Assembly is listening

London community groups had a rare hearing at the London Assembly’s Planning and Regeneration Committee on 7 September, making it very clear that a new London Plan is urgently needed, with genuine co-production with Londoners from the outset and a very different kind of London to be forged.

It was a breakthrough by this committee that it devoted an entire meeting to taking evidence from a panel of community activists and invited people whose organisations were among the 60 which had contributed to the Just Space Community-led Recovery Plan for London. 

Many of the questions posed by the Committee focussed on participation in the London Plan process.  Responses were clear that active and deep participation requires proactive support and resourcing.  We have a considerable section in our document on participation that sets out some useful ways or mechanisms.  However, not only does the input of communities have to change profoundly but the city itself must be different, prioritising meeting social need, especially of those in greatest need, and tackling the climate and nature emergencies. The current plan is seen as a developers’ charter; ‘recovery’ doesn’t mean getting back to business as usual; the Covid pandemic has shown us that the future really must be different from the past.  

The next review of the London Plan is not scheduled until May 2024 onwards and Just Space said to the committee that we cannot wait.  We should start now to be more open, free-ranging, supportive and innovative in community engagement.  

You can review the whole 3-hour meeting and it may help to have our notes [ download PDF ] beside you which are indexed to the time stamp as the video goes along. A complete official transcript will appear on the Committee’s web site shortly.

All eight of the community speakers spoke with the urgency and authority which came from their experiences of Covid’s awful impacts on top of the cumulative effects of austerity. The existing (old) London Plan, initiated in 2016 and adopted in 2021 was a business-as-usual plan which did nothing to challenge the dominance of real estate profits over identified need. A different kind of plan is needed to give centre stage to meeting the backlog of unmet need, tackling some of the major structural inequalities while taking the climate and nature imperatives seriously.

Florence Nazziwa, a practice nurse from the Equal Care Co-op London stressed the work pressures on carers, mostly women from minoritised communities on insecure contracts. She herself has to do 21 home visits daily: 7 in the morning, 7 at lunch time and 7 in the evening. People in her position have to fit in the care of their own families with that work schedule. Asked what could be done to reduce inequality, she said innovation in care commissioning, valuing community development work .  A person’s wellbeing depends on the quality of their relationship to the people, places and things that make up the community.  She also stressed the need for local care hubs – places that connect care workers to local resources and give them more visible presence in the community – and for neighbourhood mapping which brings communities together.

Asked whether she had ever been involved with the GLA or London planning, Florence said no, but she gave thanks and credit to Just Space for this opportunity to speak and would value more. 

Saif Osmani was a founder of the Bengali East End Heritage Society which was set up in response to the activity of the East End Preservation Society which had been concerned more with the buildings than the people and failed to represent the culture and material life of the strong Bengali community. He spoke of the isolation of this community, especially of the antagonism and lack of interest shown by staff of the councils (Tower Hamlets and Newham) which made Bengali people feel that they were unimportant and their views somehow not valid.  The Save Brick Lane campaign challenges the expansion of the City which would decimate the Bengali culture because the land is seen as worth more than the people. Many of the social and community services round Brick Lane have been closed down in recent years. At Upton Park we have been fighting 20 years in the Friends of Queen’s Market which is our source of cheap food for the large households we typically cook for.  The market was crucial in feeding people during Covid.  Why isn’t this valued?

Asked whether their interaction with the GLA had been any better, Saif said that they had felt listened to by the Assembly and some individual Assembly Members but that did not mean that their needs were any better reflected in policy. The exception had been when Andrew Boff AM had helped draw the Mayor’s attention to a tall block of flats threatening the Queen’s Market at Upton Park and thus got that threat removed –though not out of respect for the market’s crucial role in the food culture of East London and of south Asian communities, but rather on tall buildings policy. 

Saif said that few people would engage with planning authorities on the terms usually offered: digesting and commenting on huge PDFs or going to meetings where the talk was of ‘vibrancy’: who experiences their own community in these words? Newham has started Citizen Assemblies, which are in some ways a credit but they have created a huge area of digital disengagement.

Portia Msimang from Renters Rights London focused on the churn imposed on private renters in London, with the average tenancy lasting only 2 or 3 years, as explaining why private tenants were normally under-represented in planning and housing discussions: few people stay put long enough to identify with a locality. The views and needs of private tenants (now a third of Londoners) are systematically under-represented for this reason. People are also too stressed by time and financial pressures to go to meetings. If you want to meet people go to them, where they are. ‘For example I was able to meet a lot of people very effectively by going to the works canteen and meeting workers during their breaks.’ 

Meeting places in localities can be very important but “most of the community hubs near me have been closed by the councils”. The nearest we have is the office of the housing coop where I live. But most consultation exercises are experienced as tick-box operations and that feeling is reinforced by never getting feedback. Even to be told why your demands are not being met would be better than nothing.  It would be invaluable to get people deciding how funds like section 106 payments would be spent.  Asked about prior contact with the GLA, Portia said that she had experience only of a (failed) bid for money for a CLT. That had taught her how hard it would be to win such a bid without having a housing association as a partner – but that would have contradicted the central point of their organisation’s approach. A fair bidding process would include investment in some consultancy support for applicants – housing coops in that case. 

Natalia Perez, brought a very different perspective from Latin Elephant, an organisation set up to support and help the traders threatened with displacement (and now all displaced) from the Elephant and Castle shopping centre as part of a ‘regeneration’. The majority of these traders are Latin Americans, many Colombian, and the struggle to secure reinstatement elsewhere or get viable accommodation via the developers and Southwark was very frustrating. Half the traders remained unable to trade and faced difficulties in dealing with the authorities because of the technicalities and obscurity of planning language and limited English. But Natalia said that the traders had been perfectly well able to understand when they conducted workshops for them in Spanish.

The Equality Impact Assessment needs to include the people affected within the methodology.  Latin Elephant had made representations on successive London Plans and had done a report to City Hall on the Social Value of the Latin economy.

Yasmin Moalin


Yasmin Moalin youth engagement lead for the Anti-Tribalism Movement  is specially concerned about making things accessible to young people and letting them present their perspectives.  Yasmin spoke powerfully of the pandemic’s impact on young people of Somali origin, with whom she works, badly hit by the difficulties in studying in overcrowded homes when schools and colleges were shut.

While coping with their own problems, so many had to help parents navigate their own situations across language barriers with officialdom. She reported very little trust for authorities among young people, especially boys, so participation in planning or policy was out of reach for most. Their organisation has a housing programme which trains Somali women to help them represent their communities in regeneration areas, on boards and committees and this is valuable.  Yasmin spoke about the need for access and choice, and to educate and train so that young people are supported and prioritised in the planning process.

Christine Goodall, HEAR

Christine Goodall from HEAR, a pan-equality network of London equality and human rights voluntary and community sector organisations, was forthright on many of the topics of the meeting, stressing the intersecting impacts of multiple protected characteristics and how the pandemic had added to the stresses on those who are poor alongside some other characteristics. She identified the closure of community hubs, libraries and other centres as having been very damaging for individuals,  removing digital access and the opportunities for affected groups to meet and self-organise. Putting everything online had caused difficulties to so many people, even though some had gained by remote access.  The high cost of internet access and equipment were major barriers alongside lack of familiarity and fluency with IT. She strongly supported the proposals in the Just Space plan for community hubs and spaces where people can get onto free Wi-Fi.

One planning problem in the pandemic had been the imposition without due consultation of many traffic schemes like floating bus stops and bike lanes which – while beneficial for some and contributing to cleaner air which is good for everyone – can have very adverse effects on some older people, children and those with mobility or sensory problems. The problems of households without access to outdoor space at home were bad enough but they were sometimes amplified by the management of parks who had banned people from sitting on benches and thus in effect banned some people from their parks altogether.

Christine and a number of other speakers, asked whether they would favour a Statement of Community Involvement (SCI) or something similar being developed for the GLA gave a tentative support but all emphasised that statements of intent were a waste of time and would further undermine trust. Rules and procedures to govern community involvement in GLA planning could be useful if there were ways for citizens to invoke and enforce them and if they were available in various languages. Public bodies must go to people where they are. Financial recompense for sharing your expertise can be a valuable help for individuals and small groups. Better feedback too should be automatic.

Pat Turnbull, LTF

Pat Turnbull, regional rep for London Tenants Federation, stressed that London Plans so far had failed to meet the basic needs of the majority of Londoners, failing to halt losses of existing social housing, failing to stop the growing backlog of unmet need for social housing and generating acute problems for family households through enabling too many small flats where larger ones were needed. LTF had used every opportunity to try to influence the London Plan and other plans and policies but were endlessly frustrated by the way that all levels of government now attach higher priority to developer profitability than to meeting social needs.  The first priority for successful public consultation was that the public body must want to know what people think (they often don’t seem to care). People must also believe that what they say can lead to changes of policy and get feedback and that conformity with key policies will be monitored and enforced. It is a scandal that, even in Opportunity Areas, there is no decent data on whether the social-rent targets, so hard won in policy, are carried through into agreements and actually delivered.

Francesca Humi

Francesca Humi, Kanlungan Filipino Consortium (the word means safe haven) spoke of a community multiply affected by deprivations, by Austerity policies and by Hostile Environment policies. Most Philippine people here are women, a high proportion work in the NHS or care sector jobs in low-paid positions or as private carers or domestic servants, sometimes even living in the homes where they work. Even what may appear to be a living wage can become inadequate because people have to pay for visas for themselves and any children, pay charges to use the NHS if they need it, often pay for solicitors to help secure rights and, in many cases have ‘No Recourse to Public Funds’ (NRPF) so are unable to access many public services or social housing. Finally, many are here to send remittances home. This is a very stressed community and their housing costs are a major burden: often they are reduced to sharing beds to live near enough to their work. 

In the pandemic, especially early on, we have been overwhelmed by deaths in our community, because of our jobs, our working conditions, our homes and living conditions. We have supported each other as best we could. Consultation with communities like us should disseminate information widely, often in relevant languages, and a high priority topic within the crucial housing subject would be the need for (London government) to provide emergency accommodation for people in these very very hard conditions. 

So far this has been a summary of evidence given. The longer summary here and the complete transcript include also the questions asked by the Committee.

Clearly the Committee was focused on public consultation, especially in the production of the London Plan, and on some specific issues: the need for an SCI, the scope for activating the ‘socio-economic’ dimension of the Equality Act 2010 to make the London Plan less regressive in impact and other ways in which the London Plan could learn from the Covid experience and respond to its impacts.

Insofar as the community speakers focused on consultation the message was that it would need to be a lot better than it has been to secure the commitment of time and energy of people. It would help if people were paid for their time spent in this socially important work. It would help if planners engaged with people where they were gathered for work or other purposes and because true deliberation isn’t done individually but when people listen to each other in groups. It would help above all if consultations were felt to be genuine: if councils and officers were actually wanting to know what people thought and would act upon the results and report back. This set of conditions is rare at the moment. A Mayoral SCI or a differently named document with similar scope might help provided that it could be invoked and enforced by citizens.

The application of the Equality Act was not much discussed but those who responded to this question were clear that Equality Impact Assessments they had seen so far – including the ones on the London Plan – were seriously deficient.

The strongest link with the London Plan was clear: that the next London Plan would need to produce a very different kind of city — a city which housed and cared for the people who make it work, at costs which are viable in relation to their actual incomes. The majority of these speakers had strong demands to voice but the co-production of a new plan would clarify for them which of the issues count as ‘planning’ issues in today’s London and which fall to other spheres of public policy. Co-production just might be getting under way in sessions like this.

Assembly considers the Recovery plan

The Planning and Regeneration Committee of the London Assembly devoted its entire meeting on 7 September at 2.00pm to presentations and discussion of the future of London Planning, inviting evidence from many of the Just Space contributors to the Community-led Recovery Plan published recently. Here it is:

The following is the Committee’s invitation to Londoners:

Agenda Item 6, Appendix 1

“The Planning and Regeneration Committee is delighted to host a diverse range of London’s voices in the upcoming Committee meeting on Wednesday 7 September 2022 to consider the impact of the pandemic on different London communities, and how approaches to planning can address inequalities and reflect the needs of diverse Londoners.

In preparation for this meeting, members of Just Space1 gave an informal briefing to Planning and Regeneration Committee Members in July 2022, focused on their Community-Led Recovery Plan. The Community-Led Recovery Plan sets out 44 policy proposals for planning in London, which Just Space co-produced through discussions with grassroots groups, with the aim of ensuring that ‘all voices are included in the future planning of London’ as it recovers from the pandemic.2 Subsequently, Just Space has collaborated with the Chair to suggest guests for the meeting, ideas for discussion, and to collaboratively develop the framework for the committee meeting. The full list of attendees has been confirmed and can be found below.

Panel One:

• Florence Nazziwa, Founding Member, Equal Care Co-op;
• Portia Msimang, Project Coordinator, Renters’ Rights London;
• Natalia Perez, Co-Director, Latin Elephant; and
• Saif Osmani, Founding Member, Bengali East End Heritage Society.

Panel Two:

• Francesca Humi, Advocacy and Campaigns Officer, Kanlungan Filipino Consortium;
 • Christine Goodall, Network Coordinator, HEAR Equality and Human Rights Network;
 • Yasmin Moalin, Youth Engagement Lead, Anti-Tribalism Movement; and
• Pat Turnbull, Regional Representative, London Tenants Federation.

For those watching the meeting, the Committee would like to invite you to tune in to the full 3 hours as we are hoping some of the discussions from the first panel will inform the second panel. We hope that the ideas between the two panels can cross-pollinate and synthesise over the meeting, leading us to some constructive follow-ups.

The meeting will begin with two 5-minute presentations: the first on the work of the London Recovery Board by the GLA; and the second by Just Space representative Robin Brown, detailing their Recovery Plan work. The Committee has also invited representatives from the GLA Planning for London programme to observe the meeting in order to capture the ideas and voices in the meeting, and how these could inform a future London Plan.

We look forward to welcoming our guests on 7 September 2022.

1 Just Space describes itself as an informal alliance of around 80 community groups, campaigns and concerned independent organisations which was formed to act as a voice for Londoners at grassroots level during the formulation of London’s major planning strategy, particularly the London Plan.
Just Space, Community-Led Recovery Plan, April 2022

Meeting details and link to webcast at https://www.london.gov.uk/about-us/londonassembly/meetings/ieListDocuments.aspx?CId=441&MId=7224&Ver=4

How to get to the new City Hall: https://www.london.gov.uk/about-us/our-building-and-squares/how-find-city-hall

A recovery plan for London

More than 60 community groups and campaigners contributed to the Just Space Recovery Plan, being published on Monday 4 April 2022. It calls for a radical change of course in London’s planning: less a developers’ city, more a city for its people.

The Just Space network was formed to bring together a diverse range of groups to participate in London planning, which is usually dominated by town planners and developers. During Covid19 the network created its own community-led Recovery Plan, a set of policies that is a call for action for a positively different post-pandemic London: people-centred rather than development-centred. The Plan aims to reverse the inequalities that the pandemic has brutally exposed. 

A Pluriversal Recovery Plan In keeping with Just Space principles of seeking consensus, great care was taken to record diverse and divergent positions through a series of workshop debates. Designed to minimise bias, this innovative approach used an empathic understanding of each other’s different knowledge and lived experiences, which was distilled into a collective vision and coherent set of policies. One workshop participant named the approach ‘pluriversal’.The document ranges from the personal to the collective, from the neighbourhood to the city-wide. The 44 policy positions converge on strong demands for 

●    A Caring City

A focus on the Care economy. London must take care of people and nature, the spaces and places they occupy. Caring for each other resonates with caring for the inherited building stock as opposed to demolition. 

●    Visibility & Influence For All

Coinciding with the rise of the Black Lives Matter movement, the pandemic served to raise consciousness of systemic inequalities and the value of activism, linking with the principle of justice in the planning of the city. Policy proposals aim at resourcing diverse and bottom-up democratic structures to enable community organisations to become active agents of change.

●    A City Of Local Neighbourhoods

The pandemic experiences add meaning and urgency to our calls for a strong ‘Lifetime Neighbourhood’ approach across London so more of our needs can be met without travel, especially without driving. Importantly, many people and communities want to remain in place through all stages of life, not face displacement.

●    Priority For Climate And Nature

The urgency of the environmental crisis—not only climate change but our whole relationship with nature, buildings, food, transport. A crucial issue in transforming the environment is ‘just transition’.

A positive side of the pandemic was that Londoners looked after each other when it mattered, through solidarity, co-operation, mutual aid groups, food banks and local networks. People also discovered the value of green spaces and less pollution from road and air traffic. These strengths should be fostered in a London that cares about people and nature.

The Recovery Plan calls for action by community organisations as well as the Authorities. The way development takes place needs to change radically: planning and building can’t continue as the servant of a small minority of financial interests at the expense of existing communities and the things they value. 

Richard Lee, co-ordinator of Just Space said:
‘It is now more important than ever to ensure all voices are included in the future planning of London. This is a vital part of recovery.’ 

Wendy Davis of Rooms of Our Own said:
‘Under Covid, it has been the low-paid workers, the cleaners, the carers, the delivery drivers who have been absolutely vital to us. A definition of lockdown: the middle classes stay at home and the working classes bring things to them. The Covid lockdown has made us value the care workers, and now is the time to reward them.’

Michael Edwards Honorary Professor, the Bartlett School of Planning, UCL said:
‘What is needed is an emergency programme: something like post-war reconstruction. Special measures are called for and this is recognised by the many who say the future must be different from the past.’ 

DOWNLOAD the recovery plan: JustSpace.org.uk/recovery

Opportunity Areas: a result

In our previous post we explained our strong criticisms of the system called Opportunity Areas, used in London to drive through most of the capital’s major developer projects. We had submitted a lot of evidence about this to the London Assembly’s Planning and Regeneration Committee which met in February, repeating our call for the programme to be halted until there is a proper scrutiny.

Now (mid March 2022) the Committee has written a LETTER picking up on a few of our less contentious points but throwing the demand for a detailed evaluation of the projects back to the Mayor and his planning team. Recommendation 5 says:

The Mayor should explore options for carrying out a full evaluation of Opportunity Areas, which assesses outcomes within Opportunity Areas against original objectives and compared with equivalent sites in London which have not received Opportunity Area designation. This should include exploring the impact on local residents and businesses and the potential for gentrification and regeneration in Opportunity Areas.

Committee letter

We should welcome this as better than nothing. It’s peculiar, though, because the original objectives may often not be the only or best or most compelling yardsticks, because most Opportunity Areas simply don’t have equivalent London areas not designated and because the ‘potential for’ gentrification and regeneration is less important than whether these processes have or have not taken place, and why. We shall expect open consultation on a scoping study so that a more robust terms of reference can be established.

Are Opportunity Areas out of date?

(25 February 2022) A month ago we told the Planning and Regeneration committee of the London Assembly why we, and many community groups in London have always been so critical of Opportunity Areas and wanted the programme halted until there can be a serious review. [ see previous post ] In the last month we have been augmenting our statement by drawing on the experience of many of our member groups and today we submitted this memorandum.

Gathering this material makes us think that Opportunity Areas are doing more harm than good and should perhaps be scrapped completely —not something which had occurred to us before and not an idea we have yet discussed among our groups. But, for sure, a serious scrutiny is long overdue.

Opportunity Areas were introduced 30 years ago, mainly to focus attention and planning resources on large areas of former railway land, former industrial land and remaining areas of dockland, all of which could accommodate a lot of employment and housing growth, often with big transport infrastructure, and do so where there was not much population or activity to disturb. There has never been an adequate and democratic formal system for designating the areas, assigning housing or jobs targets to them, preparing their plans or managing the growth process. These failings matter more and more because the original brownfield lands are running out and the OA approach is being applied in areas like the City Fringe, Vauxhall Nine Elms, the Old Kent Road and even Kingston —areas already fully occupied by communities of residents and networks of functioning private businesses and public services.

The other reason why these failings matter so much more now is that the way London tries to tackle its housing problems doesn’t work. In theory the profits generated by the development of market homes at London’s inflated prices are supposed to enable 35-50% of the homes constructed to be ‘affordable’. In fact the post-2010 definition of ‘affordable’ puts most of this housing out of the reach of those in greatest need, the target percentages are rarely met and much of the profit from development goes to pay for high infrastructure costs of Opportunity Areas and to reward land owners and developers. Housing prices and rents appear to increase even faster in Opportunity Areas than elsewhere so people on low or middling incomes tend to become even worse off, on average, in these areas.

We have always argued for a complete review of the Opportunity Area system and of the individual cases. The Planning and Regeneration committee discussion in January only scratched the surface of the issues we reveal and a serious scrutiny remains to be done. Our memorandum captures some of the evidence. More is to come next month when the Assembly committee considers the Mayoral Development Corporations.

Just Space memorandum on Opportunity Areas 25 February 2022

Appendix material may also be added here.

Opportunity Areas: ?scrutiny

On 8 February the Planning and Regeneration committee of the London Assembly discussed the working of Opportunity Areas – the 30+ areas in London designated for most of the growth in housing and jobs. [ See our previous post ] Many community groups who have struggled with these very undemocratic entities for years watched the webcast and were not impressed. This doesn’t count as scrutiny. Most of the members of the committee are newly elected and have yet to learn the complexities of these Areas. They don’t have substantial staff teams to marshall material for them and the statistics they would need to do their job properly often don’t exist. For example data on numbers  of “affordable” homes completed in each Area are available at the touch of a button from the GLA’s spanking new Planning Data Hub, but the breakdown between the categories of “affordable” housing and thus the all important numbers of council homes is not. ‘We have to phone around for that’ said the officer.

You can watch the meeting here if you missed it.

We had urged them to invite representative community people from some of the Opportunity Areas to speak —as they had done so effectively last autumn on Mayoral decisions on planning applications— but they didn’t do that so were informed only by their background knowledge and a submission from us. This wasn’t enough to enable them to press home their questions to the Officers they had invited whose professional fluency and charm got the better of them.

For some reason the meeting was set up partly to explore the relationship between the Opportunity Areas and Housing Zones which often overlap with them. It turned out, though, that Housing Zones had been a brainchild of a deputy mayor in the Boris Johnson period, were not thought to be useful any more and were about to be abolished.

The democratic deficit in how Opportunity Areas are designated, how their initial plans are made and formalised, how the schemes are managed  and the impacts on citizens and the local economy in and around each Area recorded remain largely unscrutinised. These are the areas where much of the existing employment losses are felt, where many communities are displaced by estate ‘regeneration’, where prices and rents rise faster than elsewhere for firms and households. Increasingly they are also areas where development has shot ahead of social and transport infrastructure, much of which will now not be built. So many of the problems of London need to be understood in a scrutiny of Opportunity Areas. Neither the Mayor’s planning teams nor the Assembly are doing or commissioning the studies that would be needed and we hope that the Committee will return to this issue after the May elections.

A short version of our submission to the committee is in our previous post. Our much longer submission will be posted here later in February after some checking and polishing. [ Here it is now: download PDF ]

In the mean time the Deputy Mayor accepts that better initial studies and consultations are needed for new Opportunity Areas but they can’t afford to do more than one a year. The first one, for the Royal Docks and Beckton, is just getting under way and consultations have begun this week.

Opportunity Areas: Assembly investigates

On Tuesday 8 February 2022 at 10.00 the Planning and Regeneration committee of the London Assembly will consider the 40-odd areas in London where most of the new homes and jobs get provided. They are doing this by questioning the deputy mayor for planning and others from City Hall but, despite our offers to help, have not invited any community participants.

The agenda and papers are here, along with the video link for those who want to listen but can’t or won’t go. IMPORTANT CORRECTION: the meeting is at London Fire Brigade, 169 Union Street, not at the new City Hall as we said yesterday.

It’s normal among community groups in London to consider “opportunity areas” as increasingly opportunities for developers, not citizens or existing businesses. Just Space and many of its member groups have been demanding reforms to the Opportunity Area system since our foundation a decade ago, for example in 2018 here and in our submissions to the public Examination of the new London Plan. We called for a halt to the designation of any more Areas until there was a thorough review of what had happened to date. This week’s Committee discussion does not look like being the systematic review we asked for and which the GLA London Plan team seemed to promise during the inquiry, but we hope it will lead to one.

As well as statistics and maps prepared by the GLA planners, the committee has received the following memorandum from just Space:

Just Space: memorandum on Opportunity Areas for the London Assembly Planning and Regeneration Committee. 26 January 2022

Context: There have been areas designated as Opportunity Areas ever since the first London Plan written soon after 2000 and finally adopted in 2004. They were the areas where most new development activity was expected. New ones have been added in each successive London Plan.  There were originally also “Intensification Areas” which were not planned to be bulldozed, but where a lot of new development was wanted.  These were merged with OAs later and they are all in one big list now.  Just Space includes community groups active in some of the OAs and has made strong representations about both the concept/system and individual cases over many years.

Now the London Assembly Planning and Regeneration Committee has planned to scrutinise the issue and we want to be able to make a submission to inform their meetings. Provisionally, these are the issues on which we want to submit (and suggest groups who can give first-hand evidence):

  1. the process and procedures for designating OAs are unclear and undemocratic. OAs seem to be contrived in discussion between developers/landowners, boroughs and the Mayor, then then assimilated to the London Plan. Citizens  are sidestepped. Only one half day was programmed in the 2019 EiP for discussion of ALL the established OAs and new ones and broad policies. (Kingston, City Fringe have been particularly fraught.)
  2. the targets for housing numbers and job numbers seem to lack systematic justification. These are the main performance indicators used to evaluate their success while social, environmental and regeneration performance are never examined.
  3. there is a variety of guiding/governing documents (OAPFs, SPDs, some of which are subject to EiP examination, others not. All should be. (Old Kent Road has seen many permissions ahead of a properly approved plan.)
  4. The management and implementation of the OAs has no general guiding principles, no democracy of its own ( it depends on whatever democracy is practiced in the host borough(s). (Barking Riverside, Old Oak are among the OAs where this democratic vacuum has been an issue.)
  5. There is no systematic survey/inventory of the existing site of an OA or of the areas around it, so the proposals seem to be based on almost a blank sheet approach instead of the actual mass of uses, users and residents (Peckham Vision has been especially vocal on this, also Old Kent Road, also areas adjoining OldOak). Since many OAs are co-located with ‘Areas for Regeneration’, it is a major failing that they can proceed with so little data and participation from established people and enterprises.
  6. The 2 Mayoral Development Corporations (London (Olympic) Legacy LLDC and Old Oak and Park Royal OPDC) are exceptions in that they each have a special governing institution with some planning powers.  (Carpenters Neighbourhood Forum at LLDC and Grand Union Alliance at OPDC can testify to the strengths and weaknesses of these structures)
  7. The powers of OA agencies like the Development Corporations do not enable them to acquire land cheaply enough to achieve all they are tasked with achieving and this drives densities ever upwards. (Grand Union Alliance can testify on this.)
  8. Research and citizens’ experience points to Opportunity Areas as having negative effects on poorer residents and many pre-existing businesses through rising housing costs and industrial land values, often exacerbated by actual displacement. This is the opposite of ‘regeneration’ and a major failing of the Plan.

Just Space would like to submit a paper on these lines to the committee and cooperate in identifying witnesses.” END. A fuller paper is in draft and will be added in February.

The 2 Development Corporations (for the Olympic Park and surroundings LLDC and for Old oak Park Royal OPDC) will be considered separately by the following meeting of ths Committee on 17 March 2022.
LATER (19 October 2022) This consideration of the two Mayoral development corporations was deferred to a date when both CEOs could conveniently appear, on 23rd November. Just Space submissions on the two Mayoral Development corporations are at JustSpace.org.uk/MDC

GLA seeks inputs to NEXT London Plan

7 January onwards. The GLA planning team emails to say that they are having a consultation on what should go in to the next London Plan. We are shocked to find that the consultation period started in mid-December and has just 3 weeks remaining.

So unless the GLA can be persuaded to offer more time, community groups will need to move very fast indeed to make serious, considered submissions. Are the planners serious?

Looking back through the emails, we find that this was trailed on 14 December, so we should not be so put out by today’s message. Apologies. However there have been holidays in the mean time so the consultation period is very short.

Just Space has been working hard on a Recovery Plan for London but it won’t be ready before the end of February (changed from January). We do urge all member organisations to respond to this GLA invitation as best they can in the time available.

Later (17 January) we have written to the GLA:

We are responding to your email newsletter and web site posting inviting submissions about how the GLA should go about developing the next London Plan.
Just Space will, of course, wish to make submissions and representations about the next London Plan and about the process for preparing it, and to deliberate with its member-groups in the process of doing so.
We were surprised at the timing of this short consultation. There is not much time for us – or other groups – to do what you ask before 31 January and the earlier invitation just before the Christmas/New Year break escaped our notice, as it did for the London Forum and others.
Our members have been, and are, very busy indeed preparing a document provisionally entitled a Recovery Plan for London and this will be a major input from Just Space to the London Plan process. However it will not be finished until some time in February. So we are letting you know that this will reach you after your target date. 
More broadly, we live in hope that the Mayor and your team will adopt a more open and co-production approach to this next London Plan. As part of this we want to be more involved in the scoping and execution of the plan making process. 
We are glad that your December request emphasises equality issues (though with only a request for anecdotes and suggestions on widening your contact networks). We shall be particularly keen to see these crucial issues sorted out, especially given the need to greatly improve the approach to equality in the previous Plan.
Please could we have a virtual meeting with you about all this in February – either on the process/procedures or on substantive issues or both.

More about the GLA work on equality / equity is trickling out.
It seems that GLA (?Environment team) has commissioned Centric Lab to do some work on Environmental Inequity. Their web statement looks quite good and as though community knowledge will be respected on a par with ‘expert’ knowledge. They are starting with work on Hackney, Tower Hamlets, Newham and Waltham Forest. They are holding an online open meeting on Wednesday 19th january 1900h for just one hour. Sign on for details. https://www.thecentriclab.com/news-and-blog-roll/2022/1/14/working-with-the-greater-london-authority-on-inequalities-and-environmental-action-in-london

Caitlin Colquhoun is leading within GLA housing team on the equality review and they are doing a report now on housing and inequality. (Added 17 January)

The GLA Planning request in full is: At this stage, we are calling for evidence that Londoners and other stakeholders think we should consider while developing the programme. This could include:

  • Published reports, research, case studies or other information which might help us understand how London should change or develop in the future
  • Personal accounts of how development, buildings, places, spaces and planning affect different communities, especially impacts that relate to age, disability, sex, race, religion, sexual orientation, gender, marital status or pregnancy and maternity. This may include personal accounts of how people from different groups experience places very differently, and experiences of those who identify with more than one of these characteristics
  • International or national examples of best practice
  • Suggestions for how we can reach a more diverse range of Londoners

Later 10 February 2022. Michael Bach of the London Forum sent a submission to the London Plan team and has circulated this reply:

To answer your question, once the current call for evidence submissions concludes, an initial phase of engagement is envisaged during March 2022, which will seek to capture a wide range of views around broad areas of discussion. Later phases starting over the summer/autumn will enable more detailed discussions on specific issues, including key long-term challenges facing London and the range of options and approaches that could help address them. 

We will provide further details of our plans for engagement as soon as we are able to. The Programme is intended to provide a structure to capture the views of stakeholders and, through this and the gathering of evidence, identify issues and options that a future review of the London Plan (after this Mayoral term) could consider.

I hope this answer is helpful, and if you have any more queries please email the Planning for London Programme inbox. PlanningforLondonProgramme@london.gov.uk

On 13 February the London Forum posted strong criticism of the GLA’s proposed timetable for for doing the next London Plan – basically leaving it until after the next mayoral election in 2024 – and their post has a lot of helpful detail. https://www.londonforum.org.uk/updates.php#6ommnpzf

Assembly probes Mayor’s planning decisions

[Later: Since this post – and partly as a result of this story – Just Space worked with Planning Aid for London in the writing of a guidance document for community groups about the call-in process. [This is now published here ]

Just Space has been having productive exchanges with long standing and newly elected members of the London Assembly since the elections held in May 2021. Partly as a result, the new Planning Committee (now merged with Regeneration) is directing its first scrutiny to a hitherto murky aspect of how the Mayor system works: the handling of planning applications where the Mayor makes the decision instead of the Borough council.

Most of the 9 November meeting was used to hear evidence from Just Space and community groups, most of them linked to Just Space in some way. It was a very important meeting, revealing major failings in transparency, fairness and effectiveness in the system and how it works for Londoners. The transcript is available (marked DRAFT until approved at the January meeting) and is a fascinating and impressive read. At its January 2022 meeting the committee will discuss the issues with Deputy Mayor for Planning Jules Pipe and others and then write a report making recommendations.

[Planning applications are mostly decided by the local London Borough but major ones have to be referred to the Mayor of London who considers whether to get involved. A Stage 1 Report is issued by City Hall which can offer advice or indicate changes which the Mayor of London would seek so that the scheme complies with the LondonPlan. Then when the local authority is ready to make a decision the Mayor of London issues a Stage 2 Report in which (s)he can direct that permission be given, direct that it be refused or ‘call-in’ the application and take over the council’s role as planning authority. For the call-in cases, the Mayor’s City Hall staff work to negotiate with the developer a scheme which they can recommend to the Mayor and then finally prepare a Stage 3 Report to the Mayor. The Mayor then holds a one-day Hearing and makes a decision – which may or may not follow officers’ advice.]

It became clear in the Assembly Planning Committee meeting that there is a lot wrong with the whole process from Londoners’ point of view.

For most of the 20-year life of the GLA call-ins have normally led to the Mayor granting permission if it hasn’t already been directed at Stage 2. So Londoners became cynical about bothering with it. The recent decision of the Mayor to refuse permission at Mortlake Brewery (see previous post) has made many of us take the process more seriously.

Very few people know about this whole process, how it works and how they can effectively submit their views. There is little or no guidance on when and how submissions can be made, how they should differ from submissions made at borough level and how community groups can find the resources needed to make affective submissions.

It is very alarming that the Mayor of London’s staff often have frequent meetings with developers (applicants) but rarely or never with community organisations. In the recent Mortlake case the local groups had to use a Freedom of Information (FOI) request and discovered that there had been 23 such meetings with developers.

This process of negotiation is quite properly intended to produce a ‘better’ scheme, conforming more closely to London Plan policies and priorities. But there is no clear process for repeating the normal public consultations on the revised scheme: the Mayor of London’s consultations are minimal compared with what Boroughs are required to do. And even when a developer submits a radically altered scheme (as happened at Shoreditch Goods Yard) it does not go back to the boroughs but remains with the Mayor to decide.

A headline issue for us was the scope for making the entire process more democratic. Many speakers expressed dismay that the decision was being made in each case just by one individual and Just Space suggested that the Assembly Planning Committee should have a role in this decision making.

[It’s not widely known that the Assembly and its committees are NOT part of the decision-making process of the Mayor of London. They sit alongside the Mayor and the staff teams, and can only scrutinise. They don’t even receive copies of the Mayor’s Stage 1/2/3 reports although individual Assembly Members can and sometimes do lobby the Mayor on individual cases. ]

These notes simply gather some highlights. We do recommend reading the full transcript and groups can always write to the committee with further views before the January meeting. Just Space is also participating at Planning Aid for London in the writing of a guidance document for community groups about the call-in process. [This is now published here ]

Good News

Good news is rare, so Just Space has been happy about two victories over the summer. Seven Sisters Indoor Market (also known as the Latin Village or Pueblito Paisa) at Wards Corner, Seven Sisters, has a breakthrough after one of the longest-running campaigns in the Just Space network. The other, at Mortlake, was a victory at a Mayor of London Hearing at which Just Space was able to lend support to the local community organisations. There is also encouraging news below from engagement with the London Assembly.

This is an update with links, especially for those who missed these news items at the time.

Wards Corner

Wards Corner in South Tottenham has for many years been a trading and community centre for Latin American communities in London, as well as other local migrant communities. Seven Sisters Indoor Market occupies ground floor space in the former Wards department store above Seven Sisters station, a historic building neglected by its owners, Transport for London (TfL), for nearly 50 years. The traders together with local residents, businesses and customers have long campaigned for the Wards building to be repaired, restored and brought back into full use, delivering a new market alongside new low-cost retail, office and community spaces.  But they have been up against a local authority, Haringey, which was actively pro-developers and supported (and gave permission for) a comprehensive demolition and re-build of a much larger site including the Wards building to provide corporate retailing and housing (including NO social or ‘affordable’ homes at all). The developer, Grainger, had been pressed into making provision for the reinstatement of the market in part of the new scheme and for housing the traders across the road during the development. But the traders and wider community organisations remained determined to implement an alternative scheme for their own building and over which they would have control. 

After many years of inquiries, hearings and power shifts within the Haringey Labour Party, this year’s news is that Grainger have pulled out of their scheme. This is the event which has prompted the current jubilation and strenuous moves to constitute a Community Benefit Society to deliver the alternative community scheme. The latest set of Haringey Council leaders are backing the alternative. 

There is far to go, of course, in setting up a community development machinery, securing a long-term lease from TfL and addressing some of the legacies from the Grainger years, including some tensions amongst some traders. But this is good news for a campaign which has been part of Just Space since our foundation 15 years ago.

It’s a project which embodies so much of the spirit of the community-led challenge in London’s development: the pursuit of social and cultural values, not just financial value; support for the hidden but real economy where people meet each other’s needs, not just business greed, and where community itself becomes an agent for change. In the world of Covid-19 all this becomes even more important. Congratulations to Haringey for supporting it.

Mortlake Brewery

The disused Stag Brewery site was the subject of a major housing and mixed use redevelopment proposal on the bank of the Thames in the Borough of Richmond with a school adjoining it. There was a long history of the Council preparing a brief for the site and numerous local community groups making submissions on a very wide range of issues. In the end Richmond Council gave permission for a scheme which the local groups regarded as far too dense for various reasons —amenity, effects on the ‘sylvan’ riverside, traffic generation in an area of very poor accessibility, overloading of social infrastructure (with a 90% increase in neighbourhood population)— and flood risks. The primary school which residents and the Council had wanted was replaced in the plan by a proposed secondary Academy, forced on the council by the DfE against all evidence of need.

The scheme as approved by the Council in 2019 had offered 17% of ‘affordable’ housing out of 813 homes and it was called in for the Mayor’s decision by the Deputy Mayor Jules Pipe on the grounds that this proportion was inadequate. The exact grounds were “…including the delivery of housing and affordable housing as well as highways impacts and potential mitigation.”

In negotiations at City Hall the scheme was modified in July 2020 and again in September to offer 30% affordable housing (by habitable rooms), split 41% London Affordable Rent (LAR), 59% intermediate (Shared Ownership and London Living Rent). No social rent homes were proposed. To achieve even this level of ‘affordable’ housing the density of the development had been increased to 1250 homes and we understand that the GLA officers involved had been content with that. The report prepared by the GLA officer (Case Officer Ashley Russell) before the hearing recommended acceptance.

In the event, after hearing community objections (including support from Just Space on the grounds that the credibility of London Plan policies on affordability, density and building height would be threatened by a consent) the Mayor reflected and then said that he was refusing the scheme. This was a great victory. 

There are, however, two puzzling features of this case.

The Mayor’s oral decision emphasised the affordability of housing in the scheme, stressing that 30% fell short of his expectations and the requirements of the London Plan. He went on to say that the damage to the amenity caused by the additional building heights was not justified by the gain in affordable housing. However his written statement of refusal, issued a week or so after the hearing, does not discuss the affordability issues at all, focusing entirely on the bulk, massing and heritage impacts as grounds for refusal. This seems curious.

A second puzzle is how the Mayor’s viability experts came to agree to use a much higher ‘Baseline Land Value’ (BLV) for this ex-industrial site than they would have used if they were valuing it as industrial land. This higher value will have reduced the amount of ‘affordable’ housing that could ‘viably’ have been secured. But the whole point of the London Plan requirement that 50% of housing on ex-industrial land must be ‘affordable’ is that industrial land is much cheaper than residential land so developers can afford more. In their report the GLA valuers say §7.2 “Assessment of BLV … should normally be based on an assessment of the existing use value. However, given the limited demand for a brewery operation on this site, any value assessed on this basis would be negligible, and a landowner would be unlikely to dispose of the site on this basis. It is therefore appropriate to consider alternative approaches to assessing a minimum return at which a reasonable landowner would release the site.” Isn’t this giving away precisely the advantage which the former industrial use should have offered?  

Perhaps if, and when, a new scheme is developed for this very fine site, the GLA will take an even tougher line on affordability. But for the moment it is a good sign that the Mayor is prepared to stand up for affordable housing to this degree.

The future of Mayoral call-ins

The Planning and Regeneration committee of the London Assembly held an entire meeting on 9 November 2021 about citizen participation in these called-in cases. Just Space had taken an active part in the formulation of the meeting and recommended the format where multiple voices would express grassroots and other community views. Just Space and many of its member groups were present and able to contribute a strong community perspective to an excellent event. It is available to watch on YouTube (though not at the normal location on the GLA web site because of some technical breakdown). You need to scroll along to about 10 minutes to catch the start.  

More news to follow about this (next post) and future work with the Assembly on Opportunity Areas.

Participants on 9 November were
Hiba Ahmad, Save Nour, Brixton
Michael Bach, London Forum of Amenity and Civic Societies.
Mark Brearley, Vital OKR, Old Kent Road, Southwark
Tim Catchpole, Mortlake Brewery Community Group;
Clare Delmar, Listen to Locals;
Jerry Flynn, 35% Campaign, Elephant Amenity Network;
Yacob Ghebrekristos, Estate Watch
Richard Lee, Just Space;
Jonathan Moberly, East End Preservation Society;
Connor McNeil, Victorian Society;
Heloise Palin, Administrator, Spitalfields Trust;
Saif Osmani, Truman Brewery Campaigner;
Angus Robertson, Alton Action, Roehampton; 
Natalia Perez, Programme Co-Director, Latin Elephant;
Patria Roman-Velazquez, Chair of Trustees, Latin Elephant