Planning matters blog

A Brave New Order

Luke Bonnici 31 Jul 2026

The Department for Culture, Media & Sport (DCMS) has just published Turn It Up: Our plan for music [1]. It represents the most ambitious strategy for music in over a decade, asking a set of important questions about how to secure a thriving music industry, widen opportunity, and use music to strengthen communities and local economies across the UK.

The Plan commits £45 million to a Music Growth Package, in addition to £12.5 million to transform libraries into music hubs, and £10 million for creative mentoring targeted at underrepresented young people. It also backs a voluntary £1 arena levy for shows over 5,000 capacity directing proceeds into the grassroots ecosystem.

Crucially, the Plan acknowledges that rising costs, slim margins (of just 2.5% for grassroot venues), and shifting audience behaviours are placing increased pressures on the very foundations of the live music sector. It recognises that small venues have not received sufficient investment and argues that access to live music should be available “wherever people are in the UK”.

This is a welcome shift, and lands at a moment of significant political change. The new Prime Minister has been clear in his early messaging of “local first”. His agenda thus far, has emphasised empowering local areas to revive high streets, support SMEs, and reform business rates to create fairer conditions for local businesses. Live music, and the venues that sustain it, sit squarely within this agenda.

Against this backdrop, this blog explores a key question; why do towns and cities’ economies depend so much on grassroots music venues, and do these venues depend on the wider urban ecosystem in return?

Reflecting on Lichfields’ work supporting the arts, culture and music across the UK, in addition to insights from the recently held Hull Music Cities Convention [2], four themes stand out.

Grassroots venues are essential infrastructure, not ‘nice to have’

Turn It Up rightly positions grassroots venues as the bedrock of the UK’s music ecosystem. They are where artists, crew members and promoters learn their craft, where communities gather and where local identity is formed. They are also where the night-time economy begins; generating cultural energy, animating town centres and building civic pride.

Yet for years, these venues have been treated as somewhat peripheral, or sometimes even as a nuisance to be managed. Licensing regimes have constrained opening hours, impacting their vitality and driving audiences away. Additionally, investment has flowed disproportionately to larger-scale venues, with many grassroots venues being forced to shut.

The Government’s Plan begins to correct this imbalance; however, the underlying principle is bigger than any single intervention. A thriving night-time economy cannot exist without thriving grassroots venues; one cannot function without the other. For example, a recent article in The Guardian [3] highlighted how London is rapidly losing its nightlife (and consequently its night-time economy) due to increasingly restrictive licensing policies, particularly through the widespread enforcement of “core hours”, effectively imposing a council-mandated bedtime for the night-time economy.

Turn It Up acknowledges this. Grassroots venues are not simply cultural assets; they are important economic catalysts. They drive footfall, animate high streets and create the conditions for other adjacent industries (such as hospitality, retail and transport) to thrive. In other words, they provide the spark that activates the rest of the night-time economy.

Economic impact matters, but it’s not the whole story

Turn It Up emphasises the £8 billion contribution of the music industry to the UK economy. This is important, but is only one dimension of value.

At the recent Hull Music Cities Convention, presenters repeatedly suggested that economic impact should not be regarded as the sole measure of success. While in today’s environment, economic impact matters more than ever, it is correct to say that it is also important to capture cultural identity, emotional value, inclusion, belonging and community cohesion.

Lichfields’ work with clients across the industry reinforces this. When assessing the impact of construction and first year operations at Co-op Live in Manchester [4], we found that economic impact (measured in terms of gross value added) represented only a fraction of the venue’s wider contribution. The real value lay in confidence, aspirations, community pride and the catalytic effect of kickstarting the regeneration of East Manchester. This is something the new Prime Minister will be all too familiar with.

This is where Turn It Up is, perhaps, less explicit. The Plan acknowledges the civic role of music, but underplays the emotional and wider societal value that live experiences generate. Fortunately, emerging research fills this gap.

The Goosebumps Effect, and why live music matters to communities (and economies)

A recent study, The Goosebumps Effect [5], provides compelling evidence for the emotional and social value of live experiences. It shows that shared moments can increase empathy, reduce anxiety, strengthen social cohesion and build collective resilience.

A visceral, example of this was experienced by many during the 2017 memorial following the Manchester Arena attack [6], where one song – Don’t Look Back in Anger – brought people together and provided the resilience needed for the community to begin healing.

This effect matters; it shows that live music is not just entertainment but provides the emotional framework required to create belonging and wider community trust. Ultimately, it has potential to strengthen the social fabric that underpins local economies. At the grassroots level, the proximity and intimacy of smaller venues amplify these effects.

If we want a thriving night-time economy, we must therefore measure (and invest in) these forms of value. Economic impact must therefore include societal impact within it.

Building a strong night-time economy requires ecosystem thinking

One of the clearest messages from the Hull Music Cities Convention was simple; you have to be intentional to be inclusive. This message applies equally to building a music city, as well as a night-time economy. Neither is a collection of isolated assets. They are an ecosystem where transport, licensing, skills, community safety, affordability and cultural infrastructure all meet and interact.

Turn It Up opens the door to this kind of thinking by supporting more flexible licensing, investment in grassroots infrastructure and widening access for young people. However, success will require places to build on this foundation. It will require councils, venue operators, promoters and economic development professionals to stop thinking in silos and start thinking in systems.

It will also require balancing venue operations with residents’ needs. The recent “debate” between the Mayor of London and the Soho Residents’ Society [7] shows how essential it is to balance cultural vibrancy with residential amenity. The Draft London Plan [8] – currently out for consultation – reinforces this direction. Policy GLE4 Night-time economy seeks to boost economic activity in hospitality, culture, nightlight and events, whilst also protecting and future-proofing night-time areas from sensitive uses by deploying the Agent of Change principle. In addition, the Draft London Plan also makes the case for greater integrated coordination across planning, licensing and transport to ensure a thriving 24-hour economy.

This is ecosystems thinking in practice, and putting grassroots venues central to this equation aligns closely with the Prime Minister’s early ‘local first’ message that a thriving national economy begins with strong local foundations.

A brave new order, but the work starts at the bottom

Turn It Up provides a starting point and the platform for strengthening the UK’s music ecosystem. It recognises the importance of grassroots venues to widen opportunity and start addressing some of the structural challenges facing towns and cities.

But its success depends on whether places can embrace a bottom-up approach; one that values emotional and societal impact alongside economic metrics, and treats music as the tide that lifts all boats. This aligns closely with the Prime Minister’s early messaging. A modern music policy (and consequently a modern night-time economy) must reflect this.

If we want cities that thrive, and night-time economies that are vibrant, safe and resilient, we must start where music begins – the grassroots venues that give places their identity and their confidence.

And we must also build an ecosystem around them; intentionally, collaboratively and from the ground up. A brave new order starts at the bottom.

Footnotes

[1] DCMS (2026), Turn It Up: Our plan for music [Link]

[2] Hull Music Cities Convention [Link]

[3] Bedtime blues: London ‘killing off nightlife’ as UK city with strictest licensing rules [Link]

[4] Co-op Live contributes over £1.3 billion turnover to UK economy since inception [Link]

[5] The Goosebumps Effect [Link]

[6] See [Link]

[7] Sadiq Khan vows to overrule residents’ group’s objections to Soho bars and restaurants [Link]

[8] Mayor of London (2026), Draft London Plan [Link].

PBSA in London: Becoming a Strategic Housing Target

Jonathan Hoban 27 Jul 2026

The publication of the Draft London Plan marks an important moment for London's purpose-built student accommodation (PBSA) sector. Interestingly, one of the biggest changes isn't the introduction of a new policy - it's the removal of one.

For years, PBSA has benefited from its own dedicated policy within the London Plan. In the draft Plan, that standalone status has disappeared.

Instead, PBSA now sits alongside co-living, specialist housing, supported accommodation and older persons' housing within the new draft Policy HN5: Managing Specialist Accommodation.

At first glance, this might appear to downgrade the sector. However, it may signal the opposite.

Rather than treating PBSA as a niche product requiring its own bespoke policy, the GLA increasingly appears to recognise it as an established component of London's housing supply and economic infrastructure. For a sector that historically had to justify its role in London, especially in the early years of the London Plan 2021, this may represent a significant shift in thinking.

A maturing sector

The consolidation of specialist housing into a single policy inevitably creates a longer and more complex policy. However, it also reflects the fact that PBSA is no longer viewed as an exception.

In practice PBSA has become part of London's wider housing solution - reducing pressure on conventional housing stock, supporting affordable homes and helping deliver economic growth. The Draft London Plan appears to recognise this more explicitly than the current London Plan.

Familiar principles remain

Although the structure of PBSA policy has changed, the fundamentals remain largely unchanged.

PBSA developments are still expected to:

be located in accessible, well-connected locations;
contribute towards affordable housing in accordance with Policy HN3;
support mixed and inclusive neighbourhoods; and
secure affordable student accommodation through nomination agreements where appropriate.

Importantly, PBSA continues to contribute towards borough housing delivery, with 2.5 student bedspaces counting as one home for monitoring purposes. That recognition of student accommodation as part of London's housing supply remains firmly embedded within the Plan.

A more proactive approach to delivery

Perhaps the most significant policy shift in the draft London Plan is the move from simply looking to manage applications for student accommodation to actively planning for PBSA.

Draft Policy HN5 now requires boroughs to meet student accommodation needs and identify opportunities to support delivery. Alongside this, the Draft London Plan introduces:

a London-wide target of approximately 31,500 PBSA bedspaces between 2027 and 2037; and
individual borough level targets, with Barnet, Brent, Croydon, Ealing, Greenwich, Hillingdon, Newham, Southwark, Tower Hamlets and Wandsworth the ten boroughs earmarked for the highest levels of PBSA delivery.

This represents a notable departure from the 2021 London Plan, which deliberately avoided borough-specific student housing targets.

The evidence underpinning the approach to need, the Student Accommodation Need: Analysis and Review of Evidence (July 2026), concludes that London's demand for PBSA will remain strong throughout the Plan period, driven by affordability pressures and international student demand. Importantly, the GLA has adopted a cautious growth assumption, recognising the challenges experienced in parts of the UK where oversupply has emerged following changes in student demand.

The borough targets have been derived using housing growth forecasts, accessibility to higher education institutions and the availability of suitable development locations, including Opportunity Areas, town centres and Green Belt station catchments.

Overall, this should encourage boroughs to take a more positive and proactive approach towards student housing.

However, targets can cut both ways.

Once boroughs consider their target to have been met, there is a risk that they begin resisting further proposals, even where market demand remains. Likewise, the suggestion that boroughs should allocate specific PBSA sites could reduce flexibility if plans are unable to respond quickly to changing market conditions.

As we highlighted in our previous PBSA Insight, Unlocking London’s Student Housing Potential successful plan-making depends upon retaining sufficient flexibility to accommodate future shifts in demand. Broad ‘residential’ allocations allowing for PBSA (and other living sector uses) in Local Plans are surely preferable to inhibitive PBSA-specific allocations.

Location has never mattered more

Whilst the Draft Plan is broadly supportive of PBSA, it places considerably greater emphasis on where schemes should be located.

The GLA now states that PBSA should generally be located within around 30 minutes' travel time - whether by walking, cycling or public transport - of a university campus, while also benefiting from good access to services and public transport.

The Draft Plan also introduces a greater focus on concentration.

Under Policy HN5, boroughs are encouraged to consider whether clusters of student accommodation are beginning to undermine mixed and inclusive communities. Where evidence of over-concentration exists, local planning policies may be justified to remedy this.

Supporting paragraph 3.72 reinforces that it is for applicants to demonstrate that schemes are appropriately located, designed and managed so that they contribute positively to neighbourhoods, while recognising that local planning authorities may identify spatially specific considerations through their Local Plans.

This balancing exercise, supporting delivery whilst avoiding over-concentration, is likely to become one of the key planning debates for PBSA over the coming years.

A more flexible affordable housing approach

One of the most welcome changes is a shift in the approach to affordable housing policy.

The current London Plan merely promotes on site Affordable Student Accommodation (ASA) for PBSA schemes. ASA is defined as a bedroom with an annual rental cost at or below 55% of the maximum government maintenance loan for a student living away from home in London. Existing policy requires 35% ASA in qualifying PBSA schemes to follow the fast track route.

In our previous Insight, we identified three emerging models for delivering affordable housing within PBSA schemes. It is encouraging to see the Draft London Plan now proposing these as the three affordable housing options for PBSA.

Under draft Policy HN3: Delivering Affordable Housing new PBSA schemes would be able to provide affordable housing through:

on-site affordable student accommodation;
a combination of affordable student rooms (up to 10% below the policy threshold) alongside a payment-in-lieu towards conventional affordable housing; or
conventional affordable housing.

The relevant thresholds are set out table 3.2 of the policy and now vary from borough to borough and are dependent on specific circumstances. The relevant thresholds and circumstances, as well as further details on the affordable housing policy can be found in our blog, Affordable Housing Under the Draft London Plan: Progress or Further Complexity?

This shift introduces far more flexibility than the current policy, which favours affordable student accommodation secured through Nomination Agreements.

Indeed, Nomination Agreements are now only required for the affordable PBSA element itself. Under the new policy a scheme delivering 100% affordable student accommodation would not require one.

Helpfully, for Option 2 (combined ASA and PiL), the draft Plan also introduces a methodology for calculating the payment-in-lieu contribution. Until now, our own research identified that approaches have varied considerably between boroughs, with no strategic policy framework in place.

One issue we note with the current drafting, however, is that these affordable housing options appear to be framed solely around the Fast Track Route, with no reference to the viability-tested route set out in Part K of the policy. This is likely to require clarification as the Draft London Plan progresses.

Notwithstanding this, for schemes facing viability challenges, or for operators whose preferred affordable housing model differs from traditional nomination-based accommodation, the additional flexibility provides genuine choice and could improve deliverability while continuing to support wider affordable housing objectives.

Revised accessibility standards

The Draft London Plan also proposes changes to the accessibility requirements for PBSA developments.

Currently, PBSA schemes are generally expected to provide either:

10% wheelchair-accessible bedspaces; or
15% accessible bedspaces.

The draft policy instead proposes:

4% wheelchair-accessible bedrooms;
1% wheelchair-accessible bedrooms with tracked hoists and adjoining companion rooms; and
5% easily adaptable bedrooms.

These revised standards reflect the evidence contained within the supporting Student Accommodation Need evidence and represent a more targeted approach to accessibility provision.

Supporting phased delivery

Although not PBSA-specific, the Draft Plan also recognises the role that phasing can play in improving scheme viability.

The supporting text under policy MBUL1 Spatial Strategy, acknowledges that, for PBSA and purpose-built shared living developments, deferring affordable housing requirements from early phases may help establish scheme value and improve deliverability.

Questions remain as to how this approach would operate in practice and how local planning authorities would secure the delivery of the affordable housing. While this approach is likely to benefit larger multi phased projects more than standalone PBSA schemes, it nevertheless demonstrates an increased awareness of development viability which is welcomed.

Looking ahead

Taken together, the Draft London Plan sends a clear message. The GLA increasingly views PBSA as more than an alternative investment asset. It is now recognised as an important component of London's housing needs and economic infrastructure.

We think the overall direction of travel is positive. Well-located, well-managed schemes that contribute appropriately towards affordable housing should continue to receive strategic support.

Rather than questioning whether PBSA should be delivered, the focus is increasingly shifting towards how much, where, and how it contributes to London's wider housing and growth ambitions.

This is a positive change. However, with viability pressures and wider market challenges continuing to affect the PBSA sector, we question whether the Draft London Plan provides sufficient flexibility and incentives to unlock the scale of delivery it envisages.

The consultation is open until 15 October 2025. Please do get in touch if you have any questions or would like to discuss how to make your representations.

Header Image credit: JTP

Data Centres: ‘in or out’ as Nationally Significant Infrastructure?

Nancy Stuart 24 Jul 2026

There is much fanfare around Government changes to the Nationally Significant Infrastructure Projects (NSIP) consenting process, the latest update to which is a new suite of guidance published on the 3^rd July 2026, that comes into force this week - 24 July. The ambition of the changes is to cut through the procedural burden on applicants to make the process more attractive to use. In outline, changes involve redesigning the pre-application stage to create a more applicant-led process, with earlier technical input from PINS, removal of statutory consultation requirements and a greater focus on tracking the ‘main issues’ hopefully leading to a focused issue-led Examination.

There is undoubtedly a real effort being made in streamlining the process, but whether it will deliver on supposed time savings remains to be seen - as applicants are likely to remain nervous about shifting away from current practices on consultation, particularly with guidance removing procedural requirements yet still encouraging early engagement and consultation with all parties involved. There remains a need for Examinations to have no surprises - but how will this be achieved without supplying statutory consultees with sufficient information through meaningful (and time-consuming) consultation. But for data centre promoters, there is a lot to consider in deciding whether to progress projects through the DCO system.

Data Centre Options (DCO…?!)

Hugh Scanlon’s blog in December last year discussed the potential implications of the reforms and opportunities for promoters, and in particular the latest state of play regarding data centre NSIP opt-in. The Government’s July 2026 consultation response re-affirms the reforms for data centre consenting, in particular the apparent benefits of the approach for data centre projects, stating:

Much-needed infrastructure like data centres can now opt in to the NSIP regime that allows developers to rapidly deliver these projects, if granted, through strict, fixed timeframes rather than facing endless delays locally. Ministers have already directed three data centre proposals into the NSIP regime at Wapseys Wood in Buckinghamshire, Ampthill Road in Bedford[1], and New Barn Lane in Dartford.

The tone set is to highlight the benefits of the DCO regime for data centre projects. However, while there is the possibility to opt-in, there is also the choice to opt out (if qualifying) where the SoS is satisfied that an alternative regime is appropriate for the development. Guidance on Powers to Direct a Project into or out of the NSIP Regime discusses the alternative consenting regimes under which qualifying developments that can seek to opt out of the DCO process may consider as appropriate alternatives. The obvious being the TCPA, which to date has been the clear or only route for most Data Centre projects, though not without its trials.

What differences between DCO and TCPA should data centre developers be considering?

The attraction of the DCO route is its offer of a nationally managed process without local politics at play, clarity of timeframes from submission, and a single development consent that brings together planning permission, compulsory acquisition powers and other consenting powers within a single decision which may be difficult to assemble through a standard planning permission. For large data centre campuses involving grid connections, energy generation, complex highway works, or the need for compulsory acquisition, the DCO regime could provide a more attractive consenting route to a locally determined planning application.

However, the DCO process is front-loaded, resource-intensive and can be procedurally demanding (even with the removal of statutory consultation requirements). Promoters need a mature scheme, an efficient consultation and engagement strategy to enable the key issues to be drawn out and dealt with early on, detailed environmental material and legal input throughout. The new PINS guidance on preparing the DCO application reinforces the transition to applicant-led issues tracking during the pre-application stage to ensure the scheme submitted is examination ready.

Is opting-in a real alternative for data centres?

With only three data centre schemes currently opting in, attitudes towards the NSIP consenting option appears less than enthusiastic. Furthermore, two of these projects include on-site energy generation that would constitute NSIPs in their own right – in such circumstances, a single DCO for the entirety of the scheme (data centre and energy production) presents the only coherent consenting strategy for the proposals. However, earlier this month, a third was directed into the NSIP process, with the SoS stating in its Direction that the project by itself is nationally significant for the reasons of significant economic impact; driving economic growth; substantial physical size; and transboundary impacts. Perhaps we are on the cusp of a new wave of opt-in data centre schemes, as applicants look at the new streamlined consenting approach with new vigour?

To opt-in or not? What should developers consider going forward?

In advance of the long-promised National Policy Statement (NPS) on data centres, there is some uncertainty as to the potential treatment of data centres in the DCO system. The Government’s positive attitude towards the sector is clear (see the NPPF, its designation as Critical National Infrastructure, and various appeal precedents), but the NPS will need to cement this support. Assuming this outcome, potential DCO applicants may want to consider the following in consenting strategy decisions:

S35 qualifying criteria: Are projects of national significance? The opt-in mechanism depends on a Section 35 direction; it is not an entitlement. The promoter must demonstrate to the SoS that the project is nationally significant. Is there clear evidence to the economic impact and reach of the scheme; is the physical size and capacity that of national significance; is it important to the delivery of a NSIP or other significant development?
Other consents: Are compulsory acquisition powers required, or is there required links to power sources, grid infrastructure, highways or other enabling infrastructure that would require separate consents and licensing to enable delivery of the project?
Programme: The DCO process has statutory stages, with relatively fixed timeframes for most parts, and even with the removal of statutory consultation, the overall period is still likely to remain protracted. Comparison to other consenting regimes should be mapped with your planning consultant to consider realistic time savings.
Statutory consultee engagement: With the removal of statutory consultation, what’s ensuring the assistance of statutory consultees through the pre-application process – when their views and guidance on key issues to these major infrastructure projects is vital? The cost recovery system for some statutory consultees is a consideration but does not enforce the same mandatory participation in pre-application advice and consultation on NSIPs.
Local authority attitude to the sector/proposals: Local authority attitude towards development proposals is critical. Any reaction to an application proposal will of course be bespoke to the characteristics of that scheme and its context, but increasingly, issues related to power availability and a focus towards on-site job generation, rather than wider (and significant) economic benefit are heading agendas. Furthermore, with the rise in data centre development, promoters are facing increased interest from lobby groups, challenging the merits of the sector. Despite an NPPF direction to consider the needs of data centres in its plan-making and development management decisions, as a consequence of this context, the sector might find increased resistance to development proposals. In such a scenario with an unsupportive local authority, the DCO consenting option may well become a more attractive proposition.

In or Out?

The reforms represent a huge shift in NSIP consenting and only add to the attractiveness of the DCO process as a consenting option for major data centres schemes. Consenting strategies will remain dependent upon project circumstances, but Lichfields has witnessed an increased level of enquires from the sector exploring the possibilities on offer. The final piece in the jigsaw is the long-awaited data centre NPS – many are hoping that it will create sufficient encouragement to the burgeoning data centre sector to definitively tip the balance in favour of the ‘opt-in’. The early pioneers already the subject of successful s35 directions may be sitting pretty.

Footnotes

[1] Lichfields has advised on the data centre proposals at Ampthill Bedfordshire

Assessing the draft London Plan's position on housing: does it make the grade?

Sally Furminger & Ross Raftery 23 Jul 2026

The Mayor has now published his draft of the next London Plan. Some will contend that it feels like Groundhog Day[1] and others will debate whether it is a plan of realism or defeatism. What should be recognised is that drafting a London Plan in the current economic and regulatory context is an immense challenge and is one that the GLA has sought to grapple with directly.

In this blog, we deliver our initial verdict on what the draft London Plan means for housing in London and some of the key housing-related policies to look out for.

The requirements of an SDS

The government is embarking on a policy approach to roll out Spatial Development Strategies (SDSs) across England.[2] In its draft NPPF (December 2025),[3] the government defined a set of requirements (PM1) and a series of tests of soundness (PM14) that SDSs should meet.[4] The London Plan is likely to be the first SDS to be tested against these policies – and, as we consider below, this is likely to present another set of challenging decisions for its future Inspectors.

The draft NPPF (Policy PM1) requires that an SDS should, amongst other things:

set a positive vision for future growth and change
be genuinely strategic in nature and allow for more detailed issues to be considered and addressed through other parts of the development plan
set a strategy for a sustainable pattern of growth covering a period of at least 20 years
identify where changes to Green Belt boundaries may be needed to meet the development needs of the strategy area

How does the draft London Plan respond? With ‘only’ 558,000 homes

Just last year, in his ‘Towards a new London Plan’ consultation, the Mayor acknowledged that “The government has said London needs 88,000 new homes per year. So the next London Plan needs to plan for 880,000 homes, ten years’ supply.”[5]

However, the draft Plan does, in fact, only identify a strategy to meet 65% of London’s identified housing needs for the next 10 years[6] and not the 20 years required. With this approach, it seems inevitable that the next set of London Plan Inspectors will have a similarly difficult choice to make as their predecessors – considering whether it is better to have a plan in place versus the continued shortfall of housing in London which, following this strategy, would increase by a further 300k homes in the next 10 years.

In doing so, they will need to consider this (draft NPPF, PM14): “A strategy which does not provide for objectively assessed needs should be considered an exception, and only where it is evidenced that stringent efforts have been taken to meet those needs through cooperation with other strategic planning authorities”

In another recent Lichfields blog,[7] we hypothesised how the Mayor could begin to meet the target of 1.69m homes over 20 years. Our conclusion was that there is a potential gap of c.850k homes and the inescapable reality was that London would need to look beyond its boundaries, to the South East, to address this need on a strategic basis. There is no indication that this engagement with South East authorities has taken place.

Misaligned to the draft NPPF expectations of SDSs,[8] the draft London Plan only sets housing targets for the first 10 years; however, it does suggest that more is possible, and there are opportunities to deliver homes up to and beyond 850,000 homes after 10 years. This is not exactly a ‘strategy’ for sustainable growth as this overlooks the fact that a 20 year target (based on the current Standard Method and required by the draft NPPF) would be c.1.69m homes and therefore draft Policy HN1[9] would still result in a shortfall of up to 850k homes by 2047.

Release of the Green Belt

Looking to the positives, for the first time, the London Plan sets specific greenfield housing targets, acknowledging that brownfield land alone will not be enough. But, this is clearly a tentative step. Just 8 (out of 14) outer London Boroughs are given a greenfield housing target,[10] and the total of these equates to just 10% of the Plan’s overall housing target. Moreover, these greenfield housing targets exclude the use of Metropolitan Open Land (MOL) – arguably a policy construct that is most within the realms of the Mayor to amend as the NPPF does not require or include this designation.

Preventing the Presumption?

The draft Plan sets out reasons why it is not possible for it to go further with housing targets in the ten-year period. One such (bemusing) justification is seeking to mitigate the risk that the plan-led approach would be undermined if unachievable housing targets are set for London Boroughs and they then fail the Housing Delivery Test and 5-Year Housing Land Supply tests, with their associated consequences.

However, with the level of need that London has and the shortfall that the Plan will create, these are precisely the circumstances in which a stronger presumption must be applied.

Borough-by-borough assessment

A role of an SDS is to tackle the politically-sensitive matter of apportioning the SDS area’s housing need within its constituent authorities. We have assessed the difference in annual housing target that each borough will experience, firstly relative to the London Plan 2021 target and then to the Local Housing Need (Standard Method).

There are some notable outcomes:

Bromley – despite being c.50% Green Belt and the Green Belt Assessment finding numerous parcels with potential to be grey belt, sees its target reduce, and no greenfield housing target set.
Conversely, Hillingdon will see a significant increase in its housing target, with a focus on greenfield housing.
Barnet adopted a Local Plan in 2025, however its annual housing target will now increase by 900 homes, albeit still remaining significantly below the LHN.
Tower Hamlets and Newham, despite being predominately urban authorities, both see their housing target from the current London Plan reduce, by 1,000 homes and 654 homes respectively.
Ealing – as part of the Mayor’s London Growth Plan which identifies it as a borough primed for major growth and investment (OPDC and West Tech London), will experience a significant annual increase in its housing target from the current London Plan (although a small decrease from the LHN.
Wandsworth – this will experience an increase of its London Plan target by c.700 homes (although c.1,600 below the LHN) in an urban borough without Green Belt.

What else to look out for?

There is a lot of detail within the draft London Plan that we will continue to unpack in future blogs. However, the following are the key policy matters to note on housing:

Optimising use of land and site capacity – draft Policy MBUL2 introduces the Optimisation Framework. This sets minimum density and height ranges for residential development, as informed by measures of sustainable access (‘SAM’) and setting. If this sounds familiar, it should – it is reminiscent of the 2016 London Plan Density Matrix, although that was removed for reasons that we’ve covered previously.[11] Our clients will also need to consider these minimums and whether they will prove to be a challenge, in practice. The current ‘design-led’ approach no longer features; however, we would strongly advocate for keeping this principle alive, as a flexible and practical approach to optimising housing sites.
Tall buildings – under draft Policy MBUL3, Boroughs should identify the locations that may be appropriate for buildings of 30m+ (or higher, if locally appropriate) - using criteria in Box MBUL3A. Local Plans must also incorporate the locations for ‘metropolitan tall buildings’, defined by the GLA at Table 2.2. From initial review, this reads as an improvement on London Plan 2021 Policy D9[12] – it should assist to standardise the definition of a ‘tall building’ across Boroughs, ending the confusion where some Boroughs set the threshold as low as 20m; and, it includes flexibility, where robustly justified, allowing for proposals outside of identified tall building locations, or where there is departure from the criteria.
Affordable Housing – overall, the draft plan proposes a more nuanced and targeted approach, with differential thresholds introduced in response to locational considerations, greenfield/brown field, ownership and proposed use. It identifies circumstances whereby the headline affordable housing threshold can be reduced based on tenure commitments, public transport delivery or a portfolio-based approach. In doing so, the draft policy moves away from a more standardised, London-wide approach. Several of the proposed changes will go some way towards facilitating and incentivising housing development. For example, lower affordable housing thresholds in much of outer London and adjusted tenure expectations are welcome, and the ability to lower affordable housing requirements based on tenure commitments will help unlock developments. At the same time though, the framework introduces a wider range of policy considerations than the current Plan, adding another layer of complexity to an already challenging system. See this recent blog from our colleagues, for further analysis[13].
Green Belt – as above, draft Policy PV7 introduces the criteria for Green Belt release in London – but, only in the most sustainable locations, where sites are optimised, and densification is important, and necessary infrastructure improvements are enabled. Broad Locations for Growth in the Green Belt are identified (key diagram – chapter 2). Significantly, the draft Plan goes further than the draft NPPF (2025) in defining 'sustainable locations' in this context – i.e. sites within 1200m (or 15 minute) walking distance of ‘well connected’ stations at Figure 6.4; and, within 400m of high-frequency bus routes (Box PV7C). Reconciling this with the draft NPPF’s definition of "well-connected rail stations" (i.e. footnote 26 won't be straightforward. Indeed, Figure 6.3 shows a complete absence of qualifying stations across Bromley, Sutton, Hounslow, and south Hillingdon, in what feels like a missed opportunity – our initial delve into the evidence base identifies that this is because suitable Grey Belt/Green Belt release clusters of less than 3,000 homes have been excluded from the London Plan capacity. Paired with the additional "Green Belt sustainable design criteria" (Box PV7B), there is a far higher bar for Green Belt release in London. Landscape-led sustainable design is a requirement and Table 6.3 sets challenging average net density ranges of 90 – 160 dph and green space quantities, alongside typical building height expectations from 3 – 6 storeys. The ‘high bar’ approach of defining sustainable locations in the Green Belt also feeds through into the capacity-based housing targets, with several Borough's where potential Grey Belt is identified, not then necessarily compelled by the 10-year targets to release or plan for them.
Metropolitan Open Land – following through on the 'Intend to Publish' document, the new draft Plan explicitly separates MOL from national Green Belt policy[15]. Potential new MOLs are also identified in evidence base. MOL purposes and functions are set out in draft Policy PV6, with a new emphasis on the public accessibility of such land and a suggestion (part E) that boroughs consider applying the MOL designation to Green Belt land which is wholly or largely contained within the urban area. There will be a separate blog to follow on MOL, unpacking what this means in practice for development of such sites.
Housing size mix – anyone navigating varied housing mix policies across the Boroughs will be familiar with current Policy H10,which states that decision makers should have regard to (inter alia) the nature and location of the site, ‘with a higher proportion of smaller units generally more appropriate in those locations closer to a town centre, station or higher public transport access and connectivity.’ Draft Policy HN7 keeps the general premise, but it isn't as explicit, and we would question whether it will be as useful for securing pragmatism against more rigid local mixes.
Housing design – as expected, draft Policy HN8 formalises the GLA’s recently published guidance on dual aspect homes. The more rigid language of current Policy D6 (which states single aspect units should ‘normally be avoided’), is proposed to be replaced with a more pragmatic direction: schemes should ‘seek to minimise’ them. This is a subtle but welcome shift, and one that is already assisting to optimise more constrained housing sites, without compromising design quality. Eagle-eyed planners/designers will also spot a metric tweak: minimum ceiling heights are set to drop from 2.5m (across 75% of the GIA) to 2.4m.
Small sites –there is a continued focus on the important role sites below 0.25ha can play in meeting housing need, which is welcomed. The requirements of the London Small Site Design Code are expected to be met.
Accessible housing – draft Policy HN9 – increases the requirements for M4(3)(2)(b) ‘wheelchair-accessible dwellings’ – 10% and M4(3)(2)(a) ‘wheelchair adaptable dwellings’ 10%. We expect this to have an impact on site optimisation and, ultimately, feed into viability.
Minimum cycle standards – draft policy GHR11 sets the standards as per the aforementioned LPG. This is also welcomed - the standards are less onerous and reflect the reality of underutilised spaces in developments. Arguably this could go further, with a recognition that underused spaces should be designed for future adaptability for something more beneficial.

Our Initial Verdict: The Draft London Plan Report Card

Based on the draft NPPF’s tests of soundness for SDSs, we’ve given our initial verdict on the draft London Plan’s approach to housing matters:

Footnotes

[1] Based on the shortfall of the Plan to the level of need, the next set of London Plan Inspectors will certainly feel like they’ve been here before.

[2] In an attempt to signal a change in direction from the London Plan – the only example SDS that we have available – the government has states that it “does not intend to set a limit or range on the size or length of SDSs, but they are expected to be succinct, and not get into detail or locally specific issues.” https://www.gov.uk/government/consultations/areas-for-producing-spatial-development-strategies/areas-for-producing-spatial-development-strategies#spatial-development-strategies

[3] Which is now delayed to enable our incoming Prime Minister the opportunity to make his first mark on the planning system.

[4] The examination of the 2021 London Plan used the NPPF local plan tests of soundness as a proxy.

[5] https://www.london.gov.uk/sites/default/files/2025-05/Towards%20a%20new%20London%20Plan%20%28final%29.pdf

[6] The draft London Plan plans for 558k homes, against a standard method requirement of 848k homes.

[7] https://lichfields.uk/blog/2026/june/25/sound-prospects-from-abercrombie-to-opportunity-areas-to-the-next-london-plan

[8] Draft NPPF PM1 requires that SDS set out a strategy for a sustainable pattern of growth covering a period of at least 20 years.

[9] Which requires that Plan-making authorities should “positively plan for additional longer-term capacity of at least 850k up to 2047”.

[10] Compared to 18 London Boroughs with some Green Belt.

[11] https://lichfields.uk/blog/2026/january/05/draft-nppf-minimum-density-maximum-impact and https://lichfields.uk/blog/2015/november/9/the-logic-of-the-london-density-matrix

[12] It is also a clearer presentation of the policy position, which has been subject to appeal and High Court appeal precedents which established that a tall building proposal outside a designated area must not be automatically refused.

[13] https://lichfields.uk/blog/2026/july/22/affordable-housing-under-the-draft-london-plan-progress-or-further-complexity

[14] https://lichfields.uk/blog/2025/december/16/all-aboard-or-stuck-between-stations-how-the-new-nppf-might-unlock-growth-around-rail-stations

[15] Despite a recent appeal decision to the contrary, this clearly removes any suggestion that grey belt policies can be applied to MOL.

[16] Croydon Council to oppose draft London Plan over Green Belt proposals – NewStartMag

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