The draft New London Plan is close to the end of its progress towards final adoption. As Just Space and its member groups get to grips with the near-final version we gather here some responses from members. More are welcome.

As at New Year 2020 the situation  is this: On 9 December the Mayor issued the version of the Plan he ‘intends to publish’, incorporating changes recommended by the Panel of Inspectors. At the same time he published his responses to the Panel, including his reasons for rejecting some of their recommendations. All these documents can be found at https://www.london.gov.uk/what-we-do/planning/london-plan/new-london-plan/intend-publish-london-plan-2019.  The Secretary of State has until 20th January to direct any changes. After that the London Assembly gets to consider it but can only accept it or, by a 2/3 majority, reject it entirely. Then it becomes the adopted Plan.

UPDATE 23 January: The London Assembly Planning Committee held a Q&A with London Plan staff today and the webcast is available https://www.london.gov.uk/planning-committee-2020-01-23. We also learn (via Kate Gordon, FoE) that the GLA expects to have the Secretary of State’s response on 17 February.

What were we looking for? After 2 years of work, Just Space and its member groups submitted our own Community-led plan for London and this 10-point summary in 2017:

The Mayor should…

1.  …put in place a programme of effective, meaningful and continuous engagement – underpinned by the principles of inclusion and fairness – that enables all Londoners to work with the Mayor and officers in a spirit of co-operation and in co-production of the new London Plan and all the Mayor’s Strategies. Deep changes are needed in the governance of the city and this is a starting point.
2. …develop a London Housing Bill to give the Mayor devolved powers to bring housing reform in London, especially city wide rent control for private renters, regulation of landlords through mandatory landlord licensing across London and meeting the challenge of providing not-for-profit, social rented housing.   The term “affordable housing” should be removed in any documents produced by the Mayor.
3.  …care for existing homes, neighbourhoods and communities and respond to high levels of fuel poverty by scaling up refurbishment and retrofit programmes and protecting existing council housing and housing association estates.
4.  …foster a more localised, fair and green economy that acknowledges the diversity found in high streets and industrial estates such as low cost workspace, light industrial units, warehouses, studios and sheds, as a strength and a driver of the city’s future well being.
5. …promote affordable and accessible public transport, supported by revenue from road user charging to tackle congestion and pollution.
6.  …care for the environment by making London a Blue Green City, placing value on the connection and interaction between London’s blue and green assets such as green spaces, waterways, nature and air quality.
7. …require Social Impact Assessments to be undertaken to measure and calculate the impact of development proposals on existing residents and businesses in neighbourhoods being considered for substantial change.
8. …support Lifetime Neighbourhoods, scaled up to Lifetime Suburbs in Outer London, providing key amenities and job opportunities locally, thus reducing the need for costly and polluting travel.
9. …place a moratorium on any more Opportunity Areas, bringing forward an evaluation and review of successes and failures so far and a new model of regeneration that prioritises social sustainability and social infrastructure and embeds more democratic and participatory mechanisms into the regeneration of areas.
10. …develop new indicators for measuring the success of the city, such as the % of the labour force that has a secure job that pays at least the London Living Wage, and measuring life satisfaction using wellbeing surveys.

and then we made detailed comments on the consultation draft Plan, followed by individual submissions on most of the issues considered by the Panel of inspectors at the Examination in Public. We estimate that 83 community groups took part and spoke at the hearings of the Examination in Public, some directly invited and others using the Just Space ‘hot seat’.

Here are comments and assessments contributed by members/ groups:

Friends of the Earth comments on the whole Plan from an environmental point of view FoE on London Plan panel

London Forum provisional comment, likely to be superseded soon London Plan 2019 Examiners Report – Peter Eversden

Just Space Economy and Planning group on industrial and workplace issues JSEP Industry workspace comments

Natasha Sivanandan (Haringey Community Campaign) writes a short comment on Equalities & call for challenges to the Mayor at the next Question Time on 23 January
[N Sivanandan A Dream for Developers], adding:
I think the following are 2 things all in JS can agree on because (a) we said so at the EIP on behalf of JS and (b)  the Inspectors have rejected everything we said on these 2 issues.  They are:
1.  The Inspectors have ignored all our submissions on the Mayor’s failure to consult properly and particularly with groups with “protected characteristics” under the Equality Act 2010, and they have failed to have regard to the leading Supreme Court caselaw on consultation that we cited in our evidence to the EIP.
2.  The Inspectors have failed to properly consider or respond to our detailed evidence and legal submissions on the Mayor’s failure to have regard to the Public Sector Equality Duty under section 149 of the Equality Act 2010 and as a conequence the London Plan is unlawful and lets down some of its most vulnerable citizens.

Meenakshi Sharma (Ilford  NOISE) on Equalities aspects (and a more detailed version may follow) Equalities and IIA Ilford Noise

Michael Edwards on positive gains in the Plan Edwards positive gains

John Cox (GUA and Brent Cross Alliance) on Transport Transport comments John Cox

Paul Burnham (Haringey DCF) on housing highlights Housing highlights in NLP Burnham

Jennifer Robinson on Viability & Opportunity Areas Robinson Comments on Panel

Assessments by other people or organisations:

Duncan Bowie article in October 2019 Town and Country Planning, ending with comments on the Panel Report Bowie TCP article on London Plan.Oct 2019

Blog post from Lichfields

Urban Design London, report on discussion – mainly among Borough officers, clearly – on design aspects of the Panel report, mainly Small Sites. Download contains 5 copies of this picture

Consultants Barton Willmore are blogging, initially on the aggregate housing targets & failure to “meet housing needs” with GL. http://bartonwillmore.co.uk/Knowledge/News/2019/What-next-for-the-London-Plan

Similarly, in a very brief note, consultant Iceni Projects speculate on whether the Secretary of State might overrule the Mayor on housing targets https://www.iceniprojects.com/5095-2

Just Space is active on many fronts and this post is a catch-up.

London Plan

The hearings (Examination in Public, EiP) on the draft new London Plan ended in May with about 83 community groups participating. Our understanding is that what now happens is as follows:

The Panel produces a report recommending changes to the Plan for the Mayor’s consideration, which the Mayor can decide to accept or (giving his reasons) to reject.

Once the Mayor has decided which of the suggested changes he intends to accept, he will send a revised draft Plan to the Secretary of State for Communities and Local Government. They then have six weeks to decide whether or not they wish to direct that any changes should be made.

Assuming the Secretary of State decides not to make a direction, the Mayor is required to lay a copy of the draft proposals before the London Assembly, which has 21 days to decide whether to reject it in its entirety (rejection requires two thirds of those voting in favour). Provided the London Assembly does not decide to reject the Plan, the Mayor can then publish the London Plan.

Just Space has written to the GLA asking that the Panel report – which we understand has been received by City Hall – should be published right away in the interests of transparency. There is no rule we know of that requires the Mayor to withold it while the recommendations are considered. The Panel Report has now been released by City Hall in response to our request. Here it is. 21 October.

In the coming months Just Space plans to review the outcomes of the London Plan EiP and consider the main issues to take forward. This could include the preparation of a 2nd edition of the Community-Led Plan with new chapters (see publications page) and with new policy ideas (proposed – for discussion).

Just Space and its member groups challenged the draft plan on many deficiencies, notably:

• Failure to discharge the Public Sector Equalities Duty (PSED) throughout the planning process
• Failure adequately to consider alternative strategies, notably the Just Space community-led plan. 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 maximising the stock of social and low-rent housing. This mistake will lead to the backlog of unmet housing need getting even worse in the coming years. [note added 28 Sept: the press reports a rumour/leak that the Panel recommends lowering the target to a more plausible level.]
• Failure adequately to protect the jobs and services in London’s industrial areas, in and behind high streets and in town centres as housing is prioritised. 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 and timelines of targets.
• The absence of convincing ways of paying for social and physical infrastructure without cutting in to the provision of low-rent housing; contributing to unsupportable increases in housing density and probable land price inflation.
• Continuing failure to devise transparent and participatory mechanisms for the designation, planning and implementation of Opportunity Areas.

Universities – Communities Knowledge Exchange

Following on from a session at the Tate Exchange in July 2018, Sarah Bell at the UCL Engineering Exchange successfully applied for funding of £30,000, half of which is earmarked for Just Space to convene joint meetings between community groups and University participants.  This 12 month programme of work (which started in January 2019) considers how we scale up the support on offer from Universities to community groups, and the structures and mechanisms that are needed for effective partnership working London wide.  Just Space has engaged Sona Mahtani to co-ordinate and may engage others.  A free conference will take place on 23 October: details and booking at https://www.eventbrite.co.uk/e/conference-universities-and-community-groups-collaborate-tickets-74436560757  Document prepared for the event (36 pages, PDF download)

Calthorpe Community Garden – pilot social impact assessment

The Calthorpe Community Garden (in Camden) responded to a planning application by UCL Estates for the Eastman Dental Clinic buildings to be redeveloped as a research centre on neurology and dementia, an application that has significant impacts on the garden and the surrounding community.  Just Space was commissioned to undertake a community profile, impact assessment and propose ideas for future-proofing the Calthorpe project.  This has been an opportunity to pilot a Social Impact Assessment – a kind of pre-development study which Just Space has long insisted should be normal in major developments.  The work was completed in August, the fieldwork being undertaken by Sona Mahtani and Karl Murray. Meanwhile Camden Council received the report and has now granted permission. Calthorpe SUMMARY August 2019 | Calthorpe Report_ community_impact August 2019 final

London Market Campaigners network

Just Space has contributed to the national research project on Traditional Street Markets, led by Sara Gonzales and Myfanwy Taylor at the University of Leeds.  Funds were identified to support a Conference and networking between London market campaigns.  Just Space was invited to hold the funds of £9,500.  Saif Osmani is convening the project, with support from Mama D.  The project is due to end in October and a funding application will be made to try and sustain this emerging network.

Industrial strategy

Myfanwy has gained a small grant from Leeds University to hold a workshop on industrial strategy.  Just Space is a partner.  The aim is to bring together academics from the Universities of Leeds, Sheffield, Manchester and Liverpool to discuss how to produce industrial strategies in a collaborative way, including with community groups.

Land Justice Network – towards a land reform bill or manifesto

Just Space was one of the founding partners of this national network. Our main contribution has been to a Policy working group, which has produced “Working towards a People’s Land Policy: land reform from the ground up”.  This report is now published (download below).  Just Space is asked to share this document among its members and gain feedback.  It would be best to do this through a workshop discussion.  The longer term aim is to introduce a Land Reform Bill (England) to the Parliament. Peoples-Land-Policy-draft-Sep-2019

Update July 5 2020: the web site thoroughly refreshed and with details of consultation process on Environmental Land Management Scheme https://peopleslandpolicy.home.blog

Greater Carpenters Neighbourhood Forum

The Neighbourhood Plan, which Just Space has been supporting for a number of years, has been submitted for examination.  This is the first in London that is based on a council estate. The examination is likely to be in the autumn.  Before this, the LLDC Local Pan has been examined in September and includes a housing target for the Greater Carpenters which implies the demolition of the council estate.  Marian Larragy and Richard Lee are supporting the Forum, with funds from Locality. They report that the arguments of the Forum were very well made and appeared to carry weight with the inspector, whose report is now awaited. The key issue is that the draft Local Plan contains a housing target for the Carpenters Estate which could be achieved only by a great deal of demolition of existing homes. The pending Neighbourhood Plan, by contrast, proposes to retain existing homes (avoiding community displacement and waste of the embodied carbon) and increase the density by adding a great deal of infill housing – though less than the LLDC target.

Fairville – proposed EU research project

The project title is “analysing alliances between universities, civil society and professionals: research and collaborative urban action towards a just city”.  It involves participants from UK, France, Germany, Belgium, Portugal, Netherlands, Spain, Lebanon, Thailand, Senegal.  It is convened by groups in Paris and the UK participants are Just Space and the UCL DPU (Development Planning Unit).  Stage 1 approval has been achieved, and the deadline for a full funding application is April 2020.

Council estates research with LTF, Kings College London and Leicester University

This research examines what happens to the residents of council estates when faced with the threat of demolition. Interviews have taken place with residents or ex-residents of 6 case study estates (all in London).  Data has been collected for all council estate demolitions in London since 1997.  Funds are available to Just Space to hold a Conference in February 2020 and to use other methods to disseminate the findings of the research.

Requests for Just Space to attend/speak at conferences and seminars

Just Space has had recent invitations to events on community engagement in planning, led by London’s think tanks.

Centre for London – Developing Trust Conference (speakers –Eileen Conn, Leslie Barson, Michael Ball)

Town and Country Planning Association Inclusive Planning in London Stakeholder Summit (speaker – Robin Brown)

New London Architecture (NLA) Enabling Communities round tables (speakers – Eileen Conn, Richard Lee)

What should be the criteria for Just Space accepting/ declining these invitations?  Is taking part in a lively discussion (and promoting our ideas) sufficient reason to attend, or should we be seeking to change the analysis and approach of the think tanks?

Grand Union Alliance (GUA)

JS was commissioned back in Spring 2016 by the London Tenants Federation (LTF) to help LTF deliver UCL community-based research supporting the community network GUA in Old Oak Park Royal area (Mayoral Development Corporation OPDC). Although due to end in Spring 2018 when LTF’s involvement ended, the £15K received was stretched to February 2019 and has assisted London Plan work (on OAs). Since then, further support to GUA, particularly the OPDC’s Local Plan EiP, has been provided through an agreement with UCL Geography.

On looking for resources to sustain GUA, the OPDC has asked the GUA to make a proposal to OPDC Board (September) to facilitate an OPDC-GUA continuing ‘dialogue’.  This could provide funds to hire a support worker plus ‘buying in’ of advice from JS but issues of independence need consideration,  For the forseeable future, JS would be the parent body for the GUA.

This post will be augmented in the coming days with links and reports. 25 Sept 2019.

20 May: Just Space has responded to the document produced by the Mayor and still considers that the draft London Plan is unsound because the Public Sector Equalities Duty has not been discharged. Our submission is Just Space response to Panel Note 7.3 20 May 2019  There are no plans by the Panel for further discussion on this and we don’t yet know whether other participants have responded to Panel Note 7.

28 April:  As the draft London Plan Examination resumes for its final month of hearings, the GLA publishes its response to our day 1 challenge that they had not dealt properly with the Equality Duty. The panel of inspectors required the GLA to respond by 18th and the results were so big (160 pages) that they didn’t make it onto the web site until 23rd April. The history is in previous posts.

The response by GLA is partly legal argument but mostly the detailed discussion of how city hall expects each of its policy areas to impact (positively and negatively) on each of the 9 “equality” groups specified in the law. We have just 2 weeks to digest and comment on all this material and do urge member organisations to read and evaluate at least what is written in Appendix 3 about population groups or issues which specially concern them. The report is set out in 9 sections, corresponding to the 9 “equality groups”:

On March 12th 2019 the panel of inspectors examining the draft London Plan called on the Mayor/GLA to report urgently on the expected impacts of the Plan on each of the groups in society protected by law.

This follows the Just Space intervention on day 1 of the hearings in which the adequacy of the equalities impact assessment was challenged, the panel’s subsequent instruction that the unpublished details of the analysis should be released and the panel’s invitation for comments on that further material (see our previous post).

Today’s statement from the panel reads:

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

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

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

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

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

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

The first 2 weeks of public hearings on the new London Plan have been held and Just Space offers a blog to help people follow the debates. It starts here.

This is the first time that London Plan hearings have ever been so easy to follow. Journalists rarely attend, there is no broadcasting except on a few days, and very few Londoners can afford to sit in City Hall for 35 days. We are very grateful to students at UCL who have been taking and editing notes.

If you prefer to have the full details you can follow the narrative listing page which has links to the individual blog posts for each item.

This is what we wrote when the hearings opened;

EiP begins with warning on discrimination

Tuesday 15 January sees not just a ‘meaningful vote’ in Parliament but the opening of hearings at City Hall on the draft new London Plan. In so many ways the Plan flies in the face of evidence and has avoided exploring the alternatives the city could follow. It looks bad but the panel of inspectors is now asking most of the right questions.

Just Space and the groups which make it up have been submitting their responses to the first weeks of questions posed for the Examination in Public. A new page on this web site puts the panel’s questions alongside our responses (in red) and the timetable: https://justspace.org.uk/hearings-eip-2019

That page will grow throughout the EiP process which stretches through to May 2019 and we’ll add other organisations’ statements and reports on the hearings if we get enough volunteers to cover 33 days.

Bookmark it as a unique resource.

The hearings (Examination in Public EiP) on the draft new London Plan start mid-January. Community groups are busy preparing.

Just Space (with some support from UCL’s Bartlett School of Planning) is holding a series of briefing and report-back meetings for community groups involved and for students and others following the process.  The first was on 26 November. Slides are here [ UCLJS briefing 26 Nov 2018.ppt] and a writeup will follow.

The next meeting is 5 December.  Details on our events page.

For more about the process, scroll down to previous post.

Stop press 7 Nov: presentations for the Technical Seminars 6 and 7 November are now available. Here you can also watch the webcasts of the seminars on both days. https://www.london.gov.uk/what-we-do/planning/london-plan/new-london-plan/examination-public-draft-new-london-plan#Stub-175730

Our notes on 6 November (employment & household projections, housing need and demand, land supply) are here.  On 7 November (Zero Carbon and perhaps Waste to be added) here.

Continue reading →

The draft new London Plan enters public hearings in January. Just Space and some of its member groups have just written (11 October) to the panel of inspectors who are preparing this ‘Examination in Public’, pointing out key questions which have been missed in their draft list and, in come cases, seeking to be heard at the hearings. The procedures were described in our previous post.

The  Comments on draft lists of Matters submitted by Just Space will make most sense read alongside the panel’s drafts (linked from our list)

We’ll add comments submitted by our member organisations and others if and when you send them to us.