Draft London Plan response – linked policy by policy

The GLA’s consultation on the draft London Plan 2026 closed on 15 October 2026, London Forum submitted a 39-page response. This is the short version: the main points, then in ‘Our Comments policy by policy’, a one or two-line summary of key comments on each, with links to the GLA’s original text, and to the relevant section of our full response.

Why the draft Plan falls short

We agree strongly that the Government’s 85,000-a-year target for new homes is unrealistic and that a lower target is needed. But the draft Plan that follows is built on housing evidence that does not stand up, and on growth that depends on infrastructure nobody has committed to provide. In our analysis it risks failing the NPPF soundness test.

• The housing target doesn’t stand up. Projections made ten years ago for 2024 were more than 550,000 above the ONS’s own estimate. The housing-need assessment was hastily amended to fit the 558,000 target, and rests on an assumption that household formation should return to 2001 levels, with no evidence given.
  What evidence is there that 558,000 homes is a sound target, or the right mix of homes?
• The wrong homes, and too few for those in greatest need. The Plan’s evidence steers 55–65% of new homes to one-bedroom units and finds no need for new market family homes. The 50% affordable target is far too low, and the real crisis is among renters needing social rent.
  Why is a Plan for London planning so few family homes and so little low-cost rent?
• Growth without the infrastructure to support it. The Opportunity Areas must deliver over 400,000 homes, many depending on transport schemes with no committed funding. Outside Annex F the Plan makes no reference to public service infrastructure, and the Transport Strategy dates from 2018.
  Which of the transport and public service investments the Plan relies on are actually funded?
• Green Belt and industrial land are being given up first. The Plan does not require a clear, evidenced demonstration that brownfield and under-used land have been fully considered before Green Belt is released. It also releases industrial land for housing while another policy aims to protect it, and nothing explains how the two are reconciled.
  Why release Green Belt and industrial land before the alternatives have been shown to be exhausted?
• The Thames is missing from the Plan. Thames Policy Areas appear only in one policy and are ignored in the spatial strategy, tall buildings, heritage and views policies. Tall buildings could go almost anywhere, making local-plan locations pointless.
  Where is the Plan’s vision for the Thames, and what is the point of identifying locations for tall buildings if they can be built anywhere?
• Protections that Londoners rely on have been weakened or dropped. Basements, single-aspect homes, minimum ceiling height, heritage protections, community cultural space and green-space standards are all watered down or missing, while construction quality enforcement is not addressed at all.
  Why are these protections being cut, and who will inspect what actually gets built?

Our comments, policy by policy

Each entry shows whether we support, support with changes, or object, with a link to the GLA’s policy text and one to our full comment in the response. Of the 52 policies below, 8 are objections, 22 support with changes, 20 support and 2 no comment.

Jump to: Overview and housing evidence | Chapter 2 · Making best use of land | Chapter 3 · Housing | Chapter 4 · London’s economy | Chapter 5 · Green, healthy, resilient | Chapter 6 · Place visions and approaches | Annexes and drafting

More

• Sources of information for draft London Plan policies
  Extracted in the drop-down section below, are parts of answers published by the London Plan team to questions raised during the series of six public GLA webinars in July and August 2026. Many of them have links to supporting studies and reports. Note some consultations are open to 4^th December 2026 on London Views Management and on Small Sites Design Code London Plan Guidance.  The map and details of the ten Broad Locations for Growth, as published by Russell Curtis, should be considered for the implications on density and building heights. Unfortunately, we received precious little feedback from that article to build our response.
  Answers from the London Plan team

  • Phase 2 of the London Plan Viability Study will be prepared in support of the submission of the draft London Plan to the Planning Inspectorate and is anticipated to be published in Spring 2027.
  • The idea behind the approach to affordable housing in both the current and the draft Plan was to ensure that the cost of affordable housing is embedded into the land value at the point of purchase, preventing provision from being driven down by viability and allowing developers, investors and communities certainty around affordable housing expectations.
  • The draft London Plan maintains the current plan’s position on estate regeneration with some amendments. Schemes are still expected to take into account the Mayor’s Good Practice Guide to Estate Regeneration.
  • The DLR extension to Thamesmead is assumed to be delivered in the first 10 years of the plan so is associated with delivering housing numbers in that vicinity. Other projects will be important to enable the next tranche of growth in years 10-20, so it’s important that they are firmed up and become commitments in the first 10 years of the plan.
  • Policy PV8 (Strategic and local views) sets out an updated policy covering the London Views Management Framework (LVMF). This policy sets out 28 designated strategic views which is one more than the London Plan 2021. Further details on this 28th view will be included in a revised LVMF which has been published for consultation here.
  • The locations and heights in Policy MBUL3 have been underpinned by a Metropolitan Scale Tall Building Study.
  • In the case of Metropolitan tall buildings of more than 100m in height, the Plan sets out broad locations linked to an evidence base report. That report explains why those 17 locations have been chosen and why other areas that may have a few buildings of this height were not selected. The local plan will need to define exact boundary of these locations.
  • The Viability Study has found that in many areas of London, tall buildings possess a ‘diminishing returns curve’ or certain ‘pinch points’ whereby the cost of increasing building heights begins to outpace the value added by increasing storey heights.
  • The London Context Map will be updated periodically to reflect changes in character and feedback from local planning authorities.
  • All existing OAs were reviewed as part of the plan-preparation process as set out in the Pen Portraits published on our website.
  • If an Opportunity Area Planning Framework, such as those that were published some time ago, does not contain relevant density, height or other capacity guidance, applicants and decision makers should use the Optimisation Framework as a baseline and use the process set out in the policy (see Parts e – f in the MBUL2 box).
  • We have published the London-wide Green Belt Assessment online as part of the evidence base of the plan.
  • To improve clarity, all boroughs have been allocated to one specific Industrial Property Market Area for the purpose of this draft Plan. However, cross-PMA collaboration may also be required, in particular to support meeting the need of the Central Services Area PMA. The new Industrial Coordination Working Group will help to facilitate this.
  • The Economic Uses Demand and Supply Study sets out that the largest industrial demand across London is for storage and distribution uses. The benchmarks set out in draft London Plan policy GLE2 for land in storage and distribution uses should ensure developments meet the requirement for these occupiers.
  • Co-location can undermine the effective operation of industrial areas through the introduction of residential uses.
  • The Sustainable Access Measure (SAM) and Context Settings maps are available to download via the London Plan evidence base webpage for MBUL1. They are also available to view via the Planning Data Map under the ‘context’ tab.
  • While data centres are explicitly excluded from the definition of industrial uses for the purpose of this draft Plan (see paragraph 4.19), plan-making authorities can consider the inclusion of any land within suitable locations for data centres.
  • To demonstrate that it is not viable to redevelop or refurbish offices we anticipate this would necessitate a financial viability assessment including values and costs of an office refurbishment and an office-led redevelopment scenario; and a residual valuation of these scenarios compared to the outturn residual land value generated by alternative development options.
  • Draft policy GLE7 supports boroughs to introduce a local affordable workspace policy where there is a locally identified need and subject to viability.
  • Locations suitable for late-night and/or 24-hour premises should be identified, where appropriate, with complementary measures to support their safe and effective functioning. Draft London Plan policy GLE4 specifically states that boroughs should plan for growth in the night-time economy, including in high streets. The Agent of Change principle applies (Policy GLE4).
  • The GLA has published Visitor accommodation in London – Post pandemic recovery and supply – demand forecasts to 2050.
  • The London Plan Viability Assessment is the evidence base document. It sets out the reasons for challenging viability in London.
  • The Inclusive Talent Strategy is a 10-year plan to support Londoners who face barriers to work to get good quality jobs and to grow and diversify the workforce in key growth sectors.
  • Broad Locations for Growth (BLGs) are strategic areas identified at the London-wide level, not specific sites proposed for development.
  • The draft Plan does more than the current London Plan terms of promoting car clubs as part of the transport mix and new developments, particularly for areas with lower connectivity (SAM4 and below).
  • Engagement with utilities, as set out in the Utilities Impact Assessment published alongside the plan has provided assurances that sufficient infrastructure will be made available in a timely way.
  • The Regional Flood Risk Assessment (RFRA) Part 1 has a section on groundwater flood risk, detailing the distinct nature of the risk in different parts of London due to London clay and elevated aquifer levels.
  • As part of the proposed changes, the requirement for boroughs to develop their own Urban Greening Factor (UGF) scores and set local interim targets has been removed.
  • See The Mayor’s Clean Rivers and Waterways Plan.
  • The Play and Informal Recreation SPG sets out the process for play space.
  • Through the close links between the GLA’s Infrastructure Co-ordination Service (ICS) and utility providers, the Utilities Impact Assessment of the plan’s proposed level, distribution and phasing of growth has obtained assurances that there will be sufficiency electricity provision.
  • As London Plan Guidance, the London Small Site Design Code will be subject to the requirements that other LPGs have undergone, including holding a public consultation. It will not be subject to an Examination in Public as this is not a requirement for LPGs.
  • We’re still waiting for some of the details from the Government on the home energy model (HEM), which will be something we need to take account of in setting out how to comply with the policy. So, we’ll be updating guidance around that to make that clear when it is issued.
  • Communal health and well-being facilities including public bathhouses and saunas could potentially fall within Use Class E(d)/(e) or F2(c)/(d) and PV2 and PV3.
• Full London Forum response ( 39 pages)
• The draft London Plan 2026 on the GLA website