GLA to evaluate the Community Plan
As part of the collaboration between the GLA and Just Space and its member groups there have been meetings with, among others, the London Plan Team at City Hall, including the group working on the Integrated Impact Assessment (IIA) of the forthcoming London Plan and separate meetings with other City Hall teams.
Notes of these various meetings are posted here as they are agreed.
Just Space was consulted when the scope of the IIA was being worked out and was able to comment in detail on the Draft Scoping Report.
The Scoping Report for the IIA explains: “§1.1.4 A key part of reviewing the London Plan is the requirement to undertake an Integrated Impact Assessment (IIA). …[which] incorporates the statutory and non-statutory requirements of:
- Strategic Environmental Assessment (SEA)
- Sustainability Appraisal (SA)
- Equalities Impact Assessment (EqIA);
- Health Impact Assessment (HIA);
- Community Safety Impact Assessment (CSIA);
- Habitats Regulation Assessment (HRA)”
At a meeting on 2 August Just Space responded to an earlier offer that our proposals embodied in Towards a Community-Led Plan for London: policy directions and proposals would be further considered for evaluation alongside the GLA’s own alternatives within the IIA. A report of the meeting will be posted here after agreement of a draft record. This document describes what Just Space has put forward for consideration.
The IIA process includes the exploration of many variants of emerging policies with the IIA team giving feedback to the rest of the London Plan team on the results. The alternatives will include (but not be limited to) the comparison of a number of “spatial options”. Three such Options are set out in the Scoping Study for the IIA and ours would be a fourth. In addition to a different spatial vision, Just Space has a distinctive view about the strategic objectives of the Plan. This document is thus in 4 parts:
- Spatial Options
- Strategic Objectives
- Supplement on laws and guidance about the Impact Assessment process
- and at the end a proposal agreed with UCL Engineering Exchange concerning Social Impact Appraisal
The 3 Spatial Options already being evaluated within the IIA process are summarised in this extract: IIA extract 3 spatial options
Spatial Option 4
- The growth challenges facing London require a new geography and a fresh imagination, underpinned by inclusive growth, fairness and diversity of people, businesses and places, therefore avoiding over-reliance on the Central Activities Zone/Isle of Dogs, high-order Town Centres and on a small number of economic sectors.
- This new geography for London will be a network of Lifetime Neighbourhoods and Lifetime Suburbs, providing many key amenities and job opportunities locally, thus reducing the need for costly and polluting travel into the Central Activities Zone. Outer London in particular needs lifetime suburbs and a real mixed development strategy Through a new approach to public and community-owned assets driven by social sustainability objectives, social infrastructure and community spaces in all parts of London will be protected, avoiding the previous decimation of community assets in working class and multi-cultural geographic areas. It will be a Blue Green City, placing value on the connection and interaction between London’s blue and green assets.
- The South East region and the other regions of the UK are a spatial context which has to be considered in thinking about the spatial future of London. Inclusive growth, that puts economic fairness, health and well-being and environmental sustainability at the heart of development would require a re-balancing with the rest of the UK economy and involve the Mayor in partnerships and collaborations with other cities and regions. Such negotiations could lead to welcome reductions in London’s need to find space for additional homes or jobs.
- It seeks growth by fostering higher pay, investment and productivity in the 50% of London jobs where real wages have been static or falling. It avoids the extinction of viable enterprises in industrial zones, in high streets and local centres and supports the provision of new workspace suitable for diverse activities and sectors, particularly in the foundational economy. This approach offsets the historic sectoral bias in favour of financial and business services in the centre.
- To achieve a balanced polycentric development the public transport priorities will be orbital movement plus walking and cycling, with investment directed towards smaller scale infrastructure rather than commuter routes such as Crossrail 2. This connects well with the aim of protecting more workplaces outside the centre and with the Lifetime Neighbourhood and Lifetime Suburbs objectives, increasing accessibility and connectivity locally.
- All parts of London (central, inner and outer London and the more affluent geographic areas within Boroughs) will contribute in an equitable way to meeting London’s housing needs. There will be a high percentage of not-for-profit rented homes everywhere, the cessation of estate renewal on current terms (which entails demolition/eviction and big net losses of existing social rented housing in geographical areas where there is a high concentration of working class and minority ethnic communities) and direct development by GLA and Councils of not-for-profit rented housing on public land as a matter of urgency;
7. A continuous process of engagement will give voice and agency to all Londoners with a geographically dispersed model of hubs instead of all connections and resources being targeted at a central hub. Targeting areas of need will close deprivation gaps by measures that raise the Quality of Life of existing communities rather than through their dispersal/displacement. Programmes will be provided so that areas with a high concentration of working class and minority ethnic communities can access the participation tools that are available, such as community rights under the Localism Act.
[ Download PDF of Spatial Option 4: London Plan IIA spatial option 4 ]
GLA officers’ immediate response to an earlier, shorter version presented on the 13 June was to say that most of the goals we wanted to achieve were already embodied in Option 2. Our reaction to that is
(i) most of the elements of Option 2 are open to minimal or maximal interpretations because of the use of terms like “more proactive”, “an uplift in…” and “more targeted…”
(ii) We therefore suggest that Option 4 should test the effects of doing MORE or LESS of key actions than are embodied in Option 2. For example
- If Opt 2 looses 70 ha of Industrial Land / floorspace p.a, Opt 4 should have zero net loss;
- If Opt 2 envisages estate regeneration in working class areas yeilding 6000 net additional dwellings p.a. (but with a net loss of 1000 social rent), Opt 4 could test a programme of reduced demolition, more infill, yielding net addition of 3000 dwellings p.a. and zero net loss of social housing;
- If Opt 2 includes CR2 with a lot of job growth in the centre, Opt 4 would delete CR2, add massive extra (i.e. over and above MTS) investment in cycling, walking and suburban orbital movement, with consequent changes in workplace location away from CAZ growth.
Strategic Objectives – Just Space draft statements
The London Plan is likely to be written around 6 “strategic objectives”. Just Space has submitted the folllowing paragraphs, explaining how the Community alternative would interpret each of the GLA’s (provisional) headline objectives.
The Community-led vision in spatial option 4 above is complemented by 6 strategic objectives ensuring London is a city that:
Objective 1: Makes Best Use of Land in organising development and shaping growth to meet the needs and aspirations of the people and communities of London in an inclusive, fair and sustainable way, coordinated with development beyond its boundary. New models of development and regeneration will prioritise social sustainability and social infrastructure; the protection of existing settled communities to support Londoners’ attachment to place and sense of belonging; delivered to achieve the decent homes, densities, place-making and sustainable development needed by —and sensitive to— communities and localities.
A more sustainable pattern of development will be achieved through a greater recognition of a more polycentric geography for London; together with rebalancing employment and housing demands to protect and enhance diverse workspaces and the localised economy; lifetime neighbourhoods and, in outer London, lifetime suburbs, providing many key activities and facilities locally, reducing the need to travel; a crucial role for active travel and public transport, including orbital and smaller scale investments; and meeting challenging environmental limits, targets and opportunities. Implementation with clear impact evaluation and monitoring will optimise delivery.
Key land use policies (especially those governing densities and essential social & affordable housing provision) will be made firmer (less flexible, less negotiable) to give greater certainty in the land market: specifically aiming to ensure that developers don’t pay more for sites than is consistent with meeting development plan requirements.
Objective 2: Strong and inclusive communities
Interaction and participation will play an important role in building a city where all play an active part in the decisions that affect them. They will give voice to the diverse needs across London’s communities, particularly the needs of those under-represented or completely excluded, and make a significant contribution to the reduction of social and economic inequality.
Neighbourhoods that are healthy and inclusive will have facilities, amenities and community spaces that are accessible and affordable to everyone, now and for future generations. These spaces are highly valued for the opportunities they provide for social interaction, community networking and empowerment and in every neighbourhood they will be audited.
Engagement with communities will be a meaningful and continuous process, with real opportunities for co-production.
Objective 3: Healthy City
A healthy city is one where everyone enjoys a healthy urban environment to live, work, learn and play, regardless of their income, their background, or the part of London they live in.
Air pollution and active travel
The London Plan’s policies must act to bring air pollution down to safe levels, while encouraging active travel by making it safer and pleasanter to walk and cycle in the city. In practice, this includes:
- Reducing the need to travel by continuing to encourage development which contributes to lifetime neighbourhoods
- Not allowing any new roads in the capital, and restricting any new river crossings to those reserved for public transport, walking and cycling.
- Widespread pedestrianisation of central London and local town centres, and provision of safe walking and cycling infrastructure along roads
- Ensuring that new schools, care homes and hospitals are not built near main roads
Daily access to high quality nature
There is strong evidence – as noted in the IIA – that people with better access to the natural environment are less prone to mental illness. Access to green space may also increase physical activity. The London Plan must mandate boroughs to ensure that everyone in London is no more than 5 minutes’ walk away from high-quality nature, and maintain the current policy of ensuring that no one is more than 10 minutes from a local park or open space.
Planning for healthy food
Planning policies can have a significant impact on access to healthy and unhealthy food. The existing London Plan policy to support boroughs to restrict fast food outlets near schools is positive. This must be strengthened so that as far as possible boroughs are mandated to restrict the opening of such outlets.
Furthermore, the London Plan must require that all new developments improve local residents’ access to affordable fresh healthy food, or at least maintain it where this access is already good.
Objective 4: Delivering the homes Londoners need
In a city for all Londoners, everyone across all household sizes, income levels and specialist needs should be able to live in all parts of London in secure, high quality homes they can afford.
To meet the full extent of backlog, current and future housing needs for the majority of Londoners, the London Plan will prioritise the delivery of not-for-profit rented homes, including social rented and community-led housing, particularly on land owned by the GLA Group, Local Authorities and other public bodies. There will be significant improvements in the standards for security of tenure, living conditions and rent control across the private rented sector.
All new homes will be energy positive, built to lifetime home standards and provided at densities which are sensitive to the diverse needs of London’s communities and take into account social and green infrastructure, as well as affordable access to public transport, as part of Lifetime Neighbourhoods and Lifetime Suburbs.
Caring for all existing homes and communities will be prioritised through investment in energy efficiency infrastructure and sustainable retrofitting and adaptations. Not-for-profit homes will be protected from loss through redevelopment, and proposed regeneration of council and housing association estates will be subject to a ballot of tenants and leaseholders and independent environmental, social and economic impact assessments.
The delivery of new homes and measures to protect and improve existing homes will apply across the whole range of housing types and sizes, with steps taken to increase provision where there is evidence of consistent shortage and poor living conditions. These processes will ensure the full involvement of all London’s communities in housing decisions, supporting capacity building for social tenants, private renters and groups with specialist needs.
Objective 5: An inclusive economy
The economy of London will be managed in ways which foster the reduction of inequality, especially of in-work poverty, sustaining London’s production of goods and services valued by its citizens, by the rest of the UK and for export. It will, in particular, foster and nurture the sectoral and ethnic diversity of economic activity in the interests both of robustness and fairness, paying attention to the social and environmental value of activity alongside private profitability. Growing activity is to be expected in greening the economy, in attending to the safety and environmental performance of the building and vehicle stocks and in moving towards a more circular economy.
While many of the levers for influencing the economy of London lie in the hands of national government and supra-national bodies, the Mayor and the GLA Family of organisations have substantial powers and influence. These will be exercised in a spirit of cooperation with national and regional bodies and with European institutions where appropriate.
Land use and transport powers will be used alongside powers to manage and influence education, training and skills through the LEAP and alongside the procurement and employment powers of the GLA Family. Aims there will be to reduce the discrimination against SMEs and ethnic and other minorities (including the disabled), extend the implementation of the London Living Wage and foster good jobs with security and progression prospects, halting the drift towards casual and insecure work which are the source of so much in-work poverty.
Land use planning will be grounded in a much closer understanding of the social, environmental and interlocking economic value of public and private enterprises across all sectors and localities. This is especially important in respect of Opportunity Areas, Housing Zones, land in and behind High Streets and other localities subject to planned development policy designations by the Mayor and Local Planning Authorities (and in major development applications). In these cases social impact appraisals will be made in advance of decisions, evaluation criteria including the effects of change on jobs being lost as well as gained, travel and emissions impacts and cultural effects. To this end the Mayor will support and strengthen community and employer organisations in their contribution to understanding and policy-making.
Objective 6: Efficiency and Resilience
Integrating and delivering on environmental, social and economic goals, to live within environmental limits and a just society that is more resilient to changing circumstances, including extreme weather events and climate change. Strengthening targets in the light of the Paris Agreement 2015, to move away from fossil fuels and fuel poverty by scaling up retrofitting, increasing energy efficiency and renewables, within systems that are democratically controlled locally.
Making London a Blue Green City, as a cross-cutting approach to sustainable water supply and drainage, flood risk management and green infrastructure. Stewardship of the environment in which biodiversity/nature and community food growing can thrive. Applying the principles of a circular and sharing economy where waste is purposefully used and reused as a resource to maximise the green economy and minimise adverse environmental impacts. Protecting and enhancing the Blue Ribbon Network not only for its amenity and natural qualities but for its transport and economic abilities.
Supplement: Law and policy framing
The following are the principal laws and policies which specify or advise how this planning should be done.
In accordance with the Strategic Environmental Assessment (SEA) Directive, the preparation of the London Plan must allow for a systematic and iterative testing of reasonable alternative options. Government guidance on good practice for the SEA remains the Sustainability Appraisal of Regional Spatial Strategies and Local Development Frameworks (ODPM 2005)
The GLA term ‘spatial option’ as used in the IIA Scoping Report February 2017 seems to be interchangeable with “strategic option”, “scenario testing” and “reasonable alternatives”. Whichever term is used, the exercise needs to (at least) include the geography of development, capacity, regional role and sectoral bias which were tested for the London Plan adopted in 2004 (see SDS Technical Report 17 – Scenario Testing August 2002).
The London Plan is required to achieve sustainable development and equality of opportunity so a view needs to be taken of development that goes beyond traditional land use planning and brings together other policies and programmes which influence the nature and function of places and are vital for a socially inclusive and fair city.
“§ 2.4 The London Plan also provides an overarching framework for the Mayor’s other strategies, by:
- providing a spatial (geographical and locational) framework and context for his other strategies (such as those on transport, economic development, housing and the environment);
- bringing his strategies and policies together in a single, comprehensive framework, showing how together they will contribute to the sustainable development of London over the next twenty years; and
- giving effect to those of the Mayor’s policies that require the planning system for implementation.
§ 2.12 The London Plan will assume a 20 year forward planning period, and:
– set out the Mayor’s general policies for the development and use of land;
– incorporate the geographic and locational elements of transport; environmental, economic development and other strategic policies for London, bringing them together in a single, comprehensive framework;
– adopt an integrated approach, covering all aspects of physical planning, infrastructure, development and other policies affecting or affected by the distribution of activities and promoting their implementation;
– contribute to the achievement within London of sustainable development, a healthy economy and a more inclusive society. [extract – due to length not all points are quoted]
The London Plan is required under the GLA Acts to achieve sustainable development, equality of opportunity for all people, the promotion of economic development and wealth creation, social development and the improvement of the environment, addressing health inequality and the effect on climate change.
English national policy: National Planning Policy Framework § 152
“Local planning authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three. Significant adverse impacts on any of these dimensions should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued. Where adverse impacts are unavoidable, measures to mitigate the impact should be considered. Where adequate mitigation measures are not possible, compensatory measures may be appropriate.”
The publication of the European Spatial Development Perspective (ESDP) in 1999 was a key milestone in the development of a strategic spatial vision for the EU territory. The ESDP advocated “a spatial balance designed to provide a more even geographical distribution of growth across the territory of the EU (aiming at cohesion)” with the key policy objective of “polycentric spatial development”. This was mentioned in the London Plan 2004 and is still cited.
The ESDP was followed by the concept of “territorial cohesion” which became enshrined as a key objective of the EU in the Treaty of Lisbon (2007). In EU documents, the objectives of territorial cohesion are variously referred to as reducing territorial disparities; ensuring a provision of public services which does not disadvantage anyone due to their geographical location; reaching a balanced development of all national, regional and local territories; promoting their diversity and endogenous assets; fostering cooperation between various actors; improving the coherence between the territorial impacts of sectoral and spatial policies.
The 2015 UN Sustainable Development Goals (extracts)
- End poverty in all its forms everywhere; 3. Ensure healthy lives and promote well-being; 8. Promote inclusive and sustainable economic growth, employment and decent work for all; 10. Reduce inequalities; 11. Make cities inclusive, safe, resilient and sustainable; 13. Take urgent action to combat climate change and its impacts.
Engineering Exchange Project Scope
Project Name Social Impact Assessment Briefing Note
Community Group representative/s Just Space
UCL Team Leader Sarah Bell
Desired date Start: 1 August End: 31 August
Details of Project
The London Plan makes provision for Integrated Impact Assessment (IIA) of policies, plans and development proposals. This includes Environmental Impact Assessment, Equalities Impact Assessment and Health Impact Assessment. Social Impact Assessment (SIA is an established methodology that is not currently included in London planning processes.
The Greater London Authority (GLA) has committed to enhancing community involvement in IIA. Just Space are interested in exploring the potential for SIA to support community interests in IIA with the GLA.
Just Space members have previous engagement with SIA expertise, including:
– Monitoring and Implementation workshop at the 2015 Community Conference
– presentions at the Integrated Network for Social Sustainability conference in 2016
– early research by Just Space member group Ubele
– case studies of SIA for London’s Gypsy and Traveller Communities and Lifetime Neighbourhoods in the Just Space document ‘Towards a Community-led Plan for London’
This project aims to produce a briefing note on SIA principles, methods and tools. The briefing note will be used by Just Space and its members to inform discussions with the GLA about opportunities to include SIA in IAA for the London Plan. The briefing note will:
– Outline key principles of SIA
– Review the state of the art for SIA
– Focus on the use of SIA in urban planning
– Identify well established methods and tools for SIA
– Draw on existing expertise and experience of Just Space members
The project will deliver:
– 1 briefing note, 4-5 A4 pages
– Bibliography of sources for further reading and tools for SIA
– A review meeting with Just Space members
Detail the core project team, including community group members and UCL Practitioners.
Name Role Contact Details
Charlotte Barrow Project Manager
Sarah Bell Facilitator email@example.com
Aiduan Borrion Contributor firstname.lastname@example.org
Cathy Baldwin Reviewer email@example.com
Saffron Woodcraft Reviewer firstname.lastname@example.org
Yasmina Beebeejuan Reviwer email@example.com
Richard Lee Client firstname.lastname@example.org
Robin Brown Client email@example.com
Detail the key project milestones, relative to the project start date (e.g. on-site research complete, report complete, etc). These can be estimated and subject to review as the project progresses. You might also wish to highlight any specific dependencies for each of the milestones.
Milestone Target Date
First draft of briefing note for review 9 August
Review meeting with Just Space members 17 August
Final draft of briefing note for internal review 23 August
Briefing note complete 31 August
Any other relevant information.
end 7 August 2017