Consultation closes 15 October 2026. We will release a model consultation response that you can use to help you respond if you wish.
The draft new London Plan is the first London-wide plan in a generation that removes more barriers to homebuilding than it adds. The proposed reforms tackle hidden costs that are borne by buyers and renters without adding anything a resident could see or touch, together with enabling more sites for new homes.
We have compared the consultation draft against the adopted London Plan 2021 and the Housing Design Standards guidance of 2023, drawing on the policy text itself (Chapter 2, Chapter 3, Chapter 5) and the emergency ‘Support for Housebuilding’ guidance of March 2026.
Why the London Plan matters
London is delivering fewer new homes than at any point since the financial crisis, while rents are the highest anywhere in the country. London delivers fewer homes per head than Manchester, despite vastly higher prices in London. Part of the reason for that is that planning policy has nearly doubled the cost of building homes in London compared to bare constructions costs; policy costs in Manchester are much lower. To turn this around, the new London Plan should reconsider previous requirements that both prevented the homes Londoners need and provided little benefit to residents. The draft Plan, to its credit, has started to do this.
What has been removed or relaxed
The eight-homes-per-core limit is gone entirely. Since 2023, guidance arbitrarily capped the number of homes per floor that could share a lift-and-stair core at eight. This forced many mid-rise buildings to have multiple cores, each one consuming floorspace, lifts, and maintenance charges, and made many otherwise viable buildings on infill brownfield impossible, reducing the number of homes built. The cap was withdrawn as an emergency measure in March 2026 and the draft Plan does not bring it back. Building Regulations continue to govern fire-escape distances.
Dual-aspect rules are now a principle which is subject to optimising site capacity. The 2021 Plan said single-aspect homes should be ‘normally avoided’; guidance required dual aspect in all but ‘exceptional circumstances’, and effectively banned north-facing single-aspect homes outright. The draft (Policy HN8) asks schemes to maximise dual aspect ‘within the overarching aim of optimising site capacity’, and accepts single-aspect homes wherever the applicant shows adequate ventilation, daylight, privacy, and protection from overheating. The north-facing prohibition does not reappear. Homes with two aspects can be a preference for some residents, and the draft still rewards them, but a requirement that could heavily limit the number of homes a site can provide has become a design consideration, which is what it should have been all along.
Minimum ceiling heights move from 2.5 metres to 2.4 metres (for 75% of each home’s floor area). Ten centimetres per floor sounds relatively little, but over a tall building it can be an entire additional storey of homes.
Carbon offset payments are abolished, and replaced with something stricter. Under the 2021 Plan, schemes paid councils a cash ‘offset’ for the gap between their on-site carbon performance and net zero: typically £500 to £1,000 per home, of which councils have spent just 13% of the £333 million collected since 2016. The draft replaces that apparatus with limits on how much energy a building may actually use (energy use intensity and space heating demand), verified by five years of measured in-use reporting, with numeric limits on embodied carbon for the largest schemes. Some of this is welcome: the levy delivered little; performance is now verified against reality rather than a model; and boroughs are barred from setting their own energy standards, ending gold-plating borough by borough. But the new limits are not the levy money redirected into insulation; they are a tighter standard. Meeting them plausibly adds several thousand pounds of policy costs onto building just one new home, and no costing has been published. Before the Examination in Public, the GLA should publish a per-home cost assessment of these standards against the forthcoming national Future Homes Standard.
Heating is decided by evidence, not hierarchy. The 2021 Plan required communal heating systems in large parts of London and ranked heat sources in a fixed order, with connection to district heat networks at the top, whatever the cost to residents in standing charges and heat-interface equipment. The draft asks instead for a ‘low carbon heat appraisal’: find the lowest-cost, lowest-carbon solution for the site, weighing upfront, whole-life, and end-user costs, with individual systems assessed on equal terms. In practice the winner will usually be the individual heat pump, which is also what national Building Regulations now demand. This will reduce requirements to build expensive plumbing on schemes in the name of a network that may never arrive. Where the Government’s heat network zoning designates an area, the national process governs.
Cycle parking falls to realistic levels. The flat London-wide standards (up to two spaces per larger home) become banded by location, dropping to 0.7–1.5 spaces per home in outer London, with credit for shared cycles and off-site provision, and explicit permission to provide less where compliance would force an extra basement level. The evidence from boroughs suggests that much of the cycle storage which has been required previously sits empty, and storage that sits empty is floorspace taken from living rooms.
Affordable housing thresholds are now banded to reflect the borough’s viability context. The single 35% fast-track threshold becomes 35% in the highest-value band, falling to 20% where values are lowest, with industrial land at 35% (down from 50%). The serious slowdown in the London housing market suggests that developments are struggling to handle the current thresholds, and a threshold that exceeds what a site can provide will deliver no housing at all. Calibrating affordable housing requirements to what can actually be delivered is essential to ensure we build the homes.
The Green Belt is carefully reviewed. The draft contains the first Green Belt release policy in the London Plan’s history: around 56,000 homes on land beyond the built-up area, limited to sites within 1,200 metres of a station or 400 metres of a frequent bus corridor, with greenfield housing targets for eight outer boroughs. That is the right type of release: homes beside stations rather than car-dependent sprawl, and a small fraction of the Green Belt in exchange for better planning and more homes.
Metropolitan Open Land can now be released based on defined tests. MOL protects strategically significant open space, around a tenth of London. Its boundaries could always in principle be redrawn in ‘exceptional circumstances’, but no policy said what those were, and in practice very little qualified. The draft (Policy PV6) enables boroughs to release land where it does not provide sufficient public benefit. Protection for what remains is unchanged: development on retained MOL still requires ‘very special circumstances’. Release remains a borough choice rather than a duty, so use will depend on borough appetite, but a willing borough now has a Mayor-endorsed route to trade publicly inaccessible golf courses for homes and public parks. Boroughs should look at it carefully.
A presumption in favour of small sites. Schemes under 0.25 hectares that follow the coming London Small Site Design Code are ‘acceptable in principle’. Boroughs are expected to make Local Development Orders for small sites, to allocate small sites and list them on Part 2 of their brownfield registers (giving them Permission in Principle), and to combine neighbouring small sites into single allocations where that enables mid-rise development.’
New targets
Every borough gets a ten-year housing target, plus a duty to plan for at least 850,000 homes by 2047. For the first time the plan also tells named outer boroughs how many of those homes should come from greenfield land, as a figure separate from brownfield.
New land released for housing. Under the 2021 Plan (Policy G2) Green Belt release was difficult in principle and opposed in practice. Policy PV7 tells boroughs with greenfield targets to release it, but only in the best-connected spots, at densities high enough to support public transport, and with new public green space added in return.
New density rules to encourage good land use. The 2021 Plan had no density rules, so how many homes a site could hold was fought over case by case. The draft sets a minimum for every site over 0.25 hectares with decent transport access: from 3 to 4 storeys in the most sensitive areas, up to 5 to 12 storeys in the best-connected ones. Building fewer homes than a site can hold now weighs very heavily against a scheme.
Homes in built-up areas. Eight named industrial estates are released for housing straight away (Policy PV5). Car parks are marked for more intensive use, estate rebuilds must replace at least the existing floorspace and add homes wherever possible, and the Brownfield First Opportunity Area are given target capacities that local plans should meet. Building on land that already is the cheapest and greenest way to add homes.
The gaps in the plan: the target, and former industrial land
The Plan aims at two-thirds of the need it acknowledges, which is in turn far short of the true economic need. The draft states London’s assessed housing need as 84,884 homes a year, then sets a ten-year housing target of 558,451 homes, around 56,000 a year. That is an improvement on the 52,300 a year of the 2021 Plan, and the draft identifies capacity for at least 850,000 homes by 2047. But a plan whose own target is a third short of its own need figure, let alone the vastly higher numbers that would start to address the shortage of homes, is a plan for the shortfall to continue: roughly 29,000 homes a year that London needs and does not intend to permit. There is a much larger gap between sale prices and bare construction costs today than in the 1960s or 1930s, which means that building homes creates vastly more value. Despite that, London built two times more homes per head in the 1960s and four times more in the 1930s.
The former industrial land at Park Royal which will be the temporary terminus for HS2 is still unlikely to deliver on the scale of its huge potential for new homes that Londoners need. It is roughly 450 hectares of low-rise sheds, car dealerships, low-value warehousing, and a biscuit factory. The site is the largest Strategic Industrial Location in London. It sits within a 650-hectare development corporation area, ringed by 11 Underground and Overground stations, and is at the doorstep of the Old Oak Common superhub which the Government is spending over £100 billion to make the best-connected location in the country. It will have direct links to Heathrow, Central London, Paddington and the West, and via HS2 to Birmingham and the North.
The current plan for the area contemplates around 24,000 homes. An ambitious mixed plan of council homes and market flats together could support many times that, every one of them within walking distance of high-capacity public transport, on brownfield land, without touching a blade of Green Belt grass. Yet the draft firmly restates the industrial designation, and points the proposed new release mechanism only at two modest estates on the area’s periphery. Protecting genuinely needed logistics space is sensible, but freezing the largest and best-connected development opportunity in Britain mainly in lower-value sheds, while the city around it queues for homes, is not. Building homes at good density beside stations is the pro-environment choice: it allows growth without sprawl, cars, or carbon.
There are versions of reform that would work for everyone already on the site: planned release coupled with a worker welfare fund, financed from the development value the change of use creates. This would give existing workers payouts, retraining, and placement support so that the people who work in Park Royal today share in what replaces it, while ensuring that necessary logistics space is re-provided elsewhere. Growth should fund the transition it requires.
Our assessment
The draft Plan removes the eight-homes-per-core cap, the dual-aspect rule, higher mandatory ceiling heights, the carbon offset levy, the heating hierarchy, and a quarter to a half of prescribed cycle storage. It will make it easier to build new homes. Overall, it deserves support for that. It could and should go much further.
Consultation closes 15 October 2026. We will release a model consultation response that you can use to help you respond if you wish.
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