribunal delivers verdict” ( http://affordable.heroku.com/blog/2014/05/10/foi-appeal-decision/ link dead ). They write (extracts follow):
“The Information Tribunal has directed that the whole viability assessment be made public, apart from developer Lend Lease’s bespoke development model in the assessment’s final appendix and the calculations concerning retail & office space – all other information has to be disclosed. Lend Lease and Southwark have been given 28 days to supply the information Commmissioner with the information as outlined by the Tribunal’s decision notice. All parties may appeal the decision but only on a point of law”.
“The Heygate decision puts the balance of public interest with local people. Their right to information that enables them to take part in the planning process has been found to outweigh the developer’s interest in keeping information confidential”.

And on 21 May 2014, campaigners in Earl’s Court area, who had challenged the affordable housing provision in the Capco development, announced that the Royal Borough of Kensington & Chelsea are applying to withdraw its appeal against the decision of the Information Commissioner’s Office that the Council should disclose the viability assessments. The Tribunal had been due to meet on 11-12 June. It is now expected that the Council will disclose unredacted documents to meet the requests of the community campaigners.

Checked by Michael EDWards 17 07 2025

24/05/2014
New London Plan out

January 2014. A new set of changes to the London Plan has been published by the GLA: Further Alterations to the London Plan (FALP. Consultations are open until 10 April and Just Space will be ensuring that community groups are able to support each other in preparing and making representations. More details on the Greater London page of this site. The document is referred to by the acronym FALP and we suggest that the hashtag #falp14 is used for it in Twitter. Important 6 March and 15 March events for community groups.

In the mean time consultations closed earlier (February 17th) on the Mayor’s Draft London Housing Strategy. Just Space worked with the London Tenants Federation and other groups to prepare responses to this document. Details here.

Checked by Michael Edwards 16 07 2025. Links checked and one replaced.

16/01/2014
Constitution
1. JUST SPACE Just Space is a London wide network of voluntary and community groups working together to influence planning policy at the regional, borough and neighbourhood levels. It grew from sharing information, research and resources on the Further Alterations to the London Plan in 2007.
2. AIMS AND OBJECTIVES The Just Space ethos is one of grass-roots networking, informing and supporting local communities so that their contributions to planning policy are empowering and effective.
  It does this by:-
- Maintaining an overview of strategic planning issues and their implementation
- Providing mutual support to community organisations engaging in the London Plan EiP process
- Raising awareness of London planning policies at local level
- Cascading learning to the local level in a way that informs involvement in Local Plans
- Working in partnership at the local level to develop new links between voluntary and community sector groups, groups concerned with equalities and active residents
- Developing plain language information that is accessible for all Londoners
1. MEMBERSHIP Membership of Just Space consists of organisations and community groups who are active in working on London Plan related policies and who are participating in the EIP process. Members at general meetings will consider and approve any requests for membership of Just Space. Groups do not have to be constituted to be members. Just Space welcomes observers who are interested in developing their knowledge of London Plan policies or who may have an interest in specific policy areas and are keen to share their expertise.
2. MEETINGS General Meetings (the Just Space network) are held at least 6 times a year and are key to the success of Just Space, allowing members to come together to share information and expertise. Meetings will be chaired by a member elected at the beginning of each meeting. Just Space seeks rotation of the chair. A proper record of meetings will be kept. At least 7 days notice will be given of general meetings. There will be an Annual General Meeting (AGM) within 15 months of the previous Annual General Meeting. AGM’s will require 28 days notice. Representatives of at least 6 Just Space member groups must be in attendance to form a quorum at General Meetings and at least 9 member groups at Annual General Meetings.
3. DECISION MAKING The main decision making body is the General Meeting, where decisions are made on the basis of consensus. In between meetings, a Planning Group set up by the General Meeting will deal with the implementation of decisions and the preparation of reports for the next meeting. The Secretary and Treasurer will be members of and work through the Planning Group. Members attending general meetings can decide to set up sub-groups and to delegate day-to-day decision-making, including the conduct of any urgent business, to these sub-groups or to its employees.
4. ELECTIONS Just Space elects a Treasurer at its Annual General Meetings (AGM). The Secretary will normally be the paid co-ordinator. Should the post become vacant during the year, a replacement will be agreed at a general meeting and will remain in post until the next AGM.
5. FINANCE The Treasurer will be responsible for maintaining the accounts, and will present annual accounts to the AGM. Funds will be lodged in a bank approved at a General Meeting. All cheques will require at least 2 signatories.
6. INTERNAL AND EXTERNAL COMMUNICATION Just Space will publicise its activities through email lists, the Just Space website and regular conferences. When responding to any press and media inquiries or issuing statements Just Space will only comment on issues where there is a consensus.
7. AMENDMENTS TO THE CONSTITUTION Amendments to the Constitution can take place at the AGM or at a Special General Meeting arranged for the purpose. The amendment proposed must be set out clearly in the notice of the meeting. Amendments to the Constitution must be passed by a two thirds majority of the votes cast.
8. DISSOLUTION Just Space can be dissolved by a resolution at a Special General Meeting. 28 days notice must be given of any such resolution and will require the support of two thirds of those present at a general meeting. Should Just Space be dissolved any monies, other than that which would be required to be returned to any funding source, shall be donated to a non-profit or charitable organisation with similar objectives determined by the meeting.
  
  This constitution was adopted at a general meeting held on 20 July 2012.
17/10/2013