Draft London Plan Examination in Public (EiP) 15 January 2019
Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk
Matter 2. 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 20103 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? 12:06 Bold type denotes questions posed by the panel in advance.
Panel: seek a broad discussion about equality; we as a public authority have duty to ask and to inform our recommendations, as well as asking it of the GLA. Questions to ask, general principles first then specific contributions.
Criticism from first speaker: IIA shouldn’t be too general; this IIA has put all protected characteristics together and summed up the average or overall position, rather than analysing and presenting them separately. This dilutes or hides particular impacts. GLA responded that all of the policies have been assessed against 9 protected characteristics independently; individual assessment had gone back from Arup (consultants) to GLA, then integrated to inform the plan-making.
Panel: nothing of this detail is expressed in the document but you say that the detailed analysis is underlying the IIA?
GLA: what we don’t do is to repeat the assessment for every group
Panel: we hear there’s lack of information about some of those groups; where do estimates of the impact come from? Lack of information is given as explanation for blanks.
GLA: published baseline in the IIA Scoping Report has a lot of data, but there is more information we base assessments on; there are also professional judgements, …a great deal of information, interesting question of what level of baseline detail to take for London plan,
Panel: not very nuanced in the IIA tables, outcomes seem positive but not specific, what do you say of the grouping, outcomes may be positive, but maybe negative impacts are obscured due to that integrated or averaging perspective.
GLA: (response inaudible)
Panel: that’s a general major issue, now do any third parties have questions?
My Fair London: fundamental problem is economic inequality, it is not apparent in the document, there no causal recognition of inequality impact to health or other aspects, the structural distribution of inequality plays out in housing, transport,
Just Space: at London strategic level, what are the impact for Black and Ethnic Minority communities? Robustness of IIA requires that decision makers should have the records. Methodology is flawed: we keep hearing it is hard to find a balance, professional judgement, but BME communities expect to be able to guague the impact of the plan. BME communities are not benefiting evidently, especially in housing. We would quote from the IIA on the Mayor’s Housing Strategy (which feeds in to the London Plan) where the GLA said:
“While a substantial commitment has been made to providing affordablehomes at low cost rents that are affordable to the poorest Londoners,the Mayor’s agreement with Government means the majority of new affordable homes funded in line with Policy 4.1 and Proposal 4.2B will befor the ‘intermediate’ market – i.e., for middle income Londoners. This may mean there is less of a positive impact for some lower income households, among whom those with protected characteristics are over-represented, for whom low cost rent homes would be more appropriate. The forms of intermediate housing funded by the Mayor may also be more suitable for younger people, because of their emphasis on home ownership – something that may be more viable for those able to take out a mortgage over an extended period.” 2017
Mhairi McGhee (HEAR network): questioning process and methodology, the individual assessment, how is it there are still question marks and gaps there? There must have been a final assessment
Natasha Sivanandan Just Space & StART two points, not good to integrate the various assessments bizarrely, because law does not allow you. We request the separate assessment published. Statutory duty does not allow you to make general statements but evidence-based assessment of what are the impacts and possible mitigation; if not mitigated then need policy changes; the way in which the narrative has been weaved is not accordance with statutory requirements, you keep making generalized statement, I want to see the evidence and causal relationship, listen to us and stop being defensive. We can help you do that, allow us to raise detailes as we hope to do.
Panel: the legal duties you refer to, please clarify?
Natasha Sivanandan Just Space & StART: some case laws, European legislation like human rights to decent housing
Trust for London: environment and equalities already very complicated, maybe it would be better to make equality separate. It would be simpler.
Mhairi McGhee (HEAR) housing estimation for LGBT population is not addressed in IIA. LGBT concerns addressed only in Culture chapter, about venues. (!)
Just space: it is not clear which groups will be negatively influenced, like Vietnamese traders, if you do not look into particular groups particularly will not know the needs and properly address it, but we have evidence as working with them. No evidence shown in the plan to indicate such respect.
Panel to GLA/Arup: you said what you have done but others have different view of what you should have done.
GLA: question mark in the IIA matrix means outcomes are uncertain at pan-london level, because they would be borough or district level specific, LGBT housing is included, 5.2.
Data sources are in the Examination Library, draft plan consultation, and this EiP all part of the duty of consultation.
Paragraph 4 regeneration need to follow Good practice guides, assessment does recognize that.
Natasha Sivanandan Just Space & StART: can we ask if the detailed assessment can be made public? [see note]
Panel: further questions I would like to ask for. We notice some groups of representatives haven’t spoken, is there anything you want to say?
John Shephard (Brethren’s Gospel Trust): we haven’t noticed the consultation until it was pointed by Just Space recently.
Ilinca Diaconescu (London Gypsies and Travellers) main concerns: what is included in the public document is insufficient for the impacts to be considered, IIA Scoping report doesn’t show any data, no statistics or evidence showed as references. It is important for consultant to communicate to the public, not just with those of us who work in representative organisations
National Alliance of Women’s Organisations : on gender equality we are not able to read what this plan is going to bring for women, important to look into lifestyle cycle —like young women, old women, people in middle age, single parents— bring them into the frame, to use their talents and skills to build the British economy. We don’t see it in the plan.
Mhairi McGhee (HEAR): There should be accessible formats of the plan, write in plain form as far as possible
Panel: any more questions about general principle?
GLA: IIA, Gypsies were specially considered s3, s1 (travel, social infrastructure, education, specifically referenced there). Women, this is a spatial strategy not everything can be achieved in this strategy document,
Rachael Rooney from GLA: we have an inclusive design panel, tomorrow we will discuss, took the plan to the panel not prior the plan making.
Mhairi McGhee (HEAR): question about consideration on disability…
Panel: Please would the GLA comment: if we were to find that IIA is deficient in respect of the legal requirement under equality duty, what remedies might be possible.
GLA: We could publish the detail assessment, depending on what aspects you seek, then we can provide.
Panel:, we will reflect on that & background date required. We as panel need to have due regard to that, & we will make it public if we are to request data.
Natasha Sivanandan Just Space & StART: (strongly requesting the Panel to ask GLA for equalities assessment data and details) A procedural point, if the groups we represent are the subject of substantial data, we should be able to have that newly-released information and time to digest it and we need to be able to come back to those points rather than have the EiP postponed.
Panel: We heard what you say, but cannot commit until the Panel has met.
We reach the end of matter 2.
Notes by Yinuo Hu, Lily Downes, Zoe Rasbash, Emma Woodward
[Note. The detailed Equalities analysis which the GLA & Arups admtted had been carried out but not published are now to be made available. The Panel met and considered that the analysis was needed and announced that itshould be made available to them by Monday 21 January. Participants would have until (
15 a subsequently extended period till) midday 25 February to submit written comments if they felt it necessary. The “Supplementary Information on Equality Assessment” can now be found on the london.gov website as part of the EiP Library here.
There is no blog post for Matter 3, Habitat Regulations Assessment; we believe there may have been no discussion.