London Plan (Towards…)

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.

Disciplines and comparative work

This blog post started as an abstract, put together in response to a plan by colleagues Susan Moore and Michael Short at the Bartlett in 2025 for a round table meeting on Critical Dialogues in Comparative Urbanism. The abstract was:

My enthusiasm for the project of dissolving disciplinary/professional boundaries in the Bartlett in the 1970s. Building student experiences to replace architecture, building and planning and knit a lot of ’science’ in the mix.

The highlights in my experience, notably the work of some individual students and the survival until [date] of the first year undergraduate module in which students studied the gestation of one London building and then took their methods on an overseas field trip

A research outcome in the Bartlett International Summer School on the Production of the built environment (BISS) which ran from 1979 to 1996, annual colloquium of scholars, trade unionists and a few activists built round an explicitly Marxist programme, leading to the International Network for Urban Research and Action INURA, founded in 1991 and still going strong as a network and annual meeting but never quite consummating its theoretical texts under the banner of The New Metropolitan Mainstream – though some of it appears in the work curated by Christian Schmid and Neil Brenner on Planetary Urbanism.

My personal effort from about 1990 to build BSP’s first new Masters programme European Property Development and Planning, initially parallelled by initiatives in Newcastle (Patsy Healey), Turin (Mazza, Ave), Venice (Folin) and … It struggled to become quorate for want of students with critical appetite but became a massive ’success’ as it later filled up with more business-oriented students from global elites and the newly capitalist countries. The international university partners faded away. UCL, BSP and many of the students got rich on the basis of what became IREP. A waste of 20 years, I think from my point of view.

The UCL School of Environmental Studies

When I joined UCL as a lecturer in 1969 Richard Llewelyn-Davies was in the process of forming a new department with this title by merging the Bartlett School of Architecture, the Department of Town Planning and various research units. Part of the project was to break out of the blinkered framework of professions, enabling teaching and research to draw on urban history, engineering (his original discipline) and other social and physical sciences. There was no particular orientation to international comparative study in this programme but the staff body included eminent people from European traditions of the Architect-Engineer: Bruno Schlaffenburg, planning officer of the new borough of Camden, Walter Bor who had been planning officer of Liverpool together with Ruth Glass, sociologist from Berlin and Duccio Turin. I was an enthusiast for all this, having just spent some years in my first job in the master planning team for Milton Keynes which was great mix of ‘disciplines’ and boundary-crossing. I wrote about the stirring atmosphere of the 1970s (and its defeat by resurgent professions) in the festschrift for historian Adrian Forty: Yes, and we have no dentists (2014).

The 1970s did not, for me, generate ideas about critical comparative study but we already did international field trips – always to Bologna – so a lot of comparative work went on, albeit without much explicit analysis.

Research: BISS

Through the 1980s, as neo-liberalism was extending its reach and penetration everywhere, some of us were developing critiques in the Bartlett International Summer Schools on the Production of the Built Environment BISS. This was an annual gathering of more-or-less Marxist and radical researchers, trade unionists and professionals in which class relations in the production process were centre-stage. Much of the work was international-comparative in scope developing explicit Marxist framings for this. It was captured in a 1985 book edited by Michael Ball, myself and others and recently reprinted. For just one or two memorable years we ran a Bartlett MSc on Production of the Built Environment, using this material. [The annual proceedings of Biss have been scanned by Jake Arnfeld and are now online at https://drive.google.com/drive/folders/1QwqDhyeiothvxt_Z5GVDiWjNhBSy2vVV]

Some of these ideas were revisited in a teach-out on Rent in 2019 and a reading group in 2021. The production-focused research continued in the work at the University of Westminster where Dr Linda Clarke moved from the Bartlett.

1990s: Roles and Relationships in the production of the built environment

The potentialities of international comparative study for teaching were most explicitly developed in a module which we ran through the 1990s, compulsory for all students in the Bartlett (now a faculty comprising departments with names like architecture, planning, construction). Fortunately it is well written up and preserved online though the journal in which it appeared is dead.

Research: INURA

As the BISS was wilting in the 1990s ascendancy of neo-liberalism, we launched a new network in which activism was meant to be as important as research: The International Network of Urban Research and Action INURA. Like the BISS it was headquartered in Switzerland and has annual meetings, though without its own scholarly publication. Its ‘method’ consists of a few days of listening and exploring in a host city with local activists, interspersed and followed with informal workshops which engage with the research and theoretical interests of participants. An attempt at publication of a systematic study of multiple cities has foundered as the unruly crowd of contributors failed to meet the high ambitions of the main leaders, notably Christian Schmid. Under the banner of The New Metropolitan Mainstream, some of it appears in the work curated by Christian Schmid and Neil Brenner on Planetary Urbanism. Most of the work sits like an iceberg on hard drives around the world. It contains valuable attempts to define variables and episodes common to multiple cities and thus generate principles for critical comparative study.

EPDP

My personal effort from about 1990 to build BSP’s first new Masters programme European Property Development and Planning, was initially paralleled by initiatives in Newcastle (Patsy Healey), Turin (Mazza, Ave), Venice (Folin) and ?? It struggled to become quorate for want of students with critical appetite but became a massive ’success’ as it later filled up with more business-oriented students from global elites and the newly capitalist countries. The international university partners faded away. UCL, BSP and many of the students got rich on the basis of what became IREP. A waste of 20 years, I think from the point of view of developing critical comparative analysis.

I thought of adding instances of students, and student dissertations, which have represented the achievement of these aspirations over the years. F

Adesope, G. (1993) Public-private relations in two major station redevelopments MPhil, London UCL compared the King’s Cross railway lands with Paris Rive Gauche, both ‘regeneration’ schemes above and around major stations and both hit by the same crash of the speculative office markets. The thesis examined how the London project evaporated while in Paris the municipality just kept on building decking, running up mounting public debt but harnessed the new Biblioteque Nationale to occupy some of the space.

Reference list

Edwards, M, Campkin, B and Arbaci, S (2009) Exploring roles and relationships in the production of the built environment Centre for Education in the Built Environment (CEBE) Transactions 6, 1, 10.11120/tran.2009.06010038 http://discovery.ucl.ac.uk/15579

Edwards, Michael (2014) “Yes, and We Have No Dentists.” In Forty Ways to Think About Architecture: architectural history and theory today, edited by Iain Borden, Murray Fraser and Barbara Penner, 280 pages. London: Wiley, ch 28, 2014. http://eu.wiley.com/WileyCDA/WileyTitle/productCd-1118822617.html
[
 e-print Edwards for Forty ]

Ball M J, Bentivegna, V, Edwards, M, and Folin, M, Eds (2018) Land Rent, Housing and Urban Planning: a European Perspective Reprint of 1985 book in Routledge Revivals series. https://www.routledge.com/Land-Rent-Housing-and-Urban-Planning-A-European-Perspective/Ball-Edwards-Bentivegna-Folin/p/book/9781138494435

2022, Michael Edwards, Harvey’s Urbanization of Capital: why it helped me so much, in Camilla Perrone (ed) Critical Planning & Design: Roots, pathways, and frames, pre-print as accepted: edwards-on-harvey-v1   Book now published. Details and ordering at http://link.springer.com/book/10.1007/978-3-030-93107-0…

BISS. https://drive.google.com/drive/folders/1QwqDhyeiothvxt_Z5GVDiWjNhBSy2vVV