Half the Length, Double the Ambition

The publication of Mayor Sadiq Khan’s draft London Plan opens a major debate about how London should grow over the next two decades. More streamlined than its predecessor, the Plan sets out a strategic framework focused on two core objectives: delivering as many affordable homes as possible and supporting economic growth that benefits Londoners.

At nearly half the length of the 2021 London Plan, the draft is a deliberate attempt by City Hall to reduce complexity, improve certainty and make the planning system easier to navigate for applicants, boroughs and communities. It retains key London-specific standards but aligns more closely with national policy changes that have seen national policy address matters that would have previously sat within the London Plan.

The Plan identifies how the capital could deliver up to 558,000 homes by 2037, while acknowledging that brownfield land alone will not be enough to meet long-term housing need. It also acknowledges that Government targets far exceed this target and notes that delivery on the Government’s proposed scale could only be achieved with major Government investment in infrastructure.

The Plan recognises the pressures facing the development sector, the limits of a brownfield-only approach, and the need to protect land for economic uses as well as homes. However, it also exposes the difficult choices that will define London’s next phase of growth.

The political context is also materially different from the one that shaped the current London Plan. Recent local elections saw a significant shift away from Labour across London, with the party losing control of vast swathes of the capital.

The Mayor may still set the strategic planning framework, but many of the most difficult decisions on site allocations, Green Belt release, estate renewal, industrial land, infrastructure priorities and local plan-making will sit with boroughs that are now less politically aligned with City Hall.

A Plan that asks boroughs to accommodate difficult trade-offs, including higher housing numbers, selective Green Belt release and stronger protection for strategic industrial land, will require sustained cooperation from local authorities. Where councils are Conservative, Green, Liberal Democrat, Reform-led or under no overall control, the political calculus around growth is likely to become more complex.

Meeting London’s Housing Challenge

Housing remains the dominant theme running through the Plan. The Mayor’s strategic affordable housing target remains 50%, but the Plan proposes a more responsive framework that reflects differing development values and viability conditions across the capital.

The changes acknowledge the difficult conditions facing London’s development market. High interest rates, rising construction costs, the legacy of the pandemic, labour shortages and the lasting impact of Brexit have created a challenging environment for housebuilding, impacting viability significantly.

Against this backdrop, the revised affordable housing approach can be viewed as a recognition that rigid policy requirements alone cannot deliver homes if schemes remain financially unviable. The Mayor’s willingness to adjust thresholds for Fast Track eligibility shows a degree of pragmatism that is reflected in the current emergency affordable housing measures that remain in place for the next 2 years.

The Plan proposes to move the Fast Track threshold back towards 35% from 2028 for as many boroughs as possible, while using varying thresholds elsewhere to reflect local viability. The Mayor’s long-term ambition remains to return to a 35% threshold across London as market conditions improve, with boroughs able to move between bands where evidence supports it.

Yet the fundamental question remains whether the Mayor alone has sufficient tools available to achieve the scale of housing delivery envisioned by the Plan.

While City Hall can simplify planning requirements, shape land-use policy and advocate for investment, many of the factors determining delivery sit beyond its direct control. Housing output remains heavily dependent on market conditions, infrastructure funding, development finance and national policy decisions.

The gap between the ambition of London’s housing targets and the reality of delivery therefore remains one of the defining challenges that will need to be addressed outside the London Plan process.

Breaking New Ground on Green Belt Policy?

Perhaps the most politically significant aspect of the Plan is its approach to the Green Belt.

The Plan accepts that brownfield land alone cannot meet London’s long-term housing needs. However, it does not itself release Green Belt land or identify individual sites. Instead, any release would sit with boroughs through their Local Plan processes, supported by evidence and guided by the accompanying Green Belt work.

There is a suggestion the GLA see a mixture of ‘90% Brownfield, 10% Green Belt’ as a preferred approach. While the Mayor falls short of explicitly earmarking sites within the Green Belt, the plan clearly identifies sites with ‘development potential’.

These include:

• New Addington – Croydon
• The Eastern Hainault Loop
• East of Ickenham – Hillingdon
• Mill Hill and Barnet – Barnet
• Northwood – Hillingdon
• Crews Hill and Chase Park – Enfield
• West Ruislip – Hillingdon
• Harold Park – Havering
• Upminster – Havering
• Dagenham – Barking & Dagenham

Map showing broad locations identified for growth over 10 years

Even with the Mayor being clear responsibility for Green Belt release remains with the boroughs, this policy does mark a shift in the GLA’s approach.

For many years, Green Belt policy was treated as politically untouchable despite growing evidence that available brownfield land alone would struggle to meet the capital’s housing needs.

The Mayor’s position remains caveated. Any Green Belt release would need to deliver clear public benefits, including substantial affordable housing, good transport connectivity, appropriate infrastructure, improved access to green space, biodiversity net gain, a landscape-led approach and enhanced access to nature. In practice, this points more towards carefully selected grey belt opportunities than wholesale Green Belt release.

While many in the development sector will welcome the change in principle, there are legitimate questions about whether the restrictions attached to release will unlock enough land to make a meaningful impact on overall housing supply.

Crews Hill: A Test Case for London’s Future

The ongoing debate around the proposed Crews Hill new town in Enfield offers a useful illustration of the opportunities and challenges associated with Green Belt release.

The proposal has emerged as one of London’s most prominent examples of how Green Belt land could potentially contribute to long-term housing delivery. Advocates argue that strategically located Green Belt sites with existing transport connections offer some of the best opportunities to deliver large-scale housing growth, alongside new infrastructure, community facilities and environmental improvements.

The Plan effectively creates a framework through which schemes of this nature may become easier to justify in planning terms..

However, the controversy surrounding Crews Hill also highlights why Green Belt release remains politically difficult. Questions about environmental impacts, local infrastructure capacity, landscape character and the precedent created by development on protected land continue to generate significant opposition.

The Plan therefore attempts to strike a middle ground. It accepts that some Green Belt release may be necessary, while setting a high bar for schemes seeking to benefit from the policy.

The Land Use Balancing Act

Arguably the most interesting policy challenge within the Plan is not Green Belt release but the tension between the Mayor’s housing and economic ambitions.

On the one hand, the Plan prioritises brownfield land for housing delivery and seeks to accelerate development on suitable sites. On the other, it places strong emphasis on protecting and providing the spaces for businesses including affordable workspace, industrial land, logistics, freight, data centres and strategic infrastructure. These objectives are not always compatible.

Across parts of London, the land most suited to large-scale redevelopment already performs important industrial and employment functions. Strategic Industrial Land continues to play a crucial role in supporting logistics networks, servicing London’s economy and accommodating increasingly land-hungry sectors such as data infrastructure.

The challenge is particularly acute given the Mayor’s ambition to support AI, life sciences and green data centre infrastructure. These sectors require land, power, transport connections and long-term certainty. Protecting the land needed for these uses may inevitably reduce the pool of brownfield sites available for housing.

The resulting tension is likely to become one of the most heavily debated aspects of the Plan, as stakeholders consider whether the balance between homes and jobs has been struck appropriately.

It will also serve to strengthen the voices of individuals and groups who believe the Green Belt should be a last resort or remain entirely untouched.

The Plan’s twin drivers, housing delivery and economic growth, will therefore need to be reconciled site by site, particularly where brownfield land is also performing a strategic employment, logistics or infrastructure function.

Culture, Pubs and the ‘24-hour Economy’

The Plan highlights the importance of London as a global destination, drawing reference to the transformation of Oxford Street and the West End while also highlighting the importance of the Central Activity Zone and strategic economic clusters across the capital.

The emerging AI and life science clusters in locations like King’s Cross and White City should benefit from a more supportive approach and it is clear the Mayor intends to prioritise the growth of high-tech sectors and the supporting infrastructure they require.

The Plan also maintains a clear emphasis on protecting London’s pubs, music venues, theatres, cultural spaces and night-time economy. This is significant because national planning policy gives these uses less explicit weight than the Mayor has historically sought to apply through London planning policy. Retaining strong London-level protections will therefore be important when boroughs assess redevelopment proposals that could affect cultural infrastructure.

Where Does London Go from Here?

The Plan represents a significant evolution in City Hall’s approach to planning policy. It is more streamlined, more pragmatic and arguably more willing to engage with difficult questions around viability, infrastructure and land supply than previous iterations.

Its acceptance that Green Belt release may be necessary marks a notable shift in London’s planning orthodoxy, while its emphasis on AI, life sciences and strategic infrastructure reflects the growing importance of future-focused economic sectors.

However, the success of the Plan will ultimately depend on delivery rather than aspiration. The housing targets remain exceptionally ambitious given current market conditions, Green Belt release remains tightly constrained and important tensions remain around how housing growth can be reconciled with the need to retain strategic industrial land.

As the consultation begins, stakeholders across the planning, development and regeneration sectors will be examining whether the Plan provides the right framework to address these competing priorities.

What is certain is that the conversation about how London grows over the next 20 years has entered a new and significant phase.