16 September 2025 Ian Gordon has published a blog post about all this, reviewing 6 submissions. A good read. https://blogs.lse.ac.uk/lselondon/towards-an-effective-london-plan/
22 June (closing day for responses to the GLA document Towards a New London Plan). This is my personal submission. Ill health has greatly reduced my capacity and all I have been able to manage is a response to part 1 of the survey. I tried to pack in all my main concerns. (Much has also fed in to the Just Space submission which Michael Ball is finalising right now.)
It is still not too late for anyone to make their own submission – to all or part of the Towards… document. All the links you need to read it and reply are at JustSpace.org.uk/towards
1. Paragraph 1.1: What is the London Plan?
GLA often argues that LP can only deal with town and country planning matters. That’s arguable. But this Towards… document is not constrained in this way and should have ranged across all the linked proceses: economy, housing, environment and so on.
Its scope is utterly unfit for the multiple crises we confront.
3. Paragraph 1.3: How many homes will it plan for?
Towards… is based on the same completely mistaken interpretation of the crises which we all agree the city confronts; the belief that the affordability problems would be solved by dramatic increases in supply. This myth has been roundly debunked as a national strategy and, for London, successive London Plans have attempted to apply the remedy of maximising total output. Not only has this failed to slow the growth of rents or prices but it has led to a growing unmet backlog of need for low-rent council homes and caused great damage to other aspects of the city: diverting employment land, eroding greenspace, overloading social infrastructure and – now – threatening green belt as well. It has also eroded the stock of council homes through the estate regeneration process and permitted other disposals. Not only does Towards… fail to recognise this massive failure, but it proposes to make matters worse by chasing the impossible output target set by an equally misguided national government.
4. Paragraph 1.4: Viability and delivery
The coalition government’s decision to make ‘viability’ the make-or-break criterion for development decisions has been a disaster. While outside the GLA’s control, much more could have been done to minimise its impact, especially its impact on land values and on S106 negotiations.
New approaches are now essential: to lobby government more effectively on Right to Buy, on rent controls, on AHP budgets; to adopt policies aimed at moderating land price growth and to force land prices down to the levels at which council-level rental housing proportions can be accommodated.
5. Paragraph 1.5: What is this document about?
The Towards… document is profoundly inadequate. Ill health is preventing me from responding to later sections of this survey which I would normally want to do.
6.Paragraph 1.6: Legal and procedural requirements
I am profoundly dissatisfied with the conduct of the London Plan team since work ended on the 2021 Plan.
You should have analysed the effects of the radical policy changes embodied in the 2021 Plan. The density matrix was criticised for not being enforced. Instead of enforcing it, and thus probably damped land values, the GLA insisted on scrapping it, relying instead on boroughs to use ‘design considerations’ to develop density policies and (related) tall buildings policies. What effect has this had on densities and land prices? Other novel policies in the 2021 plan should also have been evaluated. No such analyses are visible.
A second key activity for the LP team should have been to evaluate the possible futures for London opened up by climate change and by the mounting inequalities of income and wealth generated by the London economy and housing system. The pandemic made some of these processes very visible and dramatised the inequalities experienced by Londoners, especially those in low paid and insecure jobs, in transport, retailing and distribution and those from certain ethnic groups.
A further set of futures needing exploration are the consequences flowing from Brexit.
Instead of informing London through this kind of research and fostering a better-informed and engaged population, the LP team seems to have been keeping us at arm’s length while they have conducted a one-way harvesting of opinions and experiences through the Planning for London programme. They are behaving like control freaks.
7. Paragraph 1.7: Integrated Impact Assessment (IIA)
I and Just Space and others were very critical of the GLA last time around for the many inadequacies of the Equalities Impact assessment. The Panel of Inspectors in 2019 insisted repeatedly on the GLA doing more work on this topic – which revealed in the end how regressive were many or most of the Plan’s policies. We had argued that the London Plans were dominated by property and investor interests and this tardy and reluctant analysis proved us substantially right. But nothing could be done then to deal with the criticism that the equality studies should have started at the beginning of the planning process and it bodes very badly for this new plan that the long-promised consultation on the draft IIA scoping report will begin ‘later in the year’.
The same issue arises with the SEA which should already be evaluating alternative strategies for London.
10. Paragraph 1.10: Good growth objectives
The mayor clearly feels the need to trumpet growth out of respect for the new national government leadership, and perhaps as a means of levering funds to support the ‘engine of the nation’. But his London Growth Plan is just a marketing document which appears to be written by estate agents and contains no serious analysis.
Seriously, though:
Towards… does not confront the fact that London’s economy is a machine which sucks in investment in transport and other infrastructure, pumping up central area commercial property values and city-wide house prices and rents. Thus landlords, owner-occupiers and property interests benefit from massive asset value growth while renters have seen their real incomes (after meeting housing costs) static or shrinking. This is not an economy to be proud of and it is hard to sustain in the light of the regional disparities to which it contributes.
While it is welcome that the term “good growth” still survives, this treatment of growth remains very weak indeed.
michael edwards 