Looking back, after a summer break from thinking about the EiP, our initial optimism about the scope for productive debate about crucial strategic aspects of the draft Plan seems misplaced. Maybe we will be somewhat reassured when the Panel’s report becomes available in the next couple of months. Whatever the outcome, there are evident problems with the process, the nature of political interaction, and about timescales within which any substantially positive changes could be expected. But it is also the case that as newcomers to this part of the London planning process, we initially failed to appreciate how constrained the EiP contributions would be from authorities and other stakeholders with seemingly substantial stakes in its conclusions.

Our initial optimism was grounded in the last (FALP) Inspector’s report – with its explicit criticism of the deliverability of London housing targets within the established spatial horizons of Mayoral Plans – and the transparent failure of the ‘New London Plan’ to pay any attention to this reliable advice. During the EiP, from day one on, we and some other independent participants did vigorously pursue this issue, with questions that were actively addressed by the Panel. Still, it was not more widely taken up by others in more constrained positions.

As we see it now:

• in the absence of political representation – except in textual responses to some specific Panel questions – GLA officials could do nothing but protect the position set out in the draft Plan;
• with a few notable exceptions, local authorities saw no benefit in fighting what they judged unlikely to be changed, while those from the Wider South East took little part on the big issues; and
• although making a written submission, and corresponding with the Mayor, the central government simply opted out of active participation.

Once these positions were clear, it was no surprise that contributions on housing matters tended to focus almost wholly on the familiar technical issue of whether identified site ‘capacity’ within London could meet projections of housing ‘need,’ in line with the relevant (though out of date) NPPF. The complete artificiality of this accounting comparison – especially given the clearly fudged close match between identified capacity and need – could not be hidden. And the real-world questions (raised by the last EiP Inspectors) about whether the housing delivery gap can be substantially narrowed, and the consequences of failure both for living standards in the region and for central government penalties on boroughs failing to meet the Plan’s unrealistic targets, remained unanswered.

This real failure in constructive engagement on genuinely strategic issues highlights the (now) obvious fact that an Examination in Public cannot be the place to address fundamental policy, political, or analytical questions. These need to be determined well before an effective Plan can be put in place. A sub-point, clarified on day 1 of the EiP, is that – whatever the bureaucratic requirements – a meaningful ‘Integrated Impact Assessment’ of the proposed Plan needs to be undertaken, published, and discussed during the period of Plan preparation. This, in turn, requires a clearly distinguishable independent (analytic/evidence-based) element alongside statements of prior Mayoral policy commitments, together with responses to the analyses. By contrast, what the current system gave us was just a confusing array of many matrices interspersed with anonymously ‘preferred’ options.

The much broader failure to secure real debate about the direction of the Plan, at appropriate stages in its development, seems to reflect two pervasive political problems. One of these is the current gulf between a widely recognised housing supply crisis and realistic assessments of the homes that are deliverable within the relevant timescale. This cannot be addressed without radical shifts in policy that neither central, local, or London government are willing to contemplate. Instead, what we get are statements of housing targets from both Whitehall and City Hall that even their authors cannot believe. That doesn’t stop them from blaming each other, nor does it stop local authorities who have little capacity either to reply or the speed development in the current framework, ending up carrying the can.

Another obvious political problem lies with a directly elected Mayoral system, with weak institutional support (politically or in the media), which encourages short-termism and the evasion of politically difficult challenges. This reflects both timescale issues concerning Plan making/implementation and the extraordinarily low political profile accorded to this central function of the devolved London authority.

The experience so far is that Strategic London Plans take four years to prepare and (according to this Mayor) would take another 3 years if they were to be significantly revised. That is clearly much faster than with the old London Development Plans. But since the proof of the pudding is in the eating (and statistical evidence of outcomes), it still means that no significant assessment of impact can be made until the close of a Mayor’s second term. Indeed, even that may be too early, since the implementation of strategic initiatives (such as Cross Rail in the 2004 Plan or the ‘small sites’ initiative on which hopes are pinned in the new one) always takes a lot longer than initially suggested. Retrospective assessments of evidence on the impacts of the earlier Mayoral Plans should be seen as a critical element in developing better policies. But this has so far never been the case, nor has any assessment been demanded by the Assembly. One reason for this lack of interest in outcomes is that the time lags involved mean that such reviews cannot be an effective way of holding Mayors to account.

It would be entirely feasible, however, to feed lessons from such assessments into a debate about the credibility of Mayoral manifestos. Though, so far, candidates’ positions on key strategic policy directions (such as the ‘compact city’ strategy) have not figured at all significantly in election campaigns. To take one example: in 2016, all candidates came to adopt the same defensive stance on the London Green Belt –basically closing down debate.

Co-operation, at all three spatial levels, is one casualty of this structural short-termism. But it is a direction in which some real progress might be made toward unlocking the other dysfunctional dimensions of Greater London planning. For that to work, however – via formal and practical recognition of real duty to co-operate across authorities in the Wider South East – requires much more focused debate in the run-up to the next Mayoral election as to how candidates would provide leadership in this process.