Do you agree that Sir Davey is right to support vast swathes of Kingston Borough becoming an “opportunity area” ("OA"), that the GLA and the government are to blame for our housing targets and that the council is “legally and politically” challenging that target? Please ask Sir Davey some of the questions below at edward.davey.mp@parliament.uk

1. Sir Ed Davey*: “The very high housing target for our borough is due to the policies of the Mayor and national government (in particular the London Plan) not actually Kingston’s status as an opportunity area”
*statements reproduced with kind permission of Sir Ed Davey from correspondence with a Kingston resident

Question 1: Kingston’s large site target flows from the “Direction of Travel”. Why doesn’t Sir Davey oppose this target given the Direction of Travel (“DoT”) is a flawed and unsound document and the current LibDem council leader herself voted against it?

According to the South West Boroughs (Richmond, Kingston, Merton and Sutton) submission M19 on Housing Targets to the Examination in Public of the London Plan (EiP), each of the 4 south west boroughs has roughly similar small site development targets.

The difference is in LARGE SITES. Kingston’s has 42% of total large site development which comes from sites submitted by the council to the GLA, many of which are confidential – but which include sites for significant development in many areas of the Borough, including mass high rise redevelopment of council housing sites and around railway stations and development on Metropolitan Open Land (“MOL”) and the Green Belt.

2. Sir Ed Davey “the Opportunity Area does not mean that Kingston’s housing target has increased. What it does is ensure support from the Greater London Assembly in delivering housing growth. Indeed, the reason for going for this status is that it gives money to the council for infrastructure without increasing the borough’s housing target.”

Question 2: How can Sir Davey support OA status for the Borough when residents were not told the truth about the purpose of the Direction of Travel?

Kingston council worked with the GLA to establish very high growth targets for the Borough to be delivered on large sites across the Borough in the opaque and misleading Direction of Travel (DoT) (see earlier update). The council then allowed the GLA - through the DoT which the council itself snuck through an accelerated approval process over the summer holidays in 2016 - to seek to designate vast swathes of the borough as an “opportunity area”

Residents were never told that the Direction of Travel IS the Opportunity Area Planning Framework needed to establish Kingston as an OA in the new London Plan. The image above is the agenda item for the Mayor's Planning and "SDS" meeting at which the DoT was approved

The opportunity area doesn’t mean our housing target HAS gone up, it means it WILL go up further

According to the GLA at the EiP session on OAs, which I attended, development targets for OAs are MINIMUM targets. Any large site housing and jobs target that has been agreed with the GLA will therefore become a minimum target if Kingston is designated an OA in the London Plan and that site is within any agreed OA boundary. And, given density of development in OAs happens at vastly elevated densities and includes provision for huge numbers of jobs, both housing and job targets will rise considerably

This growth will happen despite the fact that there is no guaranteed funding for any transport infrastructure improvements except perhaps the GoCycle route. CrossRail2 (“CR2”) may never happen

3. Sir Ed Davey: “The council are challenging the housing target both politically and legally (on the basis that the target is only so high as it is predicated on the existence of CrossRail 2)”

Question 3: In what way is the council legally challenging our housing target, especially given the current administration has not legally challenged the Direction of Travel as a flawed growth document which should not be used to determine growth in the Borough?
Question 4: Why is the council not challenging the target for growth on large sites?

The council’s large site housing target was never dependent on CR2. The Strategic Housing Land Availability Assessment 2017 (“SHLAA”) makes it clear that Kingston will be expected to deliver at least another 16,307 homes on large sites around CR2 stations if we get CR2. Development proposals in the areas that may get CR2 are expected to “plan for its arrival” (DoT) ie start planning now to build at higher densities

The council is NOT challenging large site development

Submissions by the South West Boroughs to the Examination in Public of the London Plan: M19 Housing Supply and M20 Small Sites both include a challenge on small site development and no challenge whatsoever on large site development. Indeed, Kingston Council is one of those four councils arguing that all small site development could more easily happen on LARGE sites. This would push Kingston’s large site development targets up even higher, or mean that the council pushes even harder to build on MOL and the Green Belt

M19 - 1.18 “26,680 net additional dwellings are required from small sites in the Partner Boroughs over the ten-year housing target period. This means that just 18 large site schemes, as defined in the above review, would deliver the same number of homes as the small sites target.”

4. Sir Ed Davey “I know my Liberal Democrat colleagues on the council will be working to ensure new development is in keeping with the character of our area and provides the affordable family homes that are particularly needed.”

Question 5: Ask Sir Davey to explain his comment above in the context of the designation of vast swathes of Kingston Borough as an “opportunity area” after reading the following statement:

Just Space** "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." **https://justspace.org.uk/next-london-plan/opportunity-areas/