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To the Chair and Members of the Strategic Priorities and Policy Committee, City of London, and Deloitte project team, Thank you for circulating the Deloitte Draft Economic Development Strategy. We recognise the volume of work that sits behind this document, including the research, engagement, and system review that inform it. For ease of reference, after this first use we refer to it as the DEDS. We would also note that this response has been assembled on very short notice – we did the best we could!! From the Chamber’s vantage point, the DEDS is a credible starting point. It reflects several priorities we consistently hear from business, including the primacy of talent attraction and retention, the need for system performance and predictability, and the importance of place and infrastructure in shaping investment decisions. That said, if the DEDS is to serve as the scaffolding for the final strategy and implementation plan, several elements require strengthening. Our comments below are confined to the DEDS itself and are intended to help ensure the final strategy is ambitious, distinctive to London, and built to deliver.

1) London’s competitive foundation should be carried through the DEDS, not left behind in narrative language

The DEDS identifies competitive advantages, including London’s UNESCO City of Music designation and the link between lifestyle, culture, and talent retention. This is important and should not be treated as background context. Our concern is that the framework does not consistently carry these advantages into the pillars and strategies in a way that would drive investment logic, workplans, accountability, and measurable outcomes.


What we recommend:
* Treat the cultural and creative economy as a defined economic workstream with clear ownership, targets, and reporting. If culture remains only a values statement, it is unlikely to be implemented as an economic driver.
* Make the UNESCO City of Music designation operational within the strategy by connecting it to delivery mechanisms and performance measurement, not simply describing it as a differentiator.

2) Downtown should be elevated to Pillar status

The DEDS is organised around five pillars: Talent and Innovation, Investment Attraction and Retention, Regional Collaboration, Transportation and Access, and System Optimisation. This architecture matters because it signals to staff, partners, and investors what the City intends to prioritise, how resources will be allocated, and what success will be judged against. Within this structure, downtown is positioned primarily as a sub-component of Investment Attraction and Retention, while Regional Collaboration is elevated to pillar status in its own right. Yet, in stakeholder sessions the Chamber attended, a Deloitte representative observed that the clearest area of broad consensus throughout the consultation process was, in essence, “revitalise the downtown”.

The DEDS links downtown vitality to talent retention, perceptions of safety, vacancy, and investment decisions. That alignment is correct. However, the DEDS then treats downtown as a single bullet under Investment Attraction and Retention. That framing is too light for what the DEDS itself describes. More importantly, as we know, the City is advancing a Downtown Plan in parallel. If the DEDS is intended to guide economic development priorities over the next several years, it is difficult to reconcile a “downtown is critical” narrative with a structure that does not treat downtown as a pillar. A downtown pillar would not be symbolic. It would create clarity of ownership, measurable outcomes, sequencing, and alignment between the DEDS and the Downtown Plan.

We are encouraged to see the DEDS now frame downtown as an “economic and cultural driver”. Earlier drafts used the phrase economic “magnet”. The new language is stronger and more accurate because it captures downtown’s role as an engine that creates value, signals confidence, and animates the wider urban and even regional economy. The Chamber had recommended this change.

The current pillar configuration also creates a messaging and implementation risk. In practice, the teams responsible for executing the Economic Development Strategy will take cues from the pillar architecture about what matters most, how resources should be allocated, and what success will be judged against. Meanwhile, the Downtown Plan will signal that downtown revitalisation is of the utmost importance. If the DEDS relegates downtown to a sub-point while elevating Regional Collaboration to pillar status, these two workstreams risk being set up to operate at cross purposes.

The result is predictable: a department tasked with delivering the DEDS will prioritise pillar commitments, even if the City’s parallel planning process is urging a downtown-first focus. That is precisely why the two documents need to “talk to one another”. None of this diminishes the value of Regional Collaboration. Regional relationships can strengthen labour markets, supply chains, tourism flows, and investment attraction. The question is structural: whether Regional Collaboration is best advanced as a standalone pillar, or as a set of cross-cutting actions embedded across pillars, especially when the DEDS itself describes downtown outcomes as central to London’s competitiveness. In the Chamber’s view, Regional Collaboration can and should be embedded across the strategy, but it should not displace a pillar-level focus on downtown delivery for the next several years.


What we recommend:
* Elevate downtown revitalisation to a dedicated pillar for the next several years, explicitly aligned with the Downtown Plan.
* Retain and reinforce language that explicitly links downtown and culture, for example “economic and cultural driver”, “economic engine”, or “city-wide catalyst”.
* Define outcomes and indicators suitable for Council oversight and public accountability, such as vacancy, business openings, footfall, office utilisation, investment commitments, and perceptions of safety.
* Ensure the DEDS and the Downtown Plan “talk to one another” by aligning pillar structure, ownership, and metrics, and by establishing an explicit coordination mechanism: a joint implementation roadmap and a single reporting dashboard to Council, so departments, partners, and resources are not set up to \ work at cross purposes. Pillars set direction, but businesses experience outcomes through delivery. The next issue, therefore, is whether the DEDS moves beyond coordination language and sets out a clear operating model, service standards, and accountability that will actually improve system performance.

3) System Optimisation is pointed in the right direction, but it still reads as coordination rather than a delivery model

The DEDS is strongest when it names the real problem: navigation challenges for business, the “no wrong door” need, and ambiguity caused by multiple organisations with overlapping or adjacent mandates. That clarity needs to translate into a delivery model that businesses will actually experience as simpler, faster, and more accountable.


What we recommend:
* Commit to a single-door business navigation model with clear service standards and public reporting across approvals, permitting, licensing, and business supports.
* Specify what will change structurally, not only what will be coordinated. The final strategy should show accountable leads, defined roles across funded partners, and measurable outputs tied to mandates and performance expectations.
* If the DEDS signals improved data sharing and impact measurement, specify what will be measured, who will report, and how performance will be made visible to Council and the public.


4) Indigenous economic partnership requires clarity and specificity
The DEDS includes language about building mutually beneficial economic partnerships with Indigenous Nations and communities. That direction is welcome. However, the strategy does not yet explain what partnership means in practice, how Indigenous partners will shape priorities and delivery, or how outcomes will be measured and reported. To be effective, the DEDS should move from aspiration to a clear, resourced, and accountable partnership model.


What we recommend:
* Adopt a clear Indigenous economic partnership model, grounded in early engagement and co- creation, not consultation after priorities are set. This model should be distinctions-based, and inclusive of First Nations, Inuit, and Métis partners where relevant to London’s context.
* Establish an Indigenous Economic Partnership Table as part of the DEDS operating model, with a defined mandate to help shape priorities, implementation sequencing, and performance measures across the strategy (particularly investment attraction, downtown revitalisation, and regional collaboration). To be credible, this table should be Indigenous-led or co-chaired, supported by City staff, and connected to decision-making rather than operating as an advisory afterthought.
* Resource participation properly. Partnership requires capacity. The City should budget for participation supports such as honoraria, meeting facilitation, and where appropriate, capacity funding for Indigenous partners to engage in co-design, project development, and evaluation.
* Create practical pathways for partnership and opportunity. The final strategy should specify mechanisms such as Indigenous procurement targets and supplier development, Indigenous business and entrepreneurship supports, joint investment promotion, workforce and skills initiatives, and project specific partnership structures (for example, on tourism, placemaking, and cultural and creative economy initiatives).
* Clarify governance and accountability. Identify a senior accountable lead, define how Indigenous partners will be engaged at key decision points, and ensure alignment with the City’s broader reconciliation commitments. Where decisions may affect Indigenous rights and interests, engagement should be consistent with the principles of the UN Declaration on the Rights of Indigenous Peoples, including free, prior, and informed consent.
* Measure and report outcomes transparently. At minimum, report annually to Council and the public on indicators such as Indigenous partnership initiatives launched, contracts and spend with Indigenous businesses, participation and leadership roles in governance, training and employment outcomes, and partner feedback on the quality of engagement.

5) The DEDS should provide an enabling foundation and framework for flagship initiatives emerging from the Downtown Plan.

A strategy gains credibility when it is not only clear on themes but also clear on how investable priorities will be identified, sequenced, governed, and measured. We recognise that it is not Deloitte’s role, nor necessarily within scope, to originate or select specific flagship projects. Our point is that the DEDS should be designed to enable delivery of the investable priorities that will flow from the Downtown Plan, so the two documents reinforce one another rather than pulling implementation in different directions. To that end, the Chamber has already shared sample flagship opportunities with Deloitte as illustrative examples of the type of initiatives that may emerge through the Downtown Plan. They are offered not as a request that Deloitte choose projects, but to underscore why the DEDS must create the enabling conditions for evaluating, prioritising, and delivering such initiatives. They are also offered to Council and staff as a suggestion of what the DEDS must ultimately end up looking like in order for the DEDS to support and nurture what may be to come from an ambitious, forward-looking plan.


What we recommend:

* Establish an explicit alignment mechanism between the DEDS and the Downtown Plan, including a joint implementation roadmap and a single dashboard reported to Council, so departments, partners, and resources are not set up to work at cross purposes.
* Specify the decision framework for investable priorities, including evaluation criteria, governance, sequencing, and performance measures, so projects emerging from the Downtown Plan can be assessed and advanced consistently.

6) Conclusion and request to Council
The Chamber supports Council receiving the DEDS as an important step forward, and we appreciate that the consultant’s work reflects substantial engagement and analysis. However, receiving the DEDS should not be treated as the end of the process. The success of this strategy will ultimately be judged on whether it aligns with community expectations and whether it is structured to deliver measurable outcomes, particularly as the City advances the Downtown Plan in parallel.

Accordingly, we respectfully ask that Council receive the DEDS subject to additional consultation prior to finalisation, with the explicit objective of ensuring that the final strategy aligns with the expectations of the business community in particular and the broader community at large. This additional consultation should also ensure that the DEDS and the Downtown Plan are harmonised in their priorities, sequencing, governance, and performance measures, so that implementation does not proceed at cross purposes. In practical terms, we ask that Council direct staff and the consultant team to undertake targeted follow- up consultation and return to Council with a final version of the Economic Development Strategy and implementation approach that reflects that input, including:


* Pillar architecture and downtown priority: Revise the pillar architecture to elevate downtown revitalisation to pillar status, explicitly aligned with the Downtown Plan, with clear ownership, deliverables, and measurable outcomes. Confirm that Regional Collaboration will be advanced through cross-cutting actions embedded across pillars.
* DEDS–Downtown Plan alignment mechanism: Establish an explicit mechanism to ensure the DEDS and the Downtown Plan “talk to one another”, including aligned priorities, sequencing, governance, and performance measures, supported by a joint implementation roadmap and a single dashboard reported to Council.
* Operating model, service standards, and accountability: Strengthen the delivery model by specifying accountabilities and measurable service standards for business-facing functions (approvals, permitting, licensing, and business navigation), with transparent reporting so Council can assess whether system performance is improving.
* Culture and UNESCO as economic drivers: Specify how the cultural and creative economy, including London’s UNESCO City of Music designation, will be operationalised as an economic workstream with delivery mechanisms and performance measures.
* Indigenous economic partnership mechanisms: Define the Indigenous economic partnership model, including governance roles, where Indigenous partners shape priorities and delivery, and how outcomes will be measured.
* Decision framework for investable priorities: Set out a decision framework to evaluate and prioritise investable initiatives emerging from the Downtown Plan (criteria, governance, sequencing, measures). This is not a request for Deloitte to originate projects, but to ensure the DEDS enables delivery once priorities are identified.
* Indigenous partnership model: Establish and resource an Indigenous-led or co-chaired partnership table with authority to shape DEDS priorities and implementation, supported by practical levers (procurement, business supports, workforce initiatives, and project partnerships).
* Indigenous outcomes reporting: Add Indigenous partnership metrics to the DEDS dashboard and report annually to Council on delivery and results. The Chamber remains ready to participate constructively in that consultation and to support a final strategy that is ambitious, coherent, and deliverable.

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