Category: The Overall Strategy

  • The overall strategy

    The overall strategy

    INTRODUCTION

    On the face of it London is booming. The nation’s economic engine has been growing at its fastest rate over the past 30 years. With cranes on the skyline and construction trucks on the roads, high-density, high-cost apartments have been built across 47 Opportunity Areas and 600 more towers are in the pipeline. 

    But people on the ground know that something is wrong. We have not built the genuinely affordable homes needed by a population that has been encouraged to grow by over 40% since 1990. With the population now at 9.7 million, only one large new park has been created. There is an acute shortage of affordable housing, including the loss of 300,000 council homes through Right to Buy and the council estate demolition programme. 60,000 families are in temporary accommodation including 70,000 children, with 300,000 households on the boroughs’ waiting lists. 

    As the price of housing has risen to eye-watering levels, London has been hollowed out and no longer has a range of land uses for businesses and employment, nor a diversity of homes for all. Less expensive housing is forced outwards, requiring hours of travel time for workers. Vital services like libraries, doctors surgeries and youth centres are stripped down and community spaces disappear. There is less and less care for poorer Londoners.

    Solutions in OUR MANIFESTO

    PROPOSALS TO GOVERNMENT AND MAYOR

    1. Stabilise growth: GDP growth is simplistic, amplifies inequalities and entails increasing carbon emissions. Measure a wider range of values (set out in this Manifesto) to pursue for human well-being such as health, biodiversity, care and community
    2. Replace Council Tax with a more progressive property tax to generate revenues for councils, initially by adding more bands
    3. Aggregate financial gains from development and land value at a metropolitan scale, sharing them among Opportunity Areas
    4. Introduce Land Value Taxation in the longer term
    5. Change property value tax, housing inheritance tax, capital gains tax, to discourage treatment of housing as a wealth generator
    6. Damp down developer, shareholder, investor expectations to put land prices on a stable or downward trajectory
    7. Lower the level of profit expected by developers
    8. Large public land holdings should provide 100% not-for-profit housing 
    9. Public investment in a new model of housing development which does not rely on developing high end housing
    10. Long-term and secure tenancies to enable household well-being and stable communities 

    LINKS, GROUPS CAMPAIGNING ON THIS ISSUE

    https://neweconomics.org/2019/11/funding-local-government-with-a-land-value-tax

    https://www.landjustice.uk/

    Homes that don’t cost the earth

    ARCHIVE

  • News: Londoners vary

    News: Londoners vary

    9 August 2023 Though GLA didn’t have the decency to tell us – or anyone else (?) – when they actually published findings from the winter’s “deliberative/engagement” Planning for London sessions , these did actually appear in the location where they said all the material would be. The findings are write-ups by the GLA’s consultants (2cv) of discussions held with carefully-chosen participants representative of London’s diversity. Our first impression is that the emphasis is on how much Londoners and their opinions vary. There does not seem to be any emphasis on which variations are particular to which population groups.

    Covering page: 
    https://consult.london.gov.uk/planning-for-london-deliberative-events

    Event 1 : A Green and Fair Economy:    how and where London’s businesses should start, grow and create jobs; how to support high streets and town centres; how we upgrade London’s existing homes and make new buildings to be greener; and what the impacts of large-scale redevelopment on existing businesses are.
    https://consult.london.gov.uk/24854/widgets/70359/documents/45348

    Event 2: Sustainable transport and public spaces:  how we can turn spaces into places where people want to spend time; how we prioritise competing demands for limited public space and streets; how we reduce traffic in a way that is fair; and what our public transport priorities should be.
    https://consult.london.gov.uk/24854/widgets/70359/documents/45347

    Event 3:  Housing: who housing is for, where it should be located, how it should be designed and the impacts on existing communities.
    https://consult.london.gov.uk/24854/widgets/70359/documents/45349

    Event 4: Places and communities: how to plan for large-scale development with finite space and funding; night-time activities; green spaces; Outer London; and how to create strong communities in a changing city.
    https://consult.london.gov.uk/24854/widgets/70359/documents/45350

    Checked by Michael Edwards 21 07 2025

  • Labour leader defends Plan

    Labour leader defends Plan

    Following our letter of 3 February asking members of the London Assembly to reject the Plan (our letter is the previous post here), we received a prompt reply on 5 February from Nicky Gavron, planning spokesperson for the Labour group of AMs. She writes:

    Thank you for your recent email regarding the upcoming Plenary Session at the London Assembly to approve the Mayor of London’s new London Plan. [1000h at City Hall, Thursday 6 February, open to all – ed]

    Writing and implementing the London Plan is one of the most significant powers the Mayor has, and as Assembly Members our responsibility to scrutinise and approve the plan

    As Planning Spokesperson for the Labour Group on the Assembly, I am responding to the points you raised with my colleagues below.

    Procedure

    Although the Assembly is considering this Plan before the final version, with any amendments from the Secretary of State, is available, one of the primary responsibilities of the Assembly is to scrutinise the work of the Mayor, and the version we are considering on Thursday is the London Plan as the Mayor intends. It means we can scrutinise the Mayor’s policies and decisions, rather than allow issues to be deflected to the Secretary of State.

    The Assembly has also agreed that if/when the Secretary of State does respond to the Intend to Publish version of the plan with significant revisions, we will hold a further session to scrutinise the impact of any changes. We have also received legal advice that the relevant legislation does not allow for the Assembly to reject directions made by the Secretary of State to the Plan.

    Policy

    The London Assembly Labour Group has worked now over two and a half years to challenge the Mayor and his team, with views from community groups, constituents and our own research, to improve the Plan at each stage of consultation. Through our work, we have secured significant improvements to policies including: affordable housing, family-sized housing, industrial land, biodiversity assessments, air quality mitigation and waste capacity.

    The Mayor’s Plan sets out a bold vision to deliver sustainable economic growth for London in the coming 20 years, and will help the city tackle some of the biggest challenges we face, not least the housing crisis and the climate emergency. We do not believe that it is a perfect plan, but it is a significant step forward from the policies of the previous Mayor – which delivered record low numbers of social housing – and the London Assembly Labour Group will continue to pressure the Mayor so that any supplementary guidance and revisions to the plan best meet the needs of all Londoners. We will continue to hold the Mayor to account and monitor the delivery of development

    The Plan seeks to deliver high levels of affordable housing to meet London’s urgent needs, and sets a strategic target of 50% of all homes to be affordable, of which up to 70% should be at social rent levels – matching the ambition set out in the first London Plan in 2004, since lost by the last Mayor. We pushed the Mayor to increase this further to reflect the massive and urgent need for social housing in London, and will continue to make this case in the coming months and years.

    The new Plan introduces many policies which will protect existing social and other types of low cost housing. Policy H8 makes clear that all alternative options should be considered in full before the demolition of existing affordable homes. Any social rent homes that are demolished must be re-provided with the same or increased floorspace, and in order to receive Mayoral support, there must be a ballot of residents ahead of any estate demolition, in line with the Mayor’s Good Practice Guide to Estate Regeneration, implemented in 2018.

    The Plan must also be seen in the context of non-planning and national Government policies. The planning system alone cannot deliver the levels of social housing we need. The Mayor has joined many others to state that the current “cross-subsidy” model – whereby private sale developments fund affordable housing through Section 106 – is broken and will never deliver what we need in London.

    Direct grant funding is responsible for the majority of affordable housing in London, but grant has been cut considerably since 2010. The Mayor has secured £4.82 billion from Government over five years, and has delivered a record number of affordable housing starts since City Hall took responsibility for this in 2012. But in order to build what London needs would require £4.9 billion per year in funding from Government, seven times what London currently gets. Furthermore, councils and the Mayor are hampered in their efforts by the continuation of the Right to Buy, which over 40 years has drained London of much need council homes. Since the Government “reinvigorated” Right to Buy in 2012-13, councils have been forced to sell more homes than new social homes have been built in London.

    The first Good Growth objective is about building strong and inclusive communities and talks specifically about tackling inequalities and building a more inclusive city. Independent Planning Inspectors agreed that the Plan’s policies will tackle the disadvantages faced by groups with protected characteristics, and the Plan implements much better policies for marginalised groups, including Gypsies and Travellers. The Mayor has resisted Government and introduced a more progressive and encompassing definition of this group to ensure that the community’s needs are properly assessed. The Mayor will lead a new London-wide needs assessment of Gypsy and Traveller accommodation, and ensure that new targets are set to all boroughs. In addition, 10% of all new homes should be fully wheelchair accessible, and all others should be accessible and adaptable for people with disabilities.

    The London Assembly Labour Group has worked to improve the industrial land policies of the new Plan to ensure better protections for “behind the high streets” light-industrial premises and workspaces. These are the kind of SMEs that ensure London thrives, but are often “non-designated” industrial sites, which makes up 36% of all industrial land in London. The Plan has been strengthened to better protect these sites from residential development, as part of an overall “no net loss” approach to industrial land across the city. The Plan also sets out London-wide policies on affordable workspace for the first time, encouraging boroughs to secure below market-rate workspace for community groups, charities and social enterprises.

    The Plan seeks to meet the Mayor’s target for London to be 50% green by setting requirements for development proposals to incorporate green infrastructure, achieve biodiversity net gain, avoid damaging mature woodlands and protect Metropolitan Open Land and Green Belt. The Labour Group and the Mayor have stood firm in protecting green belt designations, despite Government objections. This is one of the key areas of disagreement between the Mayor and the Government. Biodiversity net gain, a policy adopted early on in the development of this London Plan, has now been brought forward at national level. Labour Group secured an improvement in the Plan by noting that biodiversity net gain must be achieved within a limited distance from the original loss.

    The Plan builds on the Mayor’s targets to clean up London’s air, we secured a requirement for all development proposals to be at least air quality neutral as well as major developments being air quality positive, i.e. improving London’s air quality. In practice, this means they must use cleaner heating technologies that do not emit toxic fumes, promote clean travel and contain green infrastructure.

    The Plan contains some of the most ambitious energy efficiency policies of any planning policy across the country. The Mayor has set a requirement for new developments to reduce their carbon emissions by 35% above what is required by current buildings regulations, in large part through energy efficiency measures. This means that London’s new buildings will be some of the most affordable to run in the country. Furthermore, by promoting the uptake of new low- and zero-carbon heating technologies, the Plan is helping to prepare the industry to fully decarbonise heat, which has historically been harder to decarbonise than electricity. Major developments are required to offset the rest of their operational carbon by contributing cash sums to local funds. This is helping to move London towards meeting the Mayor’s target to be net zero-carbon by 2030 and zero-carbon by 2050.

    [end]. Just Space letter, to which this is a reply.

    Checked by M Edwards 21 07 2015

  • Assembly urged to reject Plan

    Assembly urged to reject Plan

    Call to reject this London Plan

    Letter sent to all Members of the London Assembly on 3 February 2020

    On 6 February the Assembly will consider the Mayor’s draft new London Plan before the GLA has received the Secretary of State’s formal response to the Plan.  The SoS has written that he will provide his response on or by 17 February, so the 6 February debate is procedurally unfair and irrational as Assembly members should have an opportunity to study the response before deciding on the Plan.  We question the logic and lawfulness of this 6 February decision and urge Assembly Members to defer their decision to the 6 March meeting.

    The draft new London Plan should not be adopted. Just Space and its many member groups challenged the draft plan on many deficiencies throughout its progress, have chalked up some small gains but it remains a Plan which will further deepen inequalities in the city and fall badly short on environment.

    The emperor has no clothes. We call upon the Assembly to send it back for a complete re-think.

    Like its predecessors, the London Plan reinforces the dominance of property and financial interests in the development of the city, at the expense of low- and middle-income Londoners, the environment and the ordinary economy.

    Specifically, the draft Plan is bad because of its…

    • Deepening inequalities and poverty, particularly in the provision of cheap housing;
    • Failure to discharge the Public Sector Equality Duty (PSED) from the outset of the planning process. If the Mayor had considered the PSED properly from the outset – and the duty to consult those groups properly – he would have had some chance of achieving the ‘Good Growth’ he favours.
    • Failure adequately to consider alternative strategies, notably the Just Space community-led plan of 2016. (LSE London made a similar challenge, arguing the need for an explicit evaluation of alternative strategies beyond the London built-up area.)
    • A mistaken approach to housing based on maximising total housing numbers, rather than protecting and growing the stock of council and low-rent housing which is London’s overwhelming need. This mistake will lead to the backlog of unmet housing need getting even worse in the coming years, families being sent miles from home if they become homeless and to those who do find housing spending so much on rent that they can neither save nor enjoy London.
    • Failure adequately to protect the jobs and services in London’s industrial areas, in and behind high streets and in town centres as land is switched to produce yet more expensive homes. This failing makes the economy less robust, increases the need to travel and would have regressive effects on many protected equalities groups.
    • Weak approaches to climate change and bio-diversity, lacking urgency, tangible measures and timelines of target outcomes. failure to meet the requirements of the UK Habitats Directive in concluding that the London Plan will not have adverse impacts on Natura 2000 sites, and the last minute removal without consultation of Policy G6 C(3) which required Boroughs in their development plans to provide net biodiversity gain when harm to a SINC is unavoidable. [Second sentence added on web after the letter was sent to Assembly Members.]
    • The absence of convincing ways of paying for social and physical infrastructure without cutting the provision of low-rent housing; contributing to unsupportable increases in housing density and land price inflation, especially in Opportunity Areas which are supposed to contribute so much of the housing we need.
    • Continuing failure to devise and require transparent and democratic mechanisms for the designation, planning and implementation of Opportunity Areas.

    Download PDF version of this letter: Reject this London Plan 03022020

    Checked M.E. 21 07 2025

  • M67 Sustainable Infrastructure 29 March

    M67 Sustainable Infrastructure 29 March

    Sustainable Infrastructure
    Minimising Greenhouse Gas Emissions, Energy Infrastructure and Managing Heat Risk
    Written statements in response to M67 may be up to 3,000 words in length.

    Panel questions:  M67. Would Policies SI2, SI3 and SI4 assist in creating a healthy city in accordance with Policy GG3 and provide an effective strategic context for the preparation of local plans and neighbourhood plans? How would they affect the implementation of Policies GG4 and GG5 on delivering the homes Londoners need and growing a good economy? Are these policies and their detailed criteria justified and necessary and would they provide an effective basis for development management? In particular:
    a)  In seeking to minimise greenhouse gas emissions does Policy SI2 provide sufficient clarity about the zero-carbon target and how and when it is to be achieved? Is the target justified and consistent with national policy and other policies in the draft London Plan? Are all the criteria and supporting text necessary
    b)  How are unregulated emissions and whole life-cycle carbon at Policy SI2 DA and DB to be calculated and is this justified?
    c)  Are the provisions in Policy SI3 relating to energy masterplans justified? Should they be limited to large-scale development locations and is the list of items to be identified comprehensive?
    d)  Are the provisions in Policy SI3 relating to major development proposals within Heat Network Priority Areas justified? Is the sequence and content of the heating hierarchy justified having regard, amongst other things, to greenhouse gas emissions?
    e)  Would Policy SI4 adequately address the contribution of the design of outdoor space to urban cooling without creating other adverse impacts and does it consider overall thermal comfort?
    f)  What is the justification for the cooling hierarchy as set out in Policy SI4B?
    g)  Do the policies place sufficient emphasis on the use of renewables and energy efficiency?
    Just Space submission in full: M67 Greenhouse emissions Just Space

    Policy SI2 to start with. Panel asks Mayor: What is “NET zero carbon”? GLA speaker gabbles. Zero = Net zero. Same thing. Panel: 2050 target is not in the Plan; it’s elsewhere. Too slow? Too fast? Milestones on the way. The target for the LP is for new development. London Env Strategy is for the whole city… (another gabbling GLA speaker). On interim targets: the LES does set 5-year interim targets. SI2 applies only to major developments: why not all? GLA: boroughs can take an approach to smaller ones. And we’d like to see the building regulations updated to cover these.  Panel: why was construction omitted? GLA says it’s covered by other parts of the policy. What about JS’s call for more detail on monitoring. GLA: we are working on that and will publish…  Panel: offsetting? GLA: it’s in use already and we are doing more. Something about costs…  Panel: MHLG advice on retrofitting? GLA: major refurbishments should be covered by the plan. Outside of the LP the Mayor has other instruments to use on existing building.

    Kate Gordon FoE: offsetting price too low, not a strong enough incentive. // Promise of later guidance n design and construction is too vague: make it stronger. // Need a strong statement on non-major development, not leaving it all to boroughs. // 2050 taget too late //

    JS  2030 target should replace 2050. IPPC report conservative…  National policy is anyway under review, and other cities M/c, Bristol, Reading have already deviated. Progress alreaday made (ref to a Mayoral document) shows that a much more ambitious approach is feasible. // Offsetting must be a last resort, and price much higher.

    Fuel Poverty Action: support JS and FoE. Reject fuel poverty being used in some places to justify less ambitious policies. // Offsetting: far too easy for developers to pay to pollute. Breeds cynicism too. // Worried about offsets used to pay for district heating – can just boost the profits of for-profit firms..

    Mr Simon Sturgis:

    London Energy Initiatives: Support the policy but made some detailed suggestions.

    Public and Social Services Union PCS: Net zero and Zero are NOT interchangeable. // we think more analysis is needed on what companies are doing about their offsetting.

    CIBSE: there were problems with offset initially. too soon to judge and it’s a useful mechanism.  Do not agree with Sturgis: we should keep operational carbon and embodied carbon separately. //

    Cory: policy not consistent with NPPF which just calls for LOW, not Zero…

    Levitt Bernstein: very important to reduce initial embodied energy (?). Fabric improvements also reduce other costs (plant rooms etc); the more we do on site, the less we need to use offset. Must avoid reducing on-site improvements.

    London First: Practical problems: unintended consequences: detail required in energy strategies is onerous; requirement to achieve 15%…too broad for all non-domestic buildings. SI2Ac.  revise so 15% just becomes an “aim”

    Assembly labour group: methodology should be in SPG so everyone knows what the Zero / Net zero distinction is.//  Refers to an Assembly Resolution calling for 2030 to be the deadline. // Mistake to apply the policy only to major development.  Can’t leave to  boroughs or wait for building regs // Plan must refer explicitly to details in Env to add weight. // Must include embodied carbon. // Refers to Assembly research and reports.

    Panel asks GLA: definition ? include embodied carbon? GLA don’t want to confuse the established practices; but embodied and whole-life emissions to be developed separately. Panel: JS points to unambitious targets. GLA: It is ambitious enough as the 35% will become harder to achieve (? as gas/elec mix changes?) .

    Now on to Da Db. Panel: This is all over and above NPPF standards. GLA: govt has expressed no view on this policy. It’s in line with the (turbulent) way govt thinking is going. Unregulated and whole life emissions are an ever-growing share of total. Panel: can a spatial development strategy help? GLA: yes…..

    Whole life cycle: is there a RICS methodology which should be referenced? GLA gabbles. Panel: why limit it to referrable cases? GLA: it’s a new policy and we want to get it right on a limited range of cases.

    Demolition: Panel asks. It will be covered in later detailed advice. Inspector Smith: it would be clearer if the policy makes that clear. Retrofitting should thus be given priority over demolish (esp estate regen).

    Labour Group: Calls for post-completion estimates for effective monitoring and offset charging. // Support priority for retrofit over demolition. //  MUST require all schemes to…and not just the biggest ones. //  Mayor should be (tougher) on unregulated emissions.  // Do favourthe RICS approach to whole life cycle.

    London First: Fine…  but so difficult and uncertain to predict life-cycle energy… (trying to soften it).

    Veolia: plan should signpost to methodology.  We support life-cycle evaluation.

    Cory: Need transparency for all such evaluations.

    CIBSE: agree should refer to RICS, though others may emerge. //  supports Assembly view that on-completion reports are needed as well as early-stage ones.

    Env Services Assn: (can’t follow speech.)

    ??

    RIBA/RICS: Embodied energy now likely to exceed emissions in use. Savings are immediate, not spread over the years. Treasury supports view that low carbon buildings save money too. Professional procedures etc are now very advanced, stabilised, and there is no justification for delay. So we urge that embodied and life-cycle assessment should be done – with post-completion part- in an integrated way from the outset. Include medium size schemes.

    Fuel Poverty: Stresses post-completion assessments: yes residents do know… Nothing in here about consultations with residents post-Grenfell. //  should be provision for requiring district heating pipework to be built in to estate designs…  Maybe it should be built in everywhere but…

     

    Just Space: Wording should be stronger:  ”’required..  ”   // Not just large developments . // Stress role of workers in workplaces and residents in homes can contribute to unregulated emission reductions.  Must stress working with unions and residents.

    FoE. Agree.

    GLA: asked to comment on JS inclusion of workplaces: policies apply to everything needing planning permission.

    GLA sees carbon assessment and circular economy assessments will develop in parallel.

    Policy C (gap in blog – discussion between panel and GLA on heat networks)

    GLA will look at how heat networks can be monitored.

    CIBSE: Support monitoring. Fast-=changing technology and plan needs to allow for that.

    Assn for decentralised energy: good networks operated well can contribute well. Updated code of practice forthcoming and could usefully be mentioned. Low temp networks may not always be best. Retrofit important to develop. // Add ref to on-site generation.

    xxx  We’d especially like to see Mayor backtrack on public energy company. There should be a London-wide energy strategy, and one way round terrible things like the Myatts Fields North which locked residents in to a PFI contract removing ay choice.  Must be done with workers, union and communities. Swedish experience is that only publicly-owned models can bring rapid emissions reductions with workers and residents fully contributing. Has important implications for skill development for fitters(merging elec/gas and usage skills. We welcome no new connections to gas after 2025.

    Env Services Association. We do see energy from waste as one of the elements in a solution, sometimes linked to CHP. New developments should be CHP-enabled. Perhaps GLA could guarantee demand to encourage providers.

    London Energy Transition Network: (couldn’t hear)

    Fuel Poverty Action: we see nothing in the Plan to prevent a repeat of Myatts Fields North. Call for planning consent stage to take full account of prices for final consumers. All too vague. No provision for cost to residents to be considered in Heat priority Networks. Accountabilities and incentives are NOT designed to produce good outcomes for existing or new ones.  Southwark has many out of date systems. One Elephant Park building has logged outages..  The Heat Trust is not up to the job, can’t deal with cost. Audits secret. Ombudsman also useless – dealing only with individual, not estate-wide schemes.  Mayor is the only possible source of effective regulation. Also a training issue where a strong public role is needed. Clearer criteria needed for CHP…

    Just Space. we agree on 5 ///  ref grantham Institute on need for upskilling for carbon transition. SI3a. Retrofitting must be included in this policy section, aligns Good Growth, workforce development, equity and climate change. (Adds new wording.) Importance of small developments also be included. Ref Assembly report on scope for solar PV on half of London rooftops.

    FoE is very specific. We need a policy requiring ALL development to contribute to zero energy. Need to add material on how the layout and design of developments should also contribute. Could boroughs be asked to do more? Why can’t they be got to

    (leaving now. Others will add.)

     

     

  • m16 notes 25 January 2019

    m16 notes 25 January 2019

    The Wider South East and Beyond

    Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by postgraduate students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

    The panel asked the following: M16. (a) How, if at all, should the Plan address the matter of development and growth in the wider South East?
    (b) Are policies SD2 and SD3 necessary, and would they be effective in assisting in implementation of the Plan and/or informing a future review of the Plan?

    Panel’s Opening Announcements The panel of inspectors opened the session by asking that participants engage in structured discussions around the matters highlighted on the agenda. Further stating that the purpose of the sessions was to assist in the National Planning Inspectorate’s decision on whether the plan is viable.

    The Inspector opened the session by stating that the Wider South East had been touched on in previous sessions, particularly Matters 4, 5 and 6 last week. The GLA’s position is that there should be no dependency on the Wider South East (WSE) region to accommodate London’s growth. London’s demands, in housing or otherwise, should be met within London. GLA representatives expanded on this by saying that the Mayor cannot govern development outside London but it is not denied that the capital does have links strong links with the WSE region, so it makes sense to collaborate with these authorities, particularly on strategic matters that go beyond London and its administrative boundaries.

    a) How, if at all, should the Plan address the matter of development and growth in the Wider South East (WSE)? 

    The London Forum stressed that this issue isn’t just about housing but also the economy which, like many other issues, operates beyond administrative boundaries. The Home Builders Federation (HBF) added that according to the National Planning Policy Framework (NPPF) 2018 the mayor has a duty to cooperate on cross boundary planning, something which the HBF feel the mayor has refused to engage with over the last three years; the plan should reinforce this duty. The HBF further stated that neither the mayor nor the WSE governening authorities have fully engaged with the housing gap that they believe is inevitable. The HBF felt that in order for the plan to be in line with the NPPF (2018) policies SD2 and SD3 need to state that the mayor is responsible for producing statements of common ground. The House Builders Consortium concurred and added that they believe that the shortfall is inevitable and the GLA should prepare and plan for it.

    The Common Futures Network, a national body of academics and practitioners, advocate for a more strategic, evidence-based approach which applies a consistent methodology. This applies to issues much broader than housing and, due to the extent of interregional commuting, London and the WSE needs to be treated as a wider city region. The Network advocated for central government departments to get involved in the planning process arguing that integration could not be achieved through bilateral discussions.

    Natural England added that the natural environment is an important part of the growth and development agenda as the Good Growth Policies set out in the plan cannot be delivered without due regard to the environment. The Inspector acknowledged that there is a wide range of issues, not just housing, that needs to be considered in the discussion around London’s relationship with the WSE region.

    Ian Gordon from the London School of Economics (LSE London) found the plan to be evasive when dealing with the issue of housing and argues that the GLA cannot simply transplant the demand in London to the WSE region. A mutual agreement must be reached via a collaborative and integrated approach. The London Assembly Green Group further stressed the need for integration across a host of issues such as housing, transport and natural infrastructure which is currently missing from the plan. The Assembly Green Group representative felt this had been done well within London but not between London and outside areas. The London Forum noted that exporting people to outside of London will overload already stressed transport links. The representative argued that encouraging prosperity and economic growth in the WSE in a way which is balanced would mean some people would have to commute out of London, relieving some pressure on transportation networks.

    HBF called for a clear structure to be expressed in the plan explaining how strategic issues will be addressed in relation to the WSE as the current plan doesn’t live up the expectations in the NPPF. A representative from Gatwick Diamond highlighted that authorities in the WSE are already under pressure to meet their own housing needs. The London Plan lacks a realistic approach of what these extra demands will mean not only in terms of housing but the associated social infrastructure. The Inspector appreciated this summarising the representative’s point by saying that the scale of the growth they will inevitably have to accommodate is huge.

    (BREAK at 11:05)

    b) Are policies SD2 and SD3 necessary, and would they be effective in assisting in implementation of the Plan and/or informing a future review of the Plan? (11:25)

    The GLA were asked to clarify what policies SD2 and SD3 were. The response from the Mayor’s team was that SD2 provides a procedural approach and commitment to collaboration whereas SD3 sets out a spatial approach to collaboration on growth and unlocking infrastructure opportunities in the WSE.

    The representative from the county of Buckinghamshire expressed their support for the policy and the general approach but asked that there be a clearer approach for future collaborations. East of England Local Government Authorities asked that the plan be more specific about which areas London will require the WSE region’s help with.

    The Common Futures Network were encouraged by the GLA’s pooling resources approach as they believe this will improve the evidence base on which spatial strategies are made. Nicky Gavron, representing the London Assembly, seconded the need for a strong evidence base as without one it is impossible to have more structured discussions and clearer actions. Gavron further suggested that there should be a technical secretariat which would work to formalise the process and create a more structured space in which to have these discussions.

    Natural England support for SD2 for wider collaboration, in particular subsection E and its inclusion of biodiversity and green infrastructure.

    The HBF felt that through the London Plan the Mayor is ignoring central government policy, in particular his duties under the NPPF, and not for the first time. In order for the plan to be implementable it needs to change. He adds that the willing partners matrix should be deleted from SD2 and SD3 as it doesn’t have the weight of the NPPF or the weight of statute.

    In conclusion the London Borough of Bromley representative felt that policies SD2 and SD3 were vague; the London Forum recalled the statement by Jennifer Peters (GLA) that 80% of the housing built in London is only affordable to 8% of Londoners; finally, LSE stressed the Mayor and by extension the plan has a duty to cooperate in a transparent and realistic way.

    notes by Emma Woodward

    Back to the EiP narrative page

    On to the next day’s blog – overall housing target

  • m10-13 notes 22 January 2019

    m10-13 notes 22 January 2019

    M10-13 Overall Spatial Development Strategy

    Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by postgraduate students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

    The Panel questions were: M10 Should the vast majority of London’s development needs be met within London?
    a)  Is the approach of seeking to accommodate the vast majority of identified development requirements between 2019 and 2041 within London justified and would so doing contribute to the objective of achieving sustainable development?
    b)  Alternatively, would accommodating more of London’s development needs in the wider South East and beyond better contribute to the objective of achieving sustainable development?
    c)  If so, is there a realistic prospect that such an approach in London and the wider South East could be delivered in the context of national policy and legislation?

    M11. Is the strategic approach to accommodating development needs within London justified and consistent with national policy? In particular:
    a)  Is the focus on the Central Activities Zone, Town Centres, Opportunity Areas and through the intensification of existing built-up areas in inner and outer London whilst protecting the Green Belt and Metropolitan Open Land justified and would it be effective in meeting identified needs and achieving sustainable development?
    b)  Alternatively, should some of London’s development needs be met through reviewing Green Belt and Metropolitan Open Land in London?

    M12. Is the broad spatial distribution of housing and employment development proposed in the Plan, including between inner and outer London10, justified and would it contribute to the objective of achieving sustainable development particularly in terms of minimising the need to travel and maximising the use of sustainable transport modes; building a strong, competitive economy; creating healthy, inclusive communities; and respecting the character and appearance of different parts of London?

    M13. Would the Plan be effective in ensuring that adequate physical, environmental and social infrastructure is in place in a timely manner to support the amount and type of development proposed? In particular:
    a)  Is the development proposed in the Plan dependent on the provision of the infrastructure identified in the London Infrastructure Plan 2050 [NLP/EC/020]?
    b)  If so, is the strategy justified and would it be effective, bearing in mind that the delivery of some of the infrastructure projects is not certain and that there is an identified infrastructure funding gap of at least £3.1billion per year?
    c)  What, if any, strategic infrastructure other than that identified in the London Infrastructure Plan 2050 is likely to be needed to support the development proposed in the Plan?

    On Tuesday 22nd January, the Examination in Public focused on the overall Spatial Development Strategy laid out in the New London Plan (NLP). The session ran over a full day and was the occasion to question the relevance (and likelihood) of meeting London’s housing, infrastructure and jobs needs within the GLA boundaries, following the ‘compact city’ approach laid out in the NLP. Overall, the discussions set out the scene for further thematic examination of the NLP’s approach to spatial development by highlighting that the housing targets it introduces would be extremely difficult to achieve, for multiple reasons.

    Firstly, there is evidence of a consistent failure in meeting housing targets set out in past London plans. Various participants including Outer Boroughs, local authorities from the East of England and South East (together called Wider South East), house building organizations and community groups expressed concerns on the feasibility and consequences (in terms of density, displacement, etc.) of the objectives set out in the NLP (66,000 homes a year). LSE London and Just Space both highlighted that London’s footprint extends beyond its administrative boundaries and this has implications for housing markets beyond the GLA border. Similarly, major infrastructure projects – and national policies – do create connexions between London and its broader functional region. As a result, growth projections and housing strategies need to account for these effects and to engage with local authorities in the Wider South East in order to realistically assess what the appropriate (and realistic) response to housing needs and population growth might be. The point was made that more engagement from the Mayor (beyond the ‘willing partners’ approach) was needed to ensure mutually beneficial strategies could be laid out in collaboration with other local authorities. The GLA team responded this was something they were pursuing and that it would take time to engage in collaboration with partners outside the GLA.

    Secondly, it was noted that the NLP differs from previous plans in that Outer London Boroughs are asked to contribute to the provision of housing and jobs in a greater proportion than Inner London Boroughs. A representative from the London Borough of Enfield welcomed this ambition but doubted it could be achieved without giving greater autonomy and flexibility to Boroughs themselves so that they can achieve their targets. A representative from the London Borough of Croydon stressed that housing and job targets should be supported by an assessment of their impact on local communities. A lot of Outer Boroughs’ housing density targets will be conditioned by the delivery of major infrastructure schemes, such as Crossrail 2, which are themselves highly uncertain. Unlocking land for development and incentivising densification might be necessary to address housing needs, but the NLP should incorporate further consideration of the issues it will raise in relation to the provision of key services (schools, health) and transport infrastructures within the GLA boundaries and beyond.
    Thirdly,  the mechanisms laid out in the NLP to accelerate housing delivery in Town Centres, Opportunity Areas and Small Sites were deemed problematic for various reasons including the lack of clarity on their impact on employment & services, local character (for Town Centres), the type of incentives and behavioural changes that would be needed to bring these forward (in the case of small sites), their ability to deliver affordable housing for all Londoners and to protect existing communities (in the case of Opportunity Areas).
    Overall, there was a consensus that the targets set out in the NLP were likely to be unrealistic and that their delivery – particularly as they focus on unlocking opportunities for private-led developments – would raise sustainability challenges, specifically in relation to the protection of local communities – low and middle income –, the provision of affordable housing and in relation to the protection of local character and heritage.
    Just Space was almost alone in challenging the spatial structure of London as it was emerging and foreseen in the draft Plan, challenging the GLA’s asssertion that the premium rents paid by firms to locate in the Central Activities Zone (CAZ) was adequate evidence to support the Plan’s continuing priority for central employment growth. JS agreed that the benefits of agglomeration do indeed accrue to businesses and to the owners of bulldings in which they operate, but that the costs of agglomeration were great too, and are borne by the population (air quality, housing costs, travel costs) or mitigated by massive state invetments in radial transport. This was partly why Just Space has called for less emphasis on CAZ growth, more on sustaining existing and growing employment in the rest of London. The spatial strategy of Just Space, of which this is an element, should have been evaluated as part of the Strategic Environmental Assessment (which we had argued under Matter 1 SEA). This community-generated spatial strategy is based in maximising local accessibility between homes and jobs, sustaining and building upon non-central local economies, focusing transport investment on orbital and bus routes as well as walking and cycling and thus reducing the need to travel.

    Edited by Enora Robin from notes by Cecilia Colombo, Gabi Abadi, Sam Colchester, Alice Devenyns and Emma Woodward

    Later Paul Burnham from Tottenham who spoke from the Just Space seat, presenting the Just Space case for part of the day, wrote
    “The existing London Plan 2016 (Policy 3.3) advocates estate demolition both to build additional homes, and because the estates are seen as bad in themselves: supposedly mono-tenure places which entrench social exclusion, etc.  All of this is all changing in the Draft New Plan, which lists in Policy H1, six sources of new housing supply, which do NOT include the redevelopment of council estates.  Of course the GLA is still facing both ways.  But it is no longer encouraging estate demolitions as hard as before.”

    back to main EiP page

    On to next blog post: Opportunity Areas M14

     

  • M7&8 notes 18 January 2019

    M7&8 notes 18 January 2019

    Matters 7 and 8: Format, Scope and Content of the Plan; conformity with national policy.

    Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk       

    Friday January 18 2019

    Note: Comments have been paraphrased. Some comments have been removed based on repetition or lack of clarity.

    M7. Does the Plan set out a spatial development strategy in accordance with relevant legislation and national policy? In particular:

    a) Does the Plan deal only with matters which are of strategic importance to Greater London?

    MHCLG:   London Plan does not provide a definition of ‘strategic’.

    Home Builders Federation:  There is a policy vacuum regarding what is appropriate for the London Plan to address. It should focus on strategic matters.

    Retirement Housing Consortium:

    • What is strategic is a matter for the Mayor to decide.
    • London Plan is regional and does not cut across borough plans.

    London Forum:

    • Current London Plan is more prescriptive than the New London Plan.
    • London Plan has been a great help: been up-to-date. It is an essential decision-making tool. London Plan is part one of spatial development plan. It is the basis of many Local Plans.

    Just Space:

    • On sustainable development: no one size fits all. There must be variations.

    London Neighbourhood Planners:

    • What makes a policy strategic?
    • Many practical implications for neighbourhood planners.

    London Forum:

    • Mayor is creating a framework through London Plan.

    Sustainable Development Commission:

    • NPPF and definition of sustainable development. Macro carbon budget.

    Greater London Authority:

    • What is of strategic importance? Variation in interpretation over time.

    Just Space:

    • Gap between policy and practice.
    • London Plan does not deal with matters of strategic importance.
    • Not consistent with national policy.

    Aitch Group:

    • What constitutes a strategic matter?
    • London Plan goes into too much detail.

    London Borough of Hammersmith and Fulham:

    • Contaminated land and sustainable design not in the New London Plan.

    London Forum:

    • Priorities shift over time.

    Neighbourhood Planners London:

    • Role of strategic spaces.

    MHCLG:

    • What should be of strategic importance?

    London Borough of Bexley:

    • There is a lack of a Plan B. What if prescriptive policies don’t work?

    Greater London Authority:

    • Aim not to reject strategies and not too much cross-referencing.
    • Sustainable design and construction and contaminated land are covered in other legislation and Opportunity Areas
    • No one size fits all in London Plan.
    • Policies continually reviewed and Greater London Authority consults with boroughs about local policy and national policy.

    [Break]

    b) Would the policies in the Plan provide an effective strategic framework for the preparation of local plans and neighbourhood plans in London?

    Greater London Authority:

    • Some policies in which London Plan has a wider remit.

    London Forum:

    • Supports London Plan.

    London Assembly Planning Committee:

    • Support plan teams and representatives.
    • London Plan deals with matters of strategic importance.
    • Unless plan has a clearer objective and strategic direction then it won’t have a sufficient framework.

    London Borough of Hammersmith and Fulham:

    • If sustainable design and construction and contaminated land were in the plan then it would have a better strategic vision. If no policies then no supplementary planning guidance.

    London Borough of Bexley:

    • Plan does not provide a strategic framework.
    • How do you reflect the aspirations of local people?

    Aitch Group:

    • Focus on time frame and matters in terms of strategic direction.

    Home Builders Federation:

    • London Plan might become ineffective as it contains too many policies.
    • Requires a lot of contextual work by London boroughs.

    London Forum:

    • Concern about local resources and skills.
    • There should be area-based frameworks.

    London First:

    • Best practice design guidance should be provided.

    Neighbourhood Planners London:

    • Neighbourhood forums accustomed to working with Local Plans.

    MHCLG:

    • A consistent set of terms for boroughs would be helpful.
    • There should be aspects for broad strategic plans.
    • Are the good growth sections policies or objectives?

    Greater London Authority:

    • London Plan saves boroughs some work to a degree.
    • Detail should be at local level.
    • New London Plan is not that bloated.
    • London review panel can review design.

    (c) Does the Plan address detailed issues that would be more appropriately addressed in local plans and neighbourhood plans?

    Aitch Group:

    • Detail is more appropriate in Local Plans.

    Retirement Housing Consortium:

    • Not necessary to have strategic objective only provided in London Plan.
    • Boroughs may implement differently.

    London Forum:

    • Fast approval rather than long debates can help build more affordable homes.

    London Neighbourhood Planners:

    • Current version of London Plan is not great at exploring how strategic priorities can be balanced.

    [Unknown]:

    • Plans should be simplified and more strategic to be more effective.

    London Borough of Bexley:

    • Not always possible to provide level of detail.

    Home Builders Federation:

    • Merit of London Plan is it is a way to do heavy lifting.
    • Issue with idea that increasing detail will make it more deliverable.

    Greater London Authority:

    • Challenge in terms of level of growth.
    • Detailed space standards and no comments about level of prescription.
    • SPG: feedback on over-egging.

    [Break]

    d) Is the approach to planning in London described in paragraphs 0.0.21 and 0.0.22, particularly with regard to the relationship between the spatial development strategy and local plans, neighbourhood plans and the Borough’s development management responsibilities, justified and consistent with national policy and legislation?

    MHCLG:

    • Local Plan coverage can be limited in terms of how up-to-date and comprehensive it is.
    • London Plan has been through its iterations in a timely manner.

    London Forum:

    • Requirement for detail at Local Plan level.

    Home Builders Federation:

    • Requirement of Local Plans to reflect NPPF.

    Aitch Group:

    • SPG is a good place.
    • What if policies are examples of how an objective can be achieved?

    London Neighbourhood Planners:

    • ‘Neighbourhood plan’ and ‘neighbourhood forum’ should be included as part of glossary.

    Just Space:

    • There should be more emphasis on ‘neighbourhood’ in London Plan.

    Greater London Authority:

    • Neighbourhood plans and forums will be in the New London Plan.

    [Unknown]:

    • How is plan in accordance with policies and role in planning applications?
    • Local authorities could create policies to achieve aims of London Plan.
    • Can we remove over-prescriptive aspects of the strategic plan?

    Greater London Authority:

    • Policy is established by local authority.

    Home Builders Federation:

    • What is role of national policy?

    M8. Given the legal requirement for the Mayor to have regard to the need to ensure that the Plan is consistent with national policies, is it justified for certain policies to deviate from national policy and guidance?

    Greater London Authority:

    • Aspects are not consistent with national policies and aspects are not consistent with an element of national policy.

    Home Builders Federation:

    • Some policies more effective at borough-level.

    MHCLG:

    • Is there evidence of justifications for policies not being consistent with national policies?

    London Forum:

    • London Plan and NPPF.

    Home Builders Federation:

    • Impact of London Plan on other parts of the country.

    Greater London Authority:

    • London Plan can be inconsistent with national policy.

    London Assembly Planning Committee:

    • More resources required.

    END

    Back to EiP narrative page

    On to next blog post: Spatial development strategy (M10-13)

  • M9 notes 16 January

    M9 notes 16 January

    London Plan EiP Week 1  16 January 219 M9

    Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

    M9 Good Growth

    M9. (a) Are Good Growth policies GG1 to GG6 consistent with national policy and/or justified, and would they help ensure that the Plan provides an effective strategic framework to achieve sustainable development? [Bold: Questions posed by the Panel in advance.]

    GLA:A few more amendments we intend to make.

    –  Correct an omission of GG1 (FA), race should have been on the list.

    –  GG5, to recognize importance of environmental issues shaping the economy – reconsider benefits of circular low carbon economy

    –  GG1 – a new clause for engagement

    Just Space: a number of these changes are very welcome. However, not having the precise wording in front of us makes it difficult to comment. Not clear whether amendments are to policy or text. Will you be able to tell us when the amendments will be published online?

    London Forum: GG2 jumps immediately to a design led approach without assessing accessibility. Should start with priorities, then accessibility, and then the design led approach. No logic to current sequence. 
[14:24]

    Footwork Architects: Such a re-ordering is needed. There is a lack of priority.

    London Friends of Greenspace: GG2D is currently “protect and enhance open spaces” it should be protect, enhance and expand. Addressing deficiencies is important.

    Just Space: See omissions in good growth principles:

    –  GG1, issue around governance – relating to support and resourcing of community networks

    –  GG2, we would like to see food growing and access to healthy food added to green infrastructure

    –  GG3, healthy cities needs improvement

    –  GG4, we would like to see reference to ensuring access at all income levels and specialist needs and should mention participation of London communities in housing (re Grenfell)

    –  GG5, no reference to supporting local, diverse economies

    –  GG6, issue around low-income households and fuel policy needs adding .

     

    Peckham vision: We need to have a consistent policy in London in the way that the community sector is involved in planning.

    Footwork:Omission in GG4 – London remains an inclusive place. Our general point is whether it translates into policies. One aspect of this is preventing displacement of existing communities (no mention of this).

    London Tenants Federation: Housing that meets the needs of low-income communities should be included in GG1 and GG4 
[14:46]

    Aitch Group: In the intro there is a reference to the housing crisis, but later on, the objective to ‘ensure that more homes are delivered’ is weak.

    Just Space: It would be helpful if GG amendments are published so that we will be informed for future hearings.

    GLA:They will be published as early as possible for future sessions.

    London Forum: In previous plans the suggested changes were mentioned in the morning.

    Aitch Group: If GGs are policies would expect them to be more specific in terms of linking to other parts of the plan.

    London First: Defining policies as objectives is needed. Difficult as development management policies.

    SD Commission: Rather than aspirations we want more specific language that integrates metrics and targets.

    Assembly Planning Committee: effective policy would include a clear vision with a set of objectives. The GG policies have neither of these. GGs should be redefined as strategic objectives. Insufficient weight is given to social inclusivity and environmental improvement, which are the drivers to economic prosperity, not fetters of it.

    Just Space: GGs are objectives. It’s not clear in chapter 1 what the vision is and what the objectives are. In foreword the mayor mentions: rebalancing development, a socially integrated and sustainable city where people have more of a say (we like these aims). But see that this is not followed through.

    Neighbourhood Planners London: GGs seem to be objectives, perception across London that neighbourhood planning has not had an impact since 2012. We think they (NPs) are good at identifying small housing sites and infill sites. Think that the GLA has a bit of a blind spot when it comes to neighbourhood plans.

    Just Space: ‘A city that works for all Londoners’ is mentioned by the Mayor but not defined. Would like to see this defined. There is an extremely important issue around migrants (they do not feel that they have equal rights). Would be good to have definition that includes all migrants in for ‘all Londoners’ definition.

    The glossary now provides a different definition of Sustainable Development from NPPF 2012’s clear definition. The NPPF definition provides 5 guiding principles. Changes shouldn’t throw out good governance; planning within environmental limits; and using sound science responsibly. Would like to see the 5 principles restored.

    Footwork:The social role is not sufficiently applied. Use the NPPF definition for being proactive about SD.

    Just Space: We support the good growth approach – it’s an excellent change. What I said earlier was around the usability of the plan.

    (b) Are the policies in chapters 2 to 12 of the Plan appropriately informed by and consistent with Good Growth policies GG1 to GG6?

    [16:08] London First: GG1-6 cover a huge range of objectives but there is no prioritisation. Housing provision has no reference.

    London Tenants Federation: Opportunity Areas are an unwelcome thread in the London Plan. Not brownfield sites often, often where people work. In contradiction with many of the good principles that we have been elaborating on. Exclusive housing developments for high end that do not meet the need of the people living there. Push out businesses that meet the needs of the people that live there, new jobs don’t meet local needs. Want the mayor to make a close examination of Opportunity Areas to see how they have impacted the people in the areas already living there.

    Footwork: GG policies don’t satisfactorily translate through to the chapters.

    Assembly Planning Committee: Making the link between GG and the chapters has bedevilled the plan. We are hoping that the GG policies will be reframed as strategic objectives. We feel that there are inconsistencies (H12) which pushes one-bedroom studios and lacks provision for family housing. G8 for tall buildings does not refer to the energy efficiency of constructing and maintaining tall buildings.

    London Forum: If there were cross-references from the GG to the rest of the plan then that would be a checklist to see if you have policy coverage.

    Peckham Vision: In the GG section local knowledge and experience in neighbourhoods is omitted. This has an impact all the way through.

    Just Space: Lack of expression of strategic importance of food in GG policies. Earlier I proposed a GG7 just to focus on food. Mention of it is focused on problem of childhood obesity. Absence of in- depth appreciation of food security.

    London Forum: Tendency among some of us to make this a managerial document rather than an aspirational document.

    Just Space: Would like to see monitoring: is London a fair and inclusive city; equalities and development of civil society (depth and diversity of engagement); the levels of trust in authorities that people feel. What determines homes and housing in the London Plan?

    Footwork:Aims are socially very ambitious but then don’t quite translate into the policy. If there is no policy to monitor and scrutinise them, then you devalue their significance.

    London Forum: Has not been a cross check between key principles and monitoring.

    Peckham Vision: Focus on development has been about clearing out and replacing. We have proved in Peckham that this does not need to be the case.

    Just Space: Conflicts around monitoring surround the lack of clarity by what ‘Londoners’ means.

    Notes made by Lyuboslav Petrov and Sam Colchester

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    On to the next blog post: scope of the plan and consistency with national policy M7&8

     

     

  • M5 notes 16 January

    M5 notes 16 January

    Did the Mayor engage…?

    Draft London Plan Examination in Public (EiP) 16 January 2019

    Day Two:

    Warning:Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

     

    M5. Irrespective of matter M4, did the Mayor engage constructively, actively and on an on- going basis during the preparation of the Plan:
    a) with all relevant local authorities and other prescribed bodies in London? (Bold type is the questions posed by the panel in advance.)

    Mostly the panel and participants were in agreement that engagement did take place, thus, if the duty did apply to the Mayor – then they did conform. However, there were disputes about whether this engagement was constructive, active, meaningful and productive.

    Participant Mr Edwards (Hillingdon Council) argued that the Mayor did not comply and highlighted the Mayor’s legal obligation for engagement in the GLA act 1999 section 335, 339 and 348 (public participation, publicity, consultation and outputs). He emphasised that the Mayor did engage on the basis of SHLAA methodology that rolled forward. The Mayor expressed a commitment, following consultation on the methodology, that the matters would be developed and shared with Boroughs.That is what he should have done and he did not do it. The Mayor agrees that this further consultation did not take place, but continuous engagement had done so. The Mayor recognised his duty, and failed to do this without any legitimate reasons, claims Hillingdon.

    The panel ask the Mayor what statutory requirements apply to the Mayor in consultation. The Mayor responded with Section 32 which sets out carrying out all duties outlined in Section 30 in determining what consultation is appropriate. This emphasises that engagement must include boroughs but it is not a duty to consult.

    b) all relevant local authorities and prescribed bodies outside London on strategic and cross boundary matters in the wider South East?

    Some participants asserted that again engagement was carried out but many important things weren’t resolved. These included issues of housing, excavation spoil & waste and strategic infrastructure priorities.

    The Mayor further insists that engagement with the wider south east did take place through partnership meetings, officer working group meetings, steering group meetings and summits. In those meetings 5/20 addressed housing.

    There is now a gap of 1000 dwellings per year between London’s planned supply and estimated need which is a small figure (1.5% of overall housing need). The Mayor is clear that he is not asking authorities outside of London to address this to supply but is applying the willing partners approach in order to provide some contingency to address this gap. The Mayor acknowledges this approach takes time and states if they are consistently overtime and not achieving KPI targets they will look at a partial review of the plan.

    Participants argue if more engagement had been made, so the wider south east could understand the ‘willing partners’ approach and what it entails – possibly this could be more successful.

    The Mayor indicates that it is not practical to move people outside of London as the mayor has no jurisdiction out of London. There is no government incentive to move people out of London.

    LB Bromley remind the mayor that the previous inspector gave advice for future plans which was not followed up, with zero outcome. This context highlights lack of meaningful engagement.

    East of England Authorities highlight issues as to how productive engagement has been especially in the outcome of the plan. Speaker questions where the impact of the shortfall of housing this will fall and states that failures are ‘London failures’ and should not impact of south England.

    South East England Authorities also agree that they are unclear on what the ‘willing partner’ approach entails.

    The Mayor disagrees and states that is not true that they have not made any outcomes from engagement. They argue they are jointly engaging with government in issues of housing, jointly addressed infrastructure priorities, they have produced demographic and labour projections, projections on local enterprise partnerships and their contribution to the wider south east.

    The draft plan outlines the willing partner relationship yet there is not a one size fits all approach. The Mayor argues if they do not take this approach the only alternative is for authorities to take a more mechanistic approach.

    Participants again place emphasis on the lack of dialogue between the Mayor and local authorities.

    Notes made by Lyuboslav Petrov and Sophie Hardcastle

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