The Draft London Plan – Insights into civil society and public engagement. (4)

It has been almost a month since I submitted my dissertation for my MA in Environment, Politics, and Globalisation at King’s College London. I thought it would be useful for both myself and anyone interested out there to unpack and explore the many topics I tried to tie together in my paper here on this platform. This is the fourth instalment of four.

Dissensus in the Post-Political City

The recent political climate has prompted scholars to reexamine the current state of democracy and the value of public participation in policy decision-making. Rancière (2010) and Swyngedouw (2011) argue that the concept of democracy entails the inclusion of all, in particular those outside of the ruling political class. In other words, democracy represents a political egalitarianism that acknowledges individual agency and empowers the subaltern to participate in politics. Therefore, it inevitably and invariably encourages dissensus and conflict precisely because of this act of indiscriminate inclusion. However, they argue, the post-war desire for pacification has led to a growing emphasis on consensus building, which ultimately acts against the very idea of democracy. Politics are reduced to policing, and as a result, the force of resistance within the governed remains largely repressed, barring occasional outbursts of civil unrest (Rancière, 2010; Wilson and Swyngedouw, 2014). The increasingly muted civil society becomes emblematic of the post-political city.

Rancière’s conceptualisation of the governing/ governed echoes Foucault, that power is embedded not only within institutionalised bodies but also within social relations and biophysical forms. The police represents ‘all the activities which create order by distributing places, names, functions’ (Rancière, 1994: 173). In other words, it instigates the division of society into specific functions and spaces. It is this division of society that has been argued to erode individual political power and democratic rights by eliminating conflicts through the pursuit of consensus. 

Choice and Consensus

Consensual decision making has become the norm in participatory processes such as the public consultation. Debates surrounding public participation have highlighted concerns around unjust processes that result in policy outcomes that reflect the interests of not the community members but of rich developers and politicians. This echoes the post-political phenomenon of reductionist politics with choices given to the public carefully weighed and designed. As Papandreou (2006) wrote in the International Herald Tribune, “Democracy is less credible if the choices on the electoral ballot are not determined by truly democratic means.” Then, to what extent are consensus manufactured and manipulated? To what extent is choice an illusion in political debates? Planners and scholars Bloomfield et al (2001) have argued that it is unrealistic to place consensus reaching as the aim of such public participatory processes, as the notion of consensus can produce ‘a false sense of closure and the illusion of stability’. But isn’t this what politicians want?

Let’s revisit this question after looking at the London Plan consultation.

‘A City for All Londoners’

As I have discussed in the previous instalments, civil society is complex, heterogeneous, and dynamic. Aspirations, agencies, and political will differ greatly from one actor to another. To create a city for all Londoners using a truly democratic method requires each and every member’s interests to be considered, and a collective vision should be preferred to a predetermined option. However, the worries of post-politicisation ring true as the public sphere had little means to effectively contribute to decision making. It is apparent for the community network that local communities have had to overcome many hurdles to achieve arguably little in shaping this Plan under the ironic tagline, ‘A City for All Londoners’. ‘Who are the Londoners the Mayor stands for?’ they asked. To answer that, I considered means of knowledge production and self expression. In the case of the London Plan, it was clear that divergent opinions and conflicting knowledges were considered, but ultimately a singular document was produced, so are certain knowledges superior over others, and why?

Knowledge, and modes of knowledge production and reproduction have been guiding political action and discourse in the West for centuries. In differentiating between ways of knowing, reality formation, and political imagining, Ezrahi (2004: 256) argues that the close relationship between science and politics stemmed from the desire for a ‘context-free knowledge’. Whilst she continues to argue that science could be considered abstract and anachronistic in contemporary politics, localised scientific knowledge is still pertinent to policymaking, especially in the making of the London Plan. Much emphasis was given to the Plan’s evidence base, by which the GLA meant scientific evidence that supports policy decisions. Even during the period of sifting through consultation responses and reconsidering policy targets, the London Plan team placed more value on responses that were backed by relevant scientific research to ensure objectivity. 

Objectivity, in its absolute sense, is however fundamentally impossible to achieve. Jasanoff’s (1990) seminal piece on science and policymaking argues that the rise of regulatory science simply reflects the prevailing socio-political paradigm of the time. The co-production of such paradigm and subsequent scientific movements shows a circularity that it is impossible to define an absolute objectivity in assessing scientific claims that is detached from social norms (Kuhn, 1962). Perceived objectivity is seen to legitimise policies and instil public trust in the decision making process, however the bias towards scientific claims and against ‘opinions and assumptions’ often arising from community or grassroot groups discounts a significant part of civil society who have no other means of understanding their surroundings but through their own lived experience. In the struggle of finding the right verbs, nouns, adjectives, and numbers to describe one’s living conditions and political outlook, responding to a public consultation can be, and often is far more complex and emotional than simply voicing one’s opinion into the ether. To reduce a lengthy and laborious process into a single policy document is therefore a gross misrepresentation of the sacrifices made on the basis of reaching consensus. 


I see the cost of consensus reaching reflected on two levels of policymaking: the current political infrastructure and the processes we use to make policy decisions. To tackle the inequitable methodologies, one doesn’t need to look far for inspiration. In an event earlier this year named aptly ‘Do not consult: Co-creation in Plan making‘, representatives from local planning authorities, community groups, and urban designers shared their alternative ways of public engagement to bypass the stigma of consultations and elicit genuine interest and contributions towards planning decisions. Engagement methodologies should be tailored to the local community’s demography and political stance, which in return create a more egalitarian and engaging environment for participation. It is important to recognise a one-size-fits-all approach has never been adequate, and in light of the trend towards decentralisation and devolution in politics, the local scale of policymaking has to be strengthened and supported by central government in the form of public funding but also equally and more importantly, trust and autonomy. This requires reform on the higher level, where political infrastructures are transformed to support actions on a finer grain, and more flexibility for policy decisions. The reliance on consensus needs to shift towards a multi-headed approach towards community engagement, and policy outcomes that allow community members to take ownership of development and management. In other words, The many facets of civil society need to be reflected in the policies that govern them, and appreciated for its diversity rather than reduced to a singular, unrepresentative policy vision.


The Draft London Plan – Insights into civil society and public engagement. (2)

It has been almost a month since I submitted my dissertation for my MA in Environment, Politics, and Globalisation at King’s College London. I thought it would be useful for both myself and anyone interested out there to unpack and explore the many topics I tried to tie together in my paper here on this platform. This is the second instalment of four.

How to Consult?

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Under the Public Service (Social Value) Act 2012, public bodies are now required to ‘have regard to environmental, social, and environmental well-being in connection to public services’, and that they should consult or find other ways to inform the public of policy change. This is supplemented by a set of consultation principles which act as a guidance to how consultations should be held (Gov UK, 2018). Another set of commonly cited principles derived from a legal challenge — the Gunning Principles — also provide some basic direction for consultations (Sheldon, 2012). Both sets of principles aim to deliver a fair and trusted consultation which allows effective and meaningful engagement at the right time of the policymaking process. Neither of which are set rules that public consultations have to follow, but it is common practice to adhere to the general guidance they offer.

Assessing the London Plan consultation process against some of these principles will offer a useful critique on the supposed fairness and reveal the immense reliance on civil society actors to communicate and network amongst themselves to deliver a successful engagement.

Consultation Principle A: Consultations should be clear and concise

This principle states that consultations should avoid lengthy documents and acronyms to allow for more accessibility to the process. Whilst the London Plan team has taken significant strides in creating the online commenting platform, it is by no means a small, easy-to-read document. One of the interviewees suggested ways policymakers can make use of technology in the form of simulations or visualising tools to present policy visions, rather than rely on text-based representations. Such methods can allow citizens to envisage a holistic and integrated policy outcome, instead of leaving them to try piece together policy impact across various policy areas themselves. Another interviewee also raised similar views in that the length of the document posed as a significant obstacle to ordinary citizens who would like to engage but just did not have the time to do so.

Consultation Principle C: Consultations should be informative

Gunning Principle: Sufficient reasons must be put forward for the proposal to allow for intelligent consideration and response

Both suggest that consultations should provide sufficient and accurate information for citizens or those being consulted to have a meaningful input to the process. This also includes having the knowledge of what the criteria are, when decisions are being made, and whether certain factors are considered decisive. During the period before the public consultation took place, the GLA actively reached out to various known stakeholders in civil society including developers, community networks, and professionals to publicise the document and the upcoming consultation (GLA, 2016a). Engagement with Just Space, for example, began in early 2017, but engagement with other lesser known organisations who could be equally as influential did not begin until the public consultation began. At that point, the draft document was already produced, so there is limited capacity for civil society to challenge and actively influence the policies. This leads onto the next point:

Consultation Principle D: Consultations are only part of a process of engagement / Gunning Principle: Consultation must take place when the proposal is still at a formative stage

Consultation should not be a reactive process, rather, it should be proactive if policies are truly to be co-created. However, power is still skewed towards policymakers as they alone set the schedule, and determine who to engage at various stages of the process. Taking Arnstein’s (1969) criticism of consultation, it is useless if citizen participation is restricted and its output not seen to directly influence policy decision. At the same time, the public or those consulted need to be made aware of the limits of their influence from the beginning of the process to avoid false expectations. Whilst it is premature to evaluate the outcome of the process, the London Plan consultation is arguably reactive, for the GLA relied heavily on known networks and contacts to form the initial policies, and other members of society are only given a chance to review and react to such proposals at a much later stage. There is limited scope for citizens to actively organise and form a relationship resembling more of a partnership rather than a hierarchical one with policymakers.The bias towards known stakeholders contributes to procedural injustice and inequity within the process, where citizens do not have equal means to influence.

Consultation Principle H: Consultations should be agreed before publication

After the public consultation phase, the London Plan team reviewed and responded to each response received during the consultation. This is, however, different from actively involving diverse actors to shape policies according to diverse interests. Despite regular contact with known key stakeholders like large developers, the top-down approach eclipses the potential for grassroots organisations and ordinary citizens to influence the formulation of policy at that formative stage. Again, this highlights the fact that the process is highly in favour of policy makers and those consulted in the earlier stages of the process as the public consultation phase from December 2017 to March 2018 proffered only a space for reaction instead of creation. The short and late consultation phase against the lengthy plan-making process shows quite powerfully the limited scope for participation and co-creation.

As Culver and Howe (2004: 57) pointed out, ‘the aim of a public consultation is to gain a deeper understanding of the nature and the nuances of public opinion’. However, what happens after gaining such an understanding is often not accessible nor accountable to the public. When analysing the London Plan making process, it is clear that there is a lack of transparency in decision making, which echoes the worries of post-politics scholars. Furthermore, it undermines the ‘intrinsic value in participation’, which has been argued to attract a base level of engagement due to a moral imperative and an adherence to democratic practices (Shipley and Utz, 2012: 30). In order to yield better insights, the consultation should not only be participatory, but also inclusive and deliberative. Despite the strides taken by the GLA in creating a more open and user friendly commenting system online, it does not fundamentally improve the process. Technological gap and other accessibility issues still persist, and the consultation timeline or opportunities for participation have not changed because of this online platform. Inclusivity of a democratic mechanism extends beyond the people involved, but also the range of topics they can discuss, and the length of time in which they are involved (Bloomfield et al, 2001).

More to come soon.


London Plan 2018

Currently having the pleasure to study the draft London Plan for CIBSE. More updates to follow but this is a snippet of a short article I wrote for the next issue of the CIBSE Journal

“The draft London Plan sees more stringent guidelines for some issues, but generally lacks clarity for most. The separation of ‘green infrastructure’ and ‘sustainable infrastructure’ hints at a somewhat blinkered approach to environmental issues that require integrated and strategic planning. At the moment, it is not apparent how the wider benefits of green infrastructure are being accounted for in relation to the city’s well-being, and more importantly overall sustainability.”

If you want to contribute to the next London Plan, don’t forget to put up a response before 2nd March, 2018!