What the draft London Plan is trying to do – and why it matters

Strategic planning is never simple. You’re trying to shape the future of an entire city, while being told you’re either doing too much or not enough.

The draft London Plan, published in July and now out for consultation until 15 October 2026, sits right in the middle of that tension. It arrives at a moment when London faces a perfect storm for housebuilding, a new national policy landscape and a development industry struggling to deliver.

London is the only place in England that currently has a strategic plan. Everywhere else lost theirs in 2010, when regional planning was abolished overnight by Prime Minister David Cameron’s government. The London Plan survived because it was still relatively new and because the city’s scale and complexity (and very likely the political connections of then Mayor Boris Johnson) made it difficult to remove.

Before that, London’s strategic planning had been overseen by the Greater London Council (GLC) between 1965 until its abolition in 1986. The 1980s and 1990s are widely accepted as a low point for London-wide city planning. It wasn’t until 2004 that city-wide planning was revived under Prime Minister Tony Blair and Mayor of London Ken Livingstone. 

The city-planning revival established the London Plan as a defining part of how development works in the capital: Ambitious, highly regulated, often demanding, but generally clear about what’s expected. But its position of strength has recently come under threat.

So, what is this new draft London Plan for? How should the industry respond to the consultation?

The market for property development in London is brutally challenging; very little housing is being delivered and what is built is unaffordable to many. This has stalled the cycle of higher and higher density, technically complex buildings and innovative housing products. 

Political clashes with the last Conservative government framed the London Plan as red tape holding back growth. The new draft London Plan is an attempt to reset what strategic planning is for. It comes at a time when the capital urgently needs clarity, realism and shared ambition. The London Plan also has a wider leadership role to play with strategic planning coming to the rest of England through the Planning and Infrastructure Bill’s Spatial Development Strategies, introduced in March 2025.

But London is also a conundrum. One in four Londoners live in poverty according to Trust for London – the highest poverty level in England. The capital is a highly positive net contributor to the UK economy with massive income inequality, a hugely successful world city, but with areas of very high deprivation. The UK needs London to do well, but also to do well more fairly. 

The Mayor’s vision is for a fairer, greener, more inclusive London. But the context is tough. This is a Plan written for a city where development has slowed to a crawl. It tries to strike a delicate balance that not everyone will agree with: asking enough of development to deliver the places and homes Londoners need, but not asking so much that nothing gets built.

The Plan sets a target of 558,000 homes over the next decade, while acknowledging that the Government’s expectation of more than 850,000 homes per year is simply not possible in current conditions.

There is a clear preference for brownfield first, with some Green Belt release where justified. Boroughs in the outer ring will see housing targets rise, including Hillingdon, Enfield, Waltham Forest and Havering, while Tower Hamlets, Barking & Dagenham and Kingston-upon-Thames will see targets fall. 

The Plan also sits alongside the London Growth Plan, recognising that housing delivery cannot be separated from investment, innovation, jobs, high streets, culture and London’s 24-hour economy.

Like the new NPPF, the draft London Plan separates plan-making policies (for boroughs) from development management policies (for decisions referrable to the Mayor). This is a significant shift. It clarifies what the London Plan should do - and what it should leave to boroughs.

The Plan is organised around six themes: Making the best use of land and achieving good growth; delivering the homes and neighbourhoods Londoners need; growing London’s economy in a way that benefits all; creating a greener, healthier and resilient city; and place visions and place-based approaches. The core spatial strategy is part of the chapter on good growth. 

This structure is more focused than previous versions, there are half as many pages, and something like half as many words. It reflects a recognition that strategic planning must be strategic – not a Local Plan with a wider geography.

One of the long-standing criticisms of previous London Plans is that they weren’t spatial enough. Policies applied everywhere, with limited differentiation and a focus on major growth in Opportunity Areas but in reality it happening much more widely. 

This draft changes that: It introduces multiple key diagrams with two time-horizons, five sub-topics, and a new London Context Map. The plans in the draft document bring clarity and help explain what is going on and how things relate to each other more clearly than the single key diagram across the last five London Plans. Interestingly the “key diagram” is the only drawing or diagram that the London Plan has to include. 

London Plan key diagrams over time as shown in policy documents. 

The draft London Plan introduces the Sustainable Access Measure (SAM) – a tool that measures travel times to jobs, services and amenities by public transport and walking which is effectively a more refined version of PTAL. TFL states that the objective of SAM is to: “Provide a granular, pan-London metric which reflects the ability of a typical Londoner living in a given location to meet their regular travel needs by sustainable, space-efficient modes alone.” SAM is used with the new Optimisation Framework, which replaces the old density matrix with a much more nuanced and place-based approach. It combines accessibility with character settings to give starting points for height and density. 

Looking at the London Context Map in the plan alongside the Optimisation Framework it is clear to see that much of London is categorised as Setting A (predominantly outer urban), or Setting B (predominantly inner urban terrace), with expected height and density ranges. These depend on SAM levels and a range of other criteria. Low SAM gets you lower height and density ranges, as would be expected. Taller development and higher densities are focused on well-connected locations, town centres and former industrial land.

Most of the Optimisation Framework is focussed on a wide range of medium densities between 3 and 8 storeys, with a taller and denser band focussed on more specific well-connected locations. Will this focus on medium densities and urban intensity – but not height at all costs – be seen as helpful and reasonable or just infuriating? There is a strong argument that these are the kinds of densities London needs to support shops and services, keep service charges reasonable and make places people actually want to live – but this may not suit everyone. 

Importantly, both SAM and the Optimisation Framework are set out spatially which much more clearly means you can’t just pick and choose what suits you – you have to consider a wide range of issues and set criteria. Small sites will be covered by their own London Small Sites Code, which the plan asks Boroughs not to mess with but to build on, if they so wish. 

The related policy has clear asks of the Boroughs to say where they want change and how they think this should work through design codes and masterplans. What this means is a much more place-specific and layered approach with the Mayor setting the strategic principles and the boroughs providing the detail (as it should be). 

This spatial shift has been broadly welcomed, but also prompted concerns about how far the Plan really goes. Alongside the broad welcome for a more spatial, more realistic London Plan, several challenges are worth acknowledging.

There is a sense that this Plan represents a political reset as much as a policy one. After years of tension between City Hall and national government, many see the new draft as an attempt to rebuild trust in being less prescriptive and more strategic. 

There is also worry that the shift risks some of the clarity that previously helped shape development in London. The Plan’s slimmer structure is widely understood, but some fear it may leave too much interpretation to boroughs at a time when consistency is needed. 

Another recurring concern is whether the Plan’s “spatial turn” is real enough. While the introduction of SAM, character settings and key diagrams has been broadly welcomed, it could be argued that the spatial strategy still stops short of making genuinely hard choices about where growth should go, or perhaps more importantly, where it should not. 

There is a question whether the Optimisation Framework will meaningfully change outcomes, or whether it will become a more sophisticated version of the old density matrix. It does seems more robust and layered than we’ve had before. There is also scepticism about whether all London boroughs have the capacity or will to produce the type of place-based visions this Plan relies on. 

A third area of commentary focuses on the downgrading of social and community infrastructure. Some practitioners have highlighted that the disappearance of a standalone chapter on social infrastructure sends an unhelpful signal at a time when London’s leisure, health facilities, youth spaces, schools and care infrastructure are under significant strain. 

In the case of schools, the challenge is that many boroughs have falling rolls, leading to primary school closures that no one really wants. While the Plan references these needs, some have argued that it lacks a clear mechanism to ensure the mix of uses that Londoners need keep pace with housing growth. 

This leads me to a much bigger question that the plan does not address: Do we want London to be a place that families choose and can afford to live? 

Does the draft London Plan do enough to ensure the capital works well for families, children and young people? It concerns me that where families and young people are included, it is as a secondary consideration rather than a primary aim. Without clear direction that we need to explicitly plan for families (new and existing) in the city, there is a risk of a huge missing middle of adults who just can’t afford to stay in London at great detriment to the city’s economy and richness. I understand that the economics of family housing are complex, but any primary direction on meeting the needs of families is avoided at the moment and this is a missed opportunity. 

Another difference with this plan is the way it approaches energy and sustainability. The ambition for net zero is still there (and is not prevented by the final wording in the new NPPF) but the approach updated and perhaps slightly softened. The policy mechanism now uses Energy Use Intensity and space heating standards with both baseline and aspirational levels. 

The carbon offsetting fund has been dropped. Operational, heating and whole life carbon are wrapped into one integrated framework. Minimising waste heat from buildings and using passive cooling measures are prioritised. 

This is a plan that still has energy and sustainability front and centre and none of us should expect this to be less of a focus after the summer we had this year. Time will tell if the plan is strong enough to resist a push towards air conditioning in the new normal. What is clear is that overheating is an issue that can’t be ignored. 

As for affordable housing requirements, this will be the most contentious part of the draft Plan. The strategic aim of a 50% affordable target has been retained however the draft plan proposes a tiered system based on location, with central London having a 35% requirement for affordable housing, reducing to 25% and finally 20% for the outermost London boroughs. The 50% threshold is proposed for green belt land. The proposed split of tenure is 60% social rent and 40% intermediate. 

For some, there will be a clear view that any reduction in affordable housing delivery must be resisted (and legally challenged, as in the case of the new temporary measure). However, as we have seen, 35% of almost zero homes being delivered leads to a very small number of affordable homes. Whether we like it or not, that is the reality we are working with under the current system. 

The choice is to leave things as they are, wait until the market recovers, interest rates reduce and people can afford to buy or rent new homes (and cover the service charges) or move ahead with a smaller required proportion of affordable homes, varied by location, in the hope that delivery picks up. This is the position that the draft London Plan is taking but is clear that this approach is not universally accepted. 

Separate from these thematic concerns is a more practical one – borough capacity. Almost every commentator has pointed out that the draft London Plan asks councils to do more: Place visions; spatial strategies; tall building zones; design codes; infrastructure planning. The boroughs will need to think carefully about whether this is something they can do, whether it fits with what they are already doing, and how long it will take. 

This challenge is compounded by a second issue – a timing mismatch between borough Local Plans and the London Plan. Because Strategic Plans and Local Plans take so long to prepare, examine and adopt (even in the time-limited NPPF 2024 world) many boroughs are already working with documents that are out of step with the last London Plan – and will be even further out of step with this one. 

There is a worry that the new London Plan could take years to fully embed, leaving boroughs navigating a period where their Local Plans, the London Plan and the new NPPF are all pulling in slightly different directions. Do we think this could slow delivery further or not really make a difference? Whilst this isn’t a problem of the capital’s making it is one it will have to work through and be honest about if strategic and local planning has a chance of properly working well together. 

To become half its previous length, the Plan has removed a significant amount of material. This includes duplication with national policy, detailed environmental requirements, standards that are now covered by Building Regulations, and some of the more prescriptive design rules such as on single-aspect homes. This slimming down is intentional. The Plan must be strategic, not a detailed development management manual.

Despite being shorter, the Plan introduces several important new elements that reflect London’s current challenges: Viability, safety, climate resilience and the need to support both housing and economic growth. 

New additions include: Spatial affordable housing targets expressed as locational bands; a stronger character-led approach to design and placemaking; clearer tall building policies including a new Metropolitan Tall Building category for buildings over 100m; accessibility requirements across tenures; strategic criteria for data centres; explicit consideration of public safety including women and girls’ safety and VAWG; and identification of Green Belt areas near stations that may be suitable for major residential growth. All that, as well as the SAM measure and Optimisation Framework set out above. And it also brings in some of the Mayor’s key strategic priorities such as Green and Healthy Waterways with its own specific policy GHR9. This puts a focus on cleaning up London’s rivers and making them a place for all. 

The consultation is an opportunity to shape how London grows over the next decade. In responding, it would be worth considering whether the Plan is strategic enough, whether it is spatial enough to reflect the diversity of the capital and whether it plans for the things Londoners need in terms of social and community infrastructure. 

Key questions to think about are whether the Optimisation Framework will work in practice along with the SAM model, whether the design and tall building policies are clear and workable, whether the affordable housing bands are realistic and what happens at the boundaries where one band sits next to another. Is the balance between viability and ambition right either for now or across the whole next decade. Do the boroughs have the tools they need to respond and on what timescales. 

There are deeper questions about how the Plan enables ambitions for public land, helps practically with the delivery and flexibility needed by long-term masterplans, facilitates actual practical models of cycle parking that work (my personal bug bear) and the risk of uneven delivery across borough boundaries.  

Overall, the draft London Plan feels more concise, more spatial and more honest about London’s complexity. It is based on a clear vision for the city and asks people to respond to its differences. It is more direct about what it can do and what it needs others to do.

The plan cannot solve the city’s housing crisis alone. It can’t conjure infrastructure into existence. It won’t alleviate the political tensions that have shaped London planning for decades. What it does is make a serious attempt to reset strategic planning in London at a moment when the capital desperately needs clarity, realism and ambition. 

We should all respond to the consultation constructively, critically and with a commitment to delivering places that work for Londoners now and in the future.

Hilary Satchwell is the director of Tibbalds, Mayor’s Design Advocate for the Mayor of London, co-chair Design South East and a founding member and director of Part W. 

Find out more Respond to the draft London Plan by 5pm on Thursday, 15 October 2026 www.london.gov.uk/programmes-strategies/planning/london-plan/next-london-plan/draft-london-plan-consultation

Image credit: oatsy40, CC BY 2.0