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The Planning and Regeneration Committee of the London Assembly is carrying out a piece of work on on Tall Buildings in London.

This ‘investigation’ will consider the current stock of homes in London’s tall buildings and how they impact residents. It will examine:

• the current demographics of residents of tall buildings (who is being served by this building typology).
  • the attitudes and experiences of residents in tall buildings.
    • how tall building policy should be considered in the future London Plan.

The committee issued a ‘call for evidence’ with a deadline of March 4th. OONF has submitted a paper which can be read/downloaded below. This focuses on North Acton as an example of how a major new cluster of tall buildings can emerge in London in relatively unplanned way.

From 2015 onwards the OPDC became the planning authority for North Acton. But decisions on major planning applications were delegated back to Ealing Council. Until the OPDC Local Plan was adopted in 2022 there was something of a vacuum in relation to up to date planning polices applying to North Acton. ‘Developer-led’ proposals have had a huge impact.

The location has seen a major expansion in numbers of student bedspaces granted planning consent. Two more major schemes involving towers of 54 storeys and above have yet to start construction (the Imperial College proposals for One Portal Way and the ‘twin towers’ from Aldau Development at 4 Portal Way.

North Acton now has an unusual demographic and a physical environment that many feel is far from a successful example or urban renewal.

The organisation Ealing Matters has also submitted evidence, on the spate of tall buildings developed across the Borough in the past decade.

At its September 2024 meeting, the OPDC Board commissioned an external review of its own ‘effectiveness’.   The Board is responsible for leadership, setting strategic direction, and overall policy for the Corporation.

The review has been carried out by consultants Campbell Tickell.  Their report will be discussed at the December 5th meeting of the Board. 

As covered in a previous post  we have been making the case for two years for an independent review of the track record and achievements to date of the OPDC.  We welcome this latest exercise, and asked if the Old Oak Neighbourhood Forum and Grand Union Alliance could provide the consultants with a note on the background to ‘community input’ to the work of the OPDC.

It is now almost a decade since OONF and the GUA formed to join up the work of local residents groups across the Boroughs impacted on by OPDC and HS2 plans and activities.  We feel that our experience in our dealings with both bodies is very relevant at this time. 

A third Mayoral Development Corporation is to be established in London, to oversee plans for Oxford Street.   Some form of development corporation has been proposed for Euston, by the former Prime Minister last October and by the current Secretary of State for Transport Louise Haigh. 

The extent to which local people will have any opportunity to contribute meaningfully to the work of these boards, and to influence outcomes, is an important topic for Londoners.   We have had serious reservations about the way in which the OPDC has operated since 2017, and some doubts about the inherent tensions of a model which combines the role of ‘delivery agency’ with that of a planning authority. 

Removal of these powers from a local council is one issue, and the fact that MDCs do not have responsibility or powers to deal  with highways, transport and social infrastructure is another,

OPDC’s David Lunts agreed to pass on our views on ‘community input’ to the consultants undertaking the effectiveness of the OPDC Board.   These are taken account (to a limited extent) is the Campbell Tickell report.  There remain concerns which we feel the Board should consider when it discusses the review, and a follow up letter will be posted here shortly.  

The Government has been consulting on a set of changes to the National Planning Policy Framework (NPPF).   This document is the core set of guidance for local planning authorities, first published in 2012 and revised several times since then.

These latest revisions are linked to Government proposals to reinstate mandatory housing targets for each planning authority in England.  The figures for these targets, derived from a new algorithm or ‘standard formula’ have features widely in the media as they involve significant uplifts – particularly for Boroughs in central London.

In reality, housing targets for London Boroughs are set by the Mayor of London in the London Plan.  The 2021 London Plan is at the early stages of a revision.   The OPDC area does not feature in the list of theoretical London targets, as the data used in the formula is not available for an area that crosses parts of three local authorities.

There are other aspects of the NPPF consultation which have implications for the OPDC area.  We have submitted a response, a copy of which can be downloaded below.

NPPF consultation 2024 response from OONF.V2

A new application at this site was submitted to OPDC by applicants Aldau Development.  The application is in the name of Gypsy Corner Portal Co. Ltd.   Aldau are an Egypt based real estate company active in the global hotel and leisure industry.

OPDC has convened a briefing session on the proposals for Monday 13th May at the Holiday Inn on Western Avenue (6.30pm).  Some OONF and GUA members will attend.

The content of a draft objection letter to the proposals was also discussed at our session.   A copy can be downloaded here 4 PORTAL WAY OONF OBJECTION.Draft

Apart from objecting on the grounds of excessive height, density, and lack of provision of public open space, this OONF objection also argued that the applicants cannot rely on the existence of an ‘extant’ planning permission for similar twin towers at 4 Portal Way.

This previous application was granted consent by LB Ealing’s Planning Committee in February (with the decision delegated by OPDC).  At that time Ealing Council had failed to make a formal decision to enter into the Scheme of Delegation put forward by OPDC.   It has since been argued that this and a number of other ‘delegated’ planning decisions made by Ealing are void for want of proper authority.

OPDC, as the body which initiated the delegation scheme, needs to satisfy the public that this previous planning consent at 4 Portal Way should be treated as a ‘material consideration of considerable weight’ (as claimed by the applicants in their Planning Statement).

The Old Oak Neighbourhood Forum is currently looking back at a critical period in the history of the OPDC and its plans for regeneration at Old Oak.

This period was the second half of 2018.  At this time Cargiant and their development partner London and Regional Properties had been consulting on a fourth iteration of their masterplan for ‘Old Oak Park’.   This proposed  development had been worked up over the preceding years, for the 46 acre landholding at Hythe Road W10 on which Cargiant has built its business.

This was the the ‘Place’ which OPDC badged as Old Oak North in its first Draft Local Plan. The area was destined to include a new Overground station, connecting to the planned Old Oak Common rail interchange.  A new ‘high street’ with retail and commercial floorspace was to bridge across the Grand Union canal, and east west road connections were to improve connectivity in the Old Oak part of the Opportunity Area.

In 2017 OPDC engaged a consortium of consultants led by AECOM to prepare its own masterplan for Old Oak North.  Relationships between OPDC  and Cargiaant became difficult.  In September 2018 Cargiant’s owner wrote to OPDC to say that the company was withdrawing its support for OPDC’s bid for Housing Infrastructure Funding, abandoning its plans for ‘Old Oak Park’ and wished to stay on its existing 45 acre site.

Lack of transparency by OPDC about the existence of this letter from Cargiant led to a year in which OPDC continued with its plans for Old Oak North.  Only at a session of the Local Plan Examination in July 2019 did the extent of the gulf in the thinking of OPDC and Cargiant become fully clear.

Q&A sessions of the London Assembly and its Budget and Performance Committee at this time also began to expose the problems ahead, in respect of OPDC’s Local Plan proposals for Old Oak North.

After a highly critical report from the London Assembly Budget and Performance Committee published in January 2021, OPDC posted in its website much of the documentation relating to its failed bid for HIF funding.

What did not appear on the OPDC website were the letters, press releases and briefing notes from Cargiant, setting out its own position in that critical period.   OONF has gathered these together, as they throw light on a period in the history of the OPDC when (in our view) things began to go wrong for OPDC.

We are preparing a paper on this subject which will be sent to London Assembly Members in due course and after the May 2nd 2024 Mayoral and GLA elections.

Meanwhile the Cargiant material is available at the links below.  This includes the letter from Cargiant’s Geoff Warren to OPDC interim chief executive Mick Mulhern of 18th September 2018.  This has been obtained recently by OONF in response to a FoI request and has not previously been available to the public (to our knowledge).

OPDC letter March 2024 releasing Sept 2018 Cargiant letter

Cargiant Geoff Warren to OPDC Mick Mulhern 18 Sept 2018 on HIF bid

4th consultation by Cargiant on Old Oak Park masterplan 2016

Cargiant.BriefingSheet.Feb2019

Cargiant to OPDC Board re HIF bid 7 Feb 2019

Letter from Cargiant to OPDC Board May 30th 2019

Letter from Cargiant to London Assembly Budget and Performance Committee June 14th 2019

Essential Questions for the London Assembly to ask the OPDC July 2019

PressStatement from Cargiant 19 July 2019

Cargiant press release Sept 2019

Cargiant to Mayor of London Feb 2020

Letter-from-Cargiant-to-Secretary-of-State-5-May-2020 redacted

 

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)

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.

 

 

 

 

 

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’.

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.

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’.

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.

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

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