On 20 January 2018 Just Space published a draft of a new chapter of the Community-led Plan for London, aimed primarily at Opportunity Area proposals where we have long argued the need for Social Impact Assessment Social Impact Assessment draft chapter
Some thoughts, OAs comments Oct 2017, formulated as work in progress on behalf of Just Space, have been submitted to the GLA at a recent roundtable discussion (25 October 2017) on the operation and outcomes of OAs. Just Space would welcome informed contributions to a critical review of OAs in London’s plan-making, particularly those relating to case studies of impacts and to social, cultural and governance aspects. Please comment or email to Robin Brown, hayescanal at hotmail.co.uk.
Just Space Working Group: Opportunity and Intensification Areas: briefing for 4 Feb 2016 conference
What are ‘Opportunity Areas’?
‘Opportunity Areas’ (OAs) in the London Plan are large areas designated by the Mayor as places where large scale development can provide space for high numbers of jobs and homes, typically 5,000 jobs and 2,500 homes. There are currently 38 Opportunity Areas along with 10 ‘Intensification Areas’, which have a similar, but lesser role.
When an Opportunity Area is designated, it quickly attracts a larger scale of development and encourages high density projects which might not get approval in other places.
The Opportunity Areas have their own planning guidelines, called ‘Opportunity Area Planning Frameworks’ (OAPFs) which are largely conceived and written from City Hall, in tandem with the Boroughs.
The OAs and OAPFs are at different stages of completion across London, from Cricklewood / Brent Cross in the late stages of development to ‘Kensal Canalside’ which is a new area.
Opportunity and Intensification Areas are seen to have a negative effect on the people who live and work in an area in a number of ways.
They encourage the provision of expensive, high density housing which does not meet the needs of local communities, especially of families, as family housing tends to be discouraged in the OAs. In many cases new housing is provided at the expense of existing social rented housing, of which there is already a serious shortage.
They threaten community facilities such as community halls and inexpensive sports facilities. It becomes harder for community based groups such as youth groups, tenants’ or pensioners’ organizations to find places to meet.
They encourage speculative office development which, in scale, density and character, may be inappropriate to the local community, and which may replace other buildings and amenities that more readily serve that community
Shops, cafes and service providers that serve the local community are priced out of the area by soaring rents.
Around the outside of the OA boundaries we see a similar scale of development piggybacking on the Opportunity Area and extending these negative effects.
Key Problems with the Opportunity Areas
Opportunity and Intensification Areas are designated from above without informing, let alone ensuring the effective participation of the people who already live and work in the area. The central mechanism that drives them takes no account of the aspirations of people to be involved in the redevelopment of their neighbourhoods and to benefit from changes that take place. They do not currently include consideration of the existing land uses as a viable alternative option for the future.
The main question being asked about the current development of London – why is it not providing the kind of housing that we need? – is seen on a dramatic scale in the Opportunity Areas, where growing numbers of new towers and acres of cleared land are not providing even the minimum amount of ‘affordable’ housing while much social and affordable housing is being lost in these areas.
Opportunity Areas are planned in such a way as to require extensive infrastructural investment (new roads, bridges, rail links, tube stations) to increase the permitted densities of development. Some of this is recoverable through S106 planning gain arrangements (which lowers the amount of affordable housing which can be delivered in the area); some comes directly from government investment (e.g. TfL, or borrowing against future expected revenues such as business rates uplift). We are concerned that large amounts of public money are being spent for little public benefit.
The current financial and planning models in Opportunity Areas encourage the continuing role of a limited number of favoured Volume Developers who require large cleared sites, entailing clearance of existing housing and businesses and the decanting of communities. High profit expectations and secret viability reports lead to agreements which drive down the delivery of social and affordable housing, and in some cases have led to the suspension of CIL charges. Smaller developers and smaller scale developments could often meet the actual housing demand more effectively without such dramatic negative effects and should be given an equal part to play.
There has not been a comprehensive documentation, review and assessment of the impact of Opportunity Areas (OAs) on London’s development against the principles of the London Plan. These would expect OAs to balance economic and social development, and environment, and to have regard to the health of Londoners, the sustainable development of the UK, and equality of opportunity.
Community based evidence suggests overwhelmingly negative effects and indicates that in their current form they should be reconsidered.
As planned, Opportunity Areas could deliver over 300,000 homes and 575,000 jobs. They are making the London of the future; they need to meet the needs of local residents and deliver high quality environments for current and future residents of the city.
Given the impact of these OAs on the city, the highest standards of public participation should be expected, including early and full public information and consultation prior to their designation and effective participation early in the planning process.
There has also not been an effective review of the role Opportunity Areas play in shaping the current spatial model for London’s development. The spatial and environmental sustainability of large transport investments to produce dense high-rise housing (dormitory neighbourhoods with unaffordable housing) around well-connected nodes, generating significant additional travel requirements is questioned. Alternatives which encourage more mixed-use live-work environments and which build on rather than eradicate the existing qualities and diversity of London’s neighbourhoods should be prioritised.
Questions for Debate
- Perhaps there should be no place for Opportunity and Intensification Areas in a new London Plan because our experience suggests they make it harder to meet the real needs of the majority of Londoners? OA’s do not appear to be a particularly effective way to encourage the net addition of homes for Londoners, specifically genuinely affordable homes.
- If they continue, how can Opportunity Areas be made to function more democratically and effectively? Just Space proposes stipulations requiring a Social Impact Assessment for OA/IA developments. Such an Assessment would serve as a framework to address environmental impact and social and community infrastructure in Opportunity Areas. This would involve the GLA carrying out detailed analysis of what an area already contains: its housing, jobs, community facilities, locally appreciated buildings, and so on. A report on existing land and building uses should be prepared for public consultation. Existing uses must be evaluated and made a part of evaluating the viability of any new plans. Involving People in the Plans must be central to the Opportunity Areas and they should be subject to strict community involvement principles.
Should public land within OAs be identified and dedicated to borough affordable and social-rented housing projects, remaining in public ownership?
- How can Opportunity Areas deliver the kinds of neighbourhoods Londoners need? Guidelines could promote redevelopment in the model of lifetime neighbourhoods or sustainable communities, supporting and maintaining existing local character, and indicate that such redevelopment should maximize the provision of social and affordable housing.