On Tuesday 8 February 2022 at 10.00 the Planning and Regeneration committee of the London Assembly will consider the 40-odd areas in London where most of the new homes and jobs get provided. They are doing this by questioning the deputy mayor for planning and others from City Hall but, despite our offers to help, have not invited any community participants.
The agenda and papers are here, along with the video link for those who want to listen but can’t or won’t go. IMPORTANT CORRECTION: the meeting is at London Fire Brigade, 169 Union Street, not at the new City Hall as we said yesterday.
It’s normal among community groups in London to consider “opportunity areas” as increasingly opportunities for developers, not citizens or existing businesses. Just Space and many of its member groups have been demanding reforms to the Opportunity Area system since our foundation a decade ago, for example in 2018 here and in our submissions to the public Examination of the new London Plan. We called for a halt to the designation of any more Areas until there was a thorough review of what had happened to date. This week’s Committee discussion does not look like being the systematic review we asked for and which the GLA London Plan team seemed to promise during the inquiry, but we hope it will lead to one.
As well as statistics and maps prepared by the GLA planners, the committee has received the following memorandum from just Space:
“Just Space: memorandum on Opportunity Areas for the London Assembly Planning and Regeneration Committee. 26 January 2022
Context: There have been areas designated as Opportunity Areas ever since the first London Plan written soon after 2000 and finally adopted in 2004. They were the areas where most new development activity was expected. New ones have been added in each successive London Plan. There were originally also “Intensification Areas” which were not planned to be bulldozed, but where a lot of new development was wanted. These were merged with OAs later and they are all in one big list now. Just Space includes community groups active in some of the OAs and has made strong representations about both the concept/system and individual cases over many years.
Now the London Assembly Planning and Regeneration Committee has planned to scrutinise the issue and we want to be able to make a submission to inform their meetings. Provisionally, these are the issues on which we want to submit (and suggest groups who can give first-hand evidence):
- the process and procedures for designating OAs are unclear and undemocratic. OAs seem to be contrived in discussion between developers/landowners, boroughs and the Mayor, then then assimilated to the London Plan. Citizens are sidestepped. Only one half day was programmed in the 2019 EiP for discussion of ALL the established OAs and new ones and broad policies. (Kingston, City Fringe have been particularly fraught.)
- the targets for housing numbers and job numbers seem to lack systematic justification. These are the main performance indicators used to evaluate their success while social, environmental and regeneration performance are never examined.
- there is a variety of guiding/governing documents (OAPFs, SPDs, some of which are subject to EiP examination, others not. All should be. (Old Kent Road has seen many permissions ahead of a properly approved plan.)
- The management and implementation of the OAs has no general guiding principles, no democracy of its own ( it depends on whatever democracy is practiced in the host borough(s). (Barking Riverside, Old Oak are among the OAs where this democratic vacuum has been an issue.)
- There is no systematic survey/inventory of the existing site of an OA or of the areas around it, so the proposals seem to be based on almost a blank sheet approach instead of the actual mass of uses, users and residents (Peckham Vision has been especially vocal on this, also Old Kent Road, also areas adjoining OldOak). Since many OAs are co-located with ‘Areas for Regeneration’, it is a major failing that they can proceed with so little data and participation from established people and enterprises.
- The 2 Mayoral Development Corporations (London (Olympic) Legacy LLDC and Old Oak and Park Royal OPDC) are exceptions in that they each have a special governing institution with some planning powers. (Carpenters Neighbourhood Forum at LLDC and Grand Union Alliance at OPDC can testify to the strengths and weaknesses of these structures)
- The powers of OA agencies like the Development Corporations do not enable them to acquire land cheaply enough to achieve all they are tasked with achieving and this drives densities ever upwards. (Grand Union Alliance can testify on this.)
- Research and citizens’ experience points to Opportunity Areas as having negative effects on poorer residents and many pre-existing businesses through rising housing costs and industrial land values, often exacerbated by actual displacement. This is the opposite of ‘regeneration’ and a major failing of the Plan.
Just Space would like to submit a paper on these lines to the committee and cooperate in identifying witnesses.” END. A fuller paper is in draft and will be added in February.
The 2 Development Corporations (for the Olympic Park and surroundings LLDC and for Old oak Park Royal OPDC) will be considered separately by the following meeting of ths Committee on 17 March 2022.