m14 notes 23 January 2019

Matter 14: Opportunity Areas

Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by postgraduate students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

The questions posed by the Panel were:
M14.Are the Opportunity Areas identified on the Key Diagram and Figures 2.4 to 2.12 likely to deliver the indicative number of additional homes and jobs assumed in the Plan in a way that is justified and consistent with national policy? In particular:
a)  Are sites likely to be available in the Opportunity Areas with sufficient capacity to accommodate the expected scale of development?
b)  Have the Opportunity Areas been chosen having due regard to flood risk in accordance with national policy?
c)  To be effective in preventing unacceptable risk from pollution and land instability and ensuring that development only takes place on sites that are suitable for the use proposed, is it necessary for the Plan to set out a strategic approach to dealing with despoiled, degraded, derelict, contaminated and unstable land in Opportunity Areas?
d)  How would the development proposed be likely to affect the character and appearance of existing places within and around the Opportunity Areas including with regard to heritage assets and their settings?
e)  Is the necessary transport and other physical, environmental and social infrastructure likely to be in place in each of the Opportunity Areas in a timely manner?
f)  Would the development proposed in the Opportunity Areas support policyGG1 “building strong and inclusive communities” and Policy SD10 “strategic and local regeneration”?
g)  Would Policy SD1 provide an effective strategic context for the preparation of local plans and neighbourhood plans?
h)  Is the approach to development management set out in SD1 consistent with national policy and would it be effective particularly in terms of therole of “planning frameworks”?

The OAs session was carried out over half a day and community organizations involved in the Examination, including Just Space, felt that more time should have been allocated to discuss such an important issue. With the number of OAs designated in the draft new London Plan (NLP) substantially increasing from previous years, various concerns were raised. The Examiner highlighted that the NLP did not clearly stress the status of housing and job targets: are these binding minimum targets the Boroughs will have to achieve? Are they only indications? The GLA was asked to clarify its position and to make it explicit in the text that these are indicative and should be met whenever possible, without it being a compulsory requirement, since there remains a lot of uncertainty in relation to transport projects (such as Crossrail 2, upon which many OAs are depending if they are to achieve their targets) and the ability to unlock land for investments on those sites. The GLA, however, made it clear that the housing targets for OAs included in the Strategic Housing Land Availability (SHLAA) were estimates of what could be done without Crossrail 2 and without the Bakerloo extension to Lewisham.


A representative from the London Borough of Camden welcomed GLA’s changes to the figures as result of their discussions. However, the representative added that the figures for Euston should be changed to match the Euston Plan rather than the generic London Plan as the figures in the Euston Plan had been based on more detailed studies of the Euston area and are therefore more realistic.  A representative from the Canary Wharf Group added that the employment figures presented in the plan had been carried forward from the 2008 plan and in the last 10 years more than 48,000 jobs have been created; the plan should be altered to reflect this (we need to check this). The representative further argues that the evidence base to back up the indicative figures is not justified. She suggested that there is now a different appetite for jobs, houses and workplaces. The Inspector summarised by saying that the evidence base for the figures needed to be updated.


The process through which OAs are designated was criticised as opaque, lacking in evidence-base and criteria; past experiences in King’s Cross and current development in Euston, Old Oak Common and the Isle of Dogs have demonstrated the GLA’s and Boroughs’ failure adequately to engage local communities in this process. In particular, it was highlighted that the high housing targets set out in many OAs puts immense pressure on the need to extract value to pay for transport investments (these are necessary to achieve densification targets), giving developers more room to build upwards and to cut down the amount of social housing. In addition, although OA policy has been used in various iterations of the London Plan since 2004, OAs have never been subject to an extensive and independent evaluation.


Just Space referred to its long-standing view that there should be a moratorium on further designations until there had been an independent review of the experience with OAs to date. The GLA officers responded that they do intend to undertake a full review of OA experience in the coming year.


The London Forum added that in the past OAs have been designated without any recognition of the impact that they will have on the surrounding areas.  Giving the example of White City the representative stated that the OA team and GLA and the local borough colluded to produce development that exceeded the density matrix. Further stressing that this is not just about the impact on heritage but to the intangible value that heritage has to communities. Jennifer Robinson for Just Space agreed that new places are encouraged by the NLP to ‘set their own character’ but that this should not override existing character. Caroline Shah (Just Space) from Kingston, agreed saying the process for establishing OAs is unsound and doesn’t take into account the views of communities or borough character studies. Giving the example of Kingston, a nascent OA, Shah argued that the process leading to designation happened behind closed doors and failed to consider impacts on character, heritage, visual integration with surrounding neighbourhoods, ecology or biodiversity.


The London Assembly Planning Committee consider that London’s unique selling point is the distinctiveness of its neighbourhoods but that some of the OAs have been designed and built as if they could be anywhere. Suggesting that SD1 B4 be amended with wording which requires places to be attractive and sustainable while ensuring the historic fabric, assets and character of neighbourhoods are taken care of.


The GLA team said the NLP laid out a different approach to OAs going forward, that a new team was in charge and that the creation of Opportunity Area Planning Frameworks (OAPFs) would be made more inclusive and subject to revisions every five years as OAs get developed. Concerns were raised on the status of OAPFs – where they sit in relation to the NPPF, the NLP, local development plans and Supplementary Planning Guidance remains unclear. Until now the GLA has treated these as Supplementary Planning Guidance, thus limiting the potential for public scrutiny and public engagement on the development of OAPF. However, given their importance in setting strategic directions for development projects in OAs, various stakeholders indicated that their status should be revised and clarified. In particular JS, the Forum and others argued that plans for all OAs must go through a full development plan process including Examination in Public. Interestingly the Housebuilders (HBF) representative agreed, stressing that developers also need certainty about the lawfulness and dependability of plans.


Commenting on the complaints of democratic deficit of OAPFs, the GLA said that they acquired legitimacy by having been through the London Plan EiP process, and in the case of long-established ones, been through it a number of times.


A number of groups complained that the major London-wide issues raised by Opportunity Areas, combined with the – in effect – designation of a whole new batch required more than half a day of examination and sought more time.

Edited by Enora Robin from notes by Cecilia Colombo, Gabi Abadi, Sam Colchester, Alice Devenyns and Emma Woodward

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