OONF letter to OPDC Board February 28th 2024 and TfL slides

The Old Oak Neighbourhood Forum has sent a letter to the Chair and all members of the OPDC Board, setting out the growing concerns of local residents on recent news from HS2 and TfL.

  • problems identified by Transport for London (TfL) on the design and layout of the Old Oak Common rail interchange
  • continued lack of any workable solution to provide road access at the eastern end of the interchange, increasing reliance on the western entrance/exit on Old Oak Common Lane
  • announcements from HS2 that this section of Old Oak Common Lane could be closed to vehicles for as long as 4 years, for works to lower the road and install utilities.

We continue to believe there is lack of dialogue between the key agencies involved and the ‘host’ Boroughs.   It is the Boroughs which are the Highway Authorities for the interchange and the area now badged as ‘Old Oak West’.

Our letter to the Board can be downloaded here: OONF to Liz Peace on HS2 and OPDC plans Feb 2024.V4.1OONF to Liz Peace on HS2 and OPDC plans Feb 2024.V4.1

The TfL slides from October 2023 can be downloaded here: OOC DfT Surface Oct23 v3.0 (002)

Our requests to the London Assembly for a review of OPDC

This time last year, our Forum made submissions to two committees at the London Assembly.  We asked these committees to request the Mayor of London to commission a second review of the track record of the OPDC and its future plans.

The Mayor has a statutory duty to review the work of the OPDC ‘from time to time’.  The first and only review took place in 2016 and was carried out internally by an Executive Director at the GLA.  We believe that an independent review is needed this time round.

Last month, our November 2023 submission to the Assembly’s Budget and Performance Committee was available via a link on the front page of this website.  That front page has since been updated.  The document can now be found at this link  OONF submission to Band P committee Nov 2023 final

The OPDC Board met on November 23rd.  Unusually there is no webcast recording of this meeting on the London Mayor website, as it was held at a one-off venue at Oaklands Rise.  OONF and GUA representatives attended as members of the public.

The meeting included a presentation from HS2 on the position at Old Oak Common station, following the Government announcements on October 4th.  This was followed by Board members asking questions of HS2.  Slides from our last OONF/GUA meeting on December 5th give more detail.

Put simply, we do not believe the claims from HS2 and OPDC that little or nothing has changed for the prospects of ‘strategic transformation’ of the area surrounding Old Oak Common station, as a consequence of cancellation of the HS2 project north of Birmingham.

We have questioned many times in recent years the claims made made by HS2 that Old Oak will become the ‘best connected location in the UK’.  And also the (continued) claim from OPDC that Old Oak will have ‘unparalleled connectivity’.

If ever true, these claims ceased to reflect reality once it became clear that a new Hythe Road Overground station fell off the agenda, a new Old Oak Common Lane Overground station remains unfunded, and no new east/west road connections are provided for in the OPDC Local Plan.

We are therefore submitting a further note to the London Assembly Budget and Performance Committee, following the November 23rd OPDC Board meeting.  Impact of HS2 cancellation on OPDC plans for Old Oak.draft.  This committee will be reviewing the OPDC 2024/5 budget of £11.8m at its meeting on December 12th.

This further note repeats our request for an independent review of OPDC and highlights issues on which we see OPDC (and HS2) as continuing with a fixed and over-ambitious vision of the impact of the rail interchange at Old Oak on the surrounding area.

As local people, eight years into the life of the OPDC and after many changes to the 2015 ‘vision’, we longer see OPDC plans as credible.  A new iteration of the London Plan will provide an opportunity for revised and more realistic proposals.

 

 

 

 

 

One Portal Way – the proposals are granted planning permission by OPDC

OPDC’s Planning Committee on October 12th agreed to grant planning permission to the application from Imperial College.   Details of these proposals are covered in previous posts.  Below is a reminder of their scale and their impact as an addition to the ‘North Acton Cluster’.

Picture1

The application was originally submitted to OPDC in November 2021.  Changes since then (including the addition of a second staircase to the three residential towers (all above 50 storeys) have contributed to delays in a  decision.

At the committee meeting OONF (Henry Peterson) was given ten minutes to speak as an objector.  Imperial and architects Pilbrow & Partners had a similar time to respond.  OONF had submitted six objections over the past two years.  The most recent argued that the timing of a decision was wrong, given that the whole planning context for ‘Old Oak West’ has been impacted on by the Government’s October 4th decision to reduce the scope of the HS2 project.

We also questioned how Imperial intend to finance an 11 year build project, when construction and borrowing costs have increased dramatically since the application was submitted.   Imperial gave no answers on this subject.

It emerged at the meeting that construction cannot start until late 2025.  Imperial College have a lease arrangement with Currys/Carphone Warehouse and the project has been hit by the problem affecting many in the area – the lack of electricity capacity from Scottish and Southern Electricity Networks (SSEN) and the National Grid.

The same committee meeting also approved a consultation version of the long awaited Supplementary Planning Document for ‘Old Oak West’.  Quite why a decision on One Portal Way had to be made before the start of this six week public consultation remains a mystery.  While the site is just outside the boundary defined for this SPD, it is very close.

The Draft SPD designates a ‘North Acton Cluster’ north of Victoria Road, in the following planning speak:

P7C1 North Acton town centre Cluster
A vibrant high density neighbourhood town centre, focused on an enhanced North Acton Station and new station squares. Active throughout the day, a range of town centre uses will strengthen the area’s identity. High quality and coordinated public realm, framed by active frontages will guide people to their
destinations. 

One major benefit of the proposals at One Portal Way is the planned central public open space – provided that this materialises as shown in the plans and CGIs. Revised phasing of the project and intended ‘meanwhile’ use of the Carphone Warehouse building (see earlier post) have reduced the size of this space, and we may see hoardings surrounding it for many years yet.

The six objections submitted by OONF can be downloaded below:

OONF 1st objection

OONF 2nd objection OONF_

objection_3

One4 Portal Way OONF objection No 4

One Portal Way. 5th objection from OONF

One Portal Way. 6th objection from OONF.final

It will be well into the 2030’s before conclusions can be reached on whether OPDC and Imperial are making the right decisions on the future of North Acton.   What has been built there since OPDC came into existence in April 2015 (much of it the result of applications delegated to LB Ealing) is seen by many local people as an example of the worst aspects of urban renewal in UK cities.

Imperial College proposals for One Portal Way – further changes

OPDC are consulting on a second set of changes to the application submitted back in November 2021 for a highly ambitious development at One Portal Way, North Acton.  The CGI below shows the intended project on completion, including 3 further residential towers added to the ‘North Acton Cluster’.

Picture1

These latest proposed changes to a 20 month old planning application are described by OPDC in its notification letter in these terms:

• Amendment to the demolition strategy
• Amendment to the construction phasing plan
• Amendment to facilitate the provision of a temporary ‘Meanwhile Use’ within the site.

While such changes may sound innocuous, in reality they involve a rephasing of this highly ambitious scheme for 7 residential/commercial buildings.  ‘Meanwhile Use’ of the existing Carphone Warehouse building means that the promised central public open space will not be created in the form that has been promised to the public as part of Phase 1 of the development.  This open space, with new pedestrian and cycle routes, was the one redeeming feature of the overall scheme.

This public open space is described on the consultation website for the public as a new heart for North Acton to meet the needs of existing and future communities. It has the potential to knit together other local developments to create a vibrant hub with something for everyone.   

It now looks as though this ‘new heart’ will not start beating for many years yet, were the project to be given planning consent by OPDC Planning Committee.

Picture1

OONF has long had questions over this set of proposals from Imperial College.   While Imperial already have a presence at North Acton, in the form of blocks of student housing, the proposals for One Portal Way have no academic or university content.

In October 2021 we asked to Office for Students (the regulatory body for universities) whether the College’s Charter provides the statutory powers to undertake solely commercial development activity as a form of investment?   The OfS declined to pursue this question with their legal advisers.  Imperial argue that their activities in relation to development are unfettered and that any form of ‘investment’ activity can be pursued.

These latest proposals for meanwhile use on the eastern part of the site at One Portal Way suggest that the College may be rethinking how it can finance the costs involved on a project of this scale.  We have had no answers from Imperial on how they intend to meet borrowing costs at  interest rates far higher than when the plans were drawn up by Pilbrow & Partners.

OONF has previously submitted four sets of objections to the 2021 planning application for this scheme.  We have now added a fifth, in response to these latest proposed changes.   This can be downloaded below, along with our 2022 submission to the Office for Students and a letter to the College.

We argue that the present application (for full permission for two buildings and outline permissions for a masterplan with the remaining five) should be withdrawn.   The College is a university in receipt of public funds and (like all universities) an ‘exempt charity’.

We think the 2021 proposals are now very high risk and that the College should proceed more incrementally and cautiously – rather than attempting to add to very high-density/high rise buildings bringing notoriety to the ‘North Acton Cluster’.

One Portal Way. 5th objection from OONF

Third Party Notification OONF October 2022

OONF to Imperial AW August 2023

Proposals for 5-7 Park Royal Road

This application is for development of new mixed use buildings on two sites in Park Royal Road.   The proposals are for a 33 storey building (Block A) for 988 student beds (small studios) and for a 15 storey building at Block B with 63 residential units.

In early public consultation sessions on this development, the applicants claimed that these buildings would be located within the ‘tall building zone’ at North Acton.  This was not true, as swiftly pointed out by OONF and neighbouring residents in homes along Western Avenue.   The sites lie within the OPDC ‘Place’ of Park Royal West’

Ever since proposals from Tiago Properties Ltd first surfaced in March 2022, OONF has been questioning how come these locations were added as ‘tall building sites’ at the very last stage of OPDC ‘modifications’ to the OPDC Local Plan.

This sequence of events is set out in a lengthy letter of objection to the application.   Copies of previous email correspendence on this development, between OONF and OPDC are also available for download below.

The Forum sees these proposals as a classic example of how landowners and speculative developers can use the planning system to bring forward schemes which fall outside existing policies and yet achieve supportive pre-application advice through a series of meetings and negotiations,

It has become well known that OPDC will look favourably on speculative development proposals – in its efforts to demonstrate a pipeline of housing schemes which will help the Development Corporation to display ‘momentum’ towards its ultimate target of 25,000 new homes in the OPDC area.

In the 8 years since the OPDC was established, this search for ‘momentum’ and ‘delivery’ has already led to the grant of planning consents which many West Londoners see as premature and unwise.  Uncertainty remains over the impact on the area of HS2, assuming Stage 1 from Birmingham to London is completed and Old Oak Common Station opens sometime between 2029 to 2032.

What form will a ‘new Old Oak’ take given the latest timeline for the link to Euston (early 2040s).   Is North Acton a good example of urban renewal in a global city?  Or could lessons be learned from other European cities which seem to manage large-scale regeneration more successfully?

If you wish to comment on the application at 5-7 Park Royal Road, there is still time to do so by emailing planningapplications@opdc.london.gov.uk with your views.  You need to quote the application reference 23/0014/FUMOPDC  and include your name for your comments to be taken into account.

Relevant correspondence with OPDC, including the detailed objection letter from OONF can be downloaded below:

OONF objection on 5-7 Park Royal Road.final

opdc-51_tall_building_heights_proposed_modifications

OONF and OPDC emailexchanges April 2023

OPDC EW to OONF 20 June 2022

 

OPDC and OONf email exchange September 2022

 

Government announcements on HS2

Shortly after our last open meeting on March 7th, the Secretary of State for Transport submitted to the House of Commons a Written Ministerial Statement (March 9th) on revisions to a series of Government transport projects.

On HS2, the statement said as below:

In rail, HS2 is making good progress, and we have already spent over £20 billion delivering Phase One between London and the West Midlands, supporting 2,500 businesses and creating over 29,000 jobs. The Government is prioritising HS2’s initial services between Old Oak Common in London and Birmingham Curzon Street to provide delivery of passenger benefits as soon as possible. We remain committed to delivering HS2 services to Euston, and will address affordability pressures to ensure the overall spending profile is manageable. We will therefore take the time to ensure we have an affordable and deliverable station design, delivering Euston alongside high-speed infrastructure to Manchester. We continue to take the High Speed Rail (Crewe – Manchester) Bill through Parliament, and the Crewe-to-Manchester section will also form the foundations for improved rail services in the North through Northern Powerhouse Rail.

Subsequent media coverage suggests that ‘prioritising’ the service to Old Oak Common and undertaking a further redesign at Euston means that the Euston terminus will not open until the 204os.

Leader of Camden Council Georgins Gould has said :

The community around Euston have lost homes, schools and businesses to HS2. They’ve already lived through years of disruption with no end in sight. If there is a delay, HS2 must not forget the promises they made to our community and must continue to deliver on them.

What we can’t have is a partially abandoned building site, with huge areas fenced off creating a barrier between our communities, and a general stagnation which leads to opportunities being lost. Instead, HS2 Ltd. need to make sure they open up the site where it is safe to do so and work with our communities on how they can be used during any delay.

There is as yet no press statement from OPDC on the implications of Old Oak Common station remaining the London terminus for the Birmingham/London stretch of HS2.   The Mayor of London has commented having trains going to Old Oak Common for a longer period is not a viable option.   Passenger numbers on the Elizabeth Line are already forecast to become unmanageable, without having to cope with all HS2 passengers  changing trains at Old Oak Common.

“Hundreds of millions of pounds have been spent regenerating the Euston area, and homes and businesses have been demolished to make way for HS2, causing huge disruption for zero reward.

As yet there seems to be no clarity on the impact of this Government announcement on the timetable for the release by HS2 of the four key sites at Old Oak West,  in use at present as construction compounds.  Last autumn HS2 were saying that The Atlas Road site is currently anticipated to be released in Q2 2032, which is later than the other three sites as it is a key part of the delivery of the HS2 Euston station.  (We think that HS2 refer to the whole construction compound at Channel Gate/Atlas Road as ‘the Atlas Road site’).

This slide bellow, which we have been using at our recent open meetings, may now be out of date.

HS2 site release dates

What are the implications of these latest Government announcements for the Old Oak West Supplementary Planning Document, and for the planning and development of a ‘major new town centre’ at this location?

The OPDC Place Lab sessions, organised by consultants Soundings, will be the first opportunity for local people to find out more and to discuss the consequences of Old Oak Common station remaining the HS2 terminus for what is now an indefinite period?   While the present Government has given a commitment to extend Phase 1 of HS2 as far as Euston, who knows what the position will after a General Election or in 5-10 years time?

The dates and locations for the three Place Lab sessions are below:

Place Lab sessions

 

OPDC’s response to our request for a review of this Mayoral Development Corporation

In November 2022 we sent to London Assembly Members a detailed submission, arguing the case for a full review of OPDC.   This document was included in a previous post on this website and can be downloaded here OONF Submission to Budget and Performance Committee. November 18th 2022

The submission was referred to in the discussion at the Assembly’s Policy and Resources Committee on December 7th 2022 Supplement Minutes – Appendix 2 – Old Oak and Park Royal Development Corporation 07122022 1000.   Len Duvall AM, as chair of that meeting asked David Lunts (OPDC CEO) to provide a written response to the points that we made.

This OPDC response was provided in the form of a letter to the Chair of the Committee (see at David Lunts to Chair Budget and Policy Cttee 31.0123).

Our open meeting on March 7th will be discussing this response and whether our members feel that it addresses the points made in our submission.   The letter makes no comment on the need for a review of OPDC.

The Mayor of London has a statutory duty to review both of the two Mayoral Development Corporations ‘from time to time’ (OPDC and the London Legacy Development Corporations).  Given that the last review of the OPDC was in 2016, we feel that a further review is overdue.

As set out in our submission, local residents at Old Oak are increasingly worried that OPDC’s ‘change of direction’ in November 2019 is not going to plan, and cannot now go to plan.   The choice of ‘Old Oak West’ as the focus for new development and a ‘major new town centre’ has locked OPDC into waiting until the key development sites are released by HS2.

Delayed release dates by HS2 have not been reported to, or discussed by the OPDC Board or by the OPDC Planning Committee.  We do not understand why, other than a desire by the Corporation to show that ‘all is well’.  The implications for the ongoing grant of planning consents at Old Oak West, for high density/high rise housing, are significant.

HS2 site release dates

Promises made by developers in marketing materials, of the arrival of new shops, amenities, open space and a ‘major town centre’ at Old Oak West have become fictional.  The same applies to the forecast opening date of Old Oak Common Station (originally 2026 and now 2032, if then).

It is true that almost every major regeneration initiative in London (Canary Wharf, Kings Cross, Vauxhall/Nine Elms Battersea) has seen delays, revised timescales, and new housing left stranded without surrounding amenities and social infrastructure.   We understand and accept that regeneration projects in the UK extend over decades, while cities such as Paris achieve much faster progress under different planning systems.

But this is no excuse for keeping the public in the dark on delays, or pitching over-optimistic versions of ‘momentum’ and ‘delivery’ to London’s development industry and to the public.   We will be continuing to argue the case for a second review of OPDC and its proposed approach for the period 2023-2030.

 

Ealing’s new Local Plan

Ealing Council is carrying out consultation on a first draft of its new Local Plan.   The existing local plan for the Borough is made up of a 2012 Core Strategy and a 2013 Development Sites DPD.

It is one of the most outdated local plans of any London Borough.  Hence a source of regular concern from local people that the Council’s Planning Committee takes a very cavalier approach to deciding whether applications conform with ‘planning policy’.

Details of the Regulation 18 Draft Local Plan are here on the LBE website. The consultation was originally due to close on January 25th 2023 but we hear that it will be extended for a further two weeks.

The new Local Plan for Ealing will not cover that part of the Borough which lies within the OPDC boundary.  The OPDC Local Plan, with its policies and site allocations, will continue to apply in this part of Ealing.

Ealing Local Plan

This Regulation 18 version should be followed by a further Regulation 19 version in autumn 2023 – once comments and feedback from residents, landowners, developers, and interested public agencies are taken on board.

You can comment directly to the Council by emailing to localplan@ealing.gov.uk .   Or if you prefer to send any thoughts to us at the Old Oak Neighbourhood Forum, you can send them to oonforum@gmail.com and we will incorporate them in our response.

We will be commenting mainly on the part of the Draft Local Plan which covers ‘Acton’.  This is one of the seven ‘Towns’ around which the new Local Plan is being structured as shown in the map above.   Note that this ‘Town’ does not include the increasingly notorious ‘North Acton Cluster’ of very tall buildings.  This lies within the OPDC boundary.

We are working with Ealing Matters in putting together our response.  Following discussion at the OONF and Grand Union Alliance meeting on January 3rd 2023, they have provided us with several working documents to assist in preparing a response to the Draft Plan.   This includes a helpful set of slides as well as other more detailed material:

Ealing Matters Local PLan slides

Ealing Matters High Level notes

LBE not fulfilling statutory duty

Critique of Shaping Ealing reports (final)

The case for a full review of the OPDC

The London Assembly’s Planning and Regeneration Committee is the body which scrutinises the decisions of the Mayor of London.  The Committee has been looking at the progress in London’s Opportunity areas, and (more recently) the work of the two Mayoral Development Coporations.

These are the London Legacy Development Corporation (LLDC) and the OPDC.  The LLDC has been overseseeing regeneration at the Olympic Park (created for 2012 Olympics) and the immediately surrounding area.  This Mayoral Development Corporation is now ‘in transition’ and in 2024 will be handing back its planning powers to the 5 London Boroughs, parts of which lie in the LLDC boundary.

We think that there is a strong case for OPDC to do the same.  OPDC’s efforts to deliver ‘regeneration’ at Old Oak have fallen out of sync with the timescale for completion of Old Oak Common Station (originally planned for 2026).

The transfer of public land, as envisaged in a 2016 Memorandum of Understanding between the Department for Transport and the Mayor of London in 2016 has not happened.  It is not certain that this will ever happen.   OPDC has no other assets or funds for insfrastructure (unlike the LLDC which took over the land used for the Olympic Park).

Our Forum was invited early in 2022 to submit evidence to the Assembly’s Planning and Regeneration Committee.  We had expected to be invited as ‘guests’ to a session of the committee to be held in June, and then postponed to November.

In the event this session was held on November 23rd.  Neither OONF nor the Grand Union Alliance were invited to attend.  Representatives from Just Space, involved in the LLDC area rather than at Old Oak, were able to be present and to answer questions from committee members.   You can watch the recording of the session.

After this November 23rd meeting, we sent a further letter to the committee members.  See at OONF to P and R Cttee 25.11.2022.  This set out points we had not had the opportunity to make at the session.

The 2023/4 proposed budget for the OPDC is £10.4m, up from £7.8m in the current year.   We have prepared a detailed submission to the Assembly Members on this committee.  See at OONF Submission to Budget and Performance Committee. November 18th 2022.

This submission sets out our perceptions of the track record of the Development Corporation.  We assess this against a set of ‘objectives and expectations’ set by the then Mayor of London in 2014/15. Our conclusions are that outcomes over the past 7 years have fallen well short of these benchmarks, particularly in the period when the plans for the Cargiant land unravelled in 2018/19,

The Budget and Performance Committee will meet on December 7th to discuss the budget proposals form LLDC and from OPDC.  We hope that the Committee will give serious consideration to the option of a full review of OPDC.

The Mayor has a statutory obligation to review both MDCs from time to time, and we think that now is a moment when OPDC’s aspirations need a reality check.   The context and timeline for the HS2 project, and viability for new housing and commercial development at Old Oak, have changed a lot since 2015.

A further decade of allowing a series of scattered high density/high rise developments to take place, with no surrounding amenities and no public transport improvements, is not (in our view) how to create a new and successful part of a global city

 

Adoption of the OPDC Local Plan – the flaws in the process

The OPDC Local Plan was finally adopted by the Development Corporation’s Board on June 22nd.  This is five years later that the original timetable of Spring 2017.

The Local Plan has had a difficult time in reaching adoption.  Previous posts on the website record the history.  The ‘examination’ of the Plan by Planning Inspector Paul Clark ran from October 2018 to April 2022 and involved 464 ‘major modifications’ (a very high number for a London local plan).   We have long argued that

  • OPDC should not have submitted its Regulation 19.2 Draft Plan in the first place, back in October 2018.  Cargiant had by then written to withdraw their co-operation (in a letter the existence of which was made public only in January 2020, in a report from the London Assembly).
  • OPDC should have withdrawn its ‘submission version’ and started on a fresh plan once the Inspector had issued his interim findings in September 2019.  The Inspector ruled that the Cargiant sites must be removed as development landf as an unviable way forward.  This prompted wholesale changes to the local plan, made via a ‘modidfication’ process the scope and duration of which is arguably open to challenge.

In the final stages of decisions by OPDC to proceed to adopt the Plan, OONF has continued to raise issues and ask questions of the OPDC.  Recent correspondence is listed below for those who want to see the detail.

OONF to Liz Peace April 2022.final.2 questioning why a key document of January 26th 2022 (OPDC-51 on tall buildings) had not been considered by the OPDC Planning Committee or the Board.  These very late ‘modifications’ to the Local Plan did not form part of the 2021 public consultation, and were not consulted on subsequently prior to adoption of the local plan.

Liz Peace to OONF May 2022 is the response from Liz Peace saying that Planning Committee members were ‘fully aware’ of the content of OPDC-51. But how was this the case, as the committee did not meet between a meeting held on January 17th 2022 and its meeting of June 16th which recommended adoption of the Local Plan?

Our letter of  11th June to OPDC Planning Committee members, and an summary of the discussion at the 16th June Planning Committee were reported to the OPDC Board in an addendum report at the Board meeting on 22nd June.  This addendum also includes a ‘briefing note’ sent by OPDC Director of Planning to Planning Committee members, respnding to the OONF letter before the committee meeting took place.

After the Planning Committee discussion, OONF wrote to all OPDC Board members in a final effort to bring to their attention the flaws in the content of the Local Plan, and in the process of its long period of examination by a planning inspector.   As yet there has been no reply to this letter.  OONF to Liz Peace for June 22nd Board.V2 final.

OONF will be discussing at it next regular meeting the implications of adoption of the local plan and the extent to which the process leading up to adoption is open to legal challenge.