UCL’s prof Pablo Sendra has published an article on how the tricky term co-design should properly be defined and used. He writes “There is a lack of definition in policy of the term co-design, and yet local authorities and developers are increasingly using it. To avoid this term becoming meaningless, it is essential to define how to run co-design processes ethically. Building on case studies, professional experience, collaborations with communities in Just Space and elsewhere, and a Participatory Action Research approach, this paper defines a set of principles on how to run a co-design process ethically and genuinely including communities in decision-making. Departing from the legal Principles for Fair Consultation in England and Wales, the paper expands them and results into ten ethical principles for co-design.
The enormous importance of street markets is often not appreciated. They provide the cheapest food, often the freshest food, social engagement among customers and traders and employ a lot of people. But they have been coming under relentless pressure from developers and often from the councils which manage or regulate them. This conference is supported by Just Space and should help those all over London in the defence of their markets.
Learning from East End Street Markets
1-day conference
Date: Monday 21st August 2023, 10am-5pm
Place: Hason Raja Centre, Whitechapel E1
One-day conference learning from the historic East End Street Markets: the threats, the challenges and what community value means today
The post-Covid 19 cost-of-living crisis has shown the importance of street markets for economic resilience in London’s embedded communities, yet East London’s historic street markets are increasingly under threat due to land speculation, changing public policies and shifts in consumer behaviour.
This conference follows on from June 2019’s ‘The Future of London’s Street Markets’ held in Brixton. We will hear from East London’s longest standing market campaign, the Friends of Queen’s Market (Newham) to identify future threats and key issues facing markets in ‘ethnic majority’ areas of London.
The Just Space Network’s Community-led Recovery Plan and the University of Leeds research findings on the community value of street markets(2022) will set the grounds for afternoon workshops, with input from East End campaigners facing pressures from the financial city and hardline gentrification.
Afternoon group workshops will examine the current position of street markets in understanding the historic East End, its diverse communities and evolving landscape, as places that foster community cohesion to address isolation, provide affordable food for healing and wellbeing and examine the threats to market livelihoods today.
BOOKING: Free to attend. Booking essential. Limited places. Book your place through this Eventbrite link: http://streetmarkets.eventbrite.com and there is a video at
14 July 2023: there is news from City Hall which is important for Just Space members.
Draft guidance on ‘Affordable’ housing and on Viability Assessment: consultations close on 24th July.
The Mayor produced two new London Plan Guidance (LPG) documents in draft and seeks comments before they are finalised. These documents cannot, by law, change the policies which are embedded in the London Plan but they can and do elaborate them and toughen them up through the details of implementation.
The London Tenants Federation (LTF) has submitted their very careful and detailed commentary on both LPGs and has kindly agreed that we can share it with other members of Just Space who may be preparing their own submissions, or who may want to write to the GLA supporting the LTF.
The LTF makes a refreshed and powerful case for focusing planning policy as much as possible on maximising the production of social housing at council rents and not the other, more expensive, forms of so-called “affordable” housing. It refers back to the latest GLA study of London’s housing needs in 2017 which showed how overwhelming was the need even then for secure, low rent, housing which only social/council housing can provide and it points to the extremely low levels of actual production which have been achieved since then, suggesting many ways in which more could be done.
The response welcomes some of the GLA proposals to tighten up loopholes which enable developers to avoid or minimise their obligations and pushes for a bolder insistence on delivery of at least 50% ‘affordable’ housing on land previously in public ownership.
The Viability analysis LPG is all about the details of a rotten system which the LTF and Just Space have always criticised – establishing developer profitability as the dominant criterion governing what gets built and for whom. But for the moment the provision of most social housing depends on private developers and housing associations being forced to provide it as a condition for getting planning permission. The rules and procedures for testing what developers can afford are the subject of this LPG and the Tenants Federation is very shrewdly pointing out further ways in which developers’ manipulation of the figures could be limited and the whole process be made more transparent.
The LTF response to the two LPGs is here and will also be on their own site LondonTenants.org
Remember: 24 July is the closing date for comments.
Planning For London programme
Just Space and many community groups consider that the last London Plan was a bad plan and it’s is now very old. Drafted in 2016, it would have been adopted in 2020 (though it was pushed into 2021 by the Secretary of State) and has in many ways become even more irrelevant to London’s real needs as a result of the pandemic, the fresh round of austerity, now a recession and the accelerating reality of climate and biological breakdown.
We argued that the City Hall planners could and should have got down to some urgent work to get a new plan under way but the Mayor apparently decided that no start should be made until after the next mayoral election in May 2024. So instead City Hall has devised this Planning for London programme in which they are gathering the views of citizens and organisations while declaring that this is not part of making the next plan.
They have just held the first two events at which they met with citizens and organisations (we are called “stakeholders’) and they promise to publishe what that have gleaned from listening to the many round-table discussions they orchestrated. They are also going to publish their learnings from an earlier series of focus-group-type (‘deliberative’) events to which they invited a statistically representative selection of Londoners. The whole programme is set out on the City Hall web site here. There will be a stage where they invite our inputs on how they should do impact analysis. That’s a process which they made a serious mess of last time and had to try to make good in the middle of the public Examination so it is very important that we all help.
Just Space told its member organisations about these two recent public events so quite a few of us took part and we are gradually comparing notes about what happened. We’ll post our summary here. Meanwhile one of our members wrote a personal blog post here which you might want to look at.
If you have comments or observations or took part in these events and want to offer your reactions, please get in touch or use the comments below.
Many of the strongest calls for change in London planning have, in effect, been criticisms of Opportunity Areas, the mechanisms which govern major physical developemnts in the city and are so often spurned as just Opportunities for Developers.
Taking stock of many years of engagement, Just Space has just produced a draft document to help members decide what to do next.
The term Opportunity Area has been in use since the 1990s, applied to areas where very large scale change through development is planned. This report summarises the big shifts in how the designation has been used, initially for the modernisation of employment in under-used industrial, port or railway land, but now for many ordinary parts of occupied London, the aim nowadays being mainly to create development sites for housing through intensification.
Community groups in and around the affected areas have criticised and resisted many of these schemes for decades and tried to secure changes to the London Plan policies which govern them, with scant success. The criticisms have been that the designation, planning and target-setting of OAs have lacked transparency and democracy, as have the mechanisms for implementation. Areas have been planned without the necessary understanding of the social and economic life of the affected areas and the outcomes have mostly been detrimental to working class, including minoritised, communities and to many businesses. Just Space continues to argue that there should be no further designations until a serious review of the programme has been completed and digested.
In the last 2 years Just Space has collaborated with the Planning and Regeneration Committee of the London Assembly which, in turn, has put pressure on the Mayor of London (the planners in the GLA) and secured a new policy document and web site. This represents modest progress.
The aim of the new Just Space report is to bring a scattered narrative up to date and form a basis for Just Space member groups to consider what further steps, if any, to take on this issue in the wider context of how London will be planned in the current emergencies. It thus complements the Community-led Recovery Plan for London prepared during the worst of the Pandemic.
*********************************
Because this report was facilitated by UCL Bartlett School of Planning’s knowledge exchange with Just Space, it is being presented initially to students before the summer term ends. The meeting is open to all. Friday 12 May 1600h-1800h, mainly face-to-face but with a zoom option.
Just Space has agreed with Michael Ball of the Waterloo Community Development Group that he will do coordination and media work for us.
Michael is a seasoned and experienced campaigner, skilled in community development and building coalitions to further community interests. He has worked with the WCDG for many years and led it for the last 20. He writes:
“I’m delighted to join Just Space as community co-ordinator. I’ve always been driven by people and communities thriving where too often they have been denied a say in the planning and development of this city. That has to change. I’m looking forward to ensuring that the planners and politicians hear the voices they have all too often missed.”
He is taking over the coordination role from Richard Lee who has nurtured and supported Just Space since its foundation in 2008, from just a handfull of organisations to today’s large network which saw about 60 community groups active in the examination in public of the 2021 London Plan and a similar number generating the community-led Recovery Plan for London, all created through online workshops during lockdown, against heavy odds. Richard is not leaving Just Space but withdrawing from coordination to concentrate on a raft of specific projects, most of them spinoffs from Just Space.
Michael Ball is joining us as a self-employed contractor, subject to contract, and his engagement has been made possible by a generous 2-year grant from the Trust for London to whom we are most grateful. The contract has been designed to include work on our media.
His bid was selected from a short-list of 5 excellent proposals, any of which we could have accepted, in response to a call for tenders published here last month.
Summarising his relevant background Michael Ball writes:
I started getting involved in planning issues as a community representative in the 1990s, for my estate TRA and my kid’s school’s PTA. I ended up leading a team in successful campaigns against a project to demolish an estate in Vauxhall, and another to demolish the school.
In 2002 I became Director of WCDG and led successful community campaigns to fight off development over Jubilee Gardens, and get massive investment in extended gardens (opened by the Queen in 2012), and to stop Boris Johnson’s vanity project, the Garden Bridge. We also saw off many inappropriate proposals for the Opportunity Area, and embraced partnerships with other community groups and businesses to get key improvements, such as developing a retail strategy and completely refurbishing the high street.
In all of these cases, and many others I have been involved in, critical to success has been the community’s anger and determination to inspire and bring into reality a more positive and just space.
I most recently appeared as advocate in major public inquiries for 8 Albert Embankment in 2021 (which we won) and for 72 Upper Ground – the former ITV building – (awaiting a decision of the Sec of State).
Michael Ball starts on 17 April and, for the time being, can be contacted at michael.ball@wcdg.org.uk
This is the name of the Bill going through Parliament which includes the government’s current ideas on planning “reform”.
Back in 2020 the government held a consultation on proposed changes to the Planning system for England and Just Space did briefings for members and consulted members on a draft before responding formally to the government (and to the parliament which conducted its own consultation).
In 2020 the government was proposing a number of big changes – crucially
calling for all land in England to be allocated by local authorities (LAs) in their Local Plan to one of 3 zones, each of which would be defined by central government. Development proposals which conformed to the specification for that zone would then proceed to planning permission without planning committee or community involvement.
calling for community involvement to be strengthened at plan-making stage. But it would cease at the stage of planning permission (except for schemes in the ‘protected’ zone, including conservation areas).
Section 106 and CIL would be replaced by a new Infrastructure Levy designed to cover infrastructure and affordable housing costs. Within the housing element, the first call on the money would be for “First Homes” which were to be cut-price homes for sale.
The consultation / white paper produced 4,000 responses and enormous controversies among community groups, local governments, professions, with many attacks on the proposals as a gift to land owners and developers, bad for social housing delivery, bad for democracy, unworkable and so on. We linked many of these responses. including some from Just Space groups.
Jump to 2022 when the government finally sent a draft law (a Bill) to parliament, combining a reduced set of planning changes with its new idea— Levelling Up. The Bill is thus called the Levelling Up and Regeneration Bill. Just Space was busy with other things at the main consultation stage of the Bill (the Committee Stage) and sent an update to members in November. Zoning had been dropped but the government’s aim of minimising community and council powers on individual projects was to be achieved by establishing National Development Management Policies which would take precedence over any local policies and plans. These policies would be written as regulations by ministers after the new law was in force.
The attached PDF briefing has been prepared for members by Jonathan Moberly, with inputs from many Just Space groups and policy documents. It brings us up to date with the progress of the Bill to the end of 2022. The Bill now passes to the House of Lords on 17 January 2023 and we are hoping to post some further briefing on the potential to influence the Bill during its passage through the Lords.
The briefing contains links to the Bill itself, many supporting documents and some critical comments. In addition, members may want to look at the report on the debate at the London Assembly Planning Committee, kindly prepared for us by Shibo Chen, and at the web site of the London Forum of Civic and Amenity Societies.
Michael Gove has launched the long-awaited consultation on revisions to the National Planning Policy Framework – see here. The consultation runs until the end of February 2023 and we hope to provide some commentary to members.
When the London Assembly Planning and Regeneration Committee finally got around to discussing Mayoral Development Corporations on 23 November, we made some strong oral statements about what’s been such a disappointment (or worse) at the Corporation which governs the Olympic park and surroundings (LLDC). We had also submitted detailed written evidence in advance. (See previous post.)
The Committee’s plan had been to scrutinise both Corporations at the same meeting but they switched to an emphasis on LLDC, so they stood down the community speakers lined up to give evidence about the other one, Old Oak Common and Park Royal OPDC. But they still invited the bosses from OPDC who were able to make their speeches unchallenged.
We have written a strong letter to the committee and are sending all our evidence also to the Budget and Resources Committee which is scrutinising both Corporations on Wednesday 7 December at 10.00. We can all attend in person or online or catch up later. Details here. The Old Oak Neighbourhood Forum has also sent a very strong and detailed statement which you can read here, along with ours. Added 6 December a strong letter from Prof Jennifer Robinson .
Our letter to the Planning and Regeneration Committee, copied also to the Budget and Resources Committee, is as follows:
Sakina Sheikh AM, Chair of Planning and Regeneration City Hall + members and staff of P&R committee
Dear Sakina
Mayoral Development Corporations
Following the Committee’s meeting on 23 November there were many loose ends and we considered it necessary to write to you all. We would be glad of a reply to the following points, either in writing or in a virtual or F2F meeting.
We have been pleased with the way in which your committee has, this session, taken some community voices on board but it has been hard to keep up with the twists in your programme. Our work on all this, and the work of our member groups, has had no resource from City Hall since 2008 and we believe that an adequate scrutiny system for London will require community inputs to be resourced just as much as it will require much better forensic resources for the Assembly and its committees.
In the absence of adequate resources, we don’t envisage that your committee’s report on MDCs will be able to qualify as an adequate scrutiny and we hope that it will be forceful about the need for a serious scrutiny – an independent one in which evidence is made public and open to challenge. We note that there is no sign yet of action on your recommendation earlier in the session for a review of Opportunity Areas more widely.
Your decision, quite late in the day, to focus this meeting mainly on LLDC and thus stand down the community representatives from Old Oak Neighbourhood Forum and the Grand Union Alliance might have been acceptable but the heads of OPDC were on your panel nonetheless and with no independent voices to challenge them. Thus David Lunts was able flatly to deny the allegations of low transparency reported by AM Berry and was later free to denigrate (by implication) both of the community networks as NIMBY ‘usual suspects’, best ignored. Detailed written evidence was (and is) before you on that and you should have had oral testimony too in any fair process.
We need to make a number of specific points on the LLDC discussion, having now listened to the recording of the Q&A.
4.1 On employment displaced for the Olympic Games, we understand that the figures given were based on the numbers employed by companies which received a payout under the CPO so it is an underestimate as there were companies whose leases were expiring who did not receive any compensation. In addition we know there were people working informally and there would have been people on casual or temporary arrangements who wouldn’t have been included in permanent employment figures. The businesses being evicted claimed as many as 11,000 jobs would be lost, see in this article below. That may be an exaggeration but the figure was certainly higher than 5,000
4.2 Lyn Garner’s replies on employment seemed to deal only with jobs on the Park and at the International Quarter, not with jobs elsewhere in the designated area, such as Carpenters about which Dr Myfanwy Taylor spoke, giving a much more negative narrative.
4.3 Lyn Garner’s replies on housing appeared to be limited only to the land owned by the Corporation and to exclude the rest of the designated area for which it is the LPA. And she entirely failed to respond to the question about the influence of rising property prices on housing and workplace affordability more widely in the host boroughs and east London.
4.4 Specifically in our own written submission in May we reported the dominance of open market homes and the low proportions of social housing in the output of the host boroughs between 2010 and 2019 (page 4) and the low proportions of social and “affordable” housing in the LLDC designated area, using data from the Kerslake review and the LLDC’s Annual Monitoring Reports (page 10). More recently, the latest in a long line of research by Dr Penny Bernstock reported at the September universities conference on the Legacy presents detailed figures on schemes within the Park and also for the wider LLDC area, concluding that ‘across the whole area, 29% of housing was affordable and the majority of [the affordable] housing built was intermediate.’ (tables 3, 4 and 5 in Mark Sustr, Housing Legacy, in Bernstock et al (eds) State of the Legacy, UCL, Oxford Brookes, University of Cardiff and UEL, 2022, pp 77-99). The housing activity of LLDC, as developer and as planning authority for the wider area, has overwhelmingly contributed to the open market stock of homes (70% overall) and not to meeting the needs of a deprived population or reducing deprivation.
5. We note that the Assembly’s Budget and Performance Committee is considering both MDCs next week so we are sending this letter to them as well.
Just Space has today written to the members of the London Assembly Planning and Regeneration Committee, prior to their meeting on Wednesday 23rd November about the London Legacy Development Corporation and any lessons which could be learned for Old Oak Park Royal. Interested people should try to attend the meeting in the new City Hall or follow or catch up online. We wrote:
Short statement from Just Space
This meeting on MDCs has been postponed a number of times and its scope has changed. Just Space prepared a substantial submission on both MDCs and submitted it to the secretariat, by agreement, in May 2022. In the changed circumstances indicated by the Committee’s agenda, released on 16th November, and because the Just Space and other community submissions are not being circulated as supporting papers, it may be helpful if the Committee has this short summary of the JustSpace position.
Openness to community knowledge and inputs
London’s Opportunity Areas have been strongly criticised for failing to pay attention to communities of residents and businesses in and around their boundaries. These failings, by elected local governments and the GLA, were the subject of strong representations to earlier meetings of the Committee and remain unresolved.
The creation of the two MDCs could perhaps have led to reductions in this democratic deficit if they had strong enough instructions to do so. Initially the LLDC did seem to listen and create space for the Carpenters community to express their needs and develop a Neighbourhood Plan, though in the end it was Newham, as land owner, which was able to override them. In both MDCs a number of local councillors were nominated to serve as a minority on Boards and Planning Committees and this was considered by the Mayor as providing local accountability. However it completely failed, local councillors failing to open up decisions to the community and being complicit in decisions which had adverse community impacts. Where they resisted (as in the MSG Sphere case at Stratford) they were outvoted by the property industry majority on the relevant committee. Simply reverting development management powers back to the Boroughs when the corporations are dissolved is not an adequate answer.
What was valuable was that the requirement on both MDCs to produce Local Plans led to EiPs at which community groups and local businesses were enabled to argue their case, submit evidence and have some influence – just the sort of process which we have always argued should be normal in Opportunity Areas, both for initial planning and for ongoing management. This does not mean that communuty groups are happy with the resulting plans in either case, but they have at least been heard.
Community groups in both MDC areas have pointed to the conflicts of interest which exist between the role of planning authority, responsible for pursuing the public interest and following evidence of need, and development agency, responsible for promoting its developments. A further conflict is between the Mayor of London’s roles as promoter and owner of the Corporations and as ‘person’ accountable and reliable in cases of dispute.
Housing and development achievements
No amount of clever design of special agencies could solve the problem that big development on complex sites cannot be achieved by organisations which don’t own the land and don’t have the money. The LLDC did have a lot of land and should have been able to deliver the socially rented housing so badly needed in Newham and adjoinging boroughs. This priority was not clearly embedded in its foundation nor reflected in its Board members or staffing which appear to have been oriented much more to property development interests and generating capital receipts against accumulated debt. ‘Convergence’ was always an inadequate aim because it could be achieved either by the reduction of deprivation or by the dilution or replacement of deprived people by richer people.
Major urban transformations in our sort of economy boost land values both within their patch and also for miles around and for years to come but the current London model simply tries to capture some of this value through initial negotiated developer contributions from high value developments. Then, when that doesn’t offer all the social infrastructure and social housing that is needed, additional density and height are added to an extent that is unacceptable to citizens and environmentally dangerous. This will be a problem of Opportunity Areas whether or not they have MDCs, but MDCs magnify the ambition and scale of development in ways that have become harmful to sustainable development in London.
The affordability of housing for working class people in east London has been reduced by the price and rent escalation triggered by LLDC, despite the fact that a very small number of households will have benefitted from the tiny provision of ‘affordable’ homes.
The problem is even worse at OPDC where the Corporation had neither land not the capital funding needed to transform this intricate area. Even the land in the ownership of other Mayoral or government bodies was not effectuvely under the corrporation’s control.
The arguments summarised here are elaborated and evidenced in the Just Space evidence submitted to the Committee secretariat on 24 May 2022, available with other documents at JustSpace.org.uk/MDC
8 Nov 2022. With all the changes of government and ministers in recent months, many people will have forgotten that the government’s White Paper on Plannning of 2020, on which we commented so thoroughly, did finally lead to a draft law (a “Bill”) being sent to the parliament. It was combined with proposals for “Levelling Up” and thus carries the name Levelling Up and Regeneration Bill (LURBill for short).
Just Space people have been very busy with other things and missed the chance to comment again on government proposals during the summer Committee stage. The Bill soon goes to the House of Lords and there may be scope for lobbying there. More news soon as we work out how we can help our members deal with these issues.
Meanwhile the London Assembly Planning and Regeneration Committee considered the LURBill on 12 October. For once we were not formally represented but we are grateful to Shibo Chen who volunteered to summarise it for us. His summary is here.
In short the government claims that it wants to strengthen public participation but is making proposals which would do the opposite. The key change in this Bill is that National Development Management Policies —not part of the Bill but to be written later by the Minister— would be enforced across England and would override whatever policies local authorities had in their plans. This would be a further colossal centralisation of power and would probably deter citizens from bothering to participate. Provisions for ‘Street Votes’ proved controversial with Assembly Members divided. Plans to streamline Infrastructure Levy were criticised by both Members and GLA planning staff.
The full video record of the Committee meeting is here along with minutes and agenda.
