The economic appraisal which forms part of the consultation shows that the relevant costs taken together, including environmental costs, greatly exceed the expected benefits. We cover many other issues in our response; but for that reason alone, we cannot support the draft policy statement.

You only have until 1st September to respond – our previous article has some useful guidance.

Our response is in the What we’ve said archive as usual.

The Forum does not support the classifying inner-urban developments or Green Belt extensions as ‘New Towns’. We argue that proposals like Chase Park/Crews Hill (Enfield) and South Barking do not possess the geographic or socioeconomic separation required to build a ‘clear and distinct identity’. Instead, we view these as vehicles designed to accelerate housing delivery while bypassing standard national Green Belt protections and planning scrutiny.

While the proposal to set a National Default Fee Schedule at 90% of estimated costs is a step in the right direction, we argue that it’s too blunt an instrument. London’s planning costs are significantly higher than the national average — due to heritage requirements, high-density development complexity, and staffing costs — yet the consultation lacks transparency about how the funding shortfall is distributed across local planning authorities (LPAs). For each category there should be a comparable average or median cost for London LPAs so that the shortfall is apparent.

While the principles are reasonable, clear implementation guidance will be needed. Many London boroughs will need to use local fee-setting powers to avoid an underfunded planning system.

The full response can be read along with others in our ‘What we’ve said‘ archive.

The proposals were branded as authoritarian and anti-democratic

Despite claims that these changes will focus committees on complex cases, the draft regulations actually prevent many significant, contentious applications from ever being seen by elected members.

Under the new “Schedule 1” and “Schedule 2” system, the overriding assumption is that almost all applications will be decided by officers. The Forum is particularly concerned that conservation areas have been excluded from special consideration, and that major phased developments—which can impact communities for decades—will lose essential public scrutiny.

Perhaps most damaging is the “veto” power given to nominated officers. By allowing an unelected official to overrule a Committee Chair, the government is creating a system fraught with conflict that undermines public trust. The London Forum urges the Government to abandon these flawed reforms and instead focus on properly training committee members to ensure high-quality, transparent decision-making.

The full response can be read along with others in our ‘What we’ve said‘ archive.

We are critical of some of the new decision making policies.

London Forum response to NPPF consultation December 2025

We used some AI tools to help summarise our answers to the long set of questions in a readable format, with the detailed summary now held in our ‘What we’ve said’ archive here.

A shorter summary can be found below:

Section 1: Introduction

London Forum expresses strong reservations about the imposed Government’s housing target for London of 88,000 new homes per year, arguing that it was accepted by the Mayor without a proper assessment of London’s actual needs. They criticise the standard method used to calculate this figure as a “one-size-fits-all” approach that will put excessive pressure on London boroughs to increase the scale, density, and height of developments without adequate funding for the necessary infrastructure.

The Forum is also concerned about the large number of unimplemented planning permissions, particularly in tall residential towers, and suggests these should be reviewed.

They support the London Plan’s “Good Growth” policies but believe they need to be strengthened with more specific guidance, including a higher target for affordable housing.

Section 2: Increasing London’s Housing Supply

London Forum reiterates that the 880,000 ten-year housing target is unrealistic and not based on a proper assessment of London’s housing needs. They support a “brownfield first” approach but stress that development should be focused on locations with good public transport. They welcome a review of Opportunity Areas and the Central Activities Zone (CAZ), suggesting the latter’s boundaries should be redrawn to exclude primarily residential areas and parks.

They support the existing Strategic Views but they should be extended westwards. They argue the lack of protection for the Thames Policy Areas has led to poor quality development along the river.

They strongly support policies that focus on higher-density development in and around town centres and advocate for the reintroduction of a policy to co-locate industrial uses with housing. While they support a review of the Green Belt, they insist that any development on former Green Belt land must be sustainable and provide a significant amount of affordable housing. They are firm in their stance that Metropolitan Open Land (MOL) must be protected.

A key priority for the Forum is a significant increase in the delivery of truly affordable housing, with a focus on social rent.

Section 3: Growing London’s Economy

London Forum supports the ambitions of the London Growth Plan. They call for a review of the CAZ boundaries and the identification and support of specialist economic clusters.

They believe policies for town centres should be flexible and respect their diversity, while also managing the balance of uses to prevent a proliferation of food and beverage outlets.

For the night-time economy, they stress the importance of protecting local residents and differentiating between the evening and late-night economies.

They also call for action to address the problems caused by the growth of short-term lets, which they argue is reducing the housing supply for permanent residents.

The Forum strongly supports the protection of industrial land and the promotion of co-location.

Section 4: London’s Capacity for Growth and Design Quality

The Forum accepts the need for higher-density housing but insists this must be linked to transport accessibility and respect London’s heritage. They believe decisions on building heights and design codes should be made at the local level. They are particularly concerned to have a plan-led approach to tall buildings and oppose Mayoral interventions that override local plans.

They welcome the recognition that development needs to be strongly linked to transport connectivity and support the development of a new metric to assess this.

The Forum also argues against an over-emphasis on small studio and one-bedroom homes, which they believe has created a shortage of family-sized housing.

Section 5: London’s Infrastructure, Climate Change and Resilience

London Forum recognises the constraints on public funding for infrastructure. They support maintaining current energy efficiency standards and are sceptical about carbon offsetting. They welcome strategies for nature recovery and green infrastructure, and stress the importance of small open spaces and children’s play space.

They call for strengthened strategies to protect the Thames and its tributaries. The Forum reasserts that growth must be linked to public transport improvements and advocates for stronger measures to minimise car use. They also believe that where major transport projects are not funded, the development plans for dependent Opportunity Areas need to be reassessed.

They agree the Plan should clarify how fire safety policies should be applied, but note this ultimately needs to be addressed at a national level.

London Forum commented on the need for funding for English Heritage and Historic England, the importance of grants from the Heritage Lottery Fund and the deployment of enough skilled heritage practitioners.

DCMS Inquiry: Protecting Built Heritage

Response to Brownfield planning passports – Feb 2025

Response to Planning and Tall Buildings GLA – March 2025