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London - Planning for a Just City?

Author: Town and Country Planning Association

Town and Country Planning Association, supported by Trust for London, has created a detailed evidence base on how the planning system in the capital is facing up to the challenge of promoting equality. This report has looked in detail at all of the London Boroughs’ Local Plan policies and analysed how they are addressing the equalities agenda.

It has examined the varying application of the Equality Act and of the role of Equality Impact Assessments in developing plans. It has also produced case studies of good and not-so-good practice, highlighting the challenges faced by comm unities trying to participate in planning decisions.

This report makes clear that there is a major gap between the potential of the system to deliver participative and inclusive decisions and implementation on the ground. While there are examples of good practice, much more could be achieved. The 20 recommendations it sets out provide a framework for improving practice, and also make the case for a fundamental shift in the purpose of London’s planning system, to focus on the health and wellbeing of all sections of the community.

Theme 1: The aims and ambitions of planning

  1. Local planning authorities must ensure that Local Plans are ambitious and aspirational in promoting equality and reducing socio-economic exclusion. Local planning authorities must also ensure that corporate strategies and other strategies that relate to inclusion and equality fully recognise the key role that planning plays in achieving these ambitions.
  2. Built environment institutions should urgently consider introducing a ‘Do no harm’ obligation in built environment professional codes
    of conduct and should strengthen their ambition to actively challenge patterns of inequality and exclusion.
  3. Built environment institutions (and/or other relevant organisations) should introduce into existing award programmes new categories that recognise excellence in planning for equality and inclusion.

    Theme 2: Meaningful public participation in planning process
  4. Local planning authorities should strengthen their Statements of Community Involvement by including targeted methods to include under-represented groups, improve the inclusivity of public participation processes, ensure that wider public engagement directly feeds into Local Plan development, and ensure that proactive engagement takes place at all stages of the planning system.
  5. Local planning authorities should improve the usability and transparency of their websites and planning portals and the accessibility and readability of planning documents, in particular the Local Plan, and they should ensure that hard copies of planning documents are made available to all.
  6. The Greater London Authority and local planning authorities should create new mechanisms to make funding available for community- level planning initiatives, professional and mutual/ reciprocal support, and advice services for local people, and they should enable community groups to have access to planning officer support at a pre- application stage.
  7. Local planning authorities should ensure that their Statements of Community Involvement and Local Plans fully recognise and support neighbourhood planning.

    Theme 3: Meaningful consideration of how planning policies impact different groups of people differently
  8. Local planning authorities should ensure that Equality Impact Assessments conducted in developing a Local Plan are not merely tick-box exercises, and that the Equality Impact Assessment process starts early and is embedded within the iterative process of policy development and implementation.
  9. Local planning authorities should ensure that Equality Impact Assessments evaluate the impact of policies on socio-economic status in addition to the protected characteristics outlined in the Equality Act.
  10. Government should publish Planning Practice Guidance on Equality Impact Assessments in relation to Local Plan development.
  11. Local planning authorities should ensure that there is adequate monitoring and evaluation of the impacts of planning policies – and that this information is publicly available. They should also proactively learn from cases where an absence of a strong or specific policy may have contributed to negative outcomes for people.

    Theme 4: Embedding inclusion and equality within thematic policy areas
  12. Local planning authorities should develop ambitious, positive, precise and clearly worded policies which specify detail on reducing inequalities and exclusion and which express the needs and aspirations of local communities. Assessment of the effectiveness of such policy should be a key aspect of local planning authorities’ annual monitoring reports.
  13. Local planning authorities should build into Local Plan policy opportunities for communities to define the social value of spaces and buildings.
  14. Local planning authorities should develop Local Plan policy that supports community-led initiatives – for example through policies to support community housing and community stewardship, management and ownership of assets.

    Theme 5: Local authority resources, skills and diversity
  15. The local planning service must be adequately funded to provide an effective system that can shape outcomes in the public interest and meet the aspirations of local communities.
  16. Local planning authorities should upskill planning officers to ensure that they have the skills, knowledge and confidence to undertake Equality Impact Assessments and to engage in community engagement processes effectively. These skills must also be a mandatory part of the professional qualification of planners and other built environment professionals.
  17. Local planning authorities should take action to proactively support greater diversity of staff within planning teams and related sectors.

    Theme 6: Addressing the undermining of Local Plan policy
  18. Government should remove centrally imposed barriers to Local Plan policy goals being achieved by further reforming the viability process and by rescinding the central imposition of permitted development rights.
  19. Government should reinforce the legal status of the Local Plan to support a genuinely plan-led system, providing certainty for local communities and the development sector on how and when development will take place. Policy in Local Plans should be expressed accessibly and precisely, in language that communicates the key outcomes for communities.
  20. Government should institute a limited community right of appeal.
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13 November 2019

London - Planning for a Just City?