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The London Plan Consultation 2017/2018

When it comes to planning policy, developers in London have to work to the most stringent set of rules in the UK. But it’s about to get tougher still as The London Plan – the policy document implemented by all the Capital’s boroughs – is going through a complete rewrite.

The draft is open for consultation until March 2nd, with the finalised document expected to go live by the end of 2019. There is a huge development strategy to increase housebuilding in the capital.

Right from the off, Sadiq Khan (The Mayor) is calling this 500+ page document a ‘new and ambitious’ London Plan, which takes a ‘stepchange in our approach’ and is a ‘blueprint for the future’ of the capital.

And when you consider the number of policies and pages that are purely dedicated to new houses and redevelopment, you realise that the construction industry is the main player to shape the Mayor’s London of the future.

The number of new homes needed isn’t just a finger-in-the-air guess. Each local borough has been given a precise housebuilding target to hit over the next 10 years, adding up to more than 66,000 new homes every year.

Newham, Tower Hamlets and Greenwich have the biggest targets to hit – each to provide more than 30,000 new homes through the next decade.

Despite the amount of housebuilding planned, the focus isn’t just on major schemes; separate targets have been set out for small sites (25 homes or less), with Croydon, Barnet and Ealing set to lead the way.

Specific parts of London have been highlighted as Opportunity Areas, brownfield land and surplus public sector land – key targets for growth and new construction in areas such as Crossrail 2, the Bakerloo Line extension and the Thames Estuary.

On the flipside, Central Activity Zones are areas where proposals for new homes are going to be discouraged. Local planners will instead focus on providing more shops, offices and places for
entertainment – places that you would expect to find in a bustling town centre.

The mix of homes is also going to be monitored with separate targets in place for new sheltered houses, care homes and student accommodation. ‘Urban Greening’ will also be checked on new developments. This equation will measure the amount of trees, green roofs and sustainable drainage when compared to the development size.

Of course we can’t just build houses alone; the London Plan also sets out ambitions to create tens of thousands of new jobs by looking at town centre redevelopments, by building more low cost offices and workspaces, and by asking boroughs to identify the kinds of shops, eateries and offices they need from their local perspective.

There is also a policy targeting authorities to take action over unused land which has long-term plans. The ‘Meanwhile Use’ policy encourages the idea of short term, prefabricated homes to be built on land while the long term use is still being finalised.

The Mayor coins the phrase ‘Good Growth’, looking to move away from building for building’s sake, and turning attention to cheaper, more sustainable development where Londoners can afford to rent and buy in more places.

As part of this, there is an ambitious target peppered throughout the proposal that 50% of new development on public sector land must be affordable (lowering to 35% on private land). If developers are happy to meet these figures, they will be given options to fastrack through the planning process.

In other cases, developers will need to prove why they can’t build affordable homes as part of their scheme, and may be allowed to offset by building affordable homes elsewhere, or writing a cheque to the local authority so they can invest in affordable homes elsewhere.

Expect more scrutiny on high density development, and a separate spotlight will be pointed at redevelopments that try to build less, larger homes than were there previously.


There are some big changes to the Energy Hierarchy, which will have significant impacts on construction budgets. The Hierarchy has been intensified in the consultation and all major developments should be net zero carbon by following four steps.

Be Lean: development must use less energy. This is being expanded to cover emissions from construction and operation, adding significantly to a development’s overall carbon emissions.

Be Clean: supply energy efficiently and cleanly. Sites should exploit local energy resources (which includes existing heat networks and waste heat from adjacent buildings, or even the Underground network).

Be Green: generate, and store, onsite energy from renewable sources.

Developers will be expected to achieve at least a 35% improvement over the Part L Target Emission Rate using these steps, with at least 10% (residential) or 15% (non-residential) exclusively through energy efficiency measures. Post construction monitoring and reporting of energy use will also be required.

The fourth step to the Energy Hierarchy is Carbon Offsetting. Either write a cheque for the remaining CO2 levels, or offset by other means (such as improving the energy efficiency of an existing building). Until now, it’s usually been more cost effective to reach the 35% improvement and make a payment for the rest, but going forward more emphasis will be put on developers to do more onsite by pushing for tougher checks on what is feasible.

Currently the carbon offset payment is £60 per tonne of CO2 over 30 years. This could rise to £95 – more than a 50% increase! There’s an interesting dilemma within the Be Clean section, which has often led to large schemes introducing CHP engines for heat. Separate policies around air quality and NOx levels could mean CHP engines are discouraged in certain areas with more emphasis on low NOx heating systems.


Air Quality

One of the more ambitious policies concerns air quality, and how it can be improved in London. ‘Development should not lead to further deterioration of existing poor air quality’. Where new homes and offices are being constructed in Air Quality Focus Areas, they will need to be ‘Air Quality Positive’ – that means the development must do it’s bit to make the surrounding air cleaner. How this will actually be done will need to be defined through an SPG, to give consistency when measuring air quality. Other large developments must be shown to be Air Quality Neutral.


Design Quality

The quality of the homes being built is also under review – nationally recognised Space Standards have existed for several years, but the new London Plan redefines it’s own minimum floor areas for all new homes going forward (which is very similar to the national standard, but with an extra line about minimum levels of external space). Accessibility is also being ramped up, with a requirement that 10% of all new homes should be wheelchair friendly, and the remaining 90% should meet ‘accessible and adaptable’ standards of Part M. Good levels of daylight are also required, with designers being discouraged from single façade apartments to ensure air quality and minimise overheating risk.

The Cooling Hierarchy, which exists to combat overheating in heavily glazed apartments, remains virtually unchanged in the new document.


Other points of interest...

Elsewhere in the document there is a focus on the trend to build down rather than out. Inner London boroughs need to address the ‘negative impact’ of large scale basement extensions. Car parking spaces for new developments are actively being discouraged, especially on sites with good transport links and which have poor air quality. An equation setting out the maximum permitted spaces for all kinds of development has been established. Water use for new dwellings remains at 105 litres per person per day, with commercial properties expected to meet the WAT1 target of BREEAM Excellent. And a topic close to many hearts, a policy on pub protection has been added. Developments near pubs and music venues must be designed with additional acoustic performance in mind to reduce the risk of occupants complaining of noise levels, which has already led to the demise of many a decent boozer.

In line with the Government’s own thoughts, the London Plan reiterates that there’s no quick fix to the current housing crisis.

With so many ambitious policies proposed, the Mayor of London is setting the Capital’s housebuilders on a clear path towards building cheaper, more sustainable developments than ever before.

You can find the full document in the Planning section of – you have until March 2nd to have your say. Work will continue to refine the London Plan until it’s predicted launch in Autumn 2019.



Jon Ponting

Author: Jon Ponting

This article was published by Jon Ponting on 19.12.2017.