The website of the London Forum will be back online as soon as possible. You can keep up to date for now by visiting our Twitter page (see right).

The National Policy Planning Framework
Implications for London

If you have not written yet to your MP about the draft National Policy Planning Framework, or you intend to write again, you may find this article by Mira Bar-Hillel which recently appeared in the London Magazine of interest.


Only two London MPs spoke in the House of Commons debate on the draft NPPF. In the view of the London Forum it is important that they all realise there are problems for London in the proposed national policies for England in the draft NPPF. MPs should have the issues explained in simple terms but the extent to which any one of them is prepared to accept arguments like those set out below will vary.


The draft NPPF does not mention London. It must recognise that London has a development plan at two levels, the Mayor's Spatial Development Strategy, (the London Plan and its associated strategies and supplementary planning guidance), plus the local plans of boroughs.

Recognition of the London Plan and clarification of its conformity to the NPPF is vital.
1 - It forms the basic Core Strategy content for all boroughs, to which they add.
2 - It contains details on what must be in each borough LDF to meet its policies.
3 - It describes the basis on which local decisions will be made on applications.
4 - It creates protection in the capital against the NPPF's " default answer is 'yes' "
policy where local plans are out of date, because developments must be
determined in accord with the policies in the London Plan as well as the LDF.
5 - It contains policies for the protection of Metropolitan Open Land, open space,
biodiversity, social infrastructure, industrial land, climate change, pollution,
heritage assets and waterways - all to a greater degree than the draft NPPF.
6 - It sets out essentail cross-borough spatial policies for the use of land,
place shaping, targets for quantities of homes and densities of development.

Many paragraphs in the draft NPPF have serious implications for London, unless the London Plan policies can be upheld. The issues relate to the failure of the draft NPPF to apply policies for the sequential tests for the use of previously developed land and for placing trip generating developments in or near town centres or places of high transport accesibility.

The draft NPPF lacks a sound basis for refusing unsuitable developments and for ensuring developments are sustainable. It requires Councils to "approve all individual policies wherever possible" - "unless the adverse impacts of allowing the development would significantly and demonstrably outweigh the benefits". This would represent not only a reversal of the onus of proof in planning but raise the barrier against refusal and make a nonsense of the policies in the plan.

It requires that communities "should" develop Neighbourhood Plans, whereas in London they are unlikely to be necessary in many locations. The priority is to complete policies within the local LDF for each area of development in the borough proposal maps and strategic aims. The draft NPPF states that the policies in a neighbourhood Plan "take precedence over existing policies in the Local Plan for that neighbourhood, where they are in conflict." That would allow a developer-led Neighbourhood Plan to 'trump' the planning intentions of the Council for an area.

The draft LDF seeks to avoid "burdens" for developers and to reduce the amount of contributions they have to make and obligations or conditions placed upon them by a Council because there must be "acceptable returns to a willing land owner and willing developer".

The conversion of office buildings to residential use is promoted by a policy in the draft NPPF and that would have a serious adverse effect in London, as it would remove from the market the low cost offices space needed by small and medium enterprises. Conversions of offices will not allow any part of their increased value as homes to be secured as contribution to affordable housing in them or elsewhere. No planning obligations could be imposed for mitigation of the effects of new usage. It would not be possible to impose planning conditions to ensure the resultant building met required standards and appearance in line with local plan policies.

The draft NPPF weakens the current protection for Green Belt land and introduces a threat to the undesignated greenfield land which is not defined for development in the local plan.


If you share our concerns then please write to, or email your MP as soon as possible.

Peter Eversden
Chairman, London Forum


At present enquiries about the London Forum should be directed to londonforum@riverwise.co.uk