Labour leader defends Plan

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

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

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

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


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

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


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

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

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

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

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

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

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

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

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

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

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

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


Assembly urged to reject Plan

Call to reject this London Plan

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

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

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

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

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

Specifically, the draft Plan is bad because of its…

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

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

London Plan: end game

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

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

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

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

The Mayor should…

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

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

Here are comments and assessments contributed by members/ groups:

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

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

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

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

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

Michael Edwards on positive gains in the Plan Edwards positive gains

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

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

Jennifer Robinson on Viability & Opportunity Areas Robinson Comments on Panel


Assessments by other people or organisations:

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

Blog post from Lichfields

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

Screenshot 2020-01-10 at 16.18.00

Consultants Barton Willmore are blogging, initially on the aggregate housing targets & failure to “meet housing needs” with GL.

Similarly, in a very brief note, consultant Iceni Projects speculate on whether the Secretary of State might overrule the Mayor on housing targets


Update on campaigns

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

London Plan

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

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

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

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

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

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

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

  • Failure to discharge the Public Sector Equalities Duty (PSED) throughout the planning process
  • Failure adequately to consider alternative strategies, notably the Just Space community-led plan. LSE London made a similar challenge, arguing the need for an explicit evaluation of alternative strategies beyond the London built-up area.
  • A mistaken approach to housing based on maximising total housing numbers, rather than maximising the stock of social and low-rent housing. This mistake will lead to the backlog of unmet housing need getting even worse in the coming years. [note added 28 Sept: the press reports a rumour/leak that the Panel recommends lowering the target to a more plausible level.]
  • Failure adequately to protect the jobs and services in London’s industrial areas, in and behind high streets and in town centres as housing is prioritised. This failing makes the economy less robust, increases the need to travel and would have regressive effects on many protected equalities groups.
  • Weak approaches to climate change and bio-diversity, lacking urgency and timelines of targets.
  • The absence of convincing ways of paying for social and physical infrastructure without cutting in to the provision of low-rent housing; contributing to unsupportable increases in housing density and probable land price inflation.
  • Continuing failure to devise transparent and participatory mechanisms for the designation, planning and implementation of Opportunity Areas.

Universities – Communities Knowledge Exchange

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

Calthorpe Community Garden – pilot social impact assessment

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

London Market Campaigners network

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

Industrial strategy

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

Land Justice Network – towards a land reform bill or manifesto

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

Greater Carpenters Neighbourhood Forum

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

Fairville – proposed EU research project

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

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

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

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

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

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

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

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

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

Grand Union Alliance (GUA)

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

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

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

Actual equalities study, at last?

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


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

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

  • age
  • disability
  • gender reassignment
  • marriage and civil partnership
  • pregnancy and maternity
  • race
  • religion or belief
  • sex
  • sexual orientation

Then, within the section on each group, there is a discussion for each of the 11 chapters of the Plan. Thus it is very easy to navigate.

On a first inspection, this is a fascinating essay on the diversity of needs among Londoners. If it had existed 3 years ago the preparation of the London Plan would have been hugely enriched. It doesn’t deal explicitly with the social class dimension (because the government decided not to implement that segment of the Equalities Act) but class / income / wealth variables do figure strongly where that’s the available data or where there are strong overlaps between poverty and group experience of deprivation.

Appendix 4 responds, one-by-one, to the criticisms made by respondents.

The legal section, in the ‘cover report’ and Appendix 2, is a defence. This is a non-legal comment: the GLA contend that they carried out their obligations with an appropriate level of detail, that all the studies contributing to all the Mayor’s other strategies form part of the discharge of the obligations, that they can reasonably assume that other public bodies will do likewise (i.e. boroughs in applying policy?), that the Panel has no power to judge the legality of what was done. We look forward to legal expert opinion on all this.

The documents can all be downloaded:

NLP/EX/33 Covering report Mayor of London response to Panel Note 7.2: Cover Report (Mayor of London, Apr 2019)
NLP/EX/33a List of Strategies Mayor of London response to Panel Note 7.2: Appendix 1 Mayoral strategies (Mayor of London, Apr 2019)
NLP/EX/33b Legal cases cited Mayor of London response to Panel Note 7.2: Appendix 2 Legal note (Mayor of London, Apr 2019)
NLP/EX/33c Impact of polices on each ‘protected’ group Mayor of London response to Panel Note 7.2: Appendix 3 Summary (Mayor of London, Apr 2019)
NLP/EX/33d GLA responses to participants’ comments Mayor of London response to Panel Note 7.2: Appendix 4 Table of responses (Mayor of London, Apr 2019)

The Examination in Public resumes on Tuesday 30th April, starting with policies on Waste and the circular economy. The programme is at

Inspectors taking equality seriously

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

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

Today’s statement from the panel reads:

Equality of Opportunity and the Integrated Impact Assessment

The Panel has received the written statements made following the publication of additional information relating to the equalities impact assessment. As we noted in Panel Note 7 we have considered whether any further information or analysis is required to assist us in the examination of relevant matters in the context of the public sector equality duty.

To that end we request that the Mayor:

  • Responds to the written statements with particular reference to the case law cited and legal implications, the general points of principle raised about the approach of the equalities impact assessment, and the specific policies referred to; and
  • Provide brief separate outlines of the specific implications of the Plan (both positive and negative) for each of the 9 groups with protected characteristics.This should be submitted by midday on Thursday 18 April 2019.

Just Space will be reporting this development to its member groups at a briefing on wednesday afternoon 13th March:

flyer 13 march

Grave weaknesses in the London Plan

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

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

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

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

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

The panel’s response is awaited. When further submissions are available we’ll post the links. Later (9 March): six more submissions have been made and are available at  It is not yet clear when these will be discussed. Without exception these submissions reinforce the detailed statement from Just Space summarised here.