Hearings / EiP / 2019

This page chronicles the Hearings at the Examination in Public (EiP) of the draft New London Plan. It will follow the topics and arguments as they happen, from 15 Jan to May 2019. This page is a good page to bookmark and come back to, or to find a topic. The front page of the website will continue to have news stories.

The EiP takes place in the Chamber at City Hall, The Queen’s Walk, SE1 2AA
See the Hearings programme here .  A few sessions, labelled below, will be livestreamed / webcast at https://www.london.gov.uk/media-centre/mayoral
All sessions are also available as audio files (200-500 MB each) to download at
https://data.london.gov.uk/dataset/london-plan-eip-2019

eip day 1

Skip direct to: inequalities | good growth | alternativeshousing target | housing target in detail| affordable housing | green belt | “regeneration” |densityopportunity areas | culture | industrial land | green infrastructure |  carbon emissions | circular economy | fracking | floods & SUDS | social infrastructure | transport | air quality | centres | viability of the plan | monitoring |

Article on the EiP by Julia Park of architects Levitt-Bernstein in Building Design.
Other articles and blogs on particular topics are linked below for the relevant Matters.

Week 1 Tue 15 Jan – Legal and procedural matters 
Sustainability Appraisal
M1. Does the Integrated Impact Assessment (IIA) and Addendum Report (NLP/CD/04 & 05) meet legal and national policy requirements relating to sustainability appraisal and strategic environmental assessment? In particular:
a) Is it suitably comprehensive and has it sufficiently evaluated reasonable alternatives and does it provide a basis for future monitoring?
b) Have the recommendations made within the IIA been adequately addressed within the Plan?
Just Space response: equalities and health issues are inadequately treated; the exploration of alternatives is deficient and fails to satisfy the regulations; the analysis fails to make adequate provision for monitoring outcomes. Just Space has tried hard at various stages to influence the IIA process but without any detectable effect. Full Just Space response: M1 JS Sustainability Appraisal 2718 in full
Very helpful response from LSE London who also consider the IIA unfit for purpose – though with a rather different argument.
GLA response / defense.
Friends of the Earth: failure of IIA to evaluate a sustainable alternative; bizarre internal contradictions in the approach.
Buckinghamshire districts consider the alternative of developing some Green belt within London wasn’t adequately explored.
Enfield LB considers Green Belt should have been more seriously evaluated and has many other objections.
LSE London Group is highly critical of the failure to examine real alternatives and the failure to use evidence in the evaluations, dismissing the analysis as not fit for purpose.
Notes from the examination session
Blog about this first day from Ian Gordon of LSE London

Equality of Opportunity
M2. Does the Integrated Impact Assessment and Addendum Report (NLP/CD/04 & 05) indicate that the Plan will help to advance equality of opportunity between people who share a “protected characteristic” as defined in the Equality Act 2010 and those that do not share it and further the other two aims of the Act? In particular, which policies of the Plan will achieve this? [“Protected characteristics” are age; disability; gender reassignment; pregnancy and maternity; race; religion or belief; sex and sexual orientation.]
Just Space Response: 
Were the plan to proceed on the basis of the current IIA it would do so unlawfully.   M2 JS equalities response in full
The Trust for London is especially critical of the failure of the IIA to explore the impacts of policies on specific protected groups, citing as a key example the adverse effects of estate regeneration on specific ethnic and disability groups. 
Notes from the examination session

Note. Further information has been published by the GLA on equalities known as “The Supplementary Information on Equality Assessment. The panel invited further submissions on this additional material and the seven responses received are 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

Habitat Regulations Assessment
M3. Does the Habitat Regulations Assessment Update Report (NLP/CD/07) meet the requirements of the Conservation of Habitats and Species Regulations 2017 and relevant national policy and guidance? In particular:
a) Does it adequately address whether the Plan would adversely affect the integrity of European conservation sites either alone or in combination with other plans or projects?
b) Has it taken sufficient account of relevant case law including People Over Wind and Wealden?
c) Does the Plan incorporate any recommended mitigation measures or alternative solutions?

Participants invited for M1-M3:
Brethren’s Gospel Trusts
Buckinghamshire District Councils and Buckinghamshire Thames Valley LEP Equality & Human Rights Commission
Friends of the Earth England, Wales and Northern Ireland
HEAR Equality and Human Rights Network
Just Space
Lands Improvement Holdings
London Borough of Enfield
London Community Neighbourhood Co-operative
London Gypsies and Travellers
London School of Economics
My Fair London
National Alliance of Women’s Organisations
Natural England
Trust for London

Week 1 Wednesday 16 January : Legal and procedural matters: Duty to Cooperate and Consultation [M4-M6]
Duty to Cooperate
M4. Does the duty to cooperate set out in section 33A of the Planning and
Compulsory Purchase Act 2004 apply to the Mayor’s preparation of the Plan?
Notes from the session
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;
and
b)  all relevant local authorities and prescribed bodies outside London on strategic and cross boundary matters in the wider South East?
Notes from the session
Consultation and Engagement
M6. Was the consultation carried out during the preparation of the Plan in accordance with relevant legislation, and did it involve early and meaningful engagement and collaboration with the community, local authorities, organisations and businesses? Just Space responds in relation to community consultation. It has not been sufficiently sustained or systematic. Detailed proposals are made for bringing it up to standard. 
Just Space written statement 2019 M6 Consultation and Engagement 2718
Notes from the examination session

Participants invited for M4-M6

Access Association
Buckinghamshire County Council
Camden Conservation Area Advisory Committees
CPRE London
East of England Local Government Association
HEAR Equality and Human Rights Network
Highways England
Home Builders Federation
Just Space
London Borough of Bromley
London Borough of Hillingdon
London Chamber of Commerce and Industry
London Forum of Amenity and Civic Societies
London Tenants Federation
Natural England
South East England Councils / South East Strategic Leaders

Week 1 Wed afternoon 16 January:  Good Growth M9
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? (b) Are the policies in chapters 2 to 12 of the Plan appropriately informed by and consistent with Good Growth policies GG1 to GG6?
Just Space response: even with the welcome addition of ‘good=inclusive’, the good growth concept is too imprecise to guide the Plan; the sentiments in the chapter are not carried through into the substance and policies and additional indicators are needed so that the plan’s achievements can be measured.  M9 JS Good Growth response in full
Notes from the examination session

Participants invited for M9:

Aitch Group (Davies Murch /Barton Willmore) British Property Federation
Home Builders Federation
Footwork Architects Ltd
Just Space
London Assembly Planning Committee
London Councils
London First
London Forum of Amenity and Civic Societies
London Friends of Greenspaces Network
London NHS Clinical Commissioning Groups / NHS London Healthy Urban Development Unit
London Property Alliance
London Sustainable Development Commission
London Tenants Federation
Neighbourhood Planners London
Peckham Vision

 

Week 1 Friday 18 January: Format, Scope and Content of the Plan
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?
b)  Would the policies in the Plan provide an effective strategic framework for the preparation of local plans and neighbourhood plans in London?
c)  Does the Plan address detailed issues that would be more appropriately addressed in local plans and neighbourhood plans?
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 Boroughs’ development management responsibilities, justified and consistent with national policy and legislation?
Just Space response: the draft new Plan compares unfavourably with the existing (previous) plan in some respects and it seriously underplays the role of Neighbourhood Planning. M7 JS Format, Scope and Content response in full
Notes from the examination session (M7 and M8 combined)

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?
Just Space response: the Plan could and should have gone much further in showing where London’s needs cannot be served by the direct application of national policy, especially on housing issues, land values and high streets. M8 JS national policy and guidance response in full

Participants invited for M7-M8:

Aitch Group (Davies Murch /Barton Willmore)
Catalyst Housing Limited (CBRE)
Fairview New Homes
Home Builders Federation
Just Space
London Assembly Planning Committee
London Borough of Bexley
London Borough of Bromley
London Borough of Hammersmith and Fulham
London Councils
London First
London Forum of Amenity and Civic Societies
London Friends of Greenspaces Network
London Property Alliance
London Sustainable Development Commission
Ministry of Housing, Communities and Local Government
Neighbourhood Planners London
Retirement Housing Consortium
RTPI

Week 2 Tuesday 22 January:  Overall spatial development strategy [M10-M13]
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?
Just Space response: the draft Plan has to pretend that almost all growth needs can be met within the GLA boundary but can only do so by extending the catch-up of housing need backlogs over an unacceptable 25 years, diverting land from other uses and intensifying land use to a seriously damaging degree. The imperative generated by this aspiration would impose unacceptable costs on Londoners, especially low- and middle-income Londoners, and would increase the backlog of unmet need for low-rent homes. Pushing unmet needs to areas outside the boundary —either through just letting it happen, as before, or through bilateral deals with local authorities— would probably increase the amount of travel and have adverse social and environmental effects.  Just Space full response: M10 JS contain growth within GL
GLA response defends the Plan, locating the origin of its spatial approach back with the Infrastructure Plan and stakeholder events before Mayoral election.
Bovis Homes argue Green Belt already being used and more should be developed, making a particular case for land at Purley Way in Croydon (covers Matter 11 too).
CPRE supports the plan, stressing the amount of ‘brownfield’ land available in London.
Lichfields (for Lousada/Dylon) argue ALL of London’s estimated housing need should be met within GL, not just most. Furthermore the 66,000p.a. estimate is too low. Alternatives including GB/MOL review within GL (but not outside) should have been evaluated in IIA.
East of England Local Govts say no alternative involving more overspill were discussed with them, or evaluated in IIA. Such a strategy would have to be consulted on and evaluated next time around.
FoE insists that the Plan should prioritise social need over market demand for housing and set much higher environmental aspirations for whatever growth is accommodated. Stresses need for re-balancing between UK regions.
Home Builders Federation views plan as a fantasy since capacity based on land availability which neither Mayor nor Boroughs can/will deliver. Wider regional plan would help if there were a machinery.
Barton Willmore (for a consortium of developers) argues London housing output will fall short of need by 26-37,000 p.a.. Excess must be met in wider south east and London Plan should propose where, then cooperate to implement.
Bromley Council says (at great length) that GLA (&IIA) has failed to consider the adverse effect on existing communities of intensification. Favours new towns etc in wider region.
London Assembly Planning Committee seems to like the plan, though expresses mild concern about some details.
London First doubts whether targets will be met on Small Sites; fears for industrial land losses & regards the Plan as too rigid on Green Belt. Urges more regional cooperation.
London Forum views target as extremely unrealistic, foresees far more people having to move outside GLA boundary & calls for wider regional plans.
LSE London points out failure of successive “compact city” plans to deliver actual output, suggests added emphasis on intensification may not make significant difference. Plan should be honest & launch systematic regional studies.
S E England Councils welcome attempt to meet need within GL, are sceptical about outcome, stress constraints on some of their LAs & willingness of other to be ‘partners’. Insist Mayor has not been transparent & inviting about this.
Notes from the Examination session M10-M13

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?

Just Space response: London is growing in ways which impact especially badly on low- and moderate-income people and vulnerable equality groups. Alternative and more egalitarian spatial strategies have not been explored and the mechanisms proposed in the plan are not based on evidence. M11 JS strategic development response in full

Notes from the Examination session M10-M13

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?
Just Space response: in a dense and careful response JS explains why London is becoming over-centralised with damaging economic, social and environmental consequences; the community alternative spatial strategy should have been evaluated within the IIA. The distinction between inner and outer London is becoming obsolete and the policies of intensification (including incremental intensification) need careful evaluation in both areas before they are adopted on the proposed blanket scale. The malign effect of viability considerations is to make lower-price land in the suburbs seem least attractive for low cost rental housing development and this reinforces segregation. M12 JS spatial development response in full
Notes from the Examination session M10-M13

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?

Just Space response: The Infrastructure Plan 2050, although 4 years old, has never been subjected to EiP. As we argued in a detailed critique at the time, it is a highly unsatisfactory document, lacking in even the most basic evaluation of alternatives and weak on social infrastructure. The draft Plan is heavily dependent on infrastructure (both elements in the IP 2050 and others) but funding for much of this is insecure or could only be secured through over-development. M13 JS infrastructure response in full.
Notes from the Examination session M10-M13

Participants invited for Overall spatial development strategy [M10-M13]

Barton Wilmore (housebuilders consortium)
Bovis Homes Limited
Buckinghamshire District Councils and Bucks Thames Valley LEP
Catalyst Housing Limited (CBRE)
CPRE London
The Crown Estate and Merton College
East of England Local Government Association
Friends of the Earth England, Wales and Northern Ireland
Home Builders Federation
Just Space
London Assembly Planning Committee
London Borough of Barnet, Enfield or Hillingdon
London Borough of Bexley, Bromley or Croydon
London Borough of Richmond or Royal Borough of Kingston
London Borough of Newham or Wandsworth
London Chamber of Commerce and Industry
London First
London Forum of Amenity and Civic Societies
London School of Economics
Lousada Plc
South East England Councils / South East Strategic Leaders

 

Week 2 Wed 23 January : Opportunity Areas
M14.
Are the Opportunity Areas identified on the Key Diagram and Figures 2.4 to 2.12 likely to deliver the indicative number of additional homes and jobs assumed in the Plan in a way that is justified and consistent with national policy? In particular:

a)  Are sites likely to be available in the Opportunity Areas with sufficient capacity to accommodate the expected scale of development?
b)  Have the Opportunity Areas been chosen having due regard to flood risk in accordance with national policy?
c)  To be effective in preventing unacceptable risk from pollution and land instability and ensuring that development only takes place on sites that are suitable for the use proposed, is it necessary for the Plan to set out a strategic approach to dealing with despoiled, degraded, derelict, contaminated and unstable land in Opportunity Areas?
d)  How would the development proposed be likely to affect the character and appearance of existing places within and around the Opportunity Areas including with regard to heritage assets and their settings?
e)  Is the necessary transport and other physical, environmental and social infrastructure likely to be in place in each of the Opportunity Areas in a timely manner?
f)  Would the development proposed in the Opportunity Areas support policyGG1 “building strong and inclusive communities” and Policy SD10 “strategic and local regeneration”?
g)  Would Policy SD1 provide an effective strategic context for the preparation of local plans and neighbourhood plans?
h)  Is the approach to development management set out in SD1 consistent with national policy and would it be effective particularly in terms of therole of “planning frameworks”?
Just Space response: This element of the plan is fundamentally unsound and not evidence based. Furthermore, the process of delimiting, determining targets and preparing OAPFs for Opportunity Areas is not in conformity with the national planning framework. The panel’s main question cannot be answered because the targets are set without transparency or criteria. OAs commonly damage communities and pre-existing local economies. JS calls for a review of OA experience to date and a moratorium on further designations until that review is complete. In short the Plan’s main implementation mechanism is deeply deficient. M14 JS Opportunity Areas in full.
Notes from the examination session

Participants in Matter 14 Opportunity Areas
4 Estates Forum
Ballymore Group
Bengali East End Heritage Society
Camden Civic Society
Canary Wharf Group
Catalyst Housing Limited (CBRE)
Environment Agency
GLA Industrial BIDs Group
Historic England
Home Builders Federation
Just Space
London Assembly Planning Committee
London Borough of Camden
London Borough of Enfield
London Borough of Wandsworth
London Chamber of Commerce and Industry
London Forum of Amenity and Civic Societies
Save Earl’s Court Campaigners and Save Earl’s Court Supporters Club
Sustrans
Thames Estuary Partnership

 

Week 2 Wed 23 January afternoon: Strategic and Local Regeneration

M15. Would the Plan be effective in ensuring that development contributes positively to regeneration where it is needed and the building of strong and inclusive communities in accordance with Policy GG1? In particular:
a)  Would Figure 2.19 provide an effective and justified strategic framework for the identification of regeneration areas in local plans and neighbourhood plans?
b)  Would Policy SD10 provide an effective and justified strategic framework for the preparation of (i) policies in local plans and neighbourhood plans and (ii) regeneration strategies and programmes?
Just Space response: Draft policies exclude all references to the creative, pro-active, role of communities in bringing forward regeneration plans and in subsequent implementation. Material in the supporting text should be re-phrased and incorporated in policy. M15 JS strategic and local regeneration response in full
Notes from the examination session

Week 2 Friday 25 January morning: The Wider South East and Beyond
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?
Just Space response:  The Mayor should press successive governments to facilitate the development of alternative strategies for the wider South East and other regions and nations to be prepared with full public participation, genuine Impact Assessment of environmental, social and economic effects and transparent governance arrangements, led by elected local or regional governments. Ad- hoc bilateral deals with self-selected local authorities are anti-democratic and unlikely to lead to ‘good growth’ or sustainable development. This approach would be consistent with the Mayor’s obligations to pursue the sustainable development of the UK and would take some of the pressure off London. M16 JS Wider South East response in full.
Notes from the examination session
Blog on this day’s debate from worker-owned consultancy Lichfields

Barton Wilmore (housebuilders consortium)
Buckinghamshire County Council
Buckinghamshire District Councils and Buckinghamshire Thames Valley LEP CPRE London
CBI
East of England Local Government Association
Gatwick Diamond Group of Local Planning Authorities
Home Builders Federation
Just Space
Legal and General Capital
London Assembly Green Party Group
London Assembly Planning Committee
London Borough of Bromley
London Borough of Wandsworth
London Forum of Amenity and Civic Societies
London School of Economics
London Stansted Cambridge Consortium
Natural England
South East England Councils / South East Strategic Leaders
Thurrock Borough Council
Town and Country Planning Association

 

Week 3 Tuesday 5 February all day: Housing requirement  [ livestream / webcast  at https://www.london.gov.uk/london-eip-housing-strategy-2019-02-05 ]
M17. Is the need for 66,000 additional homes per year identified by the Strategic Housing Market Assessment (SHMA) justified and has it been properly calculated for market and affordable housing having regard to national policy and guidance? In particular:
a) What weight, if any, should be given to the revised household projections published in September 2018?
b) What weight, if any, should be given to the potential impact of Brexit?
c) Has the Mayor adequately considered increasing the total housing figures in order to help deliver the required number of affordable homes in accordance with the PPG (ID 2a-029-20140306)?
Just Space response: This central feature of the Plan is wrong: the pursuit of maximum total housing numbers in the belief that prices and rents could thus be lowered is mistaken, could reinforce price inflation and worsen the accumulated backlog of unmet need which is overwhelmingly for low cost rental housing. The effects would be most severe on poorer people among whom are many protected equalities groups. Conserving inherited stocks of low cost housing and building more should be the imperative.
Even in its own terms the ‘need’ for 66,000 net additional dwellings a year in the draft Plan flies in the face of the GLA evidence. 
Big uncertainties surround many elements in the calculation: notably migration and household formation rates. On top of that Brexit could further shrink or grow the economy and wages. These wide ranges of uncertainty should have been explored in the Plan.   Download  response in full: M17 JS housing requirement
Participants:
GLA [ statement ]
Barton Wilmore (housebuilders consortium) [ statement ]
CPRE London [ statement ]
Crest Nicholson PLC [ no statement ]
East of England Local Government Association [ statement just says “no comment” ]
Highbury Group [ statement ]
Home Builders Federation [ statement ]
Just Space [ linked above ]
Kent Council Leaders  [  no statement ]
Lands Improvement Holdings  [ no statement ]
Legal and General Capital (How Planning) [ no statement ]
London Assembly Planning Committee [ statement ]
London Borough of Barnet [ no statement ]
London Borough of Ealing [ no statement ]
London Borough of Harrow [ no statement ]
London Boroughs of Richmond & Wandsworth [ no statement ]
London School of Economics [ statement ]
London Tenants Federation [ statement ]
Luton Borough Council  [ no statement ]
Ministry of Housing, Communities and Local Government [ statement ]
organisations not invited to participate which submitted statements: LB Newham | LB Sutton | London Forum | Pocket Living |
Blog from the day’s discussion
Blog by Christine Whitehead, LSE, on today’s discussion

Week 3 Wednesday 6 February all day: Housing strategy
M18  Will the housing policies achieve the good growth objectives in Policies GG1, GG2, GG3 and GG4 relating to building strong and healthy communities, making the best use of land, creating a healthy city and delivering the homes Londoners need? In particular how will the provisions of GG4E regarding ambitious and achievable build-out rates be put into effect? Will the provisions of Policy H1 B-F provide an effective strategic context for the preparation of local plans and neighbourhood plans?
Just Space Response: Due to the draft London Plan’s single-minded focus on the quantity rather than quality and appropriateness of new housing completions, as well as greatly increased densification and intensification of land, we believe that there is a real risk that the housing policies laid out in the Draft London Plan will not only fail to achieve Good Growth, as we understand it, but actively undermine it. The policies will tend to undermine communities, divert land from crucial green, recreational and community uses, fail to contribute to a healthier city and damage the economy.  Detailed JS response M18 JS housing strategey
Participants:
Ballymore Group
CPRE London
Halfords Limited
Hammersmith & Fulham Federation of Tenants and Residents Association
Highbury Group
Home Builders Federation
Just Space
Lands Improvement Holdings
London Assembly Planning Committee London Borough of Hillingdon
London Boroughs of Richmond & Wandsworth
London First
London Forum of Amenity and Civic Societies
London NHS CCGs /NHS London Healthy Urban Development Unit (HUDU)
London Tenants Federation
Ministry of Housing, Communities and Local Government
National Housing Federation
RTPI
South East Strategic Leaders
Blog from the day’s discussion

 

Week 3 Friday 8 and Monday 11 February all of both days: Housing supply (SHLAA) and targets [M19] [ livestream / webcast ]
M19. Are the overall 10 year housing target for London and the targets for the individual Boroughs and Corporations set out in Policy H1 A and in Table 4.1 justified and deliverable? In particular: (Just Space comments in red)
a) Are the assumptions and analysis regarding site suitability, availability and 
achievability and development capacity for large sites in the Strategic Housing and Employment Land Availability Assessment (SHLAA) reasonable and realistic? 

No. JS has been critical from the outset because the capacity estimates include lots of estate ‘regenerations’ not yet approved by residents or by planning & a lot of employment land; then the SHLAA applied excessive densities…
b) Have the environmental and social implications of the proposed increase in housing targets been fully and properly assessed?
No, nor the economic impacts…
c) Policy H1 B 2) a)-f) identifies various sources of capacity. Will these be sufficient to meet the ten years targets and what proportion of housing is expected to be delivered by means of the different types? How much is expected to be delivered on existing industrial land in the context of Policies E4-E7?
The Plan must be far more explicit/transparent. Impact on jobs, products and services very destructive, e.g. evidence from Vital Old Kent Road; densification round suburban centres very badly drawn.
d) Will the focus on existing built up areas rather than urban extensions using GB/MOL provide sufficient variety of house types and tenure?
Do protect open land. But Plan should specify house types/tenure irrespective…
e) Is the emphasis on development in outer London consistent with the intention in Policy GG2 that seeks to proactively explore the potential to intensify the use of land on well-connected sites?
Yes, but…
f) Does the Plan adequately consider the cumulative impacts of other policies on the deliverability and viability of housing?
No…

Break for weekend. Resuming Monday:
g) What is going to bring about the step change in delivery implied in the Plan compared to the current one? What are the tools at the disposal of Boroughs in 1.4.6?
Mayor has accepted that major new powers and budgets would be needed. Just Space argues that a whole range of changes in land policy, taxation and powers are required and spells these out.
h) Is it realistic to expect this to occur from 2019 or should there be a stepped or transitional arrangement? Should Table 4.1 include targets for different types and tenures of housing? 

Yes, the Boroughs should be given separate targets for social rented housing in Table 4.1 given the serious [past] under–performance…
i) Should the target be for longer than 10 years given that the plan period runs to 2041?
Yes, at least in outline. Otherwise…
j)  How and where is the shortfall between the identified need of 66,000 additional homes a year and the total annualised average target of 64,935 to be made up? Will LPAs outside London in the wider south east be expected to deal with this on an ad hoc basis and is this realistic? 


This difference is tiny and less than the margin of error in any data. Most likely that under-supply within the GLA boundary will be born through overcrowding and unplanned movement to destinations near and far outside the boundary, with all the associated travel costs and environmental damage, as before. 
k)  Does paragraph 4.1.8A adequately explain how Boroughs are to calculate a target beyond 2028/29? 

Yes. But, … not how much low cost rented housing.
l)  What will be the implications for London Boroughs if the Plan targets are adopted which increase the requirement in recent development plans? 

Complete Just Space response: M19 JS housing supply targets
Participants:
Mayor [ statement ]
Berkshire Strategic Planning Group [ no statement ]
Chris Philp MP Croydon [ statement Croydon target too big; give inner London more ]
CPRE London [ statement ]
Crest Nicholson PLC [ no statement ]
East of England Local Government Association [ statement ]
Hammersmith & Fulham Fed of Tenants and Residents Association [ no statement ]
Home Builders Federation [ statement ]
Just Space [ statement linked just above participant list ]
London Assembly Planning Committee [ statement ]
London Boroughs of Barnet, Brent, Ealing, Harrow & Hillingdon (West London Alliance)
London Borough of Bexley or Bromley
London Borough of Newham
London Councils [ statement ]
London First  [ statement ]
London Forum of Amenity and Civic Societies [ statement ]
London School of Economics [ statement ]
London Tenants Federation [ statement ]
Ministry of Housing, Communities and Local Government [ statement ]
Retirement Housing Consortium [ statement ]
Royal Borough of Kingston, London Borough of Merton, London Borough of Sutton & London Borough of Richmond [ joint statement ]
South East Strategic Leaders [ statement ]
Statements by organisations NOT participating: Highbury
Blog from the discussion on 8 and 11 Feb
Short overview of 11 and 13 Feb discussions

Week 4 Wednesday 13 February all day : Housing policy for small sites
M20. Are the presumption in favour of small housing developments of between 1 and 25 homes in Policy H2 and the targets in Table 4.2 justified and deliverable and will the policy be effective? In particular:

a) Is the modelling of delivery from small sites in the SHLAA justified, including reliance on PTALs?

Just Space nutshell: Town centre radius huge and worsened by revision;
We want to cut down on need to travel while PTAL emphasis assumes people will travel; we welcome addition of specialist old people’s housing, but seriously worried by limits on other community housing forms which would likely generate less travel – especially for home-working and less economically active people.
b)  Is it realistic to expect the small sites target to be achieved in the outer London Boroughs?
Certainly arguments need to be had about what sort of “growth” London agrees to pursue and which aspects it wants to avoid. That’s what the Good Growth agenda should be about.  But there is no room for individual boroughs or districts to claim exemption from whatever is agreed. 
c)  Has adequate consideration been given to the cumulative impacts of this policy on, amongst other things, infrastructure, affordable housing provision and the character of some neighbourhoods as referred to in paragraph 4.2.5?
No, especially on social infrastructure…  and a growing proportion of suburban homes are now owned by PRS and HMO landlords. It’s a reasonable assumption that they will be more financially-motivated, less attached to roses and fruit trees, than owner-occupiers, so a lot of PRS space may be lost, and even beds in sheds. This could be a serious loss of relatively low-rent accommodation and thus displace relatively poor people. 
d)  Is the policy support for infill development within the curtilage of a house consistent with national policy in paragraph 53 of the NPPF which refers to resisting inappropriate development of residential gardens?
We… welcome the minor amendment which encourages the replacement of hardstandings with permeable or green surfaces.  However we do NOT accept that green roofs or green walls should be allowed to count towards green space: you can’t play on either, or walk the dog.
e)  Will the provisions of Policy H2 provide an effective strategic context for the preparation of local plans and neighbourhood plans including support for custom-, self-build and community-led housing? Are the detailed criteria necessary and would they provide an effective basis for development management? Are the qualifications at Policy H2 HA-HC justified in themselves and would they effectively eliminate the positive presumption for small housing developments? 

Multiple detailed comments including warning that the presumption in favour would inflate prices; need for much stronger support for all forms of community-led housing on small and awkward sites.
f)  Based on the historic delivery from sites below 0.25 hectares (whether allocated or windfalls) how will the Plan’s expectations for delivery be achieved? 

It is hard to predict how a diverse collection of site owners and potential developers will respond to the inducements offered by the draft Plan so much will depend on careful monitoring.  See M22.
g)  What will happen in the interim pending the work to prepare area-wide design codes referred to in Policy H2 B 2)? 

…even if the panel agrees with the scrapping of the density matrix (D6), its upper density limits should be enforced on small sites until acceptable design codes are in place, and that these codes must specify rigid density maxima in order to discourage speculative bidding-up of land prices.
h)  Are the provisions of Policy H2 H) relating to affordable housing requirements for minor developments justified, notwithstanding that they are inconsistent with national policy?
We consider that London needs to have affordable housing onsite in all schemes larger than a single home in order to ensure area diversity and prevent the displacement of low- and middle-income people from rich areas. Cash in lieu should… be very exceptional.

Complete Just Space response here: M20 JS small sites
Last-minute changes from Mayor: M20 Further Suggested Changes to Policy H2 PDF
Participants
:
Catalyst Housing Limited (CBRE)
CPRE London
Fordyce Limited
Hadley Wood Neighbourhood Planning Forum
Home Builders Federation
Just Space
Levitt Bernstein
London Assembly Planning Committee
London Boroughs of Barnet, Brent, Ealing, Harrow & Hillingdon (West London Alliance)
London Borough of Bexley or Bromley
London Borough of Enfield or Havering
London Borough of Camden or Islington
London Chamber of Commerce and Industry
London First
London Forum of Amenity and Civic Societies
London NHS CCGs /NHS London Healthy Urban Development Unit (HUDU) London Tenants Federation
Ministry of Housing, Communities and Local Government
Petts Wood & District Residents Association
Royal Borough of Kingston, London Borough of Merton, London Borough of Sutton & London Borough of Richmond
Transport for London
Blog on the small sites discussion
Short overview of 11 and 13 Feb discussions
Blog on the small sites discussion from consultants Lichfields – mainly pessimistic

Week 4 Friday 15 February morning [ livestream / webcast ]
Gypsy and Traveller Accommodation

M21.Does Policy H16 make adequate provision for meeting the need for gypsy and traveller accommodation including pitch provision and monitoring? In particular:
a)  Is Policy H16 a justified strategic framework for the preparation of local plans?Should accommodation assessments be undertaken at Borough level or should this be done London-wide?
No: a London-wide approach is essential and leaving it to boroughs demonstrably does not work. Former policy should be reinstated, with borough-level targets.
b)  Is it justifiable to have a different definition to that in Annex 1 of the Planning Policy for Traveller Sites for gypsies and travellers in London?
Yes. There is a clear evidential basis for a definition appropriate to London
c)  Is sufficient account taken of the need for temporary stopping places? 
No…
d)  Is sufficient account taken of the needs of travelling showpeople?
No…
e)  Is sufficient account taken of the accommodation needs of boat dwellers?
No. This is a distinct set of needs which should be met, preferably as a specialist from of housing within Policy H14  M21 JS on Gypsy and Traveller sites response in full.
Last minute changes from Mayor: M21 Further suggested changes to Policy H16
Participants:
Community Law Partnership Solicitors
Just Space
London Borough of Bromley
London Borough of Camden or Newham or Lambeth
London Borough of Hillingdon
London Borough of Wandsworth or Richmond or Merton
London Gypsies and Travellers
London Gypsy and Traveller Forum
National Bargee Travellers Association
Mobile Homes Sales and Management Peabody
Showmen’s Guild of Great Britain (Ray Smith)Trust for London

 

Week 4 Friday 15 February afternoon [ livestream / webcast ]
Monitoring housing targets
M22. Does Policy H3 provide an adequate basis for the monitoring of housing targets?
Just Space proposes that additional paragraphs are added to policies H3 and H8 to require monitoring that includes not only the total net delivery of homes by borough (planning authority), but also the categories or products that make up the total to be clearly and unambiguously monitored.The London Plan identifies delivering more affordable housing as a strategic objective. The absolute numbers by categories/products of affordable homes delivered should therefore be monitored to make sure that the percentages set out in policies H5 and H6 are being met.
In particular:
a)  Does Policy H3 BA provide an adequate basis for differentiating between the small sites target as a component of the overall housing target?
b)  Are the provisions in Policy H3 C and D regarding how net non-self-contained accommodation should be counted justified?
c)  What measures should be taken if relevant targets in the London Plan are not met?
Targets set in successive London Plans regularly fail to be met by boroughs, especially targets for social and affordable housing. Just Space proposes detailed policy changes to ensure that the Plan can be enforced. M22 JS monitoring housing response in full.
Participants:
Benhill Residents
East of England Local Government Association Gladman Developments
Home Builders Federation
Just Space
Levitt Bernstein
London Borough of Richmond
London Borough of Wandsworth
London Forum of Amenity and Civic Societies London Tenants Federation
Silvertown Homes

Meeting Housing Needs

Week 5 Tuesday 26 February all day : Affordable Housing
Written statements in response to M24 may be up to 2,000 words in length per policy (H5 to H8).
M24. Would policies H5 to H8 provide a justified and effective approach to delivering affordable housing to meet the good growth objectives set out in Policy GG4? Overall, would they provide an effective strategic framework for the preparation of local plans and neighbourhood plans in relation to affordable housing? In particular, in relation to each policy:

Policy H5 Delivering Affordable Housing
a)  Would the definition of ‘genuinely affordable housing’ and the Mayor’s ‘preferred affordable housing tenures’, include the affordable homes needed?
No. The definitions do not meet housing need. Affordability needs to be re-defined in relation to lower quartile incomes.
b)  Would the strategic target of 50% of all new homes to be genuinely affordable be justified in light of the identified need?
The target is set for the wrong thing: the target should be for social rent and these dwellings should be at least 62% of total new output. The proportions in the draft Plan do not even match up to the SHMA evidence.
c)  In requiring major developments which trigger affordable housing requirements to provide affordable housing through the threshold approach, would the policy be effective in delivering the quantum of affordable housing required?
The threshold should be set at 50% right away and social rent proportions defined.
d)  Would the approach to affordable housing providers, public sector land and industrial land be justified and effective?
No. The Plan should be much more demanding, requiring 100% of housing built on public land to be affordable. The experience of the St Anne’s Hospital site in Tottenham provides strong supporting evidence.
e)  In requiring on-site affordable housing generally, would the policy provide adequate flexibility to take account of local circumstances?
We strongly support this policy that off-site affordable housing should be prevented except in very exceptional cases. We are concerned, though, that exceptions are proposed for small sites and that the equivalent policy in the current plan is not being enforced.
f)  Does the approach taken in Policy H5 provide sufficient flexibility to take account of local circumstances?
g)  Overall, would the policy be effective in delivering the affordable homes needed?
No, for the reasons given. Just Space response in full m24 affordable housing just space 2718

Participants for matter 24:
Catalyst Housing Limited (CBRE)
CPRE London
Design Council
Elephant Amenity Network (35% Campaign)
Home Builders Federation
Just Space
London Assembly Planning Committee
London Borough of Barnet
London Borough of Brent
London Borough of Camden
London Councils
London First
London Forum of Amenity and Civic Societies
London Housing Directors
London School of Economics
London Tenants Federation
Ministry of Housing, Communities and Local Government
National Custom and Self Build Association
National Housing Federation
NHS Property Services (NHSPS), NHS England (NHSE), NHS Improvement (NHSI) and Community Health Partnerships (CHP)
RTPI
Town and Country Planning Association

Policy H6 Threshold Approach to Applications
a)  Would the threshold approach to viability, with a fast track route and viability tested route, as set out in policy H6, be justified and effective? Would the threshold level of affordable housing as set out in Policy H6B be justified and effective?
The use of viability testing to regulate levels of affordable housing has been to diminish the amount delivered and the threshold approach as it stands will not correct this. The threshold (B1) should be set at full policy compliance, that is 50% (or higher as we propose). B2 and B3 should be amended to 65% or 70%.
b)  Would it provide a framework to increase delivery of affordable homes to meet the full range of identified need?
No.
c) Would the approach taken to scheme amendments be effective in increasing delivery of affordable homes?

All scheme amendments should require a full revised financial appraisal and it needs to be stated in the text that financial reviews can lead to an increase in affordable housing.  The process must be fully transparent and we seek an amendment in order to achieve this.
d)  Would the approach taken to determining benchmark land value be justified?
e)  Would the requirement to seek grants to increase the level of affordable housing to access the fast track route be effective in increasing speed of delivery?
No, grants should not be made available to help achieve 35% affordable housing, nor should grants be available for intermediate housing products.
f)  Would the review mechanism as set out in Policy H6E2 be justified and effective in increasing delivery?
Just Space response in full m24 affordable housing just space 2718

Participants for H5 – H8:
Catalyst Housing Limited (CBRE)
CPRE London
Design Council
Elephant Amenity Network (35% Campaign)
Home Builders Federation
Just Space
London Assembly Planning Committee
London Borough of Barnet
London Borough of Brent
London Borough of Camden
London Councils
London First
London Forum of Amenity and Civic Societies
London Housing Directors
London School of Economics
London Tenants Federation
Ministry of Housing, Communities and Local Government
National Custom and Self Build Association
National Housing Federation
NHS Property Services (NHSPS), NHS England (NHSE), NHS Improvement (NHSI) and Community Health Partnerships (CHP)
RTPI
Town and Country Planning Association

Policy H7Affordable Housing Tenure
a)  Would Policy H7 be effective in delivering the tenure of affordable housing to meet the objectives of Policy GG4?
No.  The targets are set far too low… 
b)  In light of the identified need for low cost rental homes, would the split of affordable products in this policy be justified and effective? Would it provide sufficiently for boroughs to determine tenure locally to meet local needs and reflect local circumstances?
The split is not justified or effective as it is likely to decrease further the amount of social rented housing.  The provision of low cost rented homes is a London wide strategic need which cannot be left to the discretion of the Boroughs
c)  Would the preferred affordable housing tenures be justified and effective in meeting identified need?
No.  The descriptions in paragraphs 4.7.3 onwards are deficient and they provide public funds to home ownership products, when public funds must prioritise the most urgent needs until there is evidence that these needs are being met.
d)  Would the mechanism for review of the preferred tenures through supplementary planning guidance in 2021 be justified and effective?
If the housing products preferred by the Mayor are not deleted at this opportunity, we support a review mechanism leading to policy change through Further Alterations to the London Plan, not an SPG.
Just Space response in full m24 affordable housing just space 2718

Policy H8 Monitoring Affordable Housing
a) Would Policy H8 provide an effective framework for boroughs to monitor affordable housing?
The Mayor must gather data and report annually on the total stock, additions and losses, of social rent dwellings, taking account of Right to Buy sales, transfers from Local Authorities to Housing Associations and their disposals, tenancies switched from social rents to higher “affordable” levels or to market levels
Blog by Haringey DCH (Just Space)
Our blog notes 
Our front page about this day


Week 5 Wednesday 27 February morning: Housing Quality and Standards 
[ livestream / webcast ]

M36. Would Policy D4 provide a justified and effective strategic framework for delivering quality housing? In particular:

a)  Would Policy D4 focus on matters of strategic relevance? In this respect, would it provide appropriate flexibility in relation to housing standards in light of the planned amount of quality housing and local circumstances? (outdoor space, internal space, balconies, single aspect) Would it effectively address matters of daylight and sunlight?
b)  In this respect, would it provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to this matter?
c)  Would it accord with national policy particularly in light of the Nationally Described Space Standards?
m36 housing standards just space 2718 response in full

Participants for Matters 36-38:
Ballymore Group
Canary Wharf Group

Catalyst Housing Limited (CBRE)
Design Council
Equality & Human Rights Commission
Gill, Tim
Home Builders Federation
Inclusive Design and Access Panel
Just Space
London Assembly Planning Committee
London Borough of Camden
London Councils
London Forum of Amenity and Civic Societies
Ministry of Housing, Communities and Local Government RTPI
Retirement Housing Consortium
Town & Country Planning Association
UNITE Group Plc (ROK Planning Ltd)
ZCD Architects

Accessible Housing and Visitor Accommodation
M37. Would Policy D5 provide a justified and effective strategic framework for delivering accessible housing? In particular:
a)  Would Policy D5 provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to this matter?
b)  Would it provide an effective framework for development management? In this regard, would the requirements set out in Policy D5A, in relation to meeting Building Regulations requirement M4(3) and M4(2) be justified? Would this be an effective approach?

M38. Are the requirements for accessible bedrooms in visitor accommodation set out in Policy E10G justified, and do they relate to a matter which is of strategic importance to London?

Week 5 Wednesday 27 February afternoon: Particular types of housing 
[ livestream / webcast ]

 

Specialist Older Persons Housing
M31. Would Policy H15 provide a justified and effective approach to meeting the housing needs of older people in London? In particular:
a)  Would the approach to affordable housing requirements be effective and justified in supporting the delivery of housing for older people? Would thedefinition of the different types of older persons’ accommodation in termsof use class (class C2 and C3) be effective and justified? Would it be appropriate in a strategic document?
b)  Would the ‘benchmark numbers’ set out in table 4.4 be justified?

c) What would be the mechanism for monitoring this policy and would it be effective?
d) Overall, would Policy H15 meet the objective of Policy GG4 in delivering the homes Londoners need?
m31 specialist older persons housing just space 2718

Student Accommodation
M32. Would Policy H17 provide a justified and effective approach to the provision of purpose built student accommodation (PBSA) in London? In particular:
a)  Would the criteria set out in Policy H17A be justified and effective in delivering PBSA to meet identified need?
b)  Would the approach to affordable student accommodation be justified and effective?c)  Would the approach to living space and layout provide good design in PBSA to meet the objectives of good growth policies GG1 to GG4?
d)  Overall, would Policy H17 meet the objective of Policy GG4 in delivering the homes Londoners need?
m32 student accommodation just space 2718 JS response in full

 

Week 5 Friday 1 March all day:  Other housing matters [ livestream / webcast ]

Meanwhile Use as Housing
M23. Would Policy H4 provide a justified and effective approach to encouraging meanwhile uses of sites for housing? In particular:
a)  Would it make an effective contribution to meeting the London wide housing need? Would it be likely to impact on the provision of permanent homes? In the absence of a time frame for meanwhile uses, would it be effective? How would it ensure the provision of homes that provide good living conditions for occupiers?
b)  Would it provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to this matter?
Participants for matters 23 and 25-28
Anthology
Catalyst Housing Limited (CBRE)
Centre for Accessible Environments
Inclusive Design and Access Panel
CPRE London
Design Council
Footwork Architects Ltd
Home Builders Federation
Just Space
London Assembly Conservative Group
London Assembly Planning Committee
London Borough of Barnet, Brent, Harrow or Hillingdon
London Borough of Merton, Richmond or Sutton
London Borough of Newham or other inner London Borough
London Councils
London Forum of Amenity and Civic Societies
London Property Alliance
London Tenants Federation
Ministry of Housing, Communities and Local Government
New Policy Institute
NHS Property Services (NHSPS), NHS England (NHSE), NHS Improvement (NHSI) and Community Health Partnerships (CHP)
Retirement Housing Consortium


Vacant Building Credit
M25. Would Policy H9 be consistent with national policy? Is the approach taken justified?

Redevelopment of Housing and Estate Regeneration
M26. Would Policy H10 provide a justified and effective approach to the redevelopment of existing housing and estate regeneration? In particular, would the approach to affordable housing be justified? In light of Policy H5, would the requirements be clear? In the context of local need and objectives for redevelopment or estate renewal, would it be effective? What is the justification for provision of affordable housing floorspace rather than units? Would it provide sufficient flexibility to reflect local circumstances and support housing and estate regeneration? Overall, would the approach taken meet the objective of Policy GG4 in delivering the homes Londoners need?
m26-estate-regeneration-just-space-2718 response in full

Ensuring the Best Use of Housing Stock
M27. Would Policy H11 provide a justified and effective approach to ensuring the best use of housing stock? In particular:
a)  Would this policy deal with a strategic planning matter?
b)  Would the approach taken to ‘buy to leave’ and short term holiday accommodation be justified?

c) Overall, would Policy H11 be effective in sustaining London’s existinghousing stock and would it meet the objective of Policy GG4 to deliver the homes Londoners need?

Housing Size Mix
M28. Would Policy H12 provide a justified and effective approach to achieving the dwelling size mix to meet London wide and local needs? In particular:
a)  Does the dwelling size and mix identified in the 2017 SHMA provide a robust and realistic assessment of London wide needs?
b)  Would policy H12 provide an effective and justified strategic framework to deliver the mix of homes needed? What is the justification for preventing boroughs from setting prescriptive dwelling size mix requirements for market and intermediate homes and would this approach be effective? Would it provide sufficient flexibility to meet local needs? In light of this and the need to optimise density would it make a sufficient contribution towards family homes?
c)  Overall, would it meet the objective of Policy GG4 to deliver the homes Londoners need?
m28 housing size mix just space 2718 response in full

Blog post on Friday 1 March topics – rough draft

Week 6 Tuesday 5 March morning: Delivering good design

M34. Would policies D1 and D2 provide a justified and effective approach to delivering good design? In particular:
a)  Would the approach to delivering good design meet the good growth objectives set out in policies GG1, GG2, GG3 and GG4?
b)  In light of the requirements of policies D1 and D2 would they be effective in achieving the level of growth envisaged?
c)  Would policies D1 and D2 provide an effective framework to protect the distinctiveness of different parts of London, with particular regard to their social, economic, cultural and residential characteristics?
d)  Would the approach taken to design scrutiny be justified and effective? Would the proposed use of masterplans and design codes, as set out in Policy D2D, help to bring forward development and ensure high quality design? Would the proposed use of design review, as set out in Policy D2F, be justified and effective? In this regard, would the policies deal with strategic planning matters?

e)  Bearing in mind the resource implications for boroughs in carrying out Policy D2A1-11, would it be effective?
f)  How would the policies be monitored, given the nature of many of the requirements?g)  Overall, would the policies provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans and development management in relation to this matter?
m34 good design just space 2718 response in full
Blog post on Design sessions

Inclusive Design 
M35. Would Policy D3 provide a justified and effective strategic framework for delivering inclusive design? In particular:
a)  Would Policy D3 address matters that can be delivered and enforced through the planning regime, in particular the requirement for emergency evacuation? Would it strike the right balance between providing for inclusive design and delivering the planned level of growth?
b)  Would it be effective in ensuring the diverse needs of all Londoners are integrated into development proposals from the outset? Would it be effective in ensuring that the experience and views of all Londoners, particularly excluded groups, are taken into account in the evaluation of development proposals?
c)  In this respect, would it provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to this matter?
m35 inclusive design just space 2718 response in full
Blog post on Design sessions


participants for Good design and inclusive design (Policies D1, D2 and D3) [M34-M35]
Centre for Accessible Environments Inclusive Design and Access Panel City of London Corporation
CPRE London
Design Council
Environment Agency
Equality & Human Rights Commission
Friends of the Earth England, Wales and Northern Ireland
Footwork Architects Ltd
Home Builders Federation
Inclusion London
Just Space
London Assembly Planning Committee
London Councils
London First
London Forum of Amenity and Civic Societies
London NHS CCGs /NHS London Healthy Urban Development Unit (HUDU) London Property Alliance
London Tenants Federation
Ministry of Housing, Communities and Local Government
RTPI

Week 6 Tuesday 5 March afternoon: Density
M39. Would Policy D6 on optimising density be effective in achieving the intentions in Policy GG2 on making the best use of land and is the policy approach justified especially bearing in mind the cumulative impact on the environment and infrastructure? In particular:
a)  Would the provisions of Policy D6 provide an effective strategic context for the preparation of local plans and neighbourhood plans? Would the detailed criteria provide an effective and justified basis for development management, are they all necessary and do they provide sufficient clarity about how competing considerations are to be reconciled by the decision- maker?
b)  Will leaving density to be assessed on a site-by-site basis compared to the matrix in The London Plan of 2011 be effective?
m39 density just space 2718
Provisional blog post from M. Edwards. Fuller note to follow here.
LSE blog post by Prof Ian Gordon here

participants for Density (Policy D6) [M39]
Mayor/GLA   defend their position and add new policy wording
Ballymore Group
CPRE London
Edwards, Michael
Friends of the Earth England, Wales and Northern Ireland
Galliard Homes
Highbury Group
Home Builders Federation
Just Space
London Assembly Planning Committee
London Borough of Barnet
London Borough of Bromley
London Councils
London First
London Forum of Amenity and Civic Societies
Monks Orchard Residents Association
Retirement Housing Consortium
Southern Housing Group
Turnbull, Pat

statements from non participants: Catalyst Housing, LSE London

Week 6 Wednesday 6 March, morning: Tall buildings, public realm and basements

Public Realm
M40. Would Policy D7 provide a justified and effective strategic framework for delivering high quality public realm? In particular:
a)  Would Policy D7 relate to strategic planning matters, particularly in relation to street furniture and management and ongoing maintenance of the public realm?
b)  Would the criteria of the policy be justified and effective, in relation to matters such as sunlight, the natural environment and meanwhile uses?
c)  Overall, would it provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to this matter?
m40 public realm just space 2718 response in full

Tall Buildings Written statements in response to M41 may be up to 3,000 words in length.
M41. Would Policy D8 provide a justified and effective strategic framework for the development of tall buildings? In particular:
a)  Would the local definition of what is considered a ‘tall building’ provide an effective strategic framework to guide the location of tall building development?
b)  Where there is no local definition of what is considered a ‘tall building’, would the definition at paragraph 3.8.2 be justified and would it be effective?
c)  Would Policy D8, generally provide an effective framework to guide the location of tall building development, taking account of its wider surroundings and any cumulative effect?
d)  Would it provide an effective strategic framework for the assessment of the impact of tall building development?

e) Overall, would Policy D8 provide an effective and justified strategic framework for the preparation of local plans, neighbourhood plans and development management in relation to this matter?
m41 tall buildings just space 2718 response in full

Basement Development
M42. Would Policy D9, in addressing the negative impacts of large scale basement development below existing buildings relate to a matter of strategic importance to London? Would it provide an effective strategic framework to ensure the best use of land whilst protecting the local environment and the living conditions of residents?

Week 6 Wednesday 6 March, afternoon:
Safety and security, fire safety, agent of change and noise

Safety, Security and Resilience
M43. Would policies D10 and D11, in addressing matters including fire safety, refer to strategic planning matters? In particular, would policies D10 and D11 provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to this matter?
m43 fire safety just space 2718 response in full

Noise and Nuisance
M44. Would policies D12 and D13 provide a justified and effective strategic framework to mitigate the impacts of existing noise and nuisance generating activities or uses on proposed new noise-sensitive development and reduce, manage and mitigate noise in relation to new development? In particular:
a)  Would Policy D12, in setting out the ‘agent of change’ principle, benecessary in light of paragraph 123 of the NPPF?
b)  Would the identification and protection of ‘Quiet Areas’ be effective, as set out in Policy D13B? Would it be justified?
c)  Would policies D12 and D13 provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to these matters?

Week 6 Friday 8 March morning : Heritage and Culture
Conserving and Enhancing the Historic Environment

M45. Would Policy HC1 provide an effective and justified approach to conserving and enhancing the historic environment? In particular:
a)  Would Policy HC1 provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to the historic environment?
b)  Would it provide sufficient detail to guide London boroughs in developing evidence that demonstrates a clear understanding of London’s historic environment?
c)  Would the approach to development management be effective, justified and consistent with national policy in relation to designated and non- designated heritage assets?
m45 heritage and culture just space 2718

 

World Heritage Sites

M46. Would Policy HC2 provide an effective and justified approach to the conservation, promotion, active protection and interpretation of the outstanding universal value (OUV) of world heritage sites (WHS)? In particular:
a)  Would Policy HC2 be an effective and justified strategic framework for the
preparation of local plans and neighbourhood plans in relation to the WHS? Would it provide sufficient guidance to London boroughs on the need for policies in Local Plans to protect OUV of WHS?
b)  Would Policy HC2 provide sufficient detail on the approach to ‘setting’ and ‘buffer zones’? In this respect paragraph 7.2.4 refers to supplementaryplanning guidance? What is the up to date position on this? Would the policy be effective without this?
c)  Would the approach taken be consistent with paragraphs 132-134 of the NPPF, which sets out the way in which proposals affecting heritage assets should be assessed?
m46 world heritage sites just space 2718

Strategic and Local Views
Written statements in response to M47 may be up to 3,000 words in length.

M47. Would policies HC3 and HC4 provide an effective and justified approach to protect and enhance the composition and character of strategic views and their landmark elements in London? In particular:
a)  Would Policy HC3 be an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to the protection of those views?
b)  Policy HC3G and para 7.3.6 refer to local views. Are ‘local views’ a strategic matter? If so, what is the justification for giving such views the same degree of protection as strategic views? In this regard, would the policy be effective?
c)  Would the criteria in policy HC4 provide an effective and justified basis for development management? Would they provide sufficient clarity to enable a decision maker to reconcile competing considerations?

Friday 8 March afternoon : Culture and Creative Industries
M48. Would Policy HC5 provide an effective and justified approach to supportingthe continued growth and evolution of London’s cultural facilities and creativeindustries? In particular:
a)  Would it provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to those matters?
b)  Would the identification of ‘cultural quarters’, comprising locally-distinct clusters of facilities, venues and related uses, be justified as set out inPolicy HC5A2?
c)  Would it be effective in supporting the diversity in London’s cultural venues, facilities and uses?
d)  Would the identification of ‘creative enterprise zones’ be effective in supporting creative industries? What justification is there that such anapproach would ‘help boost the local economy of more deprived areas andsupport regeneration’?
m48 culture and creative industries just space 2718 response in full

Night Time Economy
M49. Would Policy HC6 provide an effective and justified approach to supportthe growth and diversification of London’s night time economy (NTE)? In particular:
a)  Is the definition of ‘strategic areas of night time activity’ as set out in table A1.1 effective and justified?
b)  Does it strike the right balance between supporting the NTE and protecting the living conditions of residents and nearby uses in terms of anti-social behaviour, noise pollution, health and wellbeing and other issues?
m49 night time economy just space 2718 response in full

Public Houses
M50. Would Policy HC7 address detailed issues that would be more appropriately dealt with in local plans and neighbourhood plans? Would it provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to the protection of existing public houses and support for new public houses?
m50 public houses just space 2718

Participants for Culture and creative Industries, night time economy and public houses (Policies HC5-HC7) [M48-M50]
AEG Europe
Bengali East End Heritage Society
CAMRA
Community Food Growers Network
Historic England
Institution of Lighting Professionals
Just Space
London Assembly Green Party Group
London Assembly Planning Committee London Councils
London Culture Forum
London Forum of Amenity and Civic Societies London Property Alliance
London Wildlife Trust
National Trust London
Showmen’s Guild of Great Britain (Ray Smith)Theatres Trust
U+I

 

Tuesday 12 March afternoon: extra session for matters not discussed on Feb
M29. Build to Rent
M33. Large Scale Shared Living Development
M30. Supported and Specialised Housing

Build to rent
M29. Would Policy H13 provide a justified and effective approach to build to rent housing to meet housing need? In particular:
a)  Would the criteria to define build for rent set out in Policy H13B be justified and would they be effective in supporting delivery?
b)  Would the approach to affordable housing requirements be justified and effective? Would it be effective in meeting local needs? Would the approach to discounted market rent homes be effective? Should the discount level be defined locally to take account of local circumstances?
c)  Are there specific design requirements of this type of housing and would the policy be effective in delivering them?
d)  Overall, would it meet the objective of Policy GG4 to delivering the homes Londoners need?
m29 build to rent just space 2718 Just Space response in full
Participants for matters 29-33:
Access Association
Audley Group
British Property Federation
Canary Wharf Group
Cass and Claredale
Downing
Equality & Human Rights Commission
Elysian Residences
Get Living London
Home Builders Federation
Just Space
London Assembly Planning Committee
London Borough of Camden
London Councils
London Federation of Housing Cooperatives London First
London Forum of Amenity and Civic Societies
London Tenants Federation
NHS England
PRP
Retirement Housing Consortium
RICS
University College London
University of London

Supported and Specialised Housing
M30. Would Policy H14 provide a justified and effective approach to the delivery, retention and refurbishment of supported and specialised housing? In particular, would it meet the objective of Policy GG4 to delivering the homes Londoners need?
m30 supported and specialised housing just space 2718 Just Space response in full

 

Large Scale Shared Living Development
M33. Would Policy H18 provide a justified and effective approach to the delivery of large scale purpose built shared living accommodation in London? In particular:
a)  Would the criteria set out in Policy H18A be justified?
b)  In the absence of the application of defined space and amenity standards, would it be effective and justified in delivering good design and the objectives of policies GG1 to GG4?
c)  Would the size of development defined in paragraph 4.18.3 be justified?
d)  Would the affordable housing requirements be effective and justified?
e)  Overall, would it deliver the planned level of growth to meet the objectives of good growth policies GG1 to GG4?
 Blog on today’s discussion

Monday 18 March morning: Central Activities Zone, Offices, Industry and Freight

Central Activities Zone including Isle of Dogs (north) (“CAZ”)
M58. Would policies SD4 and SD5 be effective in ensuring an appropriate mix of housing, offices [footnote says Table 6.1 of the Plan indicates 367,700 additional office jobs in the CAZ 2016-2041 ] and other development in different parts of, and outside, the CAZ to support:
a)  the “strategic functions” of the CAZ (paragraph 2.4.4);
b)  “locally orientated uses” in the CAZ (paragraph 2.4.5) and Policy GG1“building strong and inclusive communities”;
c)  Policy GG4 “delivering the homes Londoners need”; and
d)  Policy GG5 “growing a good economy”?
Just Space submission in full: M58 CAZ Just Space

participants: Central Activities Zone including Isle of Dogs (north) (policies SD4 and SD5) [M58]
Canary Wharf Group
Catalyst Housing Limited (CBRE)
City of London Corporation
The Crown Estate
GLA Industrial BIDs Group
Historic England
Just Space
London Assembly Green Party Group
London Assembly Planning Committee London Borough of Camden
London Chamber of Commerce and Industry London First
London Forum of Amenity and Civic Societies London Property Alliance
London Tenants Federation
New West End Company
Trust for London
Waterloo Community Development Group

 

Monday 18 March afternoon : Offices
M59. Is Policy E1 justified and would it be effective in ensuring that identified needs for additional office floorspace are met in appropriate locations in accordance with national policy? In particular:
a)  Are the figures in Table 6.1 for projected office employment growth and office floorspace demand 2016-2041 in different parts of London justified?
b)  Would the locations identified in parts C and D have sufficient capacity and be likely to deliver the amount of additional floorspace required such that needs in all parts of London can be met?
c)  Are the “office guidelines” set out in Figure A1.4 justified, and is the way in which they are intended to be used in the implementation of part D2 clear?
d)  Would policies E1D4 and SD7A1 provide an effective approach for office development in town centres that are not identified as having potential for speculative and/or mixed use office development in Figure A1.4?
e)  Is the proposed use of Article 4 Directions set out in parts E and F clear and is it justified having regard to national policy, bearing in mind the minor suggested change to paragraph 6.1.6?
f)  How would Policy E1 affect the implementation of Policy GG4 “delivering the homes Londoners need”?
g)  deleted from final agenda. Would policy E1(G) be effective in ensuring the availability of an adequate supply of low cost and affordable office space [Note that policies E2 and E3 are considered under M60]
Just Space submission in full: M59 Offices Just Space

Participants:  Offices (Policy E1) [M59]
Canary Wharf Group
CBI
DTZ Investors
Federation of Small Businesses
GLA Industrial BIDs Group
Home Builders Federation
Just Space
London First
London Forum of Amenity and Civic Societies
London Property Alliance

Tuesday 19 March morning
M62 Land for Industry, Logistics and Services to Support London’s Economic Function
Written statements in response to M62 may be up to 4,000 words in length.
The Mayor published a further suggested change relevant to Matter 62 on 8 March [FSC/13]

M62. Are policies E4, E5, E6 and E7 consistent with national policy and would they be effective in helping to ensure that sufficient suitable land and premises are available to meet the quantitative and qualitative needs for all foreseeable types of industrial15 activity over the plan period? [Reference to “industrial” or “industry” in these matters includes all types of economic activity referred to in policy E4A(1)-(9A) incorporating the Minor Suggested Changes.]
In particular: M62. Are policies E4, E5, E6 and E7 consistent with national policy and would they be effective in helping to ensure that sufficient suitable land and premises are available to meet the quantitative and qualitative needs for all foreseeable types of industrial1 activity over the plan period? In particular: (sequence changed in final agenda, as follows):

Need for industrial land

a) Are the industrial job growth projections and associated estimates of land and floorspace requirements justified?

e) Is the approach to assessing floorspace and yard space capacity set out in paragraph 6.4.5 – 6.4.5B based on existing floorspace or floorspace assuming a 65% plot ratio (whichever is greater) justified and would it be effective?

Meeting the need for industrial land

b)  Is the aim of ensuring no overall net loss of (i) industrial floorspace capacity and (ii) operational yard space capacity across London in designated Strategic Industrial Locations (SIL) and Locally Significant Industrial Sites (LSIS) justified and realistic, and would achieving that objective ensure the availability of a sufficient quantity of land and premises for industrial uses?

c)  Are the borough-level capacity categorisations (“retain”, “provide”, or “limited release”) set out in Table 6.2 justified, and would the proposed approach ensure a sufficient quantity of land and premises in different industrial property market areas?

d)  Are there parts of London where significant amounts of additional industrial land are likely to be needed in addition to that which is currently in use and/or designated?

f) Is the approach set out in Policy E7D towards “non-designated industrial sites” (36% of total amount of industrial land2) justified and consistent with national policy?

j) What evidence is there about the feasibility of delivering schemes on industrial land that would lead to the provision of net additional industrial floorspace along with the provision of significant numbers of new homes on the same site?

E7F – wider South East

i) Is Policy E7F, along with Policy SD2, likely to be effective in terms of facilitating the substitution of some of London’s industrial capacity to related property markets beyond London’s boundary, and would achieving such an objective contribute to the achievement of sustainable development?

Effect of E4-E7 on meeting housing needs

k) How would policies E4-E7 affect the implementation of Policy GG4 “delivering the homes Londoners need”?

Are E4-E7 effective, or unduly detailed, prescriptive and complicated

  1. g)  Would policies E4-E7 provide an effective strategic context for the preparation of local plans and neighbourhood plans?

  2. h)  Are policies E4-E7 clear about how they would be implemented through the determination of planning applications, particularly in terms of the role of“planning frameworks3” and “a co-ordinated masterplanning process incollaboration with the GLA”, and the relationship between policies E5D andE7B?

Just Space statement in full: M62 Land for Industry Just Space

Blog post on this topic.

 

Participants for Industry, logistics and services to support London’s economic function [M62]
Amazon UK Services Limited
Ballymore Group
DB Cargo UK Limited
East of England Local Government Association
Federation of Small Businesses
Freight Traffic Control 2050 project
Gazeley UK Ltd
GLA Industrial BIDs Group/ London Industry and Logistics Sounding Board
Home Builders Federation
Just Space
London Assembly Planning Committee
London Boroughs: three from Bexley, Brent, Ealing, Enfield, Richmond Sutton and Wandsworth
London Chamber of Commerce and Industry
London First
London Forum of Amenity and Civic Societies
London Waste and Recycling Board
Prologis
ROCA Investments
SEGRO
South East England Councils / South East Strategic Leaders

Tuesday 19 March  afternoon
Freight, Deliveries and Servicing
M63.
Would Policy T7, along with policies E4-E7, provide an effective strategic framework to ensure that suitable sites and infrastructure are provided for all types of freight, deliveries and servicing in an integrated and sustainable manner in all parts of London? In particular:
a)  are all of the requirements of Policy T7 necessary to address the strategic priorities of London, or
b)  do they extend to detailed matters that would be more appropriately dealt with through local plans or neighbourhood plans?
Just Space submission in full: M63 Freight Just Space


Participants for Freight, Deliveries and Servicing [M63]
Amazon UK Services Limited
British Retail Consortium
DB Cargo UK Ltd
Federation of Small Businesses
Freight Transport Association
GLA Industrial BIDs Group
John Lewis Partnership
Just Space
London Forum of Amenity and Civic Societies
London Industry and Logistic Sounding Board
London Sustainability Exchange
Road Haulage Association Ltd
Sainsbury’s Supermarkets Ltd
SEGRO
Sustrans
Transport for London
United Kingdom Warehousing Association
UPS

Wednesday 20 March morning

Low Cost and Affordable Business Space
This matter will be dealt with by considering policy E2 and E3 in turn. There will then be the opportunity to make any further contributions related to sub questions (a) to (d) that have not already been covered.

M60. Are policies E2 and E3 justified and would they be effective? In particular:

a)  Are they necessary to address the strategic priorities of London, or do they extend to detailed matters that would be more appropriately dealt with through local plans or neighbourhood plans?
b)  Would they be effective in helping to ensure that the accommodation needs of all micro, small and medium sized businesses, including those wishing to start up or expand, could be met in all parts of London?
c)  Or would that objective be better achieved by market forces in the context of other policies in the Plan, including E1A, E4A, E4H, E5C and E6, as well as any relevant policies in local plans and neighbourhood plans?
d)  How would policies E2 and E3 affect the implementation of policy GG5 “growing a good economy”?
Just Space submission: M60 Low Cost and Affordable Business Space Just Space

Blog Post from this day’s discussion


Participants for
Low cost and affordable business spaces (Policies E2 and E3) [M60]
British Property Federation
Canary Wharf Group
CBI
Federation of Small Businesses
HEAR Equality and Human Rights Network
Just Space
Lendlease
London Assembly Green Party Group
London Assembly Planning Committee London Borough of Brent
London First
London Forum of Amenity and Civic Societies London Property Alliance
Vital OKR
Workspace Group (Lichfields)
Workspace Providers Board

Wednesday 20 March afternoon
Visitor Infrastructure
M61. Is Policy E10 justified and consistent with national policy and would it be effective in ensuring that the need for accommodation and other infrastructure for visitors can be met in appropriate locations? In particular:
a)  Is development of accommodation and other visitor infrastructure a matter of strategic importance to London, or a detailed matter that would be more appropriately dealt with through local plans or neighbourhood plans?
b)  Would Policy E10D support the “strategic functions” of the CAZ (paragraph 2.4.4) and “locally orientated uses” in the CAZ (paragraph 2.4.5)?
Just Space submission in full: M61 Visitor infrastructure Just Space


Participants for Visitor Infrastructure (Policy E10) [M61]
Access Association
GLA Industrial BIDs Group
Highgate Society
Just Space
London Assembly Planning Committee
London Borough of Brent or Ealing
London Borough of Richmond or Wandsworth
London Borough of Sutton
London Forum of Amenity and Civic Societies
London Hotel Group
London Property Alliance
West End Partnership

Tuesday 26 March March morning
Green Infrastructure and Natural Environment
Green infrastructure, open space and urban greening
M64. Would the policies for green infrastructure assist in creating a healthy city in accordance with Policy GG3 and will they provide an effective strategic context for the preparation of local plans and neighbourhood plans? Are Policies G1, G4 and G5 and their detailed criteria justified and necessary and would they provide an effective basis for development management? How would they affect the implementation of Policies GG4 and GG5 on delivering the homes Londoners need and growing a good economy? In particular:
a)  Is the Mayor’s target of making more than 50 percent of London green by 2050 and its designation as a National Park City justified and achievable?
b)  Do the policies adequately reflect the qualitative differences and value of different types of green infrastructure, including open and green space and the role of waterways (blue space) and the access to it?
c)  Given the All London Green Grid is it necessary for Boroughs to prepare green infrastructure strategies in accordance with Policy G1 B?
d)  Does Policy G4 provide sufficient protection for the amount and quality of all green and open space including private gardens and allotments and on housing estates? Is the categorisation in Table 8.1 justified? Should the policy refer to the improvement of existing spaces?
e)  Is the expectation that Boroughs develop an Urban Greening Factor based on Policy G5 and Table 8.2 justified with particular regard to viability and practicality? (NB question e deferred to Wednesday morning – tomorrow)
Just Space submission in full: M64 green infrastructure Just Space
Blog on this topic

Tuesday 26 March afternoon
Green Belt and Metropolitan Open Land
M65. Would Policies G2 and G3 provide an effective strategic context for the preparation of local plans and neighbourhood plans? Are the policies and detailed criteria justified and necessary and would they provide an effective basis for development management? In particular:
a)  Is Policy G2 on London’s Green Belt consistent with national policy and, if not, is this justified?
b)  Is the ‘swapping’ of Metropolitan Open Land (MOL) referred to in paragraph 8.3.2 and allowed for by Policy G3 AC justified? Do the other detailed criteria provide sufficient clarity about inappropriate development and how any boundary alterations should proceed? Should parts of the River Thames be designated as MOL?Biodiversity, trees, food growing and geodiversity
See the Just Space submission of March 2018.

Wednesday 27 March morning
Urban greening M 64 and e from yesterday morning.

 

Wednesday 27 March afternoon Biodiversity, trees, food…

M66. Would Policies G6-G9 assist in creating a healthy city in accordance with Policy GG3 and will they provide an effective strategic context for the preparation of local plans and neighbourhood plans? Are the individual policies and detailed criteria justified and necessary and would they provide an effective basis for development management? In particular:
a)  Will Policy G6 be likely to achieve net gains in biodiversity and consistent with national policy? Are specific provisions relating to European sites in BA necessary give other legislative requirements?
b)  Will Policy G7 be effective in protecting trees and woodland especially ancient woodland and veteran trees and in increasing the extent of London’s urban forest?
c)  Does Policy G8 provide sufficient encouragement to food growing and urban agriculture?
Just Space submission in full: M66 Biodiversity and food growing Just Space

Week 8 Friday 29 March all day
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.

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
Blog on today’s session

 

Tuesday 30 April all day
Waste and Circular Economy

The Mayor responded to the Panel’s Preliminary Question PQ14 relating to waste management on Friday 7 September 2018.

M68. Would Policy SI7 provide a justified and effective approach to reducing waste and supporting the circular economy? Would it further the aims of Good Growth policies GG1-GG6? Would it focus on planning matters of London wide importance? In particular:
a)  Would the definition of ‘circular economy’ as set out in paragraph 9.7.1 be justified and would it be effective in reducing waste, increasing material reuse and recycling and reductions in waste going for disposal?
b)  Would Policy SI7 provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to this matter? In particular what is the justification for the waste to landfill and recycling targets set out in Policy SI7A4? Could these be effectively monitored? Bearing in mind the timescales involved would these be effective?
c)  Would it provide an effective framework for development management? In particular, would the requirement for a Circular Economy Statement in relation to referable applications be effective and justified?
Just Space submission: M68 Waste and Circular Economy Just Space

 

Written statements in response to M69 may be up to 3,000 words in length.

M69., Would Policy SI8 and SI9 provide a justified and effective approach toproviding for London’s waste and promoting net waste self-sufficiency? In particular:
a)  Is the target of net self-sufficiency by 2026 as set out in Policy SI8A1 realistic? What is the justification for excluding excavation waste within the net self-sufficiency target? In light of this would it be justified?
b)  Are the Borough forecast arisings of household and commercial and industrial waste as set out in table 9.1 based on robust evidence? What waste streams are excluded and what is the justification for excluding them? In light of this are they realistic and justified?
c)  Is the apportionment of waste to be managed in Boroughs, as set out in table 9.2, justified? What waste streams are excluded from the apportionments and what are the provisions to deal with those waste streams? As some waste streams are not included would the apportionments be effective in ensuring that the waste targets in Policies SI7 and SI8, the Borough apportionments in table 9.2 and the aspirations for net self-sufficiency and shifting towards a low carbon circular economy would be met?
d)  Would they provide an effective framework for development management? In particular, would the criteria in Policy SI8C accord with national policy? Would Policy SI8D provide an effective and justified framework for the evaluation of proposals for new waste sites or to increase capacity of existing waste sites?
e)  Would they be effective in safeguarding existing waste sites particularly in relation to Policy SI9C?
See the Just Space submission of March 2018.

 

Wednesday 1 May morning
Aggregates

M70. Would Policy SI10 provide a justified and effective strategic framework for the steady and adequate supply of aggregates to support construction in London? In particular:
a)  Would the approach taken to land-won aggregates accord with national policy? What is the justification for the landbank apportionment in the four boroughs identified? Would the approach taken be effective in ensuring an adequate supply of aggregates to meet the level of growth envisaged?
b)  In the absence of a target for recycling/reuse of construction, demolition and excavation waste by 2020 and the recycling of that waste as aggregate, would the policy be effective?
c)  Would the approach taken to safeguarding resources and facilities, as set out in SI10C, be effective in ensuring the steady and adequate supply of aggregates to support construction in London?
d)  Would Policy SI10 adequately address the full range of environmental and other impacts of aggregate facilities?
e)  Would it provide appropriate, justified and effective guidance on development management matters?
See the Just Space submission of March 2018.

 

 

Hydraulic Fracturing

M71. Would Policy SI11 be consistent with national policy in respect of the exploration, appraisal or production of shale gas via hydraulic fracturing? If not, what is the justification for the approach taken? [footnote: National policy as set out in the NPPF PPG Minerals and the WMS Planning for Onshore Oil and Gas: Written Statement (16 September 2015) and Energy Policy: Written statement (17 May 2018)]
Just Space statement in full: M71 Hydraulic Fracturing Just Space

Wednesday 1 May afternoon
Flood Risk Management
M72. Would Policy SI12 provide a justified and effective strategic framework for flood risk management in London? In particular:
a)  Would it provide a justified and effective strategic framework for the preparation of local plans?
b)  Would it provide appropriate, justified and effective guidance on development management matters?
c)  Overall, would it provide for the timely delivery and funding of flood risk management?
See the Just Space submission of March 2018.

 

Sustainable Drainage
M73. Would Policy SI13 provide a justified and effective approach to sustainable drainage in London? In particular:
a)  Would it provide a justified and effective strategic framework for the preparation of local plans?
b)  Would it provide appropriate, justified and effective guidance on development management matters? In particular, what is the justification for the drainage hierarchy as set out in Policy SI13B? Would it be appropriate, justified and would it be effective?
c)  What is the justification for developments to achieve ‘green field run off rates’? Is this based on robust evidence? Would this be an effectiveapproach to sustainable drainage in London?
Just Space statement in full:   M73 Sustainable Drainage Just Space

 

Friday 3 May, morning
Social Infrastructure
Delivering Social Infrastructure
M51. Would Policy S1 provide an effective and justified approach to thedevelopment of London’s social infrastructure? In particular would it be effective in meeting the objectives of policies GG1 and GG3 in creating a healthy city and building strong and inclusive communities? In particular:
a)  Would Policy S1, in requiring a needs assessment of social infrastructure and encouraging cross borough collaboration provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to the development of social infrastructure?
b)  Would it provide a justified definition of social infrastructure?
c)  Would it provide an effective development management framework for boroughs, particularly with regard to Policy S1D, F and G?
Just Space submission in full: M51 Social infrastructure Just Space

Health and Social Care Facilities
M52. Would Policy S2 provide an effective and justified approach to support the provision of health and social care facilities in London? In particular:
a)  Would Policy S2 provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to the provision of health and social care facilities?
b)  Would it adequately provide for preventative health and social care to meet the aims of Policy GG3 ‘creating a healthy city’?
c)  Would it provide effective and justified guidance on development management matters with appropriate flexibility to reflect local circumstances?
d)  Overall, would it meet the aims of Policy GG3DA, in respect of planning for appropriate health and care infrastructure?
Just Space submission in full: M52 Health and social care Just Space


 

Education and Child Care Facilities

M53. Would Policy S3 provide an effective and justified approach to support the provision of good quality education and childcare facilities in London? In particular:
a)  Would it provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to good quality education and childcare facilities?
b)  Would it provide appropriate guidance on development management matters taking account of local circumstances? Does it take account of the impacts of poor air quality on the provision of good quality education and childcare facilities in accordance with Policy GG3 DB? Should Policy S3A3 include a development size threshold to ensure a strategic approach to the policy? In the absence of a size threshold, would this be realistic, particularly in light of Policy H2, which increases the role of small sites in meeting London’s identified housing need?
See the Just Space submission of March 2018.

Friday 3 may, afternoon
Play and Informal Recreation
M54. Would Policy S4 address strategic matters of London wide importance relating to play and informal recreation? In particular:
a)  Would Policy S4 provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to play and informal space?
b)  In light of the need for increased densities and differing local contexts, would requirements as set out at Policy S4B2 be justified, particularly a space standard per child for accessible on site play provision? Overall would it provide sufficient flexibility to reflect local circumstances?
Just Space statement in full: M54 Play spaces Just Space

Sports and Recreation Facilities M55. Would Policy S5 provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to sports and recreation facilities? In particular:
a)  Would it provide appropriate strategic guidance on development management matters?
b)  Should it make specific reference to elite sports, stadium and playing fields?
c)  Would it strike the right balance between provision of good quality sports and recreational facilities and protection of green spaces?
d)  Would it be effective in protecting existing sports and recreation facilities?
See the Just Space submission of March 2018.

Public Toilets
M56. Would Policy S6, in relation to public toilets, address a strategic matter of London wide importance?
a)  If so, would it provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to the
provision of public toilets?
b)  Would it be effective in ensuring the provision and future management of free publically accessible toilets including ‘Changing Places’ toilets as part of development proposals outlined in parts A and B of that policy?c) In light of the community toilet scheme supported by many boroughs, would it be effective?

Just Space statement in full: M56 Public Toilets Just Space

 

Burial Space
M57. Would Policy S7 provide an effective and justified approach to the provision and reuse of burial space in London? In particular:
a)  Would Policy S7 provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to this matter?
b)  Would it provide an appropriate strategic approach to guide London boroughs in developing a cross borough approach to this matter?
There is no Just Space submission

 

Week 10 Tuesday 7 May all day
Transport

Transport Schemes and Development
M76. (a) Are all of the transport schemes set out in Table 10.1 necessary and adequate to deliver the development proposed in the Plan?
(b) In the context of the identified funding gap of £3.1billion per year, is there a reasonable prospect that the transport schemes set out in Table 10.1, and any other essential strategic transport schemes, will be delivered in a timely fashion in relation to the timing of development proposed in the Plan?
See the Just Space submission of March 2018.

M77. Would the successful implementation of the policies in the Plan, including delivery of the transport schemes set out in Table 10.1, be likely to achieve
(a) the target of 80% of all trips in London being made by foot, bicycle or public transport by 2041, and
(b) the mode shares in central (95%), inner (90%) and outer (75%) London set out in Figure 10.1A?
See the Just Space submission of March 2018.

M78. (a) Are all of the requirements of policies T1 to T4 necessary to address the strategic priorities of London, or do they extend to detailed matters that would be more appropriately dealt with through local plans or neighbourhood plans?
(b) Are the expectations of development proposals relating to the provision of improvements to transport infrastructure and services set out in policies T1A, T2D, T3B-E, T4, and T9 justified and consistent with national policy? [long footnote: Expectations of development proposals include: support and facilitate the transport schemes set out in Table 10.1 (policy T1A(2)); provide mitigation to address any adverse transport impacts, including cumulative impacts (policies T4C and T9C); provide public transport and active travel infrastructure where the ability to absorb increased travel demand has been exhausted and existing public transport is insufficient (policy T4D); mitigate the cumulative impacts of development on public transport and the road network capacity (policy T4E); support capacity, connectivity and other improvements to the bus network (policy T3E); not increase road danger (policy T4F); demonstrate how they will deliver the ten Healthy Streets Indicators set out in Figure 10.1 (policy T2D(1)); and submit Transport Assessments, Travel Plans, Parking Design and Management Plans, Construction Logistics Plans, and Delivery and Servicing Plans in accordance with Transport for London Guidance (policy T4B).]
See the Just Space submission of March 2018.

M79. How would delivery of the development proposed in the Plan (particularly the housing and employment development in Opportunity Areas and housing targets in outer Boroughs) and the associated car parking standards affect the

safety, reliability and/or operation of the motorways (M1, M4, M11 and M25) and strategic trunk roads in and around London? [footnote: The Mayor responded to the Panel’s Preliminary Question PQ12 relating to this matter on Friday 7 September 2018.]
See the Just Space submission of March 2018.

 

M80. How would delivery of the Plan’s transport policies and schemes affect (a) the objectives of Policy GG1 “building strong and inclusive communities” andadvancing equality of opportunity as required by the Equalities Act; and (b) theobjectives of policies GG3 “creating a healthy city”, SI1 “improving air quality”,and SI2 “minimising gas emissions”?
See the Just Space submission of March 2018.

Thursday 9 May morning
Car Parking
M81. Are all of the requirements of policies T6 and T6.1 to T6.5 necessary to address the strategic priorities of London, or do they extend to detailed matters that would be more appropriately dealt with through local plans or neighbourhood plans? In particular:
a)  Should the Plan allow local plans and neighbourhood plans to apply the maximum car parking standards flexibly to take account of local evidence including about car ownership and use; parking stress; public transport; walking and cycling; the scale, mix and design of particular developments; the character and appearance of an area; and economic viability?
b)  Are the requirements of policies T6 and T6.1 to T6.4 relating to the provision of infrastructure for electric or other ultra-low emission vehicles justified and consistent with national policy?
See the Just Space submission of March 2018.

 

Car Parking: Residential
M82. Is the approach to non-disabled persons residential car parking set out in policies T6 and T6.1A-F justified, and would it be effective in helping to helping to achieve sustainable development? In particular:
a)  Are the maximum standards set out in Table 10.3 justified?
b)  Is the requirement for all large-scale purpose-built shared living, student accommodation and other sui generis residential uses to be car-free (other than disabled persons parking) justified?
See the Just Space submission of March 2018.

M83. Is the approach to disabled persons residential car parking set out in policies T6B, T6D and T6.1G-H justified, and would it be effective in helping to helping to achieve sustainable development? In particular:
a)  Is the requirement for a minimum of 3% of dwellings on residential developments of ten or more units to be provided with at least one designated disabled persons parking bay justified (Policy T6.1G(1))?
b)  Is Policy T6.1G(2), relating to the potential provision of an additional 7% of dwellings being provided with a designated disabled persons bay, justified and would it be effective?
c)  Are the detailed requirements of Policy T6.1H justified and consistent with national policy, and would they be effective?
Just Space submission: M83 Car Parking Disabled Residential JS

 

Car Parking: Non Residential Uses

M84. Is the approach to parking for non residential uses set out in policies T6 and T6.2 to T6.5 justified, and would it be effective in helping to helping to achieve sustainable development? In particular:
a)  Are the maximum standards for offices set out in Table 10.4 justified?
b)  Is the approach to commuter and operational parking for industrial and storage or distribution uses set out in Policy T6.2C and T6.2F justified and consistent with policies E4-E7?
c)  Are the maximum standards for retail set out in Table 10.5 justified?
d)  Is the approach to hotel and leisure uses parking set out in Policy T6.4 justified?
e)  Are the standards for non-residential disabled persons parking set out in Table 10.6 justified?
f)  Is the requirement for existing parking provision to be reduced to meet the maximum standards when sites are redeveloped justified (Policy T6I)?
g)  How would the approach to non-residential car parking affect the objectives of Policy GG5 “growing a good economy” and the vitality and viability of town centres in the context of policies SD6-SD9 and E9?
See the Just Space submission of March 2018.

 

Cycling
M85. Is Policy T5 justified and consistent with national policy, and would it be effective in helping to helping to achieve sustainable development? In particular:
a)  Are all of the requirements of Policy T5 necessary to address the strategic priorities of London, or do they extend to detailed matters that would be more appropriately dealt with through local plans or neighbourhood plans?
b)  Are the minimum cycle parking standards set out in Table 10.2 justified?
c)  Should the Plan allow local plans and neighbourhood plans to apply the minimum cycle parking standards flexibly to take account of local evidence?
Just Space submission in full: M85 Cycling Just Space

 

Thursday 9 May, afternoon
Air Quality and Water Infrastructure
M74. Would the policies for air quality and water infrastructure 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? Are the individual policies and detailed criteria justified and necessary and would they provide an effective basis for development management? In particular:
a)  Are the requirements in Policy SI1 clear and will they be effective in improving air quality whilst delivering the homes Londoners need in accordance with Policy GG4?
b)  Will Policy SI5 ensure adequate provision for water infrastructure and encourage a sustainable use of resources? Is the requirement to use the optional requirement of the Building Regulations justified?
Just Space submission: M74 Air Quality and Water Infrastructure Just Space

 


Friday 10 May morning

Aviation
The Mayor’s response to Preliminary Question 13 is relevant to this matter.

M87. (a) Are the requirements of Policy T8 necessary to address the strategic priorities of London and, if so, would they be effective in that regard? (b) Or does policy T8 cover matters that are dealt with by national policy and/or would be more appropriately dealt with through local plans or neighbourhood plans? (c) Are changes to Policy T8 and/or other parts of the Plan necessary to ensure consistency with national policy relating to Heathrow Airport including the

London Plan EIP 2018-2019: Panel Note 6 Annex 1 Matters (Nov 2018)

Airports National Policy Statement: new runway capacity and infrastructure at airports in the South East of England (June 2018)? [footnote: The Mayor responded to the Panel’s Preliminary Question PQ13 relating to this matter on Friday 7 September 2018.]
Just Space submission: M87 Aviation Just Space

 

Friday 10 May, afternoon
Waterways
M86. (a) Does the Plan contain justified and effective policies to promote and encourage the use of the River Thames and other waterways for the provision of passenger transport services and the transportation of freight? (b) Are all of the requirements of policies SI14 to SI17 necessary to address the strategic priorities of London, or do they extend to detailed matters that would be more appropriately dealt with through local plans or neighbourhood plans?
Just Space submission: M86 Waterways Just Space

 

Monday 13 May afternoon (morning free?)
Digital Connectivity Infrastructure
M75. Given that this matter is addressed in the Building Regulations, would Policy SI6, in relation to digital connectivity infrastructure be justified and effective?
a)  Notwithstanding the above, what is the justification for ensuring sufficient ducting space for full fibre connectivity infrastructure or other affordable 1GB capable connection? Would this adequately provide for digital connectivity to meet the aims of Policy GG5 ‘growing a good economy’?
b)  Would the criteria in this policy provide an effective framework for development management?
c)  Would Policy SI6 provide an effective and justified strategic framework for the preparation of local plans and neighbourhood plans in relation to digital connectivity infrastructure?
There is no Just Space submission

 

Wednesday 15 May all day?
Town Centres and Retailing
Town Centre Network
M88. Is the town centre network set out in the Plan justified and would it be effective in ensuring that identified needs for main town centre use developments are met in appropriate locations in accordance with national policy? In particular:
a)  Is the existing town centre network classification of (i) international, (ii) metropolitan, (iii) major and (iv) district centres illustrated on Figure 2.17 and set out in Table A1.1 justified?
b)  Given the definitions of the classifications of town centres set out in Annex1 and Figure 2.18, is the identification of centres other than “international” and “metropolitan” in the Plan justified and consistent with national policyrelating to town centres and compliant with legislation relating to the purpose of a spatial development strategy?
c)  Are the future potential changes to the town centre network illustrated on Figure A1.1 and set out in Table A1.1 justified?
d)  Are the classifications, as set out in Table A1.1 and described in Annex 1, for (i) night-time economy functions, (ii) commercial growth potential, and (iii) residential growth potential justified?
Just Space submission: M88 final Town Centre network Just Space 2718

Notes/blog from the session

Retailing
M89. Would policies SD6, SD7, SD8, SD9 and E9B provide an effective strategic framework for the preparation of local plans and neighbourhood plans relating to town centres and all types of main town centre use development (including bulky goods retailing), that is consistent with national policy?
Just Space submission: M89 Retailing Just Space 2718

Notes/blog from the session

M90. Is the approach to development management set out in policies SD6, SD7, SD8, SD9 and E9BA justified and consistent with national policy and would it be effective in terms of:
a)  ensuring that identified needs for all forms of main town centre uses, including bulky goods, are accommodated in appropriate locations in accordance with national policy;
b)  requiring large scale commercial development (over 2,500sqm of A Use Class floorspace) to support the provision of small shops and othercommercial units (including “affordable units” where there is evidence oflocal need); and
c)  supporting Policy GG4 “delivering the homes Londoners need”?
Just Space submission: M90 development management for retail Just Space 2718

Hot Food Takeaways
M91. Are policies E9C and E9D relating to proposals containing hot food takeaways justified and consistent with national policy and guidance about healthy communities and limiting the proliferation of certain use classes in identified areas22. In particular:

a)  Is the development of hot food takeaways and associated planning conditions a matter of strategic importance to London, or a detailed matter that would be more appropriately dealt with through local plans or neighbourhood plans?
b)  What evidence is there indicating high levels of obesity, deprivation and general poor health in London?
c)  What evidence is there of over-concentration and clustering of hot food takeaways in London?
d)  Would restricting development of hot food takeaways within 400 metres walking distance from the entrances and exits of existing and proposed primary and secondary schools positively support the delivery of policyGG3 “creating a healthy city”?
Just Space submission: M91 Hot Food Takeaways Just Space

Notes/blog from the session

Friday 17 May morning [ livestream / webcast ]

Funding Gap and Plan Assumptions about Funding Infrastructure (to be continued on 22 May) Revised agenda dated 4 April.
Policy D1 – Delivery of the Plan and Planning Obligations

M93.  Is Policy DF1 justified and consistent with national policy, and would it be effective? In particular:
a)  Would the policy be effective in helping to ensure the timely delivery of infrastructure to support development proposed in the Plan?
b)  Is the approach to viability assessments set out in parts A, B and C consistent with national policy and is it necessary for this to be set out in the Plan rather than left to be determined at the local level?
c)  Is the infrastructure prioritisation set out in part D justified?
See the Just Space submission of March 2018.

Cumulative Impact of Policy Requirements on Economic Viability

M92.  Would the cumulative cost of the policy requirements set out in the Plan, along with any other national and local requirements, threaten the economic viability of development and put implementation of the Plan at serious risk?

Consideration of matter 92 will cover the following, with reference where applicable to different forms of development and particular policy requirements:
i. Assessing viability at the strategic level – general comments
ii. London Plan Viability Study methodology
iii. LPVS development typologies
iv. Value band areas
v. Development costs (including developer profit)
vi. Development values
vii. Benchmark land values
viii. Sensitivity tests
ix. Emerging evidence of effect of draft Plan policies on viability
x. Conclusion on cumulative impact of policy requirements.

Just Space submission 12 March: M92 Viability M92

At the Panel’s request, an additional paper from the GLA has been issued on 8 May, listing disagreements among respondents.  Just Space responded to a draft of this document but our comments have not been incorporated or published. These (1 May) comments can be seen here as continuous text or the same material as insertions in the GLA draft.
JS comments on viability as text
JS comments on viability as insertions.2

Viability for beginners: a guide prepared by students at UCL (Toby Loftin, Blanca Yanez Serrano, Silvia Matisova) Not an inquiry document UCL Viability Group Report 2019

 

Participants for M92 and M93
Greater London Authority Jennifer Peters, John Wacher, Darren Richards, Jane Seymour
British Property Federation Ian Fletcher
Heart of London Business Alliance
Home Builders Federation, James Stevens
Just Space
LB Enfield
London First Sarah Bevan & Robert Fourt, (Gerald Eve)
London Forum of Amenity and Civic Societies Peter Eversden and Michael Bach
London Friends of Greenspaces Network,Dave Morris
London NHS CCGs, NHS London Healthy Urban Development Unit (HUDU)
London Property Alliance James Wickham (Gerald Eve)
NHS Property Services (NHSPS), NHS England (NHSE), NHS Improvement (NHSI) and Community Health Partnerships (CHP)
Retirement Housing Consortium, The Planning Bureau
RICS
Sainsbury’s Supermarkets Ltd
SEGRO Neil Impiazzi
Tesco Stores Ltd, Berwin Leighton Paisner
Tide Construction Ltd / Unite Group, Indigo / ROK Planning

 

Friday 17 May afternoon [ livestream / webcast ]
Monitoring
M94. (a) Would the key performance indicators and measures set out in Table 12.1 ensure that the Plan can be effectively monitored such that the Mayor and others can respond effectively if policies are not delivering the expected outcomes, including those set out in Good Growth policies GG1 to GG6? (b) Should the Plan set out measures that would be taken in the event that monitoring demonstrates that the expected outcomes are not being delivered?
Just Space submission: M94 Monitoring Just Space

Tuesday 21 May and Wed 22 may are reserve days. Of these, 22 May has now been allocated for the completion of viability M92/3.  21 May remains in reserve.

 

7 November 2018: presentations for the Technical Seminars 6 and 7 November 2018 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.

26 November and 5 December 2018: 2 briefings before the EiP opens. Both started with a background talk for people new to the process and then heard contributions from community and academic speakers. Slides from both sessions are here and there are notes coming soon.  The first session focused on London’s spatial structure, especially on Opportunity Areas, and the second on housing.