ADD2456 Consultation Tool – London Plan Guidance

The draft London Plan is completing its final statutory steps in the process and is expected to be published later in summer 2020.

A significant volume of planning guidance is being prepared in a revised format to support the implementation of the Plan, with potentially up to 14 consultations before the pre-election period next year. This will replace and update existing Supplementary Planning Guidance that are linked to the current London Plan. In order to support the consultation on them, it is proposed to procure a consultation tool to enable improved outreach and engagement with a wider, more diverse audience. This will help to make it easier for individuals, groups and other stakeholders to participate in complex planning matters which can often be difficult for some to engage with, particularly those not familiar with planning.

Whilst the London Plan consultation was successful in so far as the amount of responses received in the past – 4,000 in 2018 compared to 400 in 2010 - there is a recognition that the quality of engagement can be improved and that it’s important to reach a wider, more diverse audience, especially hard to reach groups. External factors such as COVID 19 and the Black Lives Matters movement has further highlighted the importance of engaging a wide range of Londoners and stakeholders to ensure that a range of views should influence and shape policy and guidance – particularly given the impact these have on how London evolves and develops in practice.

Since the consultation on the London Plan, there has been significant development in off-the-shelf consultation packages that offer a wide range of both front-end user experience and back-end functionality that are likely to appeal to a wider audience as well as enabling more sophisticated analysis. These off-the-shelf products are able to provide this wider functionality due to the number of users that invest in them and the benefits that accrue from this experience. They also offer opportunities to integrate with social media functions and other GLA online consultation tools such as Talk London.

Inhouse tools such as Talk London provide some functionality similar to some aspects of these third-party tools, however, Talk London is specifically aimed at residents and does not currently cater for all types of stakeholders in a seamless, integrated way. At this stage, Talk London would not provide the outreach that we consider necessary for the London Plan, and its guidance, but we will continue to work with the team to keep this under review (as set out below).

For the London Plan consultation, in 2017, a bespoke online consultation and back office function was developed to manage the consultation. Because of timing issues, it was not fully completed for the beginning of the consultation and needed significant adjustments both during the consultation and as part of the analysis of the responses. This meant workarounds had to be created to ensure the back end met basic requirements. Due to this, a number of the original features were unable to be implemented. The front-end pages also have limited functionality which would need to be significantly enhanced to ensure that the GLA can meet its objectives around higher standards for engagement.

Talk London is currently undergoing a programme of upgrading which is expected to be completed around Christmas. Whilst discussions are underway between the London Plan team, Talk London team and the Digital team to explore whether there are opportunities to integrate requirements across teams through the upgrade, any potential savings found by integrating processes will not be ready in time for the consultation proposed for the London Plan Guidance scheduled for this year.

The objective of the project is to procure a licence, initially for one year, for a consultation tool to support the consultation on the London Plan Guidance with a view to renew the licence if current inhouse solutions through upgrading works are not possible. If renewed, the tool would also be able to support the more specialised requirements for future London Plan consultations.

As many of these companies offer a rolling one year licence for the whole organisation, there may be opportunity for Talk London to embed some of the unique features of these packages into their upgrading programme as well as the potential to create a much more integrated product that could be used across the organisation to met the requirements of both Londoners and wider stakeholder engagement.

Regardless of the potential outcome of integrating products, the licence also provides opportunity for other teams to use it for engagement, if they so wish, to ensure both a seamless user experience and integrated analysis between wider stakeholders and Londoners.

The consultation tool should include the following outcomes:

• be user friendly and engaging to ensure improved outreach;
• ability to use London Plan / Guidance branding;
• be accessible through different media – tablet / phones / desktops;
• functionality to sit within London.gov.uk webpages and be searchable for search engines;
• ability to links to social media such as Facebook, Twitter, etc and integrate with internal GLA products such as Talk London (/talk-london/);
• flexibility for the organisation and displaying of pages with a wide range of features that are easy to implement with limited training needed;
• seamless user registration for all types of stakeholders, including Londoners and wider stakeholders; and
• reporting tools for analysis of all stakeholder responses.

A more detailed specification is attached at Appendix 1.

The Public Sector Equality Duty (PSED) set out at Section 149 of the Equality Act 2010 requires the GLA, when exercising its functions, to have ‘due regard’ to the need to:

• eliminate discrimination, harassment and victimisation and other conduct prohibited under the Act;
• advance equality of opportunity between people who share a protected characteristic and those who do not; and
• foster good relations between people who share a protected characteristic and those who do not.

The three aims of the duty must be fulfilled on a continuing basis by the GLA when exercising its functions. In addition, public bodies must take steps to take account of a person’s disability and make reasonable adjustments to remove barriers for disabled people. This duty is ‘anticipatory’.

All the London Plan Guidance will be subject to an Equality Impact Assessment which will specifically draw out any equalities issues that may affect or be affected by the individual pieces of guidance. This will also be used to help inform what discretionary consultation above the standard baseline might be appropriate for each piece of new guidance i.e what groups should be targeted to increase their levels of engagement.

This decision however is related to the procurement of a licence for a consultation tool to support the consultation of the London Plan Guidance and potentially the consultation on future London Plans.

Any consultation tool procured should adhere to the following equality principles:

• the layout and content of the pages for consultation should be able to be designed to be easily navigable and accessible for screen readers, with clear, short and well-structured headings and sub-headings;
• pages should have the functionality to be engaging to appeal to a wide, diverse audience including individuals and groups as well as more technical stakeholders;
• language should be clear and should be easy to understand for everyone, including using plain English and should avoid using complicated grammar or jargon. All abbreviations and acronyms should be explained, unless they are well known and in common use e.g. UK, EU, VAT;
• diagrams and images will use alternative text for screen readers. If images are purely decorative, an empty tag will be added to instruct screen readers to skip it;
• tables and survey forms will be in an accessible format to for screen readers and will include clear information and instructions;
• use of capitals and italics should be avoided. Acronyms or abbreviations should be spelt out on first reference to make sure all readers understand what it stands for;
• links should be descriptive and front-loaded with relevant terms e.g. Read the Local Plan (instead of ‘click here’ or ‘more’);
• where possible, information will be published on the website as an HTML webpage. PDF and Word documents will be accessible for screen readers, or alternative accessible version e.g. plain text document) will be produced;
• there will be an option to download the whole document in a printer friendly format for people who do not have access to a computer;
• all pages will comply with WCAG 2.1 AA accessibility standards and the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018;
• colour contrast will have a ratio of 4.5:1 to meet the AA standard; and
• web-links will be clear and front-loaded and will tell the user if they open in a new tab. PDF and Word documents will have a clear name and include the size of the file.

In order to maximise the positive impact of greater accessibility and inclusion, it will be key that the tender exercise places high value on the bidder’s level of knowledge and understanding of the requirements of the Public Sector Bodies Accessibility Regulations 2018. Organisations will be asked to demonstrate their knowledge and understanding of the regulations and provide examples of their work on accessibility.

a) key risks and issues

The contract will be managed in line with standard GLA risk management procedures by the GLA London Plan team.

Officers from the London Plan team, Talk London team and the Digital team will sit on the procurement panel to ensure opportunities for potential integration between inhouse products and third-party products are maximised.

b) links to Mayoral strategies and priorities

The London Plan Guidance supports the implementation of the London Plan as well as supports Mayoral priorities contained in the other statutory strategies. The consultation tool will provide a more user-friendly and engaging platform which will enable improved outreach and engagement with a wider, more diverse audience. This will enable us to comply with the Public Sector Accessibility Regulations 2018.

c) consultations and impact assessments

As described in paragraph 3.6, the guidance itself will be subject to an equality impact assessment, and the webpages will be designed to adhere to the specifications as set in paragraph 3.7.

The consultation tool will also allow for interactions with social media such as Twitter and Facebook as well as the potential to integrate features between internal tools such as Talk London.

Approval is sought for the expenditure of up to £36,000 over up to 3 years. This includes up to £32,000 for the procurement of an off-the-shelf consultation tool to support the London Plan Guidance consultation and a further £4,000 for the cost of short video clips, sign language interpreters, translation services, etc, as required, to support the engagement.

The costs will be across financial years and be funded from the London Plan programmes budget. It is envisaged that this is likely to be between £10,000 and £16,000 per year for a licence and between £1,000 - £1,500 per year for the accessibility / inclusive support services.

Initially, it is proposed that a 1-year licence will be procured with the view to renew it if inhouse solutions are not possible / more cost effective. This ADD will therefore cover 2 or 3 years depending on the supplier chosen.

As this is for an ongoing licence, if inhouse solutions are not possible, a further ADD will be required in future years to agree funding for the continuation of the licence or another procurement exercise.

As this work relates to consultancy contract, officers will ensure that the requirements of the Authority’s Contracts & Funding Code are adhered to and that the requirements relating to consultancy services within the Authority’s Financial Regulations and Expenses & Benefits Framework are adhered to. Any changes to this proposal, including budgetary implications, will be subject to further approval via the Authority’s decision-making process.

The decision requested of the Assistant Director concerns the exercise of the GLA’s general powers, falling within the GLA’s statutory powers to do such things considered to further or which are facilitative of, conducive or incidental to the promotion of economic development and wealth creation, social development or the promotion of the improvement of the environment in Greater London; and in formulating the proposals in respect of which a decision is sought officers have complied with the Authority’s related statutory duties to:

• pay due regard to the principle that there should be equality of opportunity for all people;
• consider how the proposals will promote the improvement of health of persons, health inequalities between persons and to contribute towards the achievement of sustainable development in the United Kingdom; and
• consult with appropriate bodies.

The Authority also has a subsidiary power pursuant to Section 34 of the Act to do anything which is calculated to facilitate or, is conductive or incidental to the exercise of any of the statutory functions of the Authority. In this case this piece of work is incidental to its section 30 powers defined above as well as its powers under section 334 and 339 of the Act.

Section 334 of the Act requires the Mayor to prepare and publish a Spatial Development Strategy (known as the London Plan). Section 339 of the Act requires the Mayor to keep the London Plan under review, especially matters which may be expected to affect the development of Greater London or the planning of its development. In this case, the decision to carry out this piece of work may reasonably be regarded as facilitating, being conductive or incidental to, the exercise of the Mayor’s power detailed above.

In taking the decisions requested, the Assistant Director must have due regard to the Public Sector Equality Duty; namely the need to eliminate discrimination, harassment, victimisation and any other conduct prohibited by the Equality Act 2010 and to advance equality of opportunity and foster good relations between persons who share a relevant protected characteristic (race, disability, gender, age, sexual orientation, religion or belief, pregnancy and maternity and gender reassignment) and persons who do not share it (section 149 of the Equality Act 2010). Throughout the process outline above in particular paragraph 3, due regard will need to be had to the legislation outlined above and equality impact considerations and mitigations.