Category: Publications and Reports

May 2023. Many of the strongest calls for change in London planning have, in effect, been criticisms of Opportunity Areas, the mechanisms which govern major physical developemnts in the city and are so often spurned as just Opportunities for Developers.

Taking stock of many years of engagement, Just Space has just produced a draft document to help members decide what to do next.

The term Opportunity Area has been in use since the 1990s, applied to areas where very large scale change through development is planned. This report summarises the big shifts in how the designation has been used, initially for the modernisation of employment in under-used industrial, port or railway land, but now for many ordinary parts of occupied London, the aim nowadays being mainly to create development sites for housing through intensification.

Community groups in and around the affected areas have criticised and resisted many of these schemes for decades and tried to secure changes to the London Plan policies which govern them, with scant success. The criticisms have been that the designation, planning and target-setting of OAs have lacked transparency and democracy, as have the mechanisms for implementation. Areas have been planned without the necessary understanding of the social and economic life of the affected areas and the outcomes have mostly been detrimental to working class, including minoritised, communities and to many businesses. Just Space continues to argue that there should be no further designations until a serious review of the programme has been completed and digested.

In the last 2 years Just Space has collaborated with the Planning and Regeneration Committee of the London Assembly which, in turn, has put pressure on the Mayor of London (the planners in the GLA) and secured a new policy document and web site. This represents modest progress.

The aim of the new Just Space report is to bring a scattered narrative up to date and form a basis for Just Space member groups to consider what further steps, if any, to take on this issue in the wider context of how London will be planned in the current emergencies. It thus complements the Community-led Recovery Plan for London prepared during the worst of the Pandemic.

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Because this report was facilitated by UCL Bartlett School of Planning’s knowledge exchange with Just Space, it is being presented initially to students before the summer term ends. The meeting is open to all. Friday 12 May 1600h-1800h, mainly face-to-face but with a zoom option.

checked M. E. 27 July 2025

3 December 2022. When the London Assembly Planning and Regeneration Committee finally got around to discussing Mayoral Development Corporations on 23 November, we made some strong oral statements about what’s been such a disappointment (or worse) at the Corporation which governs the Olympic park and surroundings (LLDC). We had also submitted detailed written evidence in advance. (See previous post.)

The complete video record and agenda papers are here, and the transcript will appear later.

The Committee’s plan had been to scrutinise both Corporations at the same meeting but they switched to an emphasis on LLDC, so they stood down the community speakers lined up to give evidence about the other one, Old Oak Common and Park Royal OPDC. But they still invited the bosses from OPDC who were able to make their speeches unchallenged.

We have written a strong letter to the committee and are sending all our evidence also to the Budget and Resources Committee which is scrutinising both Corporations on Wednesday 7 December at 10.00. We can all attend in person or online or catch up later. Details here. The Old Oak Neighbourhood Forum has also sent a very strong and detailed statement which you can read here, along with ours. Added 6 December a strong letter from Prof Jennifer Robinson .

Our letter to the Planning and Regeneration Committee, copied also to the Budget and Resources Committee, is as follows:

Sakina Sheikh AM, 
Chair of Planning and Regeneration
City Hall + members and staff of P&R committee

Dear Sakina

Mayoral Development Corporations

Following the Committee’s meeting on 23 November there were many loose ends and we considered it necessary to write to you all. We would be glad of a reply to the following points, either in writing or in a virtual or F2F meeting.

1. We have been pleased with the way in which your committee has, this session, taken some community voices on board but it has been hard to keep up with the twists in your programme. Our work on all this, and the work of our member groups, has had no resource from City Hall since 2008 and we believe that an adequate scrutiny system for London will require community inputs to be resourced just as much as it will require much better forensic resources for the Assembly and its committees. 
2. In the absence of adequate resources, we don’t envisage that your committee’s report on MDCs will be able to qualify as an adequate scrutiny and we hope that it will be forceful about the need for a serious scrutiny – an independent one in which evidence is made public and open to challenge. We note that there is no sign yet of action on your recommendation earlier in the session for a review of Opportunity Areas more widely.
3. Your decision, quite late in the day, to focus this meeting mainly on LLDC and thus stand down the community representatives from Old Oak Neighbourhood Forum and the Grand Union Alliance might have been acceptable but the heads of OPDC were on your panel nonetheless and with no independent voices to challenge them. Thus David Lunts was able flatly to deny the allegations of low transparency reported by AM Berry and was later free to denigrate (by implication) both of the community networks as NIMBY ‘usual suspects’, best ignored. Detailed written evidence was (and is) before you on that and you should have had oral testimony too in any fair process. 
4. We need to make a number of specific points on the LLDC discussion, having now listened to the recording of the Q&A.

4.1 On employment displaced for the Olympic Games, we understand that the figures given were based on the numbers employed by companies which received a payout under the CPO so it is an underestimate as there were companies whose leases were expiring who did not receive any compensation.  In addition we know there were people working informally and there would have been people on casual or temporary arrangements who wouldn’t have been included in permanent employment figures. The businesses being evicted claimed as many as 11,000 jobs would be lost, see in this article below. That may be an exaggeration but the figure was certainly higher than 5,000 

https://www.independent.co.uk/news/uk/this-britain/up-in-smoke-the-firm-that-lost-out-in-the-olympics-509766.html

4.2 Lyn Garner’s replies on employment seemed to deal only with jobs on the Park and at the International Quarter, not with jobs elsewhere in the designated area, such as Carpenters about which Dr Myfanwy Taylor spoke, giving a much more negative narrative.

4.3 Lyn Garner’s replies on housing appeared to be limited only to the land owned by the Corporation and to exclude the rest of the designated area for which it is the LPA. And she entirely failed to respond to the question about the influence of rising property prices on housing and workplace affordability more widely in the host boroughs and east London.

4.4 Specifically in our own written submission in May we reported the dominance of open market homes and the low proportions of social housing in the output of the host boroughs between 2010 and 2019 (page 4) and the low proportions of social and “affordable” housing in the LLDC designated area, using data from the Kerslake review and the LLDC’s Annual Monitoring Reports (page 10). More recently, the latest in a long line of research by Dr Penny Bernstock reported at the September universities conference on the Legacy presents detailed figures on schemes within the Park and also for the wider LLDC area, concluding that ‘across the whole area, 29% of housing was affordable and the majority of [the affordable] housing built was intermediate.’ (tables 3, 4 and 5 in Mark Sustr, Housing Legacy, in Bernstock et al (eds) State of the Legacy, UCL, Oxford Brookes, University of Cardiff and UEL, 2022, pp 77-99).  The housing activity of LLDC, as developer and as planning authority for the wider area, has overwhelmingly contributed to the open market stock of homes (70% overall) and not to meeting the needs of a deprived population or reducing deprivation. 

5. We note that the Assembly’s Budget and Performance Committee is considering both MDCs next week so we are sending this letter to them as well.

Very best wishes, (Just Space) 30 November 2022

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Just Space has today written to the members of the London Assembly Planning and Regeneration Committee, prior to their meeting on Wednesday 23rd November about the London Legacy Development Corporation and any lessons which could be learned for Old Oak Park Royal. Interested people should try to attend the meeting in the new City Hall or follow or catch up online. We wrote:

Short statement from Just Space

This meeting on MDCs has been postponed a number of times and its scope has changed. Just Space prepared a substantial submission on both MDCs and submitted it to the secretariat, by agreement, in May 2022. In the changed circumstances indicated by the Committee’s agenda, released on 16^th November, and because the Just Space and other community submissions are not being circulated as supporting papers, it may be helpful if the Committee has this short summary of the JustSpace position.

Openness to community knowledge and inputs

London’s Opportunity Areas have been strongly criticised for failing to pay attention to communities of residents and businesses in and around their boundaries. These failings, by elected local governments and the GLA, were the subject of strong representations to earlier meetings of the Committee and remain unresolved. 

The creation of the two MDCs could perhaps have led to reductions in this democratic deficit if they had strong enough instructions to do so. Initially the LLDC did seem to listen and create space for the Carpenters community to express their needs and develop a Neighbourhood Plan, though in the end it was Newham, as land owner, which was able to override them. In both MDCs a number of local councillors were nominated to serve as a minority on Boards and Planning Committees and this was considered by the Mayor as providing local accountability. However it completely failed, local councillors failing to open up decisions to the community and being complicit in decisions which had adverse community impacts. Where they resisted (as in the MSG Sphere case at Stratford) they were outvoted by the property industry majority on the relevant committee. Simply reverting development management powers back to the Boroughs when the corporations are dissolved is not an adequate answer.

What was valuable was that the requirement on both MDCs to produce Local Plans led to EiPs at which community groups and local businesses were enabled to argue their case, submit evidence and have some influence – just the sort of process which we have always argued should be normal in Opportunity Areas, both for initial planning and for ongoing management. This does not mean that communuty groups are happy with the resulting plans in either case, but they have at least been heard.

Community groups in both MDC areas have pointed to the conflicts of interest which exist between the role of planning authority, responsible for pursuing the public interest and following evidence of need, and development agency, responsible for promoting its developments. A further conflict is between the Mayor of London’s roles as promoter and owner of the Corporations and as ‘person’ accountable and reliable in cases of dispute.

Housing and development achievements

No amount of clever design of special agencies could solve the problem that big development on complex sites cannot be achieved by organisations which don’t own the land and don’t have the money. The LLDC did have a lot of land and should have been able to deliver the socially rented housing so badly needed in Newham and adjoinging boroughs. This priority was not clearly embedded in its foundation nor reflected in its Board members or staffing which appear to have been oriented much more to property development interests and generating capital receipts against accumulated debt. ‘Convergence’ was always an inadequate aim because it could be achieved either by the reduction of deprivation or by the dilution or replacement of deprived people by richer people.

Major urban transformations in our sort of economy boost land values both within their patch and also for miles around and for years to come but the current London model simply tries to capture some of this value through initial negotiated developer contributions from high value developments. Then, when that doesn’t offer all the social infrastructure and social housing that is needed, additional density and height are added to an extent that is unacceptable to citizens and environmentally dangerous. This will be a problem of Opportunity Areas whether or not they have MDCs, but MDCs magnify the ambition and scale of development in ways that have become harmful to sustainable development in London.

The affordability of housing for working class people in east London has been reduced by the price and rent escalation triggered by LLDC, despite the fact that a very small number of households will have benefitted from the tiny provision of ‘affordable’ homes.

The problem is even worse at OPDC where the Corporation had neither land not the capital funding needed to transform this intricate area. Even the land in the ownership of other Mayoral or government bodies was not effectuvely under the corrporation’s control.

The arguments summarised here are elaborated and evidenced in the Just Space evidence submitted to the Committee secretariat on 24 May 2022, available with other documents at JustSpace.org.uk/MDC

18 November 2022

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