Comment
Towards a new London Plan: Urban intensification, tall buildings and heritage assets
The new London Plan consultation sets out the ambition to deliver 88,000 homes a year over the next decade, which represents a 69% hike in the annual housing target over the current plan. But with other goals to meet, how will this be delivered? Is urban densification and tall building development, for residential, as well as mixed industrial and commercial floorspace, part of the solution? Directors, Richard Brookes and Isabel Jones explore the role it should play, alongside opportunities, challenges and the potential impact on heritage assets.
Future urban intensification
The London Plan consultation reiterates the Mayor’s priorities to deliver the homes Londoners need and to grow a good economy. That ambition was, of course, included in the current London Plan, but now the delivery of these priorities is even more critical if London is to flourish in an increasingly unpredictable, global political, economic and physical environment. The core principles of building strong and inclusive communities, and ensuring a healthy and climate resilient city remain relevant, as supported by continuing upgrades to London’s public transport network. This will require the Mayor, and all of us, to think bigger and work more innovatively as we look towards denser and, most likely, taller built development.
There is a perception that London has become a much more intensely used and densely packed place over recent decades, with tall buildings now an established feature. This is true for some parts of the city, but not all, and the GLA notes that in overall terms, London remains much less dense compared to most other world cities.
Taller buildings are going to continue to be part of the answer, but they are not the only solution. The GLA asks if we should be moving to a more prevailing mid-rise townscape where the transport infrastructure can support that densification, with prevailing heights rising from 5 to 9-storeys as common in other European cities. That may require a move away from the more familiar distinction of tall building clusters in urban centres to greater density in traditionally low-rise suburbs. But does this raise questions about the importance of protecting the unique character of London as a ‘city of villages’, or risk impacting on the varied and interesting skyline in the pursuit of a more consistent scale?
Although it cannot be addressed through the London Plan, a major obstacle to densification is the Building Safety Act, which has effectively resulted in developers either staying under the 18m (6-storey) threshold or pushing for taller buildings with storey heights in the double digits. As such, 7 to 8-storey developments have fallen away as a viable option due to the second stair core requirements and the uncertainty surrounding the Gateway 2 process. For at least the short term, this will significantly hinder any aspirations for mid-rise densification.
Turning to tall buildings, interestingly, the NLA’s annual London Tall Buildings Survey for 2025, found that planning applications for tall buildings (defined for the purposes of the survey as 20-storeys or over) were up compared to last year, but that consents were considerably down or, at least, still undecided. In addition, there remains a number of high profile consents for tall buildings that remain unimplemented. As the economy and demand, building standards, and how we live and work, all continue to shift, questions arise if they will ever be delivered.
The overall picture was reported to be mixed across locations in London and different sectors and use types. For example, the demand for Grade A office space in the City of London continues to encourage new schemes to come forward for ever taller buildings, which is also reflected in the projections for the city’s tall building clusters in their new Local Plan. High rise residential development elsewhere has been held back more recently by a challenging housing market, high interest rates, labour and material shortages, and a more rigorous building safety regime. The NLA’s tall building study reported a perception amongst developers that the planning policy environment had become less favourable for tall buildings in residential use. But it is in this sector that London needs growth the most, and where the powerful national growth agenda is now focused.
Architectural and landscape design quality, alongside environmental performance, is particularly important if local policy and guidance is going to support the delivery of more taller buildings in London. This is important to ensure that taller buildings have a positive impact on both the local and city-wide context given the potential scope for significant impacts at a large scale.
The consultation paper recognises that the more consistent approach to the identification of locations suitable for tall buildings, as advocated by current London Plan policy, has not been implemented consistently across boroughs. Would there be benefit in the Mayor taking a more pro-active role through the plan making process, and how he uses their power over major applications, to encourage a more strategic approach to tall building clusters or zones city-wide? Such discussion raises further questions about what is actually defined as a tall or taller building in policy terms for London. The current plan highlights the importance of local context and defers to boroughs to define what is considered a tall building for their own localities. This has led to a wide ranging definition and, therefore, application of policy across London, from simply any building over 6-storeys, to ones that are judged to be significantly taller than its surroundings, which obviously may be open to different interpretations, to the City of London's clearer definition as a building exceeding 75m in height (c.25 residential storeys). Is this still the right approach in the context of the growth agenda?
Current London Plan policy for tall buildings included strong encouragement for the integration of meaningful publicly accessible areas, such as viewing platforms. Should this remain an objective for policy as the number and use of these amenities has increased quite rapidly in the city centre?
Impacts on heritage assets
Another question that emerges from consideration of building height and densification is: what does a densified city mean for the significance of London’s heritage assets? It is unlikely that law and national planning policy will shift fundamentally in the near future, and so existing heritage protections remain in place.
Policy HC1 of the 2021 London Plan set out clearly that the Mayor’s role would principally be to positively manage or otherwise balance heritage conservation and the continued growth of the city. This is a policy objective that is likely to remain in the new London Plan; emphasising how heritage assets should be seen as valuable contributors to the sustainable development of London for its culture, communities and economy, rather than a constraint.
However, key supplementary planning documents published by the Mayor, such as the London View Management Framework (LVMF) are now very dated, being adopted in 2012, and becoming more difficult to apply. For example, images of the famous historic view from Greenwich Park towards the river and beyond to Canary Wharf in the LVMF are no longer representative of the rapid development of that business district and the skyline as found today.
The proposed revision of this document by the GLA is to be welcomed, and is scheduled for public consultation in autumn this year. There is an opportunity for a revised LVMF to take a more sophisticated policy approach to the management of London’s most cherished strategic views and consider how they may interface with heritage policy as it relates to the setting of heritage assets, often landmarks and key features in the strategic views. A refreshed approach will support an enhanced and shared understanding of the particular historic and aesthetic values of those views (including how they have changed since 2012), and assist in shaping new development and tall buildings in a positive way. There is an opportunity for a new LVMF to reflect the role and value that much more sophisticated digital and virtual technologies for views modelling and visualisations can bring to informed decision-making process.
Historic England will be taking a lead on new best practice guidance for the management of development in relation to World Heritage Sites, of which there are four currently in London. This is in the context of close monitoring of UK practice by UNESCO, and other international heritage bodies, including some concerns on the potential impacts of the scale of growth identified in the City of London’s new Local Plan’s on the setting of The Tower of London World Heritage Site. We are expecting public consultation on Historic England’s new guidance in this year. Ideally, the GLA should align their policy and guidance with that at national level rather than duplicate.
Tackling the climate crisis is, of course, a key theme that runs through all parts of the London Plan. No longer is this drive for achieving net zero and improving resilience to a changing climate confined to more modern or new buildings, but must apply to London’s large historic building stock too. Historic England, alongside several boroughs, have already shown leadership and innovation in the preparation of new policy and guidance. This is where a new strategic policy for the London Plan that supports the well-considered adaptation and retrofit of historic buildings could have real value.
For more information on how the direction of the new London Plan might affect tall buildings and heritage assets, please contact Richard Brookes or Isabel Jones.
28 May 2025