Savills provides initial thoughts on new draft London Plan

It arrives following consultation of the Mayor’s “Towards a London Plan” in 2025, a summary of which can be found here.

The Draft Plan comes at a pivotal moment, where housing delivery in the capital is facing a perfect storm of challenges and the need to boost economic and industrial capacity is apparent.

In response to industry criticism about the size and overly prescriptive detailed content in the current London Plan, the draft Plan is half the length, and more aligned to the Draft National Planning Policy Framework (NPPF). The overriding messaging from the Greater London Authority (GLA) is that it’s intended to boost housing supply and economic growth whilst protecting key open spaces and the environment.

Policies have seen some significant adaptions – particularly around housing supply, affordable housing provision, density and heights, industrial land supply, locations for growth, and green belt release. But will they meet the development needs of the capital? Below we highlight some key headlines.

Housing

• The Plan includes a target of 558,451 new additional homes by 2037 (policy HN1), which equates to some 55,845 homes / year, substantially below the 84,884 homes / year requirement set by the government. This, the Mayor says, is a more achievable target due to infrastructure and land constraints. The Plan includes a goal of 850,000 new additional homes up to 2047.
• Boroughs are not only provided a Brownfield housing target but, in some cases, a Greenfield housing target between 2027/28 – 2036/37. This totals 502,351 additional homes from Brownfield land, and 56,100 from Greenfield land.
• The 50% strategic affordable homes target has been retained, but threshold requirements are now differentiated by location and land. These also apply to housing for older persons and Build-to-Rent (BtR) homes.
• For developments of 10-35 homes, the fast-track route (no viability evidence) would apply as follows:

1. Green Belt = 50% affordable provision
2. Non-Green Belt = 20% affordable provision

• Developments of more than 36 homes (same for Purpose Built Student Accommodation and Large-Scale Purpose Built Shared Living) have the following fast-track affordable requirements, some of which are adjusted based on certain factors:

1. Green Belt = 50% (reduced to 35% if the development includes significant transport infrastructure delivery)
2. Public sector = 40% (reduced to 25% if the development includes significant transport infrastructure delivery, or in some limited cases strategic health infrastructure provision)
3. Industrial Land = 35%
4. Band A = 35% (reduced to 25% if the development includes 100% social rent homes, or if BtR 100% key worker living rent homes)
5. Band B = 25% (reduced to 20% if development is for at least 80% social rent homes, or 80% key worker living rent homes if BtR.
6. Band C = 20%

• Fast track requires a 60/40 split between low-cost rent and intermediate rent. For BtR development, the tenure split must be at least 30% Key Worker Living Rent and a maximum of 70% at “genially affordable rents”.
• Development following the fast-track route through planning should undergo an Early Stage Viability Review if substantial implementation of the scheme has not been made within two years, or a period agreed by the borough, of permission being granted.
• Interestingly developments proposing between 10-35 homes can provide a payment in lieu where such a payment is equivalent to the threshold level and tenure mix sought by policy.
• Developments following the viability-tested route will be subject to early, late and in some cases mid stage reviews, subject to certain timing requirements.
• In the new draft, provisions for Purpose Built Student Accommodation (PBSA) and Large-Scale Purpose Built Shared Living accommodation (LSPBSL) have been combined into one ‘Managing Specialist Accommodation’ policy (HN5). This new policy lays out the requirements for both PBSA and LSPBSL regarding design, location and amenity.
• Additionally, all Boroughs (except Bexley, City of London, Merton and Westminster City Council) have been given PBSA targets totalling 31,549.
• BtR has retained its own policy. The policy is under half the length and now deals with letting and affordability.

Locations for growth

• Delivery of new housing and employment development is expected to be focused in identified ‘Broad Locations of Growth’, ‘Strategic Growth Corridors’, ‘Brownfield-first Opportunity Areas’ and ‘Environmental Opportunity Areas’, and through intensifying land use across London, optimising brownfield land generally. Such areas are identified in the Plan (Figure 2.2).
• Local Plans are expected to make provision for c.56,000 new homes and circa 350 ha of industrial land beyond the existing built-up area through site allocations and Green Belt release in identified ‘Broad Locations of Growth’; and support cumulatively significant growth on small sites and other land use intensification opportunities, such as the redevelopment of car parks.
• A ‘brownfield first’ approach is retained, but it has changed to a ‘not-brownfield-only’ approach.

Industrial and logistics

• Within the Draft London Plan there is a clear commitment to supporting London’s future prosperity. This includes adopting a long-term approach to creating space for data centres and economic clusters by identifying suitable locations. This is through the long-awaited new specific data centre policy (GLE3) which sets priorities to strategically plan for data centres at plan-making stage by taking into account availability of current and projected electricity network and water supply capacity, opportunities for clustering, local heat recovery opportunities, availability of land and compliance with habitat regulations. When proposing data centres outside the suitable locations, a series of criteria will need to be considered and met to justify delivery.
• There is increased emphasis on issues such as electricity capacity and balancing competing demands to deliver industrial uses whilst also protecting land for housing and other essential uses.
• Support is present for the growth of strategic economic clusters and corridors (PV4) which are outside central London and town centres and encouraging boroughs to identify these areas in local plans to support their development in well-connected locations.
• Protection is afforded for the spaces businesses need to thrive by prioritising affordable workspace, industrial land, logistics and strategic infrastructure to support businesses through their lifetime.
• A dedicated affordable workspace policy (GLE7) seeks to support the delivery of affordable workspace for priority uses such as creative industries, community organisations and start-ups and promote the retention of existing affordable workspace.
• The Plan maintains a commitment to ensure that London has enough industrial land to support business activity and essential infrastructure and promoting cross-borough collaboration to provide further capacity in locations with good access for freight and logistics under Policy GLE 2 (Supply of Industrial Land). As noted above, local plans are expected to find 350ha of industrial land outside of built boundaries.
• The Plan includes a commitment to maximising access to employment and skills via a designated policy (GLE8) which seeks to utilise major developments as an opportunity to deliver jobs, training and apprenticeships for Londoners.

Design and heritage

• Sites below 0.25ha that meet the London Small Site Design Code requirements are considered acceptable in principle which signals stronger policy support for small site delivery. More emphasis is also on design codes and Local Development Orders (LDOs) to provide certainty and speed up planning decisions (also MBUL2).
• There is a clearer strategic framework for tall buildings is being introduced, distinguishing between buildings over 30m and ‘metropolitan tall buildings’ over 100m, with the latter expected to be concentrated within identified clusters. The most prominent tall beings are also expected where appropriate to incorporate publicly accessible spaces (MBUL3).
• Climate resilience is embedded more explicitly within design policy, with more emphasis on designing for future climate conditions, including overheating and shading alongside a stronger role for independent design review on referable applications (MBUL6).
• Heritage policy remains broadly consistent with the current London Plan, retaining the existing emphasis on conserving and enhancing heritage assets whilst accommodating growth, with no significant strategic shift in policy direction (MBUL7).

Transport

• Within the Draft London Plan, a stronger relationship is established between growth and transport infrastructure, with local plans expected to identify the transport interventions and developer contributions needed to support growth (MBUL5).
• A firmer policy position against car-dependant forms of development, with drive-throughs and low density retail parks, are identified as uses that should generally be refused (MBUL5).
• The ‘Healthy Streets’ approach is expanded beyond transport to place greater emphasis on public safety, inclusivity, shade, seating, public toilets, drinking water fountains and the needs of women and girls in the design of public spaces (MBUL9).
• The draft Plan embeds the temporary cycle parking standards introduced through the Support for Housebuilding – London Plan Guidance into London Plan policy and introduces a new approach to car parking standards based on the Sustainable Access Measure (SAM) and the Optimisation Framework, reinforcing a ‘car-free’ and ‘car-lite’ approach to development. (GHR11).

Sustainability

• The draft Plan retains the ambition for net zero development but shifts from percentage carbon reduction targets by introducing Energy Use Intensity (EUI) and Space Heating Demand (SHD) standards (GHR1).
• The approach to low-carbon heat becomes more tech-neutral, with Low Carbon Heat Appraisals used to determine the optimum heating solution for individual developments (GHR2).
• The document also streamlines the approach to operational energy, heating and whole-life carbon into a more integrated framework, alongside the removal of the previous carbon offsetting approach (GHR3).

Site optimisation and density

• An uplift in density is supported where the loss of self-contained housing is proposed.
• An ‘Optimisation Framework’ is introduced that sets height ranges and minimum expected densities for certain developments falling within different ‘settings’. This is a more prescriptive expectation on density and height compared to the 2021 plan and more reflects the density matrix contained in the 2016 London Plan. This applies to sites over 0.25ha and not covered by sites benefitting from design codes, masterplans allocations, green belt or tall building locations (see MBUL2).

Green Belt

• The identification for local plans to allocate sites to deliver some 51,000 new additional homes and 350ha of industrial land can only really mean that they will be on current Green Belt Land. The Plan sees a strategic change to pocketed release in appropriate areas. In ‘Broad Locations for Growth’, the release of green belt will be acceptable in principle.
• The draft Plan also introduces additional London-specific development management requirements for Green Belt Proposals, including tests on strategic need, sustainable location and design criteria alongside the national Green Belt framework (PV7).

Summary and next steps

The draft Plan sees some important policy shifts that seek to facilitate more development in London, particularly in areas not previously considered suitable such as parts of the Green Belt and greenfield locations. But do these policies go far enough to meet the housing and economic needs of the capital, whilst meeting key environmental objectives?

Acknowledgement is already made in the Plan that these approaches would not come close to the government’s published housing requirement for London, so could these draft policies help facilitate an environment that delivers the growth targets that London requires?

Savills will be preparing various in-depth reviews of the draft policies that consider this question and other implications throughout the consultation period, which closes on 15th October 2026.