03 Public Participation—the Struggle to Have a Say
Chapter 3

Chapter 3 addresses the public of public participation, the main democratic instrument with which planning in London, and the planning of London, involves Londoners. Because the plan is the product of a complicated planning and governance system, as discussed in Chapter 1, shaped by a narrow concept of the public sphere, as discussed in Chapter 2, this chapter posits there will always be, in planners’ term, a “never-ending struggle” for public involvement in the London Plan.

‘Public participation’ was introduced in UK planning legislation in the 1947 Planning Act, and then expanded upon in the Skeffington Report (1969), a government study examining the relationship between people and planning. These key moments marked a change in the wider public’s involvement in planning decisions and the production of plans. In policy rhetoric, those who previously had no or little role were empowered to ‘have a say.’ Since then, the concept of public participation has been largely accepted as necessary to the planning process but deemed inadequate or inconsistent in practice. Engaging people in planning has been described by today’s planners as a “never-ending struggle.” This chapter discusses the complexity of getting involved in planning London’s urban change, reflecting on the evolution of what ‘public’ in ‘public participation’ means in the English planning system since the 1960s. To provide the historical and political contexts behind the prompt to ‘have your say’ in the London Plan, it traces through four stages: public participation and popular planning (1960-1990s), public consultation and consensus (2000s), open planning, localism and the neighbourhood (2010s), and public planning, law and the right to plan (today). This history is followed by a discussion about the influence the Habermasian public sphere and the neoliberal idea of competition and free market have had on the development of a communicative, deliberative model of plan-making threading the above calls to have a say, what urban theorist Patsy Healey deems “planning through debate.” It highlights issues about power and democracy raised by critics of communicative planning and argues that the urban imaginary of ‘the public’ as a universal ‘all’ able to freely participate, discussed in the last chapter, is part of the problem and the struggle to have a say, resulting in only “some small gains in wording.”

Keywords: policy planning participating

Public Invitation: Have Your Say

Jules Pipe, deputy mayor of planning and one of the London Plan 2021’s leading stewards, said that the good growth of London, through the development of the London Plan, “most importantly means ensuring people have more of a say in the development of their city.” Remarks made by Jules Pipe in his address to a 1,000-plus crowd of built environment professionals during the New London Architecture’s 2018 Big Debate, as well similarly made as part of the GLA presentation on the draft London Plan at various consultation events. According to the london.gov.uk website at the time of the draft’s publication, as the new London Plan is developed there would be opportunities for the public to engage and help shape its development. The fourth opening page of the draft reads, “[t]his new draft London Plan (the Spatial Development Strategy for Greater London) is published for consultation and your comments are invited,” making clear the primary purpose and prompt of the draft document. The draft plan therefore is not only a policy framework for the future spatial development of London, but it is also an invitation for public participation in shaping it.

With every iteration and alteration of the London Plan, Londoners are invited by the Mayor and the GLA to have your say about the city’s proposed transformation and share their views via a public process that involves a written consultation and an oral examination in public. For the latest edition, Mayor Khan published his draft London Plan on 29 November 2017 and made it publicly available (in print and online) for a period of twelve weeks for review and comment, inviting formal responses by email, post or through a digital form on the GLA’s website, until the end of the consultation on 2 March 2018. The GLA received responses from: authorities outside London, business, campaign groups, community groups, government and agencies, individuals, London Boroughs, and professional bodies. As categorised under such groupings by the GLA, these comments were also made available on the website in downloadable PDF format.

After consultation on the draft ended, a select number of respondents were further invited to participate in a public examination of the proposed policies and provide additional written statements, a formal review process which occurred over three months. The Examination in Public (EIP), led by a panel of planning inspectors appointed by the Secretary of State, scrutinised the plan for ‘soundness’ and alignment with the National Planning Policy Framework. The Secretary then signs-off on the Mayor’s Intend to Publish version of the plan that reflected the necessary revisions following consultation and examination.

From start to finish, the whole undertaking spanned years and involved contributions from hundreds of participants and the review of thousands of documents. Over 20,000 representations to the draft plan were received from around 4,000 individuals and organisations (“representors”). 1 The final version, the London Plan 2021, was formally published by the Mayor on 2 March 2021, exactly three years since the end of draft consultation and nearly five years since the publication of the Mayor’s A City for All (2016) upon which the draft was originally based.

Public Opinion: More or Less Say

“Some small gains in wording,” is how Just Space had described the outcome of their participation representing grassroots organisations in responding to the draft London Plan 2017. After enduring the difficulties of going through all the motions to have their say, they concluded that the 2021 London Plan “was a developer’s dream from the outset … The plan we are now faced with is even worse [than] the bad one for the London of 2016 when it was being written.” 2 Just Space (@justspace7). 19 Sept 2019. Tweet. Captures the frustration community groups have with the public processes to get involve in London planning. This criticism was followed up with a letter sent to Jules Pipe, Deputy Mayor of Planning, calling to limit the damages they perceived in the plan’s final printed form. In it, Just Space voiced “tremendous disappointment” in the process and outcome, a blunt contrast to how Pipe had introduced the plan at a developer forum, praising its collaboration.

Many community and grassroots organisations, and others, struggled long and hard through the last five years of consultation & planning to make the London Plan a more equitable and powerful instrument to achieve the inspiring egalitarian ambitions held by the Mayor and captured in his City for All Londoners, in his preface to the London Plan and in the Good Growth Policies. Both the process and the outcome have been a tremendous disappointment at successive stages.
Just Space, ‘Just Space Letter to Jules Pipe, Deputy Mayor (Planning).’
The new London Plan has been shaped extensively by Londoners and many stakeholders […] The plan has been formed and influenced and ultimately improved by a generous and very thorough engagement of everybody involved.
Jules Pipe, ‘Keynote Speech, Movers & Shakers Developer Forum Breakfast.’

The above quotes capture two disparate views on the public consultation: one speaks of generosity, influence and improvement, and the other, of relative struggle and disappointment. 3 4 The language used casts the process in contradictory positive and negative light that calls into question how to measure impact. According to the deputy mayor, a remarkable 1.4 million words were written in response to the consultation and examination processes, and in quantitative terms of engagement numbers according to GLA statistics, over 20,000 representations to the draft were received from around 7,400 individuals and organisations, including 4,000 written submissions. In contrast to the first London Plan (2004), in which a comparatively much smaller number of 650 responses were received, comprising 12,000 specific comments, this thirty-fold increase objectively signifies greater participation and extensive public involvement. 5 For Mayor Johnson’s Draft Replacement Plan 2010, comments from 150 organisations and individuals were received, including over 200 responses, to the initial proposals for his new Plan (“Planning for a Better London”), and nearly a thousand to the draft Plan itself.

Yet, despite the high volume of responses and the purported generosity of consultation, there are conflicting accounts as to whether public participation has been adequate or effective, pointing to the stark variances in satisfaction with consultation between organisers and participants. In one view, from the Mayor and the GLA’s perspective, through different modes of communication and various participatory mechanisms including meetings, presentations, charettes, workshops, and forums, their engagement has been ongoing, active, extensive, constructive and meaningful. However, in another view, for a number of respondents, the Home Builders Federation (HBF) for instance, “engagement has been active and on-going, but it has never been meaningful and constructive.” 6

According to Just Space, one of the most vocal respondents, “the Mayor and GLA do not have a deliberate, concerted and proactive programme of consultation for the draft plan that would reach specific groups, diverse communities of geography and of interest with their different backgrounds, needs, values and aspirations.” 7 They criticise the ‘democratic deficit within Mayoral plan-making and decision making’ and the lack of diversity and specificity “to tailor engagement processes and activities to enable some communities or individuals to fully participate on an equal basis with others.” For them, “the gap between policy and practice is immense where democratic engagement is concerned,” critical of the lip service the planning system generally pays to community participation. 8 Included in their comments on the draft is a paper that identifies the gaps in community participation in all forms of regeneration outlined in the plan. 9 It claims that the Mayor’s intentions to “work closely with communities to bring about the right sort of change [to benefit Londoners equally] is not backed up by the policies in the plan.” 10 Per Just Space, there isn’t sufficient spelling out of ‘consistent’ and ‘meaningful’ community involvement.

The difference in views on the London Plan consultation process characterises the contested nature of participating in London planning today. It is rooted in a long history of innumerable but fraught attempts at giving people a say in how their neighbourhood and their vision for the wider city takes shape. According to Tony Travers, speaking to a crowd of built environment professionals at a New London Architecture event in November 2017 on the day that Mayor Khan revealed his draft London Plan, in comparing the time period between Patrick Abercrombie’s County of London Plan to Khan’s version, “life was easier for planners in 1944,” seen as the golden era of planning. Press conference for the County of London Plan during the exhibition at County Hall (1943) Source: Amati and Freestone (2016), ‘All of London’s a Stage’. The County of London Plan (1943) enjoyed wide circulation through multiple modes of dissemination aimed at the farthest reach. Its extensively shared, seductive ‘eggs in a basket’ imagery is looked upon by members of the GLA London Plan team with nostalgia, seen as the heyday of public engagement in planning. 11

Coming from a very different world, Travers said, the Abercrombie plan was a “top-down,” “elite” and individual-driven vision “from a powerful individual with a desire to deliver change.” 12 While there was public spirit for post-war reconstruction efforts and wider public awareness of the plan’s existence, little attention was paid to public opinion. 75 years ago, the public had much less say about the version of London to come. “It was good for people, by people who knew what would be good for people,” Travers remarked. The draft plan 2017, by contrast, “was produced by a large team with an enormous amount of consultation”; is democratic and broad and “has to do with the consent of millions of people and a vast civil society, of which will have to express its own opinions.” 13

On the one hand, Travers’ description signals an understanding of democracy as coterminous with consultation and consent, and the expression of opinions. Coupled with Pipe’s remarks, the enormity of consultation is seen as a positive. More people were involved in the 2021 plan than were in the 2004 plan, which in quantitative terms is arguably a good thing. Both Pipe and Travers use the word ‘millions’—millions of people and millions of words—suggesting a mass quantity, high numbers of participant involvement and textual production. By quoting the sheer volume, they give an impression of deep participation which equates the quality of engagement to the scale of it. Reception of Abercrombie’s plan may have set the benchmark of public engagement in terms of visibility and attendance count, viewed favourably as an example for today by Chris Paddock, director of the development consultancy PRD. Citing distribution of the thousands of copies of the document, he seems to suggest that the more people and the more eyes on the plan, the better, leading him to propose, “the active engagement with Abercrombie’s work that was encouraged in its time is something that should be replicated with the new London Plan.” 14

On the other hand, HBF’s note of a lack of meaningful and constructive engagement and Just Space’s decry of insufficient consultation with diverse communities speak to the hardship of participating democratically, despite the generous opportunities of engagement seemingly offered by the Mayor and the GLA. The practical experience of getting involved in planning, is complicated. Of the opportunities forthe public to have a say, the question is, which public? Opportunity specifically for whom? The answer to this has evolved over decades. The following sections lay the groundwork for understanding the context of public participation in the London Plan, where there is arguably less public awareness of the plan’s existence yet more concentrated public opinion today than three quarters of a century ago.

Public Participation and Popular Planning: Having Some Say (1960-1990s)

2019 marked the 50th anniversary of the Skeffington Report People and Planning when public participation in planning first came under intense scrutiny. MHLG (1969) Skeffington Report: People and Planning. Image credit: Ben Rogers, Centre for London. Authored by Arthur Skeffington MP and the Committee on Public Participation in Planning, the report was a sweeping indictment of the UK planning system and set out principles for how to better involve members of the public in the creation of local development plans beyond the tokenism and the gestural for which public involvement prior to this the report had criticised. It defined public participation as adequate when ‘the public’ shares in the act of the formulation of policies and proposals. 15 The report focuses on two groups: “first, the active minority who take part in influencing community affairs, and second, the passive, who although deeply affected by decisions, do not make their voices heard because of diffidence, apathy or ignorance of what is going on.” (p13)

Clearly, the giving of information by the Local Planning Authority (‘LPA’) and of an opportunity to comment on that information is a major part in the process of participation, but it is not the whole story. Participation involves doing as well as talking and there will be full participation only where the public are able to take an active part throughout the plan-making process. […] There is a growing demand by many groups for more opportunity to contribute and for more say in the working out of policies which affect people not merely at election time, but continuously as proposals are being hammered out and, certainly, as they are being implemented.
Skeffington Report

The idea of public participation debuted in professional planning literature in 1964, per planner Francesca Sartorio, but it was not until the 1969 report that it gained prominence, formally endorsed by the Minister of Housing and Local Government in his mandate to Skeffington “[…] to consider and report on the best methods, including publicity, of securing the participation of the public at the formative stages in the making of development plans for their area.” 16 The report came on the heels of the 1968 Planning Act, which introduced statutory public participation, setting the UK among its Western peers as the first to do so, and planning among the first public services to enact it. As a first, Sartorio argues, it was a pivotal document which led debates in the UK and abroad about the notion of public participation, both within the planning profession and by the public; it contributed to the definition of what public participation is (and could be) in planning, providing examples of engagement for other countries to follow. 17 It was influential in placing more value and emphasis on public participation.

The report also had its shortcomings. Seen as an establishment response to 1960s radicalism, the type of participation advocated in the report is itself tokenistic, according to community engagement consultant Jeff Bishop: a limited offering to people of a voice in plan making and a capped influence in final decisions which were ultimately still determined to be better taken by professionals and councillors. 18 In a contemporaneous review of the report forThe Town Planning Review Journal in 1971, two years after the report’s publication, sociologist Seán Damer and planner Cliff Hague criticised its proposals for the deference to the professional expertise of the planner.

There is no logical reason why elected representatives or professional planners, for that matter, should keep enforcing their aesthetic judgments in areas where people are quite capable of deciding for themselves what it is that they desire. It is becoming accepted in our time that the people who, as it were, live in an environmental design should have some say in the selection of its components.
Damer and Hague, ‘Public Participation in Planning: A Review’.

Damer and Hague were critical of the report’s ideology of the professional planner as the sole expert on these issues and of its failure to perceive planning as a political activity with political consequences. The proposals were insufficient in their view because the days of tacit acceptance of autocratic decisions in the urban system were purportedly over. They advocated for a redistribution of power where people, and not only planners, “should have some say.”

The germs of ‘have your say’ planted here parallel the larger political and cultural movement of 1968, the counterculture and uprisings of the Sixties in pursuit of a more democratic, equal and participatory society. 19 Alongside questions of how much of a say planners were actually willing to give away, debates about the Skeffington Report echoed arguments made by US planner Sherry Arnstein to address power imbalances. Arnstein’s ladder of participation (1969) showed the rungs citizens must climb to gain control and more power over their fates. 20 Ladder of Citizen Participation, Sherry Arnstein (1969) Carole Pateman’s theory of participatory democracy (1970) coalesced similar ideas into a model of democracy wherein citizens have power in decision making. 21 The 1970s then saw a period of increased public engagement activities in planning in response to Skeffington, Arnstein and Pateman, including experiments in community development by left-wing urban local authorities noted in Steve Connelly’s account of the history of participation in English local governance. 22

However, public empowerment was challenged in the 1980s by the political upheavals of neoliberal governments and the privatisation of public services, removing local democratic oversight. In particular, people’s dissatisfaction with inner city regeneration was connected to their disempowerment in municipal and central government economic policies, which led to widespread discontent and civil unrest. With the dismay and bruised confidence of the public in public processes, the decade thus saw the beginnings of what Connelly, echoing others, calls a ‘participatory turn,’ taken up in different but fragmented ways to address the role of the citizen in policy decision-making. For the radicals, there was support for groups in the community and experiments in neighbourhood decentralisation, local forums, and alternatives in community-based land use planning, in which discourse saw “participation as route to empowerment for disadvantaged groups in society.” 23

This was referred to by the Greater London Council as ‘popular planning’, whereby, in Sue Brownill’s description, “instead of a circumscribed exercise of gathering views on pregiven policies many local authorities have attempted to actively involve people in the formulation of strategies and projects and to change the relationship between the local state and the locality. The philosophy behind popular planning is one of the empowerment of groups and individuals and the building of their confidence to become active agents of change.” 24 The People’s Plan for the Royal Docks (1984) was an example of residents empowered as “active agents of change,” in this case, to contest the development proposed for the Docklands in Newham. It was also an example of what Brownill describes as an inherent contradiction in popular planning between different political agendas for change, a centralised state and locals, in the formulation of policies. ‘People’s plan,’ she argues, was a false rhetoric because, although it did reflect some local demands, the plan was a framework for GLC policy pretending to come from the grassroots. 25 There was also a power differential with the London Docklands Development Corporation set up by central government to oversee the development, who largely ignored the plan despite its success at a public inquiry. The People’s Plan showed that, in light of competing agendas and different power relationships, having some say is not enough.

Timeline of Participation, Planning and Equality in UK. Graphic illustration by me.

Public Consultation and Consensus: Having Collective Say (2000s)

Such a struggle for power in public participation in planning, exemplified by the Docklands, would continue into the 1990s, see-sawing over the ability to have more say. Following the neoliberalism of the 80s and 90s, Connelly identifies the post-1997 period as driven by communitarian ideals associated with third way ideology, with the goals of social cohesion and citizenship to address perceived breakdown and lack of community of the previous period. Tony Blair’s New Labour government initiated a broad programme of reform in the early 2000s to modernise local government, which put emphasis on local authorities as local government, not service providers on behalf of central government. 26 With this shift away from central power to local power, Connelly argues, came a shift away from old public participation to new public participation, signalling a changing relationship of citizens to local authorities. Where before the public was represented arms-length via elected officials in a form of representative democracy via the electoral process with intermittent contact with elected councillors, they now had direct, hands-on involvement, empowered to be their own representatives, realising a form of Pateman’s concept of participatory democracy. The public would share in policymaking, given a more active and collective role as citizens in governance of their own communities and working in partnerships with local government.

In a white paper, ‘Modern Local Government: In Touch with the People’, Labour put into policy their wish “to see consultation and participation embedded into the culture of all councils and undertaken across a wide range of each council’s responsibilities.” 27 The emphasis on consultation was reflected in the numerous reports and acts published at the time to stimulate public involvement. 28 Under an instrumental desire for better-informed policies, Connelly observes “the entrenchment of consultation as a routine part of policy making,” and formed part of policy rhetoric. 29

The need to consult set a precedent from which future public participation for the next twenty years would take shape, and marked, what I would call, taking Connelly’s cue, ‘the consultative turn.’ In 2004, as part of the Planning and Compulsory Purchase Act 2004 (Section 18), UK law mandated local authorities make Statements of Community Involvement, or SCI, to explain how they will involve, consult and engage with others in the preparation of development plans. Community involvement through consultation becomes the main route for participation in planning. See ‘Public participation’ in Section 335, Part VIII, GLA Act 1999; ‘Public Participation’ in Part II, Town and Country Planning (London Spatial Redevelopment Strategy) Regulations 2000

But as Chapter Two has discussed about the imaginative ‘all,’ a gap exists between Blair’s rhetoric and practice. His application of the Third Way philosophy—despite claims to not compromise either economic or social goals nor choose between the market and the state—was still a neoliberalist pursuit of growth. 30 Eunice Goes argues that he used the ‘narrative of community’ and the ‘politics of inclusion’ selectively for political gain but was scant on policy framework to address issues of rising inequalities that excludes certain groups from participation in society. 31 In this regard, consultation of communities, arguably, was set up to pay lip service to communitarian ideals without any real teeth for collective decision making. For instance, it’s up to councils to set the terms of SCIs, and so consultation standards are inconsistent.

Against the national backdrop of governmental devolution and the need to consult, the reverberations of citizen-powered governance were urgently felt at the municipal level in London. Notably, in 2001/02 two GLA Group reviews were carried out, Equalities for All and Listening to London, while the London Assembly’s Reaching Out Investigative Committee published, Is the Mayor Listening?, a report on Mayor Ken Livingstone’s consultation and engagement with Londoners. 32 On the heels of the latter, the outcome produced Consulting London Framework, GLA Consultation Strategy and a subsequent Listening to London – Good Practice Guidance for the GLA Group. 33 34 35 Consultation and engagement were set as the primary objective of the GLA Group.

After the radical legacy of the mid-late 80s of the New Left and the Greater London Council, Livingstone took the helm for the first eight years of the GLA’s formation as the first Mayor of London (2000-2008). He adopted a more conciliatory approach than when he was the GLC leader, Owen Hatherley notes that “there was no return to the insurgent popular socialism that had distinguished the GLC. Livingstone was intensely conscious of how little actual power his new role entailed.” 36 With a weak governance centre, Livingstone as Mayor needed to mobilise support for his growth agenda in a variety of ways, including community support. As part of the Livingstone administration’s Best Value delivery programme, consultation took on a larger role in the GLA across its core operations, part of a larger trend in policymaking in which the words ‘consultation,’ ‘community’ and ‘involvement’ began to appear heavily in policy text. 37 In New Labour’s commitment to involve (1997-2010), per consultants’ Penny Norton and Martin Hughes, participation in planning became associated mostly with consulting and “involving community.” 38

Coming into this complex picture of people participating in planning is the London Plan. Being the city’s most crucial policy document affecting the infrastructural makeup of the capital, the call for public input into the plan is heavily regulated by national and municipal statues mandating public consultation. In Towards the London Plan, the document that kickstarted the process and preceded the first London Plan, the ask of Londoners and how they should participate, is clear: as commentators and consultees. Billed as “the process for agreeing to the plan,” the London Plan was the beginning of the public participating in London’s strategic planning in a direct way, framed as an exercise in consultation and centred on consensus. 39 Cover and page excerpt, Summary: Towards the London Plan (2001)

Your comments count: It is important that we know whether you agree or disagree with the policy directions set out in the document. Your views will guide the preparation of the draft of the London Plan.
Mayor of London, ‘Towards the London Plan’.

Open Planning, Localism and the Neighbourhood: Having Local Say (2010s)

Yet, despite the clear tendency towards more consultative engagement in policy, including increased opportunities for public voices to be heard both as partners and as consultees, Connelly asserts that overall there has been no radical transformation for the public, arguing what has changed is, who the public has a relationship with, whether they may be working with local councillors, unelected officials, the private business sector, or community collaborators. 40 Citing a 2011 study on thirty years of urban regeneration, he noted the social and political problems which had prompted many of the reforms still endured, prompting popular discontent and critical commentary. 41

When David Cameron’s Conservative-Liberal coalition came into office in the late 2000s, the devolution of governance continued, and importantly, local empowerment was formalised into law in a significant way that would cross paths with what was happening at the London metropolitan level. The city’s transformation aligned with major national policy changes aimed at facilitating planning democracy for citizens to have a closer and more local relationship to planning, in line with a recognised need for local government “to get closer to the people.” 42 The 2011 Localism Act was introduced with the stated aim to give the people more voice and influence and to transfer planning power from central government to local authorities and local communities. A chapter of the Act is dedicated to consultation whereby officials have a duty to co-operate in relation to the planning of sustainable development, “to engage constructively, actively and on an ongoing basis.” 43

Localism was framed as “an invitation to citizens and neighbourhood groups to help build the Big Society,” Cameron’s version of social solidarity and community empowerment—“neighbourhoods in charge of their own destiny.” 44 It invited local people to meaningfully take part in plan making and to collaborate with other actors to achieve planning consensus. The set up fits within political sociologist John Gaventa’s theory of ‘spaces for participation,’ in the second of his three types of democratic spaces: 1) closed or uninvited spaces, in which bureaucrats, experts, and elected representatives make decisions with little broad consultation or involvement; 2) invited spaces, whereby people are invited to participate by various kinds of authorities; and 3) where there is limited invitation or none, citizens occupy the third, claimed or created spaces. 45 Localism changed what kind of participatory spaces the public gets invited into, or excluded from, and widened the degrees of openness afforded to policy processes.

In aiming to reduce state involvement, the move toward local planning impacted how people related to each other at the local level to effect change in their area. The National Planning Policy Framework (NPPF), first published in 2012, made a clear move away from regional planning, prioritised citizen involvement, and introduced neighbourhood planning in order to create “a framework within which local people and their accountable councils can produce their own distinctive local and neighbourhood plans, which reflect the needs and priorities of their communities.” 46 The document promotes the role of public planning and the benefit of early engagement and participation, encouraging clearly articulated approaches to involving the local community, neighbour to neighbour.

The shift to the neighbourhood level was consequential. While statutory consultations in planning in the previous decade were set up with due regard to instrumentalise citizens to be more involved and had sought to bring people into closer and more direct contact with planners, plan makers and policy makers, the localism dream via neighbourhood planning reoriented the relationship of neighbours. Not only were local residents given more of a say, but they were also tasked to say it to each other. Different from the 1960s where much of the say rested with the professional planner, local people became planners. Neighbourhood Planning occurred at a time when the community and/or neighbourhood became the preferred scalar focus in planning across political parties, urban studies scholar Katherine Brookfield notes, and its claims about greater involvement in planning from a wider range of people held promise. 47 Peers and neighbours could come together as a Neighbourhood Forum to hone their own vision and to plan together for the development of their local area.

However, Brookfield finds in her 2016 review of participation in neighbourhood planning five years after its introduction that “participation is found to be modest and partial, concentrated amongst a few, relatively advantaged communities, and relatively advantaged interests within those communities.” 48 This is because, despite the widening of participation, Neighbourhood Planning (in capital letters) is still a formal planning tool with time and cost caveats to get involved in the plan-making process. It is a privileged channel for those with the means and sustained commitment to navigate it to effect desired change. In a sense, one privilege is replaced with another, from the few (officials at the authority level) to a different few (vocal interest groups at the neighbourhood level).

In 2017, the formal implementation of the Neighbourhood Planning Act brought another complexity significant to the London Plan. In answer to a Mayor’s Question Time inquiry into the Act’s main benefits to London and its impact on the London Plan, the Mayor responded, “the Act increases the weight of Neighbourhood Plans as they go through the process. Neighbourhood Plans can play an important role in ensuring local communities have a say in their area and how growth is accommodated.” 49 This framing sees the new reform as an opportunity to bring local communities into the growth machinery. But it is a complicated ask of Londoners to reconcile a local agenda with a city-wide one, especially considering that neighbourhood planning is different in London than it is elsewhere in the country.

Counter to Brookfield, the London Assembly’s 2020 Neighbourhood Planning Report asserts that Neighbourhood Forums have confounded expectations, their evidence shows the assumption that Neighbourhood Planning is the preserve of relatively affluent neighbourhoods, is no longer the case. 50 But this is true mostly for the rest of England where take-up of Neighbourhood Forums is much higher than in London, the report finds. Particularly in London, however, in light of the highly charged debate about the planning system and the tremendous pressure for development placed on it in terms of growth previously discussed, the report acknowledges there are many challenges and obstacles community groups face in planning for their areas.

Just Space has taken these challenges head on. Outlined in Chapter Two, the organisation was formed specifically to ‘build a community-based voice for London’s planning’ in an attempt to influence strategic planning of Greater London. Just Space had emerged in response to the original London Plan from what they saw missing at the first EIP in 2003: organised community input at the grassroots level. Identifying the need to “link up the local and the regional” and the benefit of “forcing the two levels to interact,” “[they] see neighbourhood planning under the Localism Act as potentially an opportunity to promote bottom-up, community participation.” 51 Getting involved in the alterations to the London Plan 2007, alongside the London Forum of Amenity and Civic Societies and the London Tenants Federation, they succeeded to open up a previously closed space of participation into an invited space for ‘ordinary working-class’ community groups to join in. As a result of Just Space and LTF’s involvement in the 2010 EIP, supporting 63 different groups, they were able to influence London Plan policy on the definition of a ‘lifetime neighbourhood’ and be included as a case study in a 2011 government report on ‘Lifetime Neighbourhoods’: 52

All Londoners should have the opportunity to enjoy a good quality environment in an active and supportive local community. Ensuring this means planning for lifetime neighbourhoods in which communities are empowered and in which local shops, social and community facilities, streets, parks and open spaces, local services, decent homes and public transport are affordable and accessible to everyone now and for future generations.
London Tenants Federation’s definition of ‘lifetime neighbourhood’

While this was seen as a positive outcome, it’s also instructive of the great effort and attention demanded of communities to self-organise in order to secure a local say—one paragraph in a 105-page document.

Planning Law: Claiming the Right to a Say (Today)

Paralleling this recent history of planning and participation is the related timeline of equality rights and the evolving ideas of inclusive and equitable citizenship. The changes to the level of autonomy and the increase in citizen power have paralleled shifting notions of citizenship, connected to gains in equalities legislation in the UK and globally, like the Human Rights Act (1998), the Aarhus Convention (1998) and the Equality Act (2010). They make provisions with regard to the protection and rights of every person, especially protecting the vulnerable, linking the right to live in an adequate and sustainable environment with the right to participate in determining the conditions of that life and environment. Where there was a change in equalities legislation, there was resonance in planning, which reverberated in citizens involvement in policy decision making.

With public participation enshrined into law, the right to participate underpinned the right to have your say in the transformation of the city, a vestige of the language from Skeffington and Arnstein’s time. Geographer David Harvey argues, “the right to the city is not merely a right of access to what already exists, but a right to change it.” 53 It’s a right that according to the World Charter on the Right to the City is exercised through “participation in the planning, production, and management of the city.” 54 This is a right that localism and open planning was meant to deliver on but which has produced mixed results and what Just Space characterises as rare wins for community groups. Typically, minoritised groups, with few resources at hand, must assert their rights, actively and persistently.

Where participation is framed by policymakers as consultation, progressively for a number of citizens, participation is about claiming their rights, either as a reaction to development proposals, in the form of campaigning and protesting, and/or proactive public planning, in which the public does the planning on their terms, beyond the formality of localism mechanisms. There is a larger civic movement and a shift towards citizen assemblies today, a demand for citizens to not only be a part of the debate but to be meaningfully included in defining the subject and conditions of debate. A 2019 manifesto by Civic Voice, the national charity for the civic movement in England, expressed a desire to move consultation to conversation and reflects the growing calls for community participation to go beyond consultation. 55

The changeover is on trend with what Andrea Cornwall and Vera Coelho call participation in “new democratic arenas” as “spaces for change,” “spaces for contestation as well as collaboration,” to negotiate “the boundaries of the technical and the political” and to “serve an entirely different kind of interface with policy processes than other avenues through which citizens can articulate their demands—such as protest, petitioning, lobbying and direct action—or indeed to satisfy their own needs.” 56 Similar to Gaventa’s model of participation, these are spaces claimed by less powerful actors from or against the power holders, or created more autonomously by them. Citizens feel compelled to claim their own space by taking direct action, getting involved in planning activism, where participation moves outside of sanctioned rooms, taking to the streets in many instances, and to court rooms increasingly, to defend their right to have a say. Residents invent new paths where there were none before, or re-tread old paths that were not previously made available to them. They embark on community engagement with themselves.

At the neighbourhood level, another trend is active resistance to formal plans and residents taking matters into their own hands. In housing especially, as discussed by Pablo Sendra and Daniel Fitzpatrick (2020), it has manifested into what is popularly known as community-led regeneration and pursued as a form of design co-production where communities take the lead on their neighbourhood’s future; and where residents and activists resist the demolition of their neighbourhoods to propose their own alternative plans and community-led schemes. 57 E15 Mothers is one example highlighted in their study, of residents not only taking up official planning tools themselves to fight displacement but undertaking informal strategies that include occupying the estate, self-initiated skills and knowledge sharing workshops, and community gatherings held on public grounds, succeeding to disrupt and interrupt the standard processes.

Another example is the ‘Keep Hackney Crap’ campaign artists launched in 2009 in response to the then-Mayor of Hackney Jules Pipe’s accusation that opponents of the Dalston regeneration scheme wanted to ‘keep Hackney crap,’ as if they were opposed to making things better. Set up by The EEL, a locally-produced magazine, to distribute badges and t-shirts emblazoned with the slogan, it was a creative form of resistance “to celebrate that which is forgotten and marginalised,” “a campaign about retaining the things which genuinely make an area unique and loved,” noted The EEL’s Tony Collins. 58 ‘Keep Hackney Crap’ campaign. Image source: (helmet) Jim Crossley on Flickr and (badges) JimJepps.net

As some take the artistic approach, others have turned to the legalistic. Residents resort to directly using the law and challenging redevelopment through the courts, barrister Sarah Sackman writes in her contribution to Sendra and Fitzpatrick’s toolkit for community-led regeneration. 59 They must navigate what geographers Phil Hubbard and Loretta Lees call the “legal geographies of resistance on London’s gentrification frontiers” in order to assert their “right to community.” 60 Ostensibly, participation has moved away from consultation explicitly and has seen efforts concentrated on protest and protection of rights in a “quasi-judicial planning process,” the term used by Robert Jenrick, the former Housing and Communities Secretary (and main seal-of-approver of the London Plan) to describe the nature of the English planning system. 61 Jenrick’s remark came about from addressing the need for transparency after his involvement in the documents row of the Westferry Printworks redevelopment scheme in Tower Hamlets came to light, revealing the behind-the-scenes negotiations between politics and planning. For many Londoners, their first introduction to planning is through dispute of a proposed change to their local area while their direct interaction with planning mainly occurs through public hearings (‘inquiries’) after the plan has already been developed. Their participation is of the quasi-judicial kind involving lawyers and defending property; and invoking their right to plan. Southwark Notes (@SouthwarkNotes). 23 Oct 2019. Captures one state of public participation in London today from the perspective of campaigners, involving legal proceedings and showing up in court to fight against unwanted development.

This climate of rights-based public involvement in English planning underpins involvement in the London Plan, the EIP is a statutory inquiry. 62 GLA Act 1999, Section 338 (10). An examination in public—(a) shall constitute a statutory inquiry for the purposes of section l(l)(c) of the Tribunals and Inquiries Act 1992 (administration 1992 c. 53. provisions involving the holding of a statutory inquiry) Focus is on the pursuit of justice, which is encapsulated by the work of Just Space and is overt in their name. Just Space describe the public inquiry into the London Plan’s soundness, the EIP, as a quasi-judicial-style hearing. 63 The judicial setup of the EIP process manifests what political scientist Rikki John Dean defines in his theoretical model of public participation as arbitration and oversight, the objective being “to improve the legitimacy of decisions and render them acceptable to all, primarily by demonstrating that decisions have been subject to a fair process that has not been dominated by one set of vested interests.” 64 The panel plays the role of “an impartial adjudicator (arbitration) [and] an impartial critic of state activity (oversight).” The Mayor and the GLA make their case through the draft plan and suggested changes. Public respondents reply through written statements during the draft consultation.

To signal neutrality and legitimacy, the panel interrogates the arguments of both sides to come to a balanced decision. The setup is by design adversarial, the Mayor’s side taking up post as defendants. The space of participation here is not a dialogue—an exchange per se—so much as it is a defense of decisions. Though instrumentally the London Plan is a strategic framework, legally it forms part of boroughs’ Development Plans and must be taken into account when planning decisions are taken in any part of London. The objective and appearance of fairness is to strengthen the plan’s legal force. The output of the EIP process thus carries considerable legal weight.

The way to contest it is through legal means. For example, Caroline Shah, a local campaigner for Kingston, set up a Go Fund Me to crowd-fund the legal fees for a barrister’s advice on making a legal challenge to the London Plan 2021 on its heritage policies. Billed as a “last chance to stop flawed plans for London”, it culminated from “fighting the London Plan for over two years, and undemocratic and harmful development plans for Kingston for over five years.” 65 With Just Space, she spoke at several EIP sessions to raise awareness of the issues and “to help decision-makers understand the harm to London in general and Kingston in particular that will come from their plans.” Pressing the Mayor on the legal duty to ensure that individual London Boroughs have met their own legal requirements when submitting plans to the Mayor, she relied on the law to gain planning traction.

Seat-sharing with Just Space at the EIP made it possible for Natasha Sivanandan, a black feminist, social scientist and housing activist, to bring to light significant concerns about the draft plan’s deficiency in consultation with minoritised groups and risk of non-compliance with the Public Sector Equality Duty (PSED) of the Equality Act 2010. As well as a Haringey resident, Sivanandan is also a trained lawyer and former race equality advisor at London’s Brent Council, who has taken long-running legal action against racial discrimination across the city. She is associated with St Ann’s Redevelopment Trust (StART), an organisation campaigning for community-led housing development of the site. Speaking into the mic borrowed from Just Space and on behalf of Just Space and StART, on Matter 2 Equality of Opportunity, she challenged the adequacy of the Integrated Impact Assessment and Addendum Report (IIAA) on which the London Plan relied to indicate how the policies set out will help to advance equality of opportunity between people who share a “protected characteristic” as defined in the Equality Act and those that do not share it. 66 Like Caroline Shah and others who didn’t receive a direct invitation to appear at the EIP, Just Space invited Sivanandan to fill in the spot designated by the panel as “+ one other” next to Just Space’s name in the list of anticipated participants.

At the following hearing on Matter 6 Consultation and Engagement, Sivanandan further expanded on the shortcomings of the plan in consideration of equality of opportunity for all to be involved in the plan’s development. 67 Citing case law, she went on to explain how none of the elements of effective or meaningful consultation as defined by the Supreme Court in Court case: R (on the application of Moseley) v London Borough of Haringey, had been carried out with specific regard to those who were discriminated against and marginalised in London, in breach of the Mayor’s PSED. The citing of a potential breach of law turned the panel of inspectors’ attention to equalities, calling on the Mayor to report urgently on the expected impacts of the plan on each of the groups in society protected by law. They ordered the Mayor to release more information to make the justifications and assessments available for review. Supplementary written statements were also invited from Sivanandan, Just Space, and others to respond to the additional evidence. It was through rights-claiming and reference to the PSED that marginalised communities were able to call greater attention to their causes.

The (Costly) Labour of Public Participation

Public participation is difficult. Processes are formal and technical; the spaces of participation have set rules and arrangements. See APPENDIX Spaces of Participation, for a sample selection of the London Plan consultation events I had attended in person and online between 2018-2020. From free events at City Hall facilitated by the GLA to the basement of a café for a community-led discussion to a (fee-paying) breakfast meeting in a hotel banquet room hosted by a developers’ forum, the variety of spaces demonstrate the degrees of open and closed invitations to participate. The survey diagrammatically analyses each event’s format and spatial configuration (room layout), as well as photographically documents the demographics of organisers and attendees, to reveal the dimensions of contestation and power associated with the different media affordances in each space. It also illustrates the bodily engagement and physical labour involved to attend and participate. It demands a lot of attention from participants: the London Plan 2021’s draft review involved 200 listening hours and 3,600 documents. 68

To participate is costly. For citizens to make effective representations about the management or planning of their areas requires time and money. To sustain these positions through the formal procedures—especially the public inquiries—costs even more. […] Public Inquiries into individual development proposals number tens of thousands in the UK each year, thousands in London, with a duration ranging from a few hours to many weeks. Meetings are almost always held during the working day. Citizens and citizen groups need massive resources of time, technical knowledge and skill (or money) to sustain their positions in these conditions.
Michael Edwards, International Seminar on Communicating Planning (1999)

Remarks made by Just Space’s Michael Edwards in 1999 at an International Seminar on Communicating Planning in Italy, representing the London perspective, could well have been said about what is happening presently in London, over two decades later. In fact, a version of this was articulated in Just Space’s response to the London Plan draft consultation in 2018 detailing their particular experience participating in the process. From 2015, Just Space has gathered contributions from 85 community organisations, prepared 4 policy documents and coordinated 3 conferences for public discussion of the plan—mostly done on a volunteer basis and unpaid labour time. Notably, Just Space uses free student labour to support their work. Student volunteers take meeting notes and transcribe hearings.

It’s a similar case for other participants. London Tenants Federation described their involvement in the draft plan 2017 as, “we perhaps tried to take on too much.” 69 They attended sessions in seven of the 12-week period of the EIP. LTF contributed to debates on consultation and engagement, ‘good growth,’ housing need and supply, strategic and local regeneration, fire safety and estate regeneration, providing written evidence prior to and during the hearings.

Even an insider like consultant Julia Park, head of housing research at Levitt Bernstein, an architectural, landscape and urban design practice, faces a hard time navigating democracy in the planning system, recognising the attention and sustained effort involved. She finds the EIP “a trying process” that is “rather confusing and somewhat opaque.” In an advice article to other design professionals written for Building Design magazine in 2019, she contends that “grappling with the London Plan examination requires stamina.” It takes a certain kind of person and persistence, in her view, “anyone who had nothing more pressing to do than keep a constant eye on the EIP website and follow the torturous process” and attend the hearings “as long as you can manage to take the day off work, sit still and keep quiet for seven hours.” 70 That is a quite narrow subset of people privileged with that type of flexibility and patience. Notwithstanding the GLA’s advertising that anyone and everyone can take part in the plan’s review, the message appears to be, democracy is available to participate in, if you can sit quietly for seven hours.

Park’s account reflects my own experience of moving through the public processes for six months. Slogging through the London Plan requires a degree of ‘being alert to,’ vacillating between deep attention and surface attention. It is a physical, bodily engagement involving: the labour of attending events across the city, of carrying print publications around, of close listening during EIP sessions or webcasts, of downloading documents online, of reading and cross-referencing, of looking and searching and connecting the dots, and of writing letters, formal submissions, informal blog posts; the strain of sitting at a desk or in front of a screen for hours. It takes tremendous effort. Not only is it hard for respondents, it is also difficult for the GLA facilitating the numerous consultations. By one officer’s count, “we did a hundred events in two months,” with the London Plan team under daily pressure to absorb the feedback and to timely reflect it back in the draft, and “I mean when I say we, there was me to do it.” 71

Timeline of my participation in the public processes of the London Plan Draft for Consultation 2017. Graphic illustration by me.
Schedule of GLA consultations 2016-2020. Graphic illustration by me.

It’s a lot of work for the GLA. Deputy Mayor Jules Pipe states that the draft plan as a whole has been developed in consultation with teams across the GLA group, who have a range of expertise and experience: “each detail has been examined and debated both by officers and by the Mayor’s Deputies and advisers. The nature of such a wide-ranging strategy is that it has to balance conflicting demands, and many hours were spent understanding how the draft Plan could balance competing land uses, while remaining deliverable.” 72 , City Hall, London, 15 January 2019.] In response to the EIP panel’s question of whether the approach to planning in London of the plan has been agreed with all London Boroughs and other relevant interests, Pipe further highlights the pressures placed on the plan that tie the GLA’s hands and delineates the limits of engaging Londoners in debate and policy-making: 73

In developing the plan, significant consultation and engagement was undertaken. However, the development of the SDS is bound by legislation and associated regulations which afford the Mayor significant discretion on the content and style of the plan, as long as it deals with matters of strategic importance to Greater London.
Jules Pipe, Opening remarks at first Examination in Public session

‘Significant discretion’ means that the Mayor does not have to take on any of the public comments nor the Inspector’s recommendations. The Mayor can choose to reject any or all of them. While that may be a politically risky move that would require justification, legally there is no obligation to take on the suggested changes, therefore throwing the entire process of seeking public input into question.

What’s the point then? Despite the aims and the mechanisms in place to rebalance the planning scale, the obstacles to participation mean that it is often fraught in practice, experience, and results. Due to the structural barriers of official planning processes—limited timescales and resources, and the tensions between differences in expertise and lived experiences—many people feel shut out of planning rooms and are distrustful of those convening them. Participation is tied to trust, and trust in planning today is very low. Apathy and distrust in both developers and councils are widespread. In a 2019 national survey of public views on trust, placemaking and developers, only 2% trust developers to act in an honest way, and 7% trust their local council to make decisions in the best interest of their area. 74 Ironically, the survey was conducted by the Grosvenor Group, one of the world’s largest privately-owned international property businesses. “The public doesn’t trust the planning system, nor does it trust private developers,” is the unvarnished conclusion of their research. It’s a confirmation of the contentious nature of debate typical of urban developments, acutely felt in London.

The disillusionment with participation in planning leads to an unfavourable reputation described by critics as ‘pseudo-consultation’ (Southwark Notes Archive Group) Southwark Notes (2008) https://southwarknotes.files.wordpress.com/2012/03/i-you-we-particpatebluelec.jpg or ‘manufactured consent’ (Architects for Social Housing) and a ‘torturous process’ (consultant Julia Park). Reflecting in 2016 on the state of participatory democracy, 30 years after the People’s Plan at the Docklands (1984), sociologist Hilary Wainwright speaks of “an intuitive calculation” that goes into participating in consultations nowadays, “people are asking for our ideas but what is the point if they are not going to be implemented?.” 75 Wainwright worked in the Popular Planning Unit at the GLC, under Ken Livingstone’s leadership. They must weigh whether the outcome is worth the cost, labour and time investment; given the gap between intention and impact, most tend to walk away because it is not.

The Sound of Participation

For the London Plan, part of the cost-benefit calculus of public participation relates to the onerous activities involved in having a say. The crux of commenting on the draft is on written statements during the draft consultation and on oral testimonies during the EIP. The plan’s terms of consultation stipulate that “a representation is made if it is made in writing,” and regulate that “the statement must be in writing,” public comments need to be written text. 76 At a community-led consultation event at City Hall, after making an introductory presentation to leave the community groups to discuss amongst themselves, Jules Pipe and his GLA team excused their absences with a prompt to participants that representations must be written and cannot be oral. While they were supportive of the day’s discursive activities and excited for its outcomes, they noted the critical importance of providing the feedback back to the GLA in text format. Implicitly, participation here is exercised as a writing practice and legitimised through documented text—and not oral declarations. It is centred on writing and not saying. Participants were advised to write down their oral discussions in order for their feedback to have weight and legitimacy. By the same regard, the report of the EIP panel shall be in writing. Whether the Mayor accepts or rejects the report’s findings, he must also write to the Secretary of State and the London Assembly to make his case for the plan’s final form.

Despite the emphasis on written statements, contradictorily, participation in the EIP is designed as a speaking activity. While participatory democracy, on the whole, is overly concerned with having presence and appearing in the arena, the examination itself is about sound, both in the literal sense of hearing and in regard to valid reason or good judgment. The EIP is held to consider and certify whether the plan is sound, if it has been positively prepared, justified, effective, and consistent with national policy. 77 For the purpose of “testing of soundness,” it seeks to assess if the plan can be formally adopted; a process completed through a physical demand of our ears, straining to hear the voices in the room, over twelve weeks, three days per week, and six hours per day. David Smith, one of the panel inspectors, had asked during introductions at the first hearing: “Can those at the back hear everybody? I’ve got to say I couldn’t hear everybody so that just underlines the fact that when you do speak you do need, I’m afraid, to kind of lean forward towards the microphone and to speak up as clearly as you can. I think the previous experience of this Chamber is the acoustics are good for those who sit at the back but not so good strangely for those sitting near us.” Roisin Barrett, the lead panel inspector, had also instructed, “Speak into the microphone, the acoustics aren’t great here,” to kick off a different session.

Not everyone, however, is afforded the same opportunity to speak into the microphone or to lean in. In the EIP, the sound of participation is regulated in non-apparent ways to the appearance of participation. It’s not enough to show up with something to say, an invitation is firstly required. The terms of speech are very specific. ‘Have your say’ sounds colloquial, like an informal chat similar to the Mayor’s Have Your Say online community programme, Talk London. The EIP process is quite formal and speaking/conversing happens in rather structured ways. Each session takes the form of an agenda-driven discussion led by one or more of the panel members, focused on specific draft matters of the day. Invited participants were expected to have read all the relevant statements and evidence beforehand. The Panel took an inquisitorial approach, exploring each matter thoroughly in a Q&A format where the questions are pre-selected and pre-answered in written form (written submissions must be shorter than 2,000 words).

There are strict and conflicting codes as to what and who appears, and how; and importantly, who can and does speak. According to policy guidance on plan examination, “no person shall have a right to be heard at an examination in public,” at the same time that, “the right to appear and be heard by the Inspector at a hearing session is limited to [particular] persons,” while “[a]nyone may come and observe but non-participants have no right to speak.” 78 79 Who gets to be a participant, and therefore who has the right to speak, is at the panel’s discretion. Even if fortunate enough to be a named participant, the procedure for representation at public hearings has nuanced speaking rules that limit what can be said: 80

The local planning authority and applicant have an automatic right to speak. Individuals and organisations that have previously made written representations about the application either to the relevant local planning authority or directly to the GLA will be eligible to request to speak. […] Those eligible to request to speak will be given at least fourteen days’ notice of the hearing. However, this does not mean that anyone who has made a written representation on the application has an automatic right to speak as this could make the hearings unmanageable.
Greater London Authority, ‘Procedure for Representation Hearings at the Greater London Authority’.

To manage them, the EIP process is a back and forth between the panel, participants, and GLA officers that follows a pattern of panel question, participant answer, and GLA clarification. The selection of participants with the right to speak on the day was limited to those who were invited and had previously submitted a written statement of response to the panel. Outside of these authorised speakers, the session’s attendees in the gallery play the role of public witness.

From this formality, two corollaries emerge from the public inquiry format and this form of participation: 1) the primacy of text and 2) the sharing of voices. There is a conflicting push and pull between writing and speaking. Participants read aloud their submitted statements. The inspector asks for verbal clarification where needed but, as the participants were reminded, any suggestions or amendments verbally raised must be delivered in writing as a follow-up, and only if invited to do so afterwards. Following each session, the inspectors generate panel notes while participants submit additional statements and supporting documents as asked. There are audio recordings of each hearing session available on the GLA website, but these are a courtesy offer for accessibility purposes, not substituting for the substance of written statements. The function of the EIP in this regard is a pre- or post-verbalisation of texts.

Text is used to document and create a body of evidence, while speech is used to amplify text. The London Plan privileges and prioritises text evidence over oral evidence. EIP hearings are therefore a site of speaking and listening as a means to facilitate writing; they are a site for the production of (more) text. This setup adds to the complexity of having a say in the London Plan. The soundness of the plan hinges on all these various acts of writing. Have your say is, in fact, write your text. This has implications for who can have a say because writing demands a specific skillset different from speaking. It shuts out some Londoners from the process. The uninitiated need the help of a tour guide like Just Space who have learned the inner workings of the process—on how to write—to successfully navigate it.

More of the Same: The ‘Never-ending Struggle’ to Have a Say

The ground-breaking work of Abercrombie, Skeffington and Arnstein has left deep imprints from which the planning profession, decades thereafter, have not quite moved forward, frequently quoting from them but still struggling to fill in their shoes or to find an adequate replacement for their historical models. For example, in a 2003 journal article of Planning History, Keith Lilley considered how far planning exhibitions held in 1940s Britain ‘consulted the citizen’ and concluded that the evidence from one such exhibition, Coventry of the Future, revealed “a complex picture, a differentiated experience of participation.” 81 Measured using Arnstein’s ladder of participation, Lilley determined that “the exhibitions were largely paper exercises, stimulating public debate but in the long-term not tied into the decision-making process itself,” and that “planning exhibitions acted as civic propaganda and public consultation.” The article, written 20 years ago, referenced a model of participation developed 50 years ago, to examine one form of public involvement in planning from 70 years ago. The remarks could well be mistaken for criticisms presently shadowing the debate on participating in London’s planning.

The Skeffington Report had spurred debates in planning about the need for change in how to involve the public beyond information-giving toward power-sharing in decision-making—raising questions that proponents of communitarism and localism in a participatory democracy tried to answer. But, as academics, researchers and practitioners alike have noted, little progress has been made since the last mid-century. The County of London Plan’s 75th anniversary and the Skeffington Report’s 50th anniversary had set off a number of reflections from built environment professionals and scholars on the relationship between people and planning, many concluding, while much has changed, much has not.­

Participation in planning is a struggle, an admission made by planners themselves during People and Planning at Fifty, an event held at the Town and Country Planning Association’s offices in London in June 2019 to explore lessons learned over the decades and set out the likely issues and changes needed moving forward into the next 50 years. 82 In the introduction to the write-up of the event, planner Andy Inch argues that since the Skeffington Report’s publication in 1969 public participation is an idea that has become “firmly established as a ‘good thing’ within the ideology of contemporary planning and yet, whose realisation fifty-years on arguably remains as elusive and problematic as ever.” 83 Planner Francesca Sartorio adds, there exists “a never-ending struggle for planning to engage with people.” 84 She reports that nobody much likes participation, and criticisms abound from all sides, including citizens, officers, and elected members — “and yet, we keep going.” Such contradictions proliferate throughout the planning system. For instance, the irony about an event to reflect on the state of public participation over a half century, is that not many people were able to participate. Having not signed up in time after being notified of the event indirectly and belatedly by word of mouth (it wasn’t widely advertised), I was unable to take part in this discussion because of room capacity limits. There was no space for more than thirty people, the organiser informed via email. This is one example of how the spaces of participation are structurally limited spaces, and demonstrative of the subtleties of closeness and openness of the invitations to participate.

The conclusions of the 2019 London event echoed similar ones reached at the UK and Ireland Planning Research Conference held in Sheffield in September 2018. The roundtable discussions reflecting on 50 years of public participation found that it is “older but not wiser”, unable to overcome “a constant ‘crisis’ of participation [despite] repeated attempts to ‘fix’ it.” 85 David Lock put it even more starkly in the October 2018 issue of Town and Country Planning commenting on the state of public participation following the Skeffington Report, “we have gone backwards since then.” 86

The gap between the promise and practice of public participation remains large, the latter never really living up to Skeffington’s hopes. Various models and forms of participation would come about but some of the problems identified mid-century about planning’s failure(s) would remain present to this day. The rhetoric of participation often eclipses the actual practice of it. Sartorio notes, of the Skeffington Report in particular, successive governments since 1969 have not studied how to actually do participation. 87 She observes that the implementation and adoption of the recommendations proposed by the Skeffington Report have never been reviewed, not in the 90s under New Labour when audits and appraisals were introduced across all areas of public policy and not in the 2010s under the Conservative-led coalition when localism became de rigueur. In Sartorio’s view, 1969 and 2011, two historical moments meant to open up government, were perhaps not that open after all. Participation as a concept has been embedded in both planning and popular culture—there is an expectation of the right to have a say—but its actual practice is fragmented, dispersed, inconsistent, confusing, routine and/or formulaic.

Londoners need to play more of a role in shaping decisions on local planning, development and regeneration. […] Public trust in developers and local authorities proposing new developments is very low, and too many people feel that public engagement is tokenistic or mechanistic and one way: done to them but not done with them. If people think that new engagement is more of the same, it may reduce trust even more.
Centre for London, Public Planning – a Manifesto for London

In March 2021, the Centre for London published Public Planning – a Manifesto for London, which set out what the next Mayor of London could do to strengthen public engagement in planning and get Londoners more involved in shaping the way the city is built and managed. 88 It was developed by Collective Community Action (CCA), a network that brings together citizens, consultants, educators and built environment professionals, and involved an advisory group that included people from community groups, local government, architectural practices, developers and academia. The manifesto contains familiar language and a familiar ask: to overhaul participation.

The manifesto centralised the London Plan for public and community participation and outlined principles for involving Londoners in planning. While it admits that “London is already doing well with engagement in some respects: it has a vital and engaged civil society, boroughs often have good connections with their citizens, and the city has become a centre for innovation in new, often digital, methods of engagement. Mayoral initiatives like estate ballots and the Talk London engagement platform have worked well, as has neighbourhood planning in some parts of the city;” it concedes that “we need to go much further.” It advocates for the London Plan’s potential to lead effective community involvement and in doing so create a better city and gives advice to the next Mayor of London on how to go about doing it. Yet, the most telling part of the quote is the worry of “more of the same.” The manifesto carries a similar theme from the 60s which connects planning the changes the city needs with calls for the overhaul of public participation to get it done. Ironically, the manifesto is “more of the same” in 2021 as in 1969.

According to planner Yasminah Beebeejaun, participation and inclusion are contentious in “an increasingly market-dominated planning regime where people often seem to be offered more and more opportunity to participate in less and less meaningful decisions.” 89 Since public participation became institutionalised in the 60s, the planning profession has not been able to shorten the distance between intent and execution. The same case for better public involvement made in the 60s, was remade in the 90s and 2000s, and is still being made now. 90 In the document Towards a new London Plan by Green Party London Assembly member Siân Berry, there is imperative that “no residents [are] excluded from involvement in making plans for the area.” The UK was a pioneer of the concept of public participation from a governance standpoint and implemented it within policy and decision-making processes, decades later manifested as a statutory obligation to ‘consult’ in order to exercise citizens’ democratic right to a say. 91 The need for better involvement has been agreed upon since the 60s but the practice of participation in meaningful or critical ways remains outstanding and an area of general public discontent and distrust. According to Sartorio, today, “Arnstein’s [1969] ladder [of participation] continues to be used as a litmus test for any and every participation process.” 92

There is no Skeffington Report equivalent today, nothing to reflect the shift in Londoners involvement in planning through resistive, creative or legalistic ways earlier noted. Despite the flurry of policies and publications in 2000-2010 on the need to consult the public, there has been no dedicated guidance on how to go about it with the London Plan, nor thereafter a study on whether consultation is still the right framing when expectations and priorities of involvement have changed to centre on co-creation and direct action. Current guidance relies on a landmark document that hasn’t been critically explored and has an outdated framework. For example, because the Skeffington Report focused on ‘the public’ (people) and planners, assuming development would be public-sector led, participation consultant Jeff Bishop notes, it did not account for a third party; private developers. 93 It did not anticipate the role and power the property industry would come to hold in planning and had no consideration of developers’ involvement in swaying public discourse. It did not make room for the third leg of what contemporary planners consider to be, “the triangular relationship between people, plans, and property” that is “at the heart of the experience of (and frustrations with) participation over the years.” 94

That there’s been great emphasis on public participation but no progress on how to go about it, has resonance in the London Plan because much of the inertia surrounding public participation directly affects the way it’s been approached and received. The London Plan is an outcome of a history of public participation in London planning that is marked by a legacy the city can’t quite shake which does not reflect contemporary realities or specificities of who participates and how. Authorities and proponents of the London Plan imagine public participation in one way, a quantitative increase in opportunities for people to participate in planning, while activists imagine it in another, as qualitative engagement that, according to the Centre for London’s manifesto, is “informed, early, sustained, diverse, transparent and supported.” 95 While there may be a broad buy-in on the London Plan being a plan for all Londoners, the complexity and contradictions of participating, whereby the parameters, goal posts, and terms of engagement are not always clear, instead point to a gap between rhetoric and practice of who may/should have a say versus who can/does.

The key historical moments discussed above show how the goals and forms of engagement have shifted in the plan-making process but what has persisted is a struggle between rhetoric and practice. The anniversaries of Abercrombie and Skeffington brought to light what Sartorio deems the inherent tensions and contradictions of participating in planning. Sartorio points out, Skeffington and the Committee came under criticism for the lack of class, gender and racial diversity, calling into question their authority on widening participation given their 26-person membership was made up of upper middle class, older white men. A recurring theme of the industry reflections is that the planning profession has a conflicted relationship with participation. In one respect, public participation has become an accepted necessity, but in another, it is also associated with tired resignation. Participation is a begrudged bedfellow of planning with broad agreement on the need to do it yet widespread dissatisfaction of the state and nature of it, a dynamic that is actively at work in the London Plan 2021.

After enduring the difficulties and obstacles to participate in shaping the draft, Just Space only achieved, by their account, “some small gains in wording.” That is arguably a lot of effort for little return. Then again, a one-word change can sometimes be extremely consequential. London First, supported by other developer representors, succeeded to change ‘Good Growth policies’ in the draft into ‘Good Growth objectives’ in the final, citing the first phrasing as restrictive “because policies would incumber the legal framework for decision making.” 96 Interpreted plainly, meeting regulations would slow down planning applications and jeopardise a pro-growth agenda. Good growth, in the way that Khan has defined as ‘inclusive growth’ (building inclusive communities), thus, becomes aspirational. A policy has legislative and legal force. An objective (aspiration) does not. Like Statements of Community Involvement, there are no means to invoke and enforce an aspiration. So, even if Just Space managed to influence the wording of the Good Growth policies in some way, the gains nonetheless have little weight. Such as amending GC1F of the draft plan to add ‘people with protected characteristics’ into the list of Londoners for whom Good Growth should include.

In a handbook produced by London Tenants Federation, Loretta Lees, Just Space and Southwark Notes Archives Group on how to fight against gentrification of council estates, the authors describe consultation as both a con and a game, in which, “in practice, ‘consultation’ is rarely a place where communities get to decide,” yet is a game they must sometimes play to negotiate some power in say. 97 Participating in consultation, in their regard, is often ‘time-consuming’ and ‘frustrating’ and builds ‘phony agreement’ in order to ‘pretend’ the community is behind the regeneration. They equate decision-making in ‘urban regeneration’ to be as top-down (the council or developer making decisions for council estate residents) as it was during the ‘slum’ clearances after World War II. Yet, they continue to participate anyway. LTF and Just Space especially put in the work on the possibility it may throw sand into the planning machinery and force some parts to be replaced, if not the whole system.

Why Public Participation at All?

If it’s a never-ending struggle to have a say, if it’s costly to participate, if the outcomes only yield minor gains, then why public participation at all? According to geographer Margo Huxley, “by and large, most of the literature on public participation in planning takes ‘participation’ as a given ideal and aim, in which, to greater or lesser degrees, residents as citizens have a right and a duty to take active part in decisions affecting the environment of their local areas. […] There is a common thread that sees participation as a solution to a set of problems, an answer to particular forms of questions about democratic political and social life. […] Participation has become a central theme of planning theory, even while it is constantly challenged and subverted in practice.” 98

Huxley has been critical of this centralising that is not sensitive to the histories and specificities of the concept of participation. Huxley cites as an example, Arnstein’s ladder of participation was a response to a specific US context of the politically turbulent 1960s but which can be traced back much further to US history and politics around local self-determination and local/regional self-government, specifically republicanism. The ladder is a ‘tamed’ solution to problems of lack of power and resources, rather than the radical solutions of communalism, local socialism, resistance or revolution. 99 The Skeffington Report can also be seen as a response to the general upheaval of the 1960s and demands for community involvement in local planning issues. However, in contrast, Huxley differentiates, in the Skeffington Report, “participation is much more narrowly conceived as taking place within the centralised, national regulatory framework of land use and spatial planning set in place by the Town and Country Planning Act 1947.” 100

Huxley argues that the form of participation advocated by Skeffington was a managed form of ‘consultation’ on Arnstein’s ladder, the goal being to increase the efficiency of the planning system. Whereas the conceptualisation of participation by Arnstein, who was an urban activist, was part of “oppositional, grassroots calls for a limited form of citizen power,” the conceptualisation of participation by Skeffington was part of “attempts to install participation within a mundane and specific regulatory framework.” 101 In Huxley’s analysis, Arnstein’s model has an aspirational quality for citizen power to be a ‘truth’ and aim of planning and sees participation as a way “to change planning more fundamentally,” Skeffington’s model was more pragmatic and sees participation “as a way of making local authority planning more effective.” 102 Thus, for Huxley, “the problems that participation is seen to provide a solution to are historically and politically different” between the two models. “Nevertheless, despite these differences, an understanding of participation as local self-determination came to pervade British planning education and certain aspirations for practice.” 103

This conflation plays out with the London Plan and the conflicting ways in which different groups frame participation. Just Space, in the way they approach participation as enabling citizen and community empowerment, is aligned with Arnstein’s aspiration for fundamental change. In contrast, the GLA, in the way they approach participation as fulfilling the Mayor’s statutory duty to consult, is more aligned with Skeffington’s pragmatism. Both place importance on participation to locally determine the future of London as articulated in/through the London Plan, yet have very different starting and ending points.

It’s an important distinction and points to a tension that, according to Huxley in her overall criticism of participation in planning, “has rarely been interrogated in a detailed, critical, historical way.” 104 Of participation, Huxley asks questions that have elided theorists and practitioners’ attention: “What objects were made visible in the problem and solution of participation? What were the questions to which participation was invoked as an answer? And what particular historical political and communal discourses of participation inflect contemporary political debates? […] What discourses did it enter into and enable in order to become ‘sayable’ and taken for granted in different conditions? What solutions did it provide and for whom? What configurations of power did it reinforce or undermine? What tensions and contradictions did it resolve or engender?” 105

From the outset, as stipulated in the 1999 GLA Act, participation was embedded into the process of the London Plan’s development journey from draft to final publication, an essential stepping stone toward its formal adoption as policy. But while the conditions for and contexts of participation in London planning have been shown above to change over decades, the taken-for-granted assumptions about participation as being good and necessary, have not. Good for whom, good how? Needed when, where? There is a lack of specificities about the problems for which participation in the London Plan is the solution, which Skeffington’s model of participation could not have anticipated. What is the problem to which participation in the London Plan now answers? Based on the Planning for London Programme established in 2022 a year after the publication of the London Plan 2021, it’s not clear. The programme was set up to start early preparations for a future London Plan review after this Mayoral term and support engagement ahead of a future London Plan. The latter is an attempt to address widespread appeal for greater involvement of Londoners and early, meaningful and high-quality engagement in the plan-making stage. One stated objective is: 106

Increasing participation in planning: Planning can have an enormous impact on people’s lives, and yet has too often been conducted in a way that many find difficult to engage with. While technical detail and documents are necessary in the development of plans, there are fundamental issues at play that could and should be brought to life. The programme offers an opportunity to develop more engaging ways of communicating the issues planners navigate every day. Doing so could also build a foundation for future engagement work, with an ultimate aim of driving greater and more diverse participation in planning at all levels.
Mayor of London, MD2992 Planning for London Programme

It’s a similar position on participation that the GLA has taken elsewhere. For instance, the Future of Participation events programme, running in July 2023 at London’s City Hall, community locations and online, “will challenge how we think about and ‘do’ community participation.” 107 Their focus is on how to do participation—ways to increase it, make it better and more effective—and not on the why of it.

Publics, Participation and Power: the Problem of Communicative Planning

To better understand the struggles of participation, and to put them in a larger theoretical context, we now turn to the problem of participation in planning that Huxley has identified within the field of planning theory. She criticises the way in which participation has been framed by planners and theorists as a consensus-oriented exercise, and the way in which scholars have taken to describing and theorising urban and regional planning or located policymaking as communication-based action. 108 109 110 What urban planner Patsy Healey has called the ‘communicative turn’ in planning in recent decades, it is commonly billed as ‘communicative planning,’ or ‘collaborative planning’ per planner Neil Harris. 111 112 The theory gained prominence in the 1990s and is based on Habermas’ concept of the bourgeoisie public sphere and his related notion of communicative action—action coordinated through intersubjective understanding arrived at by way of rational debate. Via ‘the speech act,’ participants in planning can come to a consensus (agreement) about plans—planning practice as a form of, and forum for, deliberative (discursive) democracy, or in Healey’s terms, “planning through debate.” 113

the idea of the planner, and the practice of planning, as facilitating communicative interchanges between interested parties, whether stakeholders or the community at large, over matters of common concern, and are not necessarily confined to issues of the development and land use. […] The importance of communicative or collaborative planning is seen to rest in its ability to contribute to better debate, discussion, and deliberation about shared futures.
Communicative Turn definition, Huxley and Yiftachel, ‘New Paradigm or Old Myopia?’

In some versions of communicative planning, Huxley and political geographer Oren Yiftachel note, “communicative action is seen as fostering community empowerment and recognition of difference, diversity, and disadvantage that has implications for the development of discursive local democracy beyond the confines of specific issues.” 114 Drawing on Habermasian and pragmatist perspectives, communicative action theory envisions “discursive communities shaping their futures through democratic communicative practice.” 115 According to Huxley, “Habermas sees communicative action as connected to the lifeworld,” arenas of life such as the everyday which in his view fall outside of formal systems and institutions, “and free from the media of money and power.” 116 (emphasis original) It is “an arena for social relations distinct from the state, the economy, and the domestic sphere,” in which informal public discourse could, if not directly make, then inform decisions toward a ‘common good.’ 117

Communicative planners as such conceive of “ideal speech situations in which power and inequality can be put aside” so that planning decisions could be agreed upon through open and transparent debate. 118 Planner Mark Purcell, who is also a geographer and political theorist, further details that the ‘ideal speech situation,’ per Habermas, “requires that all participants transparently articulate what they really believe; that power differences between participants be neutralised for the purposes of deliberation; that all participants affected by the decision participate in it meaningfully; that everyone has an equal chance to participate in deliberation; that each must be willing to empathise with the arguments of others; and that everyone aim to achieve the good of all rather than their particular self-interest.” 119 These conditions form the basis for Habermas’ ‘undistorted communication,’ “which allows participants to forge decisions fairly and honestly without domination or coercion.” 120

For Huxley and Yiftachel, communicative planning scholars’ focus on, and their Habermasian framing of, communication, present a number of problems. Communicative theory “gloss[es] over contextual understandings of power and material interests, of discourse and the constraints of the taken-for-grantedness of the world. […] [T]he communicative school asks questions generally about how (is current practice conducted) and not about what (its effects are) or why (it is like it is),” absent of “the need to be reflexively and critically aware of the power contexts and effects of discourses.” 121 They highlight “a tendency in some of the communicative literature to privilege communication at the expense of its wider social and economic contexts” and “to see planning as a mainly procedural field of activity, one degree away from the political and economic realities of power and inequality in urban and regional development.” 122 In their view, “the new planning and planners seem to share culturally, historically, and geographically grounded sets of assumptions and perspectives with those of the old rationalist approaches. Part of this problem derives from the original Habermasian project, and Habermas has been taken to task by feminists and writers on difference, for the genderless and colorblind notion of ‘the public’ and the abstraction of the processes he propounds.” 123

Huxley in particular, invoking feminist theorist Nancy Fraser, highlights “[Habermas’] failure to acknowledge social, economic, and cultural inequalities that block inclusion in, and transformation of, the masculinist, property-based, and elitist public sphere,” and reminds us that “[s]ocial reproduction, non-state institutions such as the family, community organizations, the church, and the professions have been bound up in relations of power (including patriarchal power) and money and with the state since the rise of modernity. […] The public sphere cannot be cordoned off from the power relations of the system or the domestic sphere.” 124 The social and the state cannot be neatly separated from each other. “The bracketing of interests, power, and inequality,” Huxley argues, is inattentive to where and when there may be overlaps between the two. Moreover, Huxley puts emphasis on the close relationship between planning and the state, calling attention to “the unequal and involuntary nature of many planning forums (that is, people only participate when their interests are directly threatened), and the possibility that planners are not able to act as disinterested mediators, exactly by virtue of their roles in relation to the state.” 125 Further,

a conception of the bourgeois liberal public sphere inherently replicates the gender, race, economic, and other inequalities of society, and particularly, of course, relations of power. Even if planners introduce the most inclusive, gender-sensitive, multi-cultural participatory processes, the individuals and groups presenting themselves in these processes are enmeshed in, and productive of, power and inequality.
Margo Huxley, ‘The Limits of Communicative Planning’

Like Huxley, Purcell warns “we should be very wary of Habermas’ approach,” which presents ‘undistorted communication’ as the ‘ideal speech situation.’ 126 Highlighting the critique made by linguists, Purcell asserts that aiming at an ideal of undistorted communication is futile because “language and communication, the centrepiece of the communicative project, cannot be a neutral, fully shared, and undistorted medium. Rather language is always political; it is distorted by power, and those distortions establish hegemonic relations among participants. […] Practices of communicative action, because they seek to reduce communicative distortion and power, lead us away from a critical analysis of power in language. They therefore put us in danger of masking its operation.” 127 While some communicative planners do acknowledge the range of power differences existing in communication, however, the problem for Purcell is that communicative action sees power as something that can be neutralised and seeks to actively neutralise those differences for the purposes of deliberation. On the other hand, its critics see power as relational, rather than discrete and able to be set aside or contained. Purcell points out, drawing on the work of Huxley and others, “any active attempt to neutralise power through facilitation is itself an imposition of particular relations of power.” 128 The “ideal of a power-tamed deliberation” is not possible nor desirable. “Agreement is not a successful neutralisation of power,” according to Purcell, invoking political theorists Ernesto Laclau and Chantal Mouffe, because “conflict can only ever be masked, not transcended, even in the short term. 129

Aware of the shortcomings, some communicative planners try a different, Habermasian-light version. Selectively retaining his ideal of undistorted communication and power neutralisation, they mainly focus on ‘consensus building’ that aims to make all parties involved happy. Through ‘skillful management of dialogue, shared information, and education of the stakeholders,’ all participants come out with a win-win solution, Purcell summarises the argument of planning theorist Judith Innes. Her consensus-building model sees “various stakeholders work together to produce a creative new solution that is perceived by each group to benefit its self-interest; it may or may not benefit the common interest. The value added here is not, as in Habermas, that groups set aside their self-interest. It is rather that through deliberation participants invent new solutions they could not have imagined before engaging each other.” 130 For example, a development goes forward once developers get buy-in from weaker, disadvantaged groups and incorporate their concerns. But what this model doesn’t account for, and what Innes acknowledges goes untouched in her process, are the pre-existing power relations. 131

As such, Purcell argues, communication planning, whether Habermasian-full or Habermasian-light, insofar as it reinforces power and inequalities, is problematic, echoing Huxley and Yiftadel’s position. The collaborative, common-good approach tends to add to the political burden marginalized groups bear because disempowered groups must “overcome their disadvantage by proposing a course of action that is seen to be ineveryone’sbest interests, not just theirs. […] At best, the communicative ideal sits uneasily with social movements advocating for particular interests; at worst it systematically marginalizes them.” 132 Alternately, the consensus, everyone-wins approach, even while acknowledging self-interests, will always produce some bigger winners than others because of pre-existing power imbalances. The goal for Purcell is “not to develop, with Habermas, a priori processes to control, neutralise, or eliminate conflictual relations of power,” not to do away with frictions, differences and antagonisms in order to produce a seamless society, “it is instead to transform those relations.” 133

The London Plan, “the Process to Agreeing” and its ‘Danger’ to Democracy

The issues identified in Huxley’s outline of the limits of communicative planning, and raised by Huxley, Yiftachel, and Purcell in their criticisms of the communicative turn are salient to understanding the challenges of the London Plan’s form of participation. The common thread linking the changes in planning practice, outlined in the first half of this chapter, is the focus on communication and deliberation, on things that are sayable. Whether it’s some say, collective say, local say, or the right to a say, the emphasis remains on ‘say’. Especially since the 1990s, there have been efforts to increase the capacity and opportunity to have a say in the making of plans: to say it to planners, say it to each other, or say it to a multitude of others. It’s planning through saying, or in communicative parlance, planning through debate.

That tradition has been carried forward in the embrace of communicative planning both for the process of preparing the London Plan and within the policies themselves of the London Plan. In its framing of participation, I observe an overall emphasis on ‘say’ (speech), similar to Huxley’s analysis: “Debates take place within a framework that produces ‘participation’ as something that is ‘sayable’ as a solution to a diffuse set of problems […] within a discursive framework that situates participation as something which can be argued about—about which people are able to say different things,” and then, through rationality, come to an agreement. 134 The London Plan was originally framed in 2000 by Mayor Livingstone in Towards the London Plan precisely as such, as “the process to agreeing the plan.” 135

Since then, the process to agreeing, under the auspices of public consultation, has become GLA-wide policy practice, largely focused on collaboration, aligned with Healey’s idea of collaboration as the way to shape coherent places in ‘fragmented societies’.” 136 For example, they identify collaborative planning as “key to the delivery of London’s Opportunity Areas,” a major policy focus in the London Plan 2021 covering large-scale areas of development subject to mayoral strategic oversight. 137 ‘Policy SD1 Opportunity Areas’ stipulates that “the Mayor will support and provide leadership for the collaborative preparation and implementation of planning frameworks” and “ensure [they] are informed by public and stakeholder engagement and collaboration at an early stage and throughout their development.” 138 There is also a policy explicitly dedicated to collaboration in the plan, ‘Policy SD2 Collaboration in the Wider South East,’ such that coordination with partners outside London “will help to ensure mutual benefits.” 139 In ‘Policy SD10 Strategic and Local Regeneration,’ the Mayor advocates for ‘shared understanding’ and ‘shared vision’ requiring all stakeholders to operate in a collaborative way, i.e. come to agreement of a common good in everyone’s best interests: 140

All stakeholders, communities and individuals have a role to play in tackling poverty, disadvantage, inequality and the causes of deprivation, particularly in places where their impacts are acutely felt. […] In order to be effective in improving the lives of those most affected by inequality, regeneration initiatives must be undertaken in collaboration with local communities, involving a broad spectrum of groups, businesses and individuals, to develop a shared vision for the area. Successful regeneration requires all stakeholders to operate in a collaborative way, pooling resources and creating partnerships. There should be a shared understanding of how the regeneration area needs to change, and how that change will be secured, managed, embedded within and supported by the community. By taking an integrated, spatial approach to a wide range of issues, Development Plans and Opportunity Area Planning Frameworks have a key role to play in tackling inequalities and the causes of deprivation. It is important that these are developed through engagement with local communities.
Mayor of London, London Plan 2021, Policy SD10 Strategic and local regeneration

Be it consultation, collaboration and/or consensus-building, or another variation of the same communication-based theme, communicative planning is an active pursuit of the Mayor and the GLA and seen in a positive light. Problematically, as Huxley has pointed out about planning in this agreement-seeking way, there’s an assumed equality of communication as well as a non-acknowledgement of the power differential amongst participants. Use of the term ‘stakeholders’ over ‘citizens’ is particularly revealing of the influence of communicative planning language. She criticises, “widespread in the literature, [it] seems to imply some notion of strategic interests, yet there is little discussion of how individuals and groups can be induced to give up instrumental and strategic action toward securing their own aims in order to attain agreement.” 141 Arriving at a shared understanding and shared vision, or drawing out mutual benefits, as the GLA encourages, is a big ask of participants given the wide range of issues and competing interests.

In Purcell’s criticism of communicative planning, he alerts us to the specific danger of its co-option for the ‘neoliberal project,’ which seeks to establish the market and competition as universal interests, valuing them as necessary and common-sense in decision making. 142 However, neoliberalisation has a legitimacy problem arising from “the political instability it generates” relative to its four democracy deficits, discussed in Chapter 2: 1) the tension between social inequality and political equality; 2) the increasing control of capital over social life; 3) policy decisions are made by bodies unaccountable (at least in a meaningful way) to democratic citizens; and 4) cities cannot offer its citizens meaningful options. 143

In order to actively manage them, neoliberals work hard to associate their project with democracy, Purcell posits. They do so by criticising that “the Keynesian welfare state was undemocratic because decisions tended to be national, top-down, bureaucratic, and expert-driven,” and arguing instead that “their agenda of deregulation takes such decisions away from the state and its arbitrary, unchecked power, and hands them to individuals making free, rational decisions in an open market.” 144

As we saw in the sections above on Public Consultation and Consensus: Having Collective Say (2000s) and on Open Planning, Localism and the Neighbourhood (2010s), through “devolution of authority, from the national state to more local ones,” neoliberals “relocate [state] power to the market, which “allows places more power to shape decisions to their particular context. […] Neoliberals claimed they had freed communities from the tyranny of central state control and created a more democratic, ‘grassroots’ alternative.” 145 Purcell argues that “communicative planning offers an extremely attractive way for neoliberals to secure the democratic legitimacy they require, because it tends to reinforce the political-economic status quo while producing democratically legitimate decisions.” 146 He contends that “what the neoliberal project requires are decision-making practices that are widely accepted as ‘democratic’ but that do not (or cannot) fundamentally challenge existing relations of power,” and because communicative planning, insofar as it is rooted in communicative action which reinforces existing power relations rather than transforms them, is just such a decision-making practice. 147

Per Purcell’s argument, communicative planning lends legitimacy to the decisions made about the London Plan, which are deemed to have gone through an inclusive, democratic process of debate, at the same time that it suppresses the power relations and inequalities that led to ‘agreement’ on the best winning argument. Londoners are given the opportunity to ‘have your say,’ presented as a right and freedom of any Londoner to say something about the London Plan. However, those who accept the ‘open’ invitation to have your say, do so on very different and/or limited terms. “The terms on which a public is ‘open’ are crucial,” Kurt Iveson notes, quoting political scientist Carole Pateman, ‘access is not enough.’” 148 Despite Just Space’s expanded access to the process, for example, they are not on equal footing as others. Their input does not have the same power of persuasion as, say, BusinessLDN or local London authorities. Just Space must hyper-attend to certain elements of the public processes to gain equal footing. But at the other end, they also have a larger foothold in the proceedings, especially at the EIP, than other networks and community groups. For these others, getting to have a say isn’t a given. For Just Space, they have fought hard to be given that opportunity to be present at every EIP session.

In another example, during one EIP hearing, two activists who showed up in the gallery with protest signs were effectively silenced when they attempted to vocalise their discontent with the direction of the discussion. The proceeding was temporarily halted, the microphones turned off, while City Hall security escorted the deemed-disruptors outside the room and out of hearing range, both figuratively and literally. Although billed as a ‘public’ hearing, only one type of public, in this instance an invited public such as Just Space, was being heard and allowed to make noise. The protestors had no such power. The power conferred to Just Space is implicitly conditional on their acceptance of the speaking rules of the hearing. Speaking out of turn, as those protestors did, risks expulsion from the space of participation and would threaten future speaking opportunities. Thus, the power to speak still rests with those who control the microphones in the City Hall room.

The power structures in place at that meeting determine what speech is listened to, signalling what Purcell refers to as the politics of ‘recognition’ and the unequal esteem granted to different groups. He notes, citing political theorist and social feminist Iris Marion Young, “the communicative model favours some social groups and not others.” 149 150 In a planning system that embraces neoliberal ideas about growth and focuses on development, developers, property owners and the like with same interests will almost always be included in decision-making processes. According to Purcell, they will be “systematically included,” the system “virtually never excludes them” because their knowledge is esteemed and needed to achieve capitalist goals. 151 So, even in attempts to include the widest number of people, as the GLA tries to do with seeking input into the London Plan, more weight would be given to some groups’ knowledge over others, and thus their arguments more likely to be accepted than others. Not everyone carries the “same epistemological privilege,” Purcell’s term, and therefore some will have greater systemic advantage and “force of the better argument.” 152 153

The danger of a perceived evenness or even-handedness of rational debate is that it masks the anger or rage or emotional effects that some marginalised groups must suppress to be taken seriously, to be seen as politely asking rather than demanding for the safeguard of their rights. As those protestors learned, shouting at a hearing is not allowed. There is an institutional calmness, a regulated silence, that pervades the session, even when contentious topics such as affordable housing, rough sleeping, and the threat to livelihoods are at issue. Shouting is for street protests where a megaphone is used instead of a microphone. Inside these permissible speaking rooms, acoustically designed for rather specific ways to communicate, speakers must attenuate their volume to legitimise their voices, lest they want to be perceived as irrational. What auditory power and range the megaphone may grant them to reach a wide audience, it must be checked at the meeting door in order to reach a special audience.

Then there are those, developers for instance, who do not have to raise their voice at all to be heard. They have the power to be quiet at a hearing because the conversation with them, usually one on one, has already happened elsewhere. What they have to say needs no further amplification because they have a direct line to official listeners. Their speech need not be mediated by a microphone nor megaphone. These are the uneven conditions that communicative planning fails to address and that mar public debates about the London Plan. Purcell argues that resistance to neoliberalisation requires “a democratic alternative not rooted in the liberal or deliberative tradition.” 154 Because communicative planning “cannot significantly transform existing power relations,” he posits it is not the best way to resist neoliberalism. 155 In fact, “such masking [of power] can be an extremely useful tool for neoliberal interests because underlying power relations can remain essentially unchallenged even as significant political legitimacy is conferred.” 156

We can see then how communicative planning of the London Plan gives the public process political legitimacy at the same time that it doesn’t really challenge the power inequalities, thus lending implicit support to the neoliberal growth argument that drives much of London’s development. While some groups have greater force (resources) to force their argument, others are compelled to accept the conclusion even when they disagree, as Just Space did when they called for rejecting the draft plan, in a letter sent to the London Assembly days before Members considered its formal adoption. 157

When their plea fell on deaf ears, Just Space turned to mitigation to ensure “damage limitation” of what they see as the “adverse impacts” of the approved London Plan, noted at the start of this chapter. 158 To paraphrase their view, the winning argument was not the better argument, simply this version of the London Plan is the one that “London is, in effect, stuck with … for a few years.” 159 Just Space’s participation, alongside the many community organisations they represent, served to support the Deputy Mayor Jules Pipe’s contention that “the new London Plan has been shaped extensively by Londoners and many stakeholders,” and that it was “formed and influenced and ultimately improved by a generous and very thorough engagement of everybody involved.” 160 Participation does not mean buy-in nor acceptance, but Pipe’s framing gives the impression that it does. Whereas Just Space was not able to achieve the fundamental change they sought through participation and collaboration, the GLA succeeded, through the same communicative model of planning, to push forward the Mayor’s Good Growth agenda and point to the ‘very thorough engagement’ as evidence of the democratic process, of deliberative democracy, at work.

Yet still, in that same letter to Jules Pipe warning of “urgent steps [needed] to reduce the negative impacts,” Just Space’s solution for mitigation is to call on the GLA “to collaborate with community groups in doing so.” 161 In this instance, it’s perplexing how morecollaboration would better serve Just Space when it didn’t in the first place. Finding common ground for the common good in a common-sense way, the goal of collaboration efforts, places significant emphasis on the commons toward Habermas’ ideal of the public sphere as what is shared and beneficial for and “open to all.” 162 But as discussed in Chapter 2, such a premise of imagined universality is troublesome. And in the case of planning for all, the Just Space example illustrates the danger of collaboration for a common purpose and agreement: their name and involvement get attached to a vision for the future of London with which they do not share and strongly disagree.

According to urban planner Vanessa Watson, planners work from a position of perceived neutrality and rationality, in conflict with issues that are contingent and situated. “There is no ‘neutral space’ outside of traditions [of enquiry] from which one can judge different and competing claims.” 163 There is a strong focus in planning on process rather than product, the means rather than the ends, but in contexts of deepening differences, the neglect of outcomes is of great concern. 164 She writes, “where societies are relatively homogeneous and stable, where stakeholders or groups see it as being in their own interests to collaborate and perhaps submerge differences, and where dialogue occurs in terms of the ‘right conditions’ (Innes, 2004) then consensus-based planning processes may well meet the expectations of proponents and participants.” 165 But as Watson points out, this is the exception, not the rule.

The right conditions, Habermas’ ideal of undistorted communication, are rare. Just Space’s dissatisfaction with the outcome of their participation illustrates Watson’s central argument that, in a world characterised by deepening social and economic differences and inequalities and by the aggressive promotion of neoliberal values by particular dominant nation-states, “deepening difference is increasingly putting into question the possibility that planning processes will produce decisions which are first, fully supported by all participating parties in open debate free of domination or manipulation, and second, that will (directly or indirectly) address and challenge bigger questions of growing social and material inequalities and environmental sustainability.” 166

More commonly, for Iris Marion Young (2000), “deliberation may do no more than reveal structural conflicts of interest that require to be addressed at a larger institutional or economic level.” 167 Drawing from feminist philosopher Donna Haraway’s (1991) conception of ‘situated knowledges’, Young argues that the task of deliberative democracy is not to seek agreement by all, but to seek “an ‘enlargement of thought’ that comes from considering the perspectives of many differently situated people. The aim […] is to arrive at new kinds of knowledge(s) or wisdom drawn from a range of situated perspectives.” 168 Making space for new kinds of knowledges is also what planner Yvonne Rydin advocates for in her re-examination of the role of knowledge in postmodern planning theory, constituting multiple epistemologies and recognising differences alongside specificities. 169 She sees knowledge as socially constructed and open to contestation and recognition, a way of thinking “allowing for planning to hear multiple voices in the name of democratic participation and empowerment but also arguing for specific spaces within planning to test out multiple knowledge claims.” 170

Yet, with communicative planning, hearing from multiple voices is not enough as it does more harm by flattening them. Watson underscores, the achievement of democratic deliberative processes is difficult, “in part because of the need to achieve collaboration with an increasingly divided and conflictual public and in part because growing inequalities, and identity differences and hybridities, open the way for the destructive operation of power.” 171 Just Space is empowered to contribute their situated knowledge to enlarge the perspectives of the London Plan, to make knowledge claims, but the process of agreement to do so risks co-opting and undermining their power.

Planners Judith Innes and David Booher responded to criticisms of communicative planning by positing that the key tensions highlighted should be seen as contradictions to be embraced because they are aspects of our complex world. 172 In addressing their critics, Innes and Booher’s solution for the shortcomings about dialogue as a planning model is to advocate for more dialogue. 173 But it remains unclear to me how such complexity can be productively engaged with in a public planning system that rests on a simplified, uncritical notion of public, nor how more dialogue can be helpful amid the current struggle to have a say. More dialogue or greater collaboration, as per Just Space’s solution, would ultimately be to the benefit of the neoliberal project, strengthening the legitimacy of capitalist decisions while reproducing the very communication unevenness that Just Space is fighting against. Rather, Innes and Booher’s other recommendation holds greater promise for democracy in plan-making, in which they advocate for more research into the role of communication in planning to shed light on, and gain a nuanced understanding of, how communication has power. 174

Conclusion

The act of saying, “have your say,” and the act of actually “having your say” are at odds with each other. The neatness of the former suppresses the complexities of the later. It’s uncomplicated for policymakers to ask for public opinion. It’s much more complicated to follow along a years-long process, attend middle of the day meetings, navigate tranches of documents, listen to dozens of speeches, read thousands of words, and write hundreds more. ‘Have your say’ flattens the experience—and difficulties—of doing so, and understates the attention needed and energy expended to sustain the effort to say your say. To effectively go through the processes of draft consultation and public examination requires patience and persistence in addition to holding some degree of technical planning knowledge and/or familiarity with its writing practices. Criticisms from participants range from dissatisfaction with the accessibility of meeting locations to the format of the draft document. For some, there was a sense of frustration and/or futility.

Participating in London planning is complex. In 1943, there was arguably broader public awareness of planning but narrower say. Planners supposedly knew best therefore the say in planning was limited to their expertise. Londoners were widely informed of their plans, participation mediated through publicity. Ever since the Skeffington Report in the 1960s that sought to involve more people in the planning process, there has consistently been a demand for greater inclusion and more democratic forms of participation. Better public participation is not a new rallying cry. It is a drumbeat that has been repeated for decades, and more forcefully sounded in recent years. The arc of public involvement has gone from passive to active to consultative, and lately, activist, changing from a practice of informing ‘the public’ to different publics getting directly involved. By 2017, the publication year of Mayor Khan’s draft London Plan, the paradigm has flipped: narrower awareness, broader say.

The call for public participation in shaping London where “more people have a say” and there are “opportunities for the public to engage and help shape its development,” as Jules Pipe had described, sounds simple and open. But, relative to the history of public participation in London planning, there are frictions that London Plan participants encounter in taking part in co-shaping the city’s future. The open invitation for all to have a say in the London Plan is difficult to reconcile with the design of participation—a judicial, legalistic process that values text over speech yet asks for respondent speakers to get closer to the microphone to be better heard. Such contradictions hamper meaningful engagement, which the network of community organisation Just Space has defined as the processes and activities to enable some communities or individuals to fully participate on an equal basis with others. Just Space has been critical of developers gaming the system, but they too have had to ‘play the game,’ and have succeeded in one aspect, through tactics such as hot-seating and microphone-sharing, to raise a community-based voice in the London Plan. Yet, to what end? For some small gains in wording?

In a planning system where, structural barriers determine who speaks, when and how, having a say in London’s development is not a free, open debate. Having more opportunities to have a say won’t matter if what’s being said doesn’t matter. The framework of participation in the London Plan, in its present concept and practice as consultation, hasn’t caught up to the larger changes in the planning system, nor does it account for the national and local politics that challenge it and limit what can be changed in the plan. There has been a lack of progress in conceptual as well as practical development of public participation in the plan beyond consultation. It has not been suitably sensitive to the complexities of getting involved in a flawed system weighted by political pressures and differing local-regional agendas.

Given the challenges GLA organisers face to consult and the difficulties expressed and experienced by participants on being consulted, it raises a number of other questions. What is the role of public consultation of the London Plan? Is meaningful consultation possible when the Mayor has the option, ultimately, to reject the recommendations of the EIP Panel and also to ignore consultees’ rejection of the plan? In this context, what is the use of consulting Londoners? The answer is not much if development of participation continues to stall and never moves past rhetoric, not while the imagination of all Londoners participating persists. Even when some manage to participate, after all the labour, does it really make a difference? It’s a struggle to say. Given the complexity, the goal, then, isn’t to simply make participation better but to critically ask why do participation at all? Why this particular form of participation? Communicative planning, hinging on collaboration and the ideals of undistorted communication and common good in the Habermasian public sphere, may not be the right solution without a more nuanced understanding of the role of communication in the London Plan.

The next chapter, Public Relations and Publicity, expands upon this chapter’s discussion about the neoliberal public, showing how the conceptualisation of the public sphere as freedom of communication in an open space of competition has led to a marketing approach to telling and selling the story of London to would-be buyers.

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