Comment
Towards a new London Plan: Challenges, opportunities and what’s next
The Mayor of London today (9 May 2025) launched his consultation document ‘Towards a new London Plan’[1] – the starting block for what can be expected in the draft new London Plan targeted for publication in spring 2026. Director, Freya Turtle has reviewed the document and provides an initial overview of the key themes.
The framing of the consultation is very much around what the next London Plan ‘could’ do, should ‘explore’, and needs to carefully ‘consider’ – limited absolute terms are used. That being said, the consultation is by no means lightweight – there is plenty to get one’s teeth into.
With the new Government target to provide nearly 88,000 new homes per year for Greater London, a stagnating housing pipeline, evolving expectations for workspace and office stock in a post-Covid era and the ever-growing need for industrial/logistics and infrastructure capacity to meet modern life, the New London Plan certainly has a lot to tackle.
Our team will continue to review the consultation and share their thoughts in a series of articles on key topics of the consultation in the coming days and weeks, but in the meantime, some of the key points to highlight include:
- The scene is set early doors that the next London Plan must not increase the planning policy burden and instead find opportunities to streamline requirements and speed up determination of planning applications.
- The 87,992 housing target is confirmed – very much expected considering it is a Labour Government and Labour Mayor, but still a necessary step. The document makes no attempt to downplay the magnitude of the challenge in achieving this scale of development, which has not previously been achieved since the 1930s. It is, therefore, acknowledged in the Mayor’s foreword that he wants to see “local planning becoming more flexible and focused on securing permissions for housing development”.
- Brownfield first principles remain, but now potentially on steroids, with a clear directive in the document for housing on such sites ‘to be optimised to make the biggest contribution possible’.
- The consultation suggests that the London Plan have a more active role in identifying and defining tall buildings, alongside seeking to increase the threshold for what makes a tall building from seven storeys (which is not a viable option for most developers these days anyway due to new fire regulations) to ten or even 20-storeys. This is certainly a necessary point of policy to review, although you must question how achievable it will be given the political sensitivities surrounding building height. Many may recall we had this dance before in the drafting of the previous London Plan.
- Green Belt is firmly on the table for the first time in Sadiq Khan’s Mayorship, aligning with the new NPPF published in December 2024, with a particular focus on identifying Grey Belt sites and opportunities for large urban extensions. The GLA’s strategic led Green Belt review is very welcome and a positive change in stance compared to the current London Plan. London’s Green Belt is a strategic, London wide matter that should not be looked at in a piecemeal borough-by-borough basis. With this view, it is regrettable that four boroughs have opted out of the GLA’s Green Belt review.
- There is a continued recognition for the role of other ‘other housing options’ in meeting housing need, with a particular drive to redefine and increase delivery of Build-to-Rent. Those in the purpose-built student accommodation (PBSA), co-living and later living/care home space can also expect to see change in policy going forward.
- Affordable housing is still very much (and quite rightly) a priority, and the document reflects back positively on the existing London Plan’s 35%/50% ‘fast track’ threshold approach to date (others may not agree). Nevertheless, the consultation proposes to review the fast-track threshold requirements. In addition, there is a renewed focus on social rent and the proposed possibility of a new tenure: Key Worker Living Rent (KWLR).
- The consultation continues to disagree with London borough’s setting local fast track thresholds at higher levels (e.g. 40-60%) and sets the expectation for the next London Plan to be clearer about how its own threshold must be consistently applied. A welcomed approach to ensure certainty for developers and landowners, although, with many draft Local Plans already well underway, or even submitted for Examination (e.g. LB Wandsworth and LB Ealing), it raises the question of whether the horse may have already bolted on this point.
- Whilst relatively short in comparison to housing, the section on industrial land positively addresses the historic loss of London’s industrial capacity to ensure that its future industrial/logistics demand is met. This includes the consideration of whether a strategic industrial land need is identified for London (similar to the housing target), rather than this being assessed borough-by-borough. Data centres, and their vital role in London’s economy, is positively noted.
- There is a proposed continued protection for the Central Activity Zone (CAZ), but subject to potentially reviewing its boundaries. Going beyond the CAZ, industrial land and town centres, the next London Plan may also look to identify other clusters of economic activity.
- Commonly referenced throughout the consultation is the need to unlock significant transport (and other infrastructure) expansion and improvements to enable the delivery of the housing growth – with an initial focus on the DLR extension, the West London Orbital, the metroisation of suburban raise and the Bakerloo Line Extension. This is certainly essential, but begs the question: where will the money come from?
Planning and development (particularly housing) in London is arguably at one of its most challenging periods in modern history. Although there are numerous influencing factors at play, many of which are outside the Mayor’s control, it cannot be overemphasised how critical a role the next London Plan will have in tackling the crisis. It is vital for parties across the sector to respond and engage at this early stage – the deadline for comments is the 22 June 2025.
For further information on the New London Plan Consultation, please contact Freya Turtle.
Watch this space for further detailed commentary on the New London Plan Consultation.
9 May 2025