Opportunity Areas: whose opportunity?

Opportunity areas in Kingston
The bloggers will be burning the night oil after each of the Examination in Public (EiP) hearings of the Mayors London Plan. Some of yesterday's session on Opportunity Areas and Regeneration, is expounded below see also Kingston's emerging Local Plan

Whilst no one wants to stop genuine homes being provided for our citizens - shelter is a human right - many are concerned about the way this is being undertaken. The inclusion of much of Kingston as 'Opportunity Areas' to deliver housing targets of 30,000, has raised a number of questions- including from our council - who want to see this number halved.

The London Tenants Federation as well as many  other organisations  are calling for a halt in the spread of Opportunity Areas. OA's can mean that normal planning rules are suspended and density increases can be up to 300% ABOVE  average new development. They determine that an area can take extraordinary numbers of jobs and new homes; totally removing established communities.

Typically they can accommodate at least 5,000 jobs, 2,500 new homes or a combination of the two, along with other supporting facilities and infrastructure - in the case of Kingston 9,000. https://www.london.gov.uk

'Opportunity Area', confers a 'permitted development right', which can lead to 'total footprint developments' with  'total biodiversity loss' (suspending both the legal duty of the Mayor and the council  in their obligations to 'conserve wildlife in all of their functions'); but we can't let this happen - no one can live without nature, it is everything we need and interact with: air, water, earth.

Interesting to note that the number of signatures gathered by the petition against over development in Kingston, now runs at three times the number of people responding to the consultation (after only 2 weeks of going live) https://www.change.org/

Only the GLA team appeared happy with OA's- there was a consensus amongst the community organisations, who had been through the process - as follows:
  • Earls Court OA 'people have been marginalised',  'put quarts into pint pots', no social infrastructure, 'development should be integrated not isolated, gung-ho development  up to the density matrix, 'we have been sold up the river', how can the mayor call-in when he is part of the delivery vehicle,' we want homes not units';
  • Isle of Dogs OA, 'there is no longer an appetite for large scale office development, which stagnate these areas, more diversity and smaller units are required;
  • Just Space 'capacity does not increase as home and jobs are destroyed by developing OA's, OA's are outside the democratic process and should be produced through the Local Plan process not on a numbers game;
  • Enfield: we cannot move forward with the huge numbers planned for the Lea Valley (Meridian Water) due to an issue with CIL, (which was too in-house to report);
  • Euston Group, negative effect on Greenspace with loss of St. James' and Euston Garden, listed buildings demolished, air quality worsened, no light reaching homes;
  • Kingston Council,' we need to halve the housing target and make the rest contingent on Crossrail 2, not know if we have sites available, there is a conflict with Mol and Green Belt designation in the proposed OA's;
  • Nicky Gavron- the assembly supports Opportunity Areas but we recognise distinctiveness in relation to Kingston;
  • Environment Agency, no reference to flood risk, green infrastructure needed for a resilient city, no environmental infrastructure;
Opportunity Areas were born in  the Council's 'Direction of  Travel' document 2016; 'Affordable' housing and protection of the ecology of the Hogsmill Valley were afterthoughts in the document.

In the 'Director of Place's' report (to advise councillors on the "Direction of Travel" document) 2016 Appendix B, B5 under the environment heading:

"Environmental Implications 

34. None."

This is a failure of a public body to engage with its statutory duty conferred under the Natural Environment and Rural Communities Bill, (NERC) 2006 which extends the Countryside and Rights of Way Act, 2000 (CROW Act) on the duty of public bodies and statutory undertakers to ensure due regard to the conservation of biodiversity. 

The sites proposed are fundamentally unsound and not evidence based. The process of determining the Opportunity Areas is not in conformity with the following:
  • International, National Legislation in the Conservation of Habitats and Species or Case Law requiring surveys to be undertaken before designating areas of (permitted) development as well as Regional and Local Polices including the:
  • National Planning Policy Framework which requires net gain;
  • Natural Environment and Rural Communities Act which requires conservation of natural features; 
  • The Mayors Biodiversity Strategy as target habitats will be destroyed; 
  • The Mayors All Green Grid as the Arcadian Thames policy area will be developed; 
  • The Kingston Core Strategy Policies CS3, DM5, DM6 promoting Green belt and biodiversity;
  • The Green Belt Review Kingston 2018, which states that MOL and Green belt function well.
Nature Reserves will be used for infrastructure according to the Tolworth Area Plan especially at Tolworth Court Farm and its environs.

This runs counter to the Mayor’s All Green Grid ref page 111 which states ‘increase the potential for biodiversity and nature conservation at areas along the Beverley brook and Hogsmill rivers. and

‘Promote productive landscapes in particular promote historic agricultural field patterns as a transition from urban to greenbelt.’

In more detail:

Tolworth Opportunity Area

In the Sites identified as suitable for development the following are identified for Tolworth:
  • King Georges Field, proposal site in the emerging Local Plan but it is MoL;
  • Biodiversity harm- priority habitats and species will be affected by development;
  • Detrimental effect on Nature Reserve, which will be used for social and environmental infrastructure in Tolworth Area Plan
  • Area of  flood risk;
  • Heritage and cultural assets-Richard Jefferies walks, ancient drove routes etc. 
  • Major conflict with Tolworth Court Farm and the All Green Grid which states ‘Promote productive landscapes - in particular- promote historic agricultural field patterns as a transition from urban to greenbelt’, the TAP allows for TCF to be sequestered for social Infrastructure (see Tolworth Area Plan).

Berrylands Opportunity Area

  • High Flood Risk-Flood zone 3b;
  • MoL and Sites of Borough Importance on Nature Conservation may be affected;
  • Protected and priority species will be affected by development, which has not been properly assessed;
  • Conflict with All Green Grid/ Arcadian character area.
  • Inadequate infrastructure with major sewage spills at Green Lane Recreation Ground 2014, October 2018

New Malden Opportunity Areas

  • Protected and priority species may be harmed by development;
  • Possible conflict with All Green Grid


The proposed regeneration of the Cambridge Road Estate runs counter to many policy areas; the Mayor has committed to reducing the distance that people live from quality green space/Sites of Nature Conservation Importance -deemed as Areas of Deficiency- yet much of north Kingston is within an AoD (more than 1km from quality open space. 

The wildlife interest has not been assessed- important for physical well- being and mental health but No account has been taken of natural environment: more than 100 trees, some more than 50 years old; colonies of house sparrows; bat interest; etc

There will be a massive loss of biodiversity if the proposals continue at their proposed density see https://www.walk-with-jane.com/birds-and-bats

The regeneration of estates was debated in the afternoon session. These areas are often chosen on the basis of the IMD  (Index of Multiple Deprivation). Many groups complained that this meant the vulnerable were shouldering huge burdens and that the results of being regenerated were negative:
  • Redbridge, what do we mean  by regeneration-this way of distributing the housing burden is discriminatory and borne by the vulnerable, we have the third highest waste produced in the country and highest amount of homeless in our regenerated borough, only the GLA can't see what's going on;
  • Peckham Vision, 'how can a plan be sound when developers are permitted to do exactly what they like; when the inspector came to see our so-called derelict land-he was greeted by people proffering business cards as no-one had considered that the local micro- economy was fully functioning, it is these back -street  businesses that will grow;
  • Hackney, a huge area of Hackney is just an adjunct to the City, small business in the railway arches have been driven away, it is not regeneration as inequality has increased;
  •  Euston, indigenous population harmed by the costs of local gentrification;

    Gardens gone, grass verges gone, playgrounds privatised,
    • Just Space, Sustainable Development Group, My Fair London had similar positions and suggested changes to policy, wording of the Plan, collaborative partnership working not top down; 
    The only positive statements - other than from the GLA- came from a group from LB Brent commenting on the development of Old Oak Common and the role of the Development Corporation which prepared a planning framework; and Greenspaces Network, which commented on the number of friends groups now co-managing parks.

    Former Packington estate, Islington and wildlife desert


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