Planning matters

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Decarbonising the NHS Estate: Planning, Funding and Delivery through the Public Sector Decarbonisation Scheme
The Government’s commitment to reach net-zero greenhouse gas emissions by 2050 has become a defining objective across the built environment sector since it was enshrined in legislation in 2019 under the Climate Change Act 2008 (2050 Target Amendment) Order 2019. Net-zero is achieved where total greenhouse gas emissions are balanced by emissions removed from the atmosphere. Within this context, planning and decarbonisation are intrinsically linked; the planning system provides a mechanism to enable upgrades to existing estates, whilst also securing net-zero and low emission new development.
In the UK, and linked to the Climate Change Act, the NHS is working towards becoming the world’s first net-zero health service (for emissions it directly controls) by 2040. This target requires a substantial reduction in energy-related emissions across the NHS estate, reflecting the NHS’ position as one of the UK’s largest public landowners and largest single public energy user. These objectives apply equally to capital investment in existing estates and to the construction of new healthcare facilities.
 

 

Retrofitting the NHS estate

 

With energy use in existing buildings representing one of the most significant contributors to NHS emissions, and heating remaining one of the largest sources of emissions across the NHS estate[1], decarbonisation is both an environmental imperative and an opportunity to enhance the long-term resilience and efficiency of healthcare infrastructure. The Health and Care Act 2022 requires all NHS Trusts and Integrated Care Boards to implement approved ‘Green Plans’ to set out how each Trust will reduce emissions and mitigate the impacts of climate change across their estate and operations.


Lichfields Image: Wharfedale Hospital, Otley, Leeds Teaching Hospitals NHS Trust

As set out in previous Lichfields blogs[2], this often involves transitioning away from fossil-fuel heating systems through interventions such as air-source and ground-source heat pumps, alongside on (or near) site solar generation. For major refurbishment projects and new development, the approach to net-zero approach is guided by the NHS Net Zero Building Standard, which seeks to ensure consistency in the delivery of low-carbon healthcare environments while allowing flexibility to respond to site-specific constraints. This should be a consideration from project inception and can be achieved through:

  1. Increasing on site renewable generation;

  2. Phasing direct fossil fuel usage out of all primary heating and cooling systems;

  3. Optimising self-supply from renewables with energy storage and demand response technologies;

  4. Installing EV charging points;

  5. Considering embodied and whole life carbon.

Early consideration of these measures is critical to successful project delivery.
 
 

The role of planning in decarbonisation

 

Engagement with the planning system is essential to decarbonising the sector and it is a key stage of ensuring the NHS’ and health care providers ambitious net zero targets are met. Planning permission is often required for the installation of heat pumps and solar panels across existing estates making proactive engagement with Local Planning Authorities (LPAs) a fundamental component of sustainable retrofit programmes.
Funding constraints remain a significant challenge in relation to retrofitting. The NHS maintenance backlog is estimated at c. £14 billion, with capital budgets frequently absorbed by urgent maintenance rather than longer-term sustainable upgrades. This restricts the financial flexibility available to invest in deep retrofit measures necessary to meet net-zero targets. Against this backdrop, the Government’s Public Sector Decarbonisation Scheme (PSDS), introduced in September 2022, has become a key funding mechanism supporting emissions reduction across public sector buildings, including the NHS estate.
 

 

Public Sector Decarbonisation Scheme – national funding patters

 

Phase 4 of the PSDS is currently in operation, supporting projects across the 2025/26 and 2027/28 financial years. A total of £816,619,753 has been allocated across the country, with around half of this funding awarded to NHS bodies.
As illustrated in the infographic below, funding distribution varies across regions. London received the largest allocation at approximately £167 million, followed by the North West at £132 million. Yorkshire and the Humber (£112 million) and the East Midlands (£81 million) also secured substantial investment. Importantly, smaller regions such as the North East received awards in the order of £79 million, demonstrating that significant funding opportunities have been available beyond the largest metropolitan areas.

 

 

The regional distribution of PSDS funding reveals clear variation in both scale and uptake. While London and the North West secured the largest allocations - likely reflecting the size and density of their public sector estates - smaller regions have also attracted funding at levels capable of delivering transformative outcomes. For example, the North East, with the smallest population of the regions referenced (2.65 million according to ONS mid‑2024 estimates, published July–November 2025), nonetheless received a substantial share of funding. This equates to £29.80 per person and 9.7% of the total funding awarded.
This relatively high level of funding may indicate that certain Trusts possess stronger awareness of available funding streams, greater expertise in navigating application processes, or a more established commitment to delivering net-zero ambitions across their estates.
Within the North East, approximately £20 million was awarded to Northumbria Healthcare NHS Foundation Trust. The Trust has a strong track record in delivering net-zero initiatives, having previously secured £22 million in Phase 1 of the PSDS. This earlier funding supported a major carbon reduction scheme at North Tyneside Hospital, delivered in collaboration with Lichfields (see case study below). The Trust’s approach is guided by its Green Plan Strategy and supported by a dedicated team of sustainability officers focused on reducing emissions and identifying cost-effective energy solutions.
By developing established partnerships with key stakeholders such as Lichfields, the Trust has been able to streamline project delivery and position itself effectively to secure subsequent funding. This highlights the critical role of cross-disciplinary collaboration - including planning - in successfully accessing and implementing decarbonisation funding. We discuss this further below.
 

 

Delivering decarbonisation in practice: Northumbria Healthcare NHS Foundation Trust

 

Funding through Phase 4 of the PSDS is supporting a wide range of technologies, including air‑source heat pumps at 135 sites and solar PV installations at 38 sites nationally. Within the North East, a significant beneficiary of funding through the latest award, over £20 million – around 25% of the region’s allocation – was awarded to Northumbria Healthcare NHS Foundation Trust to support the decarbonisation of three hospital sites at Wansbeck, Cramlington and Hexham.
Across all three sites, existing heating systems are being replaced with a combination of ground‑source, air‑source and water‑source heat pumps. Lichfields is advising the appointed contractor, Dalkia, on the planning implications of these upgrades, drawing on a detailed understanding of each site’s planning history and local context. Notably, Lichfields previously secured planning permission for the Northumbria Specialist Emergency Care Hospital at Cramlington itself in 2013.


Lichfields Image: Northumbria Specialist Emergency Care Hospital

The project demonstrates how a combination of planning tools can be used to streamline delivery, including minor applications, prior approvals, permitted development rights and lawful development certificates. This approach enables timely implementation while ensuring that potential amenity impacts, such as noise or visual effects associated with new technologies, are appropriately assessed and mitigated. Critical to its success is early and proactive engagement with local planning authorities, in order to provide meaningful information regarding the detail and nature of the proposals at pre-application stage and agree the scope and type of application required. Amid the current pressure upon local government resource, it is fair to say that both local planning authorities and health trusts can unlock efficiencies through pursuing any more streamlined planning process is available, such as prior approvals or lawful development certificates.
This experience builds on Lichfields’ earlier work at North Tyneside Hospital, where a £22 million carbon reduction scheme was delivered in 2021. Working alongside Breathe Energy Ltd, Lichfields supported the introduction of large‑scale heat pumps, boiler upgrades and a solar PV installation with an output of approximately 975 kW. The project is estimated to deliver a 75% reduction in CO₂ emissions, saving around 3,470 tonnes of CO₂ per year and approximately £500,000 annually in energy costs, demonstrating the tangible benefits of well‑planned decarbonisation projects.
At Wansbeck General Hospital, Ashington, Lichfields are currently seeking consent for an innovative decarbonisation scheme utilising ground source heat pumps to tap into warm water from historic coal workings under the Hospital, associated with the nearby former Woodhorn Colliery. Capitalising on resources left over from Northumberland’s coal-based energy past, there is a neat symmetry and inherent sustainability in using the same infrastructure to heat and power a modern healthcare facility. With planning policy at national and local levels fundamentally supportive of both improved healthcare infrastructure, and decarbonisation, we continue to lead local community engagement and work closely with Northumberland County Council as the local planning authority in order to provide comfort that all other technical considerations arising from the scheme, for example in relation to noise, have been robustly addressed through the planning process.
 

 

Looking ahead

 

Alongside the Public Sector Decarbonisation Scheme PSDS, the Low Carbon Skills Fund previously played an important role in supporting feasibility studies and heat carbonisation plans, although it was not renewed for 2025-2026.  The absence of this preparatory funding further reinforces the need to embed decarbonisation considerations at project inception and to take a strategic, plan‑led approach.
Decarbonising the NHS estate is a complex but essential task, requiring alignment between national policy, funding mechanisms, technical solutions and the planning system. While the PSDS has provided a critical funding catalyst, successful delivery increasingly depends on early planning engagement, a clear understanding of consent pathways and the ability to integrate low‑carbon technologies into operational healthcare environments.
Lichfields has extensive experience supporting NHS Trusts and their delivery partners to navigate these challenges, combining technical planning expertise with a deep understanding of healthcare estates. As public sector decarbonisation continues to evolve, proactive planning will remain central to turning ambition into deliverable, low‑carbon outcomes.
 
Footnotes

 

[1] Five years of a greener NHS: progress and forward look report, published 30 September 2025: NHS England » Five years of a greener NHS: progress and forward look

CONTINUE READING

A New Political Era in Wales: What It Means for Planning and Tourism
For the first time in decades, Wales finds itself under a non-Labour-led Government. While the shift in leadership was not entirely unexpected, the introduction of a new proportional representation system meant that the final outcome was far from certain.
Plaid Cymru has emerged as the largest party in the Senedd, albeit without an overall majority. The party has previously held formal and informal roles in governance during Labour’s tenure, but this marks its first time leading the Government. With that comes both opportunity and challenge—particularly for the tourism sector that is integral to Wales’ future.
With only a short time since the Cabinet was announced, we remain within those critical early days where delivery priorities are being set and the direction defined. To date, there have been no new major announcements specifically targeting the tourism sector. As a result, much of this insight must be drawn from Plaid Cymru’s Manifesto[1] commitments. This blog looks at these commitments, how it aligns with the proposed changes to the planning system and what operators, landowners and developers might do as they evolve development proposals.
 

Reading Between the Lines of the Manifesto

 

One of Plaid Cymru’s five key priorities centres on “unleashing the potential of the Welsh economy” and creating well-paid jobs. While there is a clear underlying ambition to build a more sustainable, higher-value economy, the manifesto stops short of explicitly recognising the planning system as a primary driver of economic growth—something that has been more prominent in UK Government proclamations over the last two years.

Solva Harbour, Pembrokeshire

Instead, the emphasis is on supporting Welsh-owned businesses and establishing a National Development Agency for Wales to drive investment, trade and innovation. A focus on the assets and potential of Wales is not groundbreaking; in the long term, if successful, it will be the basis upon which an independence referendum will be held. Plaid Cymru has ruled out such a referendum in this Senedd term but the new First Minister, Rhun Ap Iorweth, is not shy in his position that this would be the ultimate goal.

 

Tourism: Recognised, But Understated

 

Tourism is acknowledged as an important sector within the Manifesto, with a commitment to promoting Wales as a “top quality destination”. It highlights the importance of sustainable tourism that benefits communities, the environment, and Welsh culture and language.
However, this recognition feels somewhat muted when set against the scale of the sector. With an average of one in nine people[2] in Wales employed in tourism and hospitality, its economic significance is arguably underplayed, particularly in areas such as Pembrokeshire and Anglesey where one in five people are employed in the tourism sector.
That said, there are some practical commitments:
  • The 182-day threshold for holiday accommodation will remain under review, with potential new exceptions for certain types of accommodation;

  • Visitor levies will be retained, with a focus on ensuring revenues are reinvested into local services and enhancing the visitor experience[3]; and,

  • A forthcoming review of the Visit Wales model to support tourism and promote careers is also expected.
Delivering on the work from the last Senedd term, new registration requirements for short-term accommodation will come into force from October 2026[4]. Providers offering stays of 31 nights or fewer will need to register with the Welsh Revenue Authority by 31 March 2027. While registration is free, the resulting dataset is expected to provide valuable insights for local authorities, particularly for planning policy and local development plans, and for businesses looking to grow and invest to meet the needs of visitors to Wales.
 

A Stronger Voice from Government

 

The Government has signalled a more assertive stance in its Plenary speech[5]. Speaking in the Senedd, Adam Price, Cabinet Minister for Enterprise, Connectivity and Energy —whose portfolio includes tourism, hospitality, and economic strategy—described tourism as a key economic sector with significant growth potential. He wants to see an increase the proportion of international visitors choosing Wales, alongside a commitment to build a closer, more collaborative relationship with the tourism industry.
None of this provides guarantees for the sector and the financial picture for the Welsh Government to deliver on all its commitments will be difficult. Reinforcing the tourism sector as part of the foundational economy should have greater priority alongside looking for ways to diversify the economy in a way that is vital to the people of Wales and its environment, such as through the delivery of affordable and market housing and renewable infrastructure.

 

Planning Reform: Evolution, Not Revolution

 

Hafan y Môr, Pwllheli

The planning system will be integral to such development and the Manifesto suggests changes will be made. How will these affect the development industry, and particularly tourism?
At a headline level, no radical overhaul is proposed for tourism-specific planning policy so far. However, several planning reforms could have meaningful implications for tourism development that requires engagement with the planning system:

  • Stronger community involvement: A more community-centred approach is intended to give local voices greater influence over planning decisions and priorities.

  • Earlier pre-application consultation: Developers of major schemes are expected to have to engage with stakeholders earlier in the process. It’s not clear if this would result in formal changes to the pre-application consultation (PAC) process or not but it is fair to say that leaving PAC to just before a planning application is far from effective for the community, applicants or local authorities. A review would be welcome.

  • Welsh language considerations: There will be an increased emphasis on embedding the Welsh language within the planning system in rolling out the Commission for Welsh-speaking Committees’ recommendations on town and county planning[6], which includes a review of national policy and Technical Advice Note 13: Tourism.

  • Simplification of process: Efforts will be made to reduce bureaucracy and provide greater certainty around determination timescales. Although, no suggestions of how this will be delivered are published to date.

  • Reform of planning frameworks: Including a new National Development Framework, regional planning and enhanced use of Section 106 agreements to deliver local benefits.

Collectively, these changes point to a planning system that is focused on community aspirations and delivering community value. There is no published detail on how or when any of these changes will take place. None of it will be quick. Until then, the existing legislative and policy context will continue to provide the framework for determining planning applications but maybe communities will feel empowered to engage earlier and perhaps to challenge proposals that they consider are not wanted in their areas.
 

Localisation and Ownership

 

There are strong signals around increasing local ownership within and outside the tourism sector. The prominence given to the Gwynedd and Eryri Sustainable Visitor Economy 2035 strategy reflects a desire to embed sustainable tourism models that prioritise local benefit. The Manifesto commits to introducing a community right to buy local assets when they come up for sale, although there are no details yet to understand how this would work in practice.
This aligns with broader goals of strengthening community resilience and ensuring tourism contributes positively to Welsh identity and place-making.

 

What Should the Sector Do Now?

 

The Parkgate Hotel, Cardiff

For operators, landowners and developers, the evolving policy landscape presents both opportunities and challenges. Key actions for the sector include:
  1. Engage early and often
    Participate in local authority and national consultations and collaborate with industry bodies to shape emerging policy.
     
  2. Influence plan-making
    Ensure the tourism sector is actively represented in local, regional and national strategy development.
     
  3. Strengthen community relationships
    Go beyond statutory consultation requirements—early, meaningful engagement can build support and reduce risk.
     
  4. Demonstrate value
    Planning applications should clearly articulate the economic, social, cultural and environmental benefits of proposals[7].
 

Politics and Pragmatism

 

Without a majority, Plaid Cymru will need to work collaboratively to deliver its agenda. Labour, alongside smaller parties, is likely to play a key role in supporting priorities—particularly where there is already policy alignment. In reality, there is significant common ground between Plaid Cymru and Labour on tourism and planning. Many initiatives—such as the visitor levy and accommodation registration system—are continuations of previous policies.

Llandudno seafront and Great Orme

Reform UK, as the official opposition, will no doubt put under scrutiny proposed changes to the planning system and those that affect the tourist industry. Its own Manifesto[8] appeared to take a stronger position on the value of tourism and hospitality to Wales. In doing so, it wants to see the tourism ‘tax’ scrapped, lowering the threshold to the current 182-days for holiday lets, adjust business rates and cut VAT for certain businesses within the sector. It also wants to change Visit Wales into an independent marketing-led body led by the tourism industry and to create a national tourism strategy to increase visitor numbers and spending as well as ensuring tourism works for residents and strengthens local economies. Whilst there are some clear differences between Plaid Cymru and Reform UK, there is also some degree of alignment at a headline level.
While the change in Government marks a significant political moment, the direction of travel for planning and tourism appears more evolutionary than revolutionary, at least in the short-medium term. The focus on sustainability and community benefit is not new—but it is being sharpened and reframed under Plaid Cymru’s leadership. Looking for cross party consensus across the spectrum will be key for Plaid Cymru if it wants to deliver quickly on its Manifesto commitments.
For those working in the tourism and leisure sectors, success will depend on embracing this shift: engaging with communities, aligning with policy priorities, and demonstrating how development can deliver lasting value for Wales.

 

Footnotes

  

CONTINUE READING

Sound prospects? From Abercrombie to Opportunity Areas to the next London Plan

Sound prospects? From Abercrombie to Opportunity Areas to the next London Plan

Matthew Spry, Isabelle Wall & Ross Raftery 25 Jun 2026
The current fundamental crisis in London’s supply of new homes is widely recognised but its historical resonance is still striking. The drop off in planning and delivery (clearly signposted in the London Plan Review)[1] is now forecast to be the lowest since 1944 (See Figure 1).

Figure 1: Housing Delivery in London 1937 - 2027

Source: GLA data, Centre for Cities and MHCLG published Table 123/217 and Molior January 2026 report.

The causes of near zero housing delivery were different 80+ years ago (not least the role of the Luftwaffe),[2] but London at that point faced a housing crisis – including overcrowding and squalid slums - at least as serious as that faced in 2026. Then, as now, the response was a new plan for London: The Greater London Plan produced by Sir Patrick Abercrombie. It set an agenda that we are living with today.

 

With the draft of the next London Plan (the sixth iteration of its modern incarnation) expected to be published for consultation in July,[3] more signals are emerging on what it will include to address the challenges of 2026, by way of proposals to meet the new local housing need of c.84,000 homes a year.[4]

 

Deputy Mayor Jules Pipe used a series of recent speaking events to trail some of its key policy measures.[5] He largely confirmed what he said in 2025, that a plan to meet the Standard Method target in London is an “intellectual exercise” without a change to the funding approach to infrastructure and affordable housing, given the structural shift in development viability.[6] Although the plan would “absolutely not increase the overall burden of planning policy requirements on development” it would set “high standards” and would also seek higher densities on Green Belt release (at five to six storeys) and around rail stations, something that will surely pose viability and design difficulties on some sites.[7]

 

The “intellectual exercise” positioning – that the London Plan will show how housing targets can be met within London’s boundaries, but only in theory[8] – sets a challenge for the Government, not least given its proposed tests of soundness for Spatial Development Strategies (SDS) in the draft NPPF, scheduled (prior to recent national political ructions) for publication this summer.[9]

 

It also marks a vivid contrast with the policy approach adopted back in 1944.
 

Abercrombie’s Greater London Plan

 

Abercrombie’s Greater London Plan had as its object “to provide the foundations for Greater London upon which homes, work and fresh food can be supplied not only quickly but permanently in full measure.”[10]

 

He delivered a bold and pioneering piece of strategic planning that defined London for its post-war growth and set development patterns and constraints that remain.  His answer combined two core policy instruments, (in)famous in today’s world: the protection of a Green Belt and the creation of New Towns beyond London,[11] linked through a broader vision of decentralisation and growth corridors, set within four rings (see Figure 2). An eagle-eyed observer will note that the Green Belt now is far wider than originally conceived by Abercrombie.[12]

Figure 2: The Greater London Plan’s Four Rings

Source: Greater London Plan 1944

In due course, the opportunity half of the Abercombie concept – New Towns – fell away,[13] but the constraining other half – Green Belt – remained.
 

The Compact City and Opportunity Areas

 

The adopted Spatial Development Strategy for London – the London Plan - was published in 2004, with an express ‘compact city’ model.[14]

 

But this concept for London was not new, carrying forward several planning principles that had been introduced by the post-1986 settlement following abolition of the Greater London Council and which saw formation of LPAC.[15] In its 1988 Strategic Planning Advice for London (which informed RPG3)[16], LPAC said it:

 

“supports the regional objectives of containing development within London and regenerating the older parts of Inner and East London. It accepts that both are a prerequisite to ensure that new development does not conflict with the ... aim to conserve the countryside. [...] Development within London avoids the need to develop greenfield sites outside London and that over-provision for development in ROSE could be wasteful and unnecessary. [...] Housing development must not be at the expense of the Metropolitan Green Belt, Metropolitan Open Land, or other urban open spaces; and housing demand alone should not be sufficient justification in itself for the release of Green Belt or Metropolitan Open Land."[17]

 

So, the current strategy has now run for around four decades, and Figure 1 shows it has not delivered the scale of housing delivery that the Capital now needs. It is based on intensifying the urban area, building at higher densities, initially in Docklands under the LDDC and then in designated Opportunity Areas (Figure 3).

Figure 3: London’s Opportunity Areas

Source: GLA Opportunities Areas Map

These zones have been central to successive London Plans, where they were introduced to “intensify and accommodate substantial growth, especially in economic activity.”[18] In the 2021 London Plan, 275,000 of the 523,000 homes planned for 2019 to 2029 were in these areas. Some of the most recognisable feats of housing delivery in London stem from this Opportunity Area thinking; Nine Elms, Greenwich Peninsula, King’s Cross and Olympic Park are examples of what coordinated land assembly/ownership and robust delivery mechanisms can achieve.

 

However, each of the 48 Opportunity Areas have developed – or remained undeveloped – at differing paces. In preparing for the next London Plan, the GLA categorised its Opportunity Areas.[19] and with our interpretation of each, we have identified the remaining housing capacity. Out of the total capacity of c.246,000 homes, our analysis suggests around two thirds (c.169,000) are delayed in their progress, stalled through infrastructure blockers, or perennially nascent (See our interactive graphic as Figure 4 for the categorisation of each - click on each category to identify the relevant capacity and OAs).

Figure 4: Opportunity Area Categorisation

Source: GLA / Lichfields analysis

 

Why do Opportunity Areas fail?

 

By their nature, Opportunity Areas face many challenges, often in combination, which are causing them to stall, broadly across three key themes: a) infrastructure; b) frameworks and coordination; and c) deliverability (See our interactive chart as Figure 5 - click the icons for more information).

Figure 5: Opportunity Areas: Why they fail

Source: GLA / Lichfields analysis

Of these, the most significant barrier is dependence on major infrastructure. In 16 of the 48 areas, housing capacity is tied to transport schemes that remain unfunded, delayed or politically uncertain. New Southgate exemplifies this issue, where its reliance on Crossrail 2 has held back any real growth and it is expected that this will lead to the area’s de-designation.

 

Alongside these ‘big ticket’ infrastructure dependencies, lack of local connectivity has also been a barrier. Even where strategic transport exists, many opportunity areas (around 20 out of 48) are weakened by physical severance, poor pedestrian access and lacking effective cycle links – all of which rely on sufficient development viability to secure investment.

 

In essence, the more deliverable Opportunity Areas have been secured – often with concerted investment efforts.[20]  This leaves the more challenging locations representing a substantial proportion of remaining capacity: areas that are already underway but progressing more slowly (c.84,000 homes) or classified as ‘ready to grow’ but with major barriers unresolved (a further c.52,000 homes). A further c.77,000 homes are not out of the starting blocks or look set to be dropped.

 

Without moves towards more targeted investment, infrastructure delivery and stronger coordination, this potential remains under-realised.
 

The new London Plan: what’s next?

 

The draft NPPF set an expectation that Spatial Development Strategies look ahead a minimum of 20 years.[21] Assuming the Mayor follows this stipulation (which surely makes more sense for a strategic plan than the ten year targets that are automatically set up to fail)[22], then the London Plan needs a positive vision for securing up to 1.69 million homes. Draft NPPF policy PM14 says that for an SDS to be “sound” it should be, inter alia, “effective” where “there is a reasonable prospect that local plans will be capable of identifying site allocations to implement its spatial strategy.” For Local Plans to be sound, Draft Policy PM15 requires them to be “realistic” where “there is a reasonable prospect that its site allocations are capable of being deliverable at the time envisioned.”[23] 

 

An analysis of potential sources of supply points to the major challenge involved in this endeavour (See our interactive chart for Figure 6 - hover over each component for the rationale analysis).

Figure 6: Sources of Supply for 1.69m homes


Source: GLA / Lichfields analysis

 

Even with optimistic assumptions about addressing the current viability challenge; small site capacity (including an uplift based on rolling out the Croydon experiment);[24] strengthened pro-development policies including grey belt and development around ‘well connected’ railway stations; and the residual capacity of all extant opportunity areas and large brownfield sites, there remains a substantial housing gap (perhaps as much as 875k homes) over the next two decades.

 

The social and economic implications of this gap are stark. London Boroughs are facing unprecedented costs – estimated at £5.5m a day – in providing temporary accommodation for homeless households.[25]  The lack of secure housing clearly undermines prospects for young people.

 

The Deputy Mayor’s remarks suggest a SDS for meeting need that is more an “intellectual exercise” than one it considers likely or realistic. This seems intended to set the Mayor of London up for some interesting discussions with HM Treasury and asking likely Prime Minister Burnham (the "King of the North") for more transport investment in a Capital he has not always talked about positively.[26] 

 

If London is to genuinely meet the challenges with a realistic long-term strategy – one with an Abercrombie-esque scale of ambition and boldness – on top of the benefits arising from a more rules-based system and encouraging development of smaller sites, it seems likely to require at least four strategic moves:

 

  1. First, unlocking the existing pipeline. The most immediate gains are likely to come from those homes already in the pipeline in existing Opportunity Area designations and other large sites. Yet, this requires investment and proactivity that the GLA already understands: viability gaps, infrastructure timing, land assembly and delivery coordination to name a few. A credible strategy starts with these identified zones shifting existing capacity into on-the-ground delivery. Easier said than done.

  2. Second, within the GLA boundary and taking account of the 20-year horizon for SDS, creating the next generation of Opportunity Areas, without necessarily any expectation that much is delivered in the short term.  A mix of bold ambition but also realism to focus on creating the right conditions early, including delivery structures, the framework for land assembly and infrastructure planning. The tests of soundness for SDS recognise this.[27] 

  3. Third, the Green Belt needs to be loosened strategically, as the Mayor has signalled he will do.[28] However, the challenge here relates to the Mayor’s expected demand for high densities which pose challenges for viability, the demand for family homes, and the design and landscape considerations often applicable on such sites.[29]  Further, because the SDS cannot allocate Green Belt sites itself, it relies on Local Plans that will not be adopted for some years and this puts their delivery trajectory into the second or third phases of any strategy.

All of the above is needed, but even with an optimistic outlook, this might realistically get London to a position where it is achieving development of around 40-50,000 homes a year. This takes one to the inescapable conclusion that a fourth strategic move is needed, and it is as old as the hills:

  1. Looking beyond the boundary. This was a foundation of Abercrombie’s strategy. It was part of the 1967 Strategic Plan for the South East.[30] Both recognised that London’s problems cannot be solved within London alone. The current London Plan recognises it even if not responding directly: Policy SD2 is designed to frame engagement with the wider South East for future reviews of the Plan and Policy SD3 focuses on potential growth locations outside London.[31] The Inspectors examining the last London Plan said:

    “If London cannot accommodate all of its development needs, the most significant strategic issue facing the wider South East for the coming decades will be how and where to accommodate that growth outside London in a way that will contribute towards achieving sustainable development. Many representors, with a wide variety of interests, have argued that this could and should be achieved. However, it is clear from past experience and evidence about increasing development pressures that areas in the wider South East outside London already face, that there are no easy solutions or clearly identified potential growth locations.”[32]

    All of this was based on an assumption – with evidence - that London would not meet its needs within its boundary, and that there was a requirement to work with the wider South East, even if it was acknowledged at the time that there were no clear mechanisms (or appetite) to do so. A similar argument existed in 1944, in 1967 and it exists now.

    The draft NPPF would require the next London Plan to be positive in seeking to meet needs, but also be appropriate and effective. If it becomes apparent that needs cannot be met, the Mayor will need to show that “stringent efforts have been taken to meet those needs through cooperation with other strategic planning authorities”. Footnote 20 expressly references the Mayor of London as being subject to this test.

    The new London Plan seems likely to adopt a different, entirely inward-facing approach to meeting its needs, just at the moment when – over the M25 - the new architecture for strategic planning is emerging, blinking into the light. There is also a more overt central Government intervention by way of New Towns (albeit not on the scale of post-war programme).[33] Arguably, there is more of a platform – or at least a smaller, more manageable number of interlocutors – for the Mayor to engage on strategic matters than has been the case since 2010.
 

Conclusions

 

London was famously described by William Cobbett as the ‘Great Wen’ – a monstrous entity that drains the life, wealth and population from the rest of Britain. And yet the Capital undisputedly faces an acute housing crisis; authoritative studies on Britain’s poor economic productivity show that addressing the lack of homes – in and around London - is part of any policy to help support an improvement in economic growth, as part of - not instead of - an approach that addresses regional inequality.[34]

 

The Mayor's prospective London Plan – in advancing an ‘intellectual exercise’ capacity-based approach to meet need (at least on paper) within its boundaries that expressly relies on high densities and an ask for public money to address a broken funding model – seems set for a collision course with either HM Treasury or the new NPPF tests of soundness for SDS. Perhaps both.

 

One must assess a plan based on what it says and the evidence on which it is based – and nobody outside the GLA has seen that yet – but realistically the supply it might unlock is unlikely to exceed 40,000 – 50,000 homes per annum. It is difficult to conceive that any Inspectors examining the Plan will do anything other than conclude – as they did in 2019 and in 2014[35] – that London on its own will fail to meet its objectively assessed housing need and that it is necessary – as was the case (albeit in different circumstances) in 1944 and 1967 – to look beyond into the wider South East for solutions. Those solutions must work in parallel with whatever is a realistic outcome from the vision put forward by the Mayor.

Footnotes

 

[1] London Plan Review: Report of Independent Advisers. Lichfields was engaged by-then DLUHC to support the review.

[2] Including the site of Lichfields’ London office which was nearly completely destroyed as shown here.  

[3] As reported here (£). 

[4] Based on the Standard Method for Local Housing Need

[5] This included the Landmark Chambers London Planning Conference – at which one of the authors of this blog also presented some of the analysis that forms the basis of this blog. 

[6] Remarks made to the London Assembly planning and regeneration committee in June 2025, as reported here

[7] Media write-ups of the event include in Planning and OnLondon

[8] Akin to basing a housing target on the largely abstract estimates of urban capacity that were generated by the studies of the late 1990s prepared under the guidance of Tapping the Potential (see here) (see this blog on PPG3 for the history lesson)

[9] Housing Secretary Steve Reed indicated publication “very very shortly” in his remarks to UKREiiF in May 2026 – reported here – but this obviously pre-dates the small matter of a change in Prime Minister, a possible change to Secretary of State, and the Cabinet Secretary’s missive to Departments not to announce any major new policy until a new Prime Minister is in place (£).

[10] Greater London Plan, 1944 Preamble

[11] Green Belt was progressively designated by local authorities. Following the New Towns Act 1946, between 1946 and 1970, 22 New Towns were designated, many of which delivered upwards of 25,000 homes each.

[12] Abercrombie’s Green Belt finished before towns like Guildford, Royal Tunbridge Wells, Chelmsford and St Albans; all of which are now surrounded in whole or in part by the Metropolitan Green Belt.

[13] The New Towns programme ended in the late 1970s, although developments in designated New Towns continued.

[14] This 2017 piece by Duncan Bowie reviews the genesis of the ‘compact city’ approach advocated by Lord Rogers as adviser to Mayor of London Ken Livingstone and expressly sought to meet London’s housing needs within its boundary.  It finds that the concept increased social polarisation and displaced lower income households.

[15] LPAC was the Joint Planning Committee for Greater London. The Local Government Act 1985 required the London Boroughs to establish the committee; it provided advice to the Secretary of State who was responsible for preparing Regional Planning Guidance (RPG3)  An account of the story of LPAC – prepared by Richard Derecki - can be found here

[16] The 1989 iteration of RPG3

[17] Paras 2.5 and 3.12 Strategic Planning Advice for London: Policies for the 1990s October 1988

[18] London Plan 2004 §2.3

[19] The GLA’s evaluation of London’s Opportunity Areas through Pen Portraits:  

[20] Not least, the works for the 2012 Olympics, the Channel Tunnel Rail Link, or the TIF model for Northern Line extension.

[21] Draft Policy PM1 of the December 2025 Consultation Draft NPPF

[22] Relying on implementation by Local Plans that are often not adopted until mid-end of the ten year period and which the NPPF requires to look ahead a minimum of 15-years from adoption, perversely providing more of a strategic outlook than the strategic plan that sits above them.

[23] Draft Policy PM15 of the draft NPPF

[24] The Croydon Suburban Design Guide (SDG) was introduced in 2019 through to 2022. See for example this Centre for Cities analysis 

[25] As referenced in this London Councils analysis

[27] Policy PM14 states: “Where spatial strategies anticipate a change in market conditions which the strategy itself is intended to foster, a proportionate approach should be taken in assessing assumptions in the longer term given the uncertainty which is likely to surround them.” On reliance on future infrastructure, it says: “there may be limited certainty about the delivery of infrastructure towards the end of the plan period. Where this is the case, it will be sufficient to assess whether reasonable assumptions have been made based on a adequate engagement with the relevant infrastructure providers.”

[28] The mayor signalled his change in policy in a 2025 speech.  Even in 2019 the Inspectors examining the current London Plan said “the inescapable conclusion is that if London’s development needs are to be met in future then a review of the Green Belt should be undertaken to at least establish any potential for sustainable development.”

[29] Developments on Green Belt land are typically a max of three storeys to minimise landscape impacts, respond to the typical character and setting, address local objections, and provide family housing which is often the market demand in these locations. Mid-rise height introduces viability challenges – potentially requiring more stringent fire safety requirements, but without the critical mass of a high-rise building, and involving provision of more apartments when the prevailing demand might be for two or three storey houses.

[30] The 1967 Plan proposed growth centres, following a testing of two alternative options: the corridor strategy of the South East Economic Planning Council based on the ‘countermagnet’ strategy of the 1964 South East Study; 2) more emphasis on population and employment growth close to London, aligned to ideas from the Standing Conference on London and South East Regional Planning. A summary is in this article from 1971 by D. E. Keeble of University of Cambridge in Vol 3. No. 2 of Area – the Journal of the Royal Geographical Society.

[31] See the London Plan 2019 Examination Report Para 108

[32] Ibid para 111

[33] See New Towns Draft Programme 23rd March 2026. The New Towns Taskforce report expressly addressed the role of new settlements within and outside London as a means for addressing the housing crisis in London – note Lichfields assisted the Taskforce with its strategic case.

[34] For example, Stansbury, Turner & Balls, Tackling the UK’s regional economic inequality: Binding constraints and avenues for policy intervention, 2023. It states: “Investing in housing in London and the South East would contribute to easing regional divides by easing the barriers to labour mobility. Interregional mobility in the UK goes in the wrong direction: people on net move away from high-productivity London to other regions, as high housing costs in London, and to a lesser extent the South East, erode the London wage premium for most of the income distribution, making the net return to migration to London small or negative (and therefore limiting the opportunity to benefit from London’s productivity to either the highly educated, or to those who happened to own property there already). This suggests a clear role for policy in alleviating London’s housing crisis.”

[35] Mr Thicket’s 2014 report on the Further Alterations to the London Plan concluded that: “The evidence before me strongly suggests that the existing London Plan strategy will not deliver sufficient homes to meet objectively assessed need. [...] The Mayor has committed to a review of the London Plan in 2016 but I do not consider that London can afford to wait until then and recommend that a review commences as soon as the FALP is adopted in 2015. In my view, the Mayor needs to explore options beyond the existing philosophy of the London Plan. That may, in the absence of a wider regional strategy to assess the options for growth and to plan and co-ordinate that growth, include engaging local planning authorities beyond the GLA’s boundaries in discussions regarding the evolution of our capital city.”

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Amazon Now: The Planning Implications of Ultra-Fast Grocery Shopping
At the start of the year, Amazon announced the launch of its latest UK grocery proposition, Amazon Now—an ultra-fast delivery service providing groceries and everyday essentials to customers, from warehouse to door, within 30 minutes. Initially piloted in south London, the service has already expanded to Canary Wharf, Bethnal Green, Shoreditch, Hoxton and Holborn with ambition for UK coverage in due course. Most cities are able to provide a 60-minute grocery delivery from Amazon via their partnership with Gopuff, the US delivery company, but no 30 minutes yet.
Amazon’s renewed push into grocery, through delivery, follows the closure of all its Amazon Fresh convenience stores in 2024. That decision, it is understood, reflected the challenges of competing in a mature convenience retail market.

Image credit: Unsplash

While attention has focused on competition with the already established fast delivery operators such as Just Eat, Deliveroo and Uber Eats, it also raises the question of how this model of convenience retailing will drive demand for space—and the further impact this may have both on the traditional grocery market and on high streets.
Ultra-fast delivery co-dependant on proximity – to both storage and customers. To achieve a 30-minute fulfilment windows, operators require a dense network of small-scale, urban fulfilment pick hubs. Typically ranging between 5,000–10,000 sq ft, these units act as mini distribution centres. Goods are then delivered by employees, in Amazon Now’s case, by e-bike in ranges of up to 6km[1]. However, and notably, Amazon have previously trialled autonomous vehicles and, most recently, drones[2] in its wider Amazon Prime network which could provide the basis of further future delivery options for Amazon Now.
This represents a notable departure from traditional retail requirements, focusing on what Amazon knows best, logistics; but introducing a different set of locational and design considerations. Sites and premises must sit within dense residential catchments, offer efficient last-mile access, and accommodate extended (often 24hr) business hours, operating often under a Class B8 Use, rather than retail.
 

Implications for the High Street

 

The expansion of ultra-fast grocery delivery is likely to have implications for the future of high streets. However, any ‘impact’ is more complex and nuanced than simply the bifurcation of convenience retail.
 
  • Convenience grocery has traditionally acted as an anchor for local centres, generating frequent footfall. A shift toward ultra-fast convenient home-delivered retail risks reducing in-store visits, with knock-on effects for the high street. However, much of this impact potentially has already occurred, with consumers responding positively and decisively to the food retailers omnichannel strategies – that is shopping online and in-store - with suggestions that we spend more as a result[3].

  • Whilst some high streets will be further impacted, there is potential for repurposing of retail and other town centre units to accommodate micro-fulfilment uses. This may help vacancy rates but may also alter the character and function of the wider high street as a whole.

  • Conversely, the integration of last-mile logistics into town centres could reinforce their role as multi-functional hubs—combining retail, leisure, residential, and distribution. This aligns with broader planning objectives around increased densification and sustainable urban living, provided impacts are effectively managed.

  • The growth of distribution uses in close proximity to residential areas raises considerations around noise, traffic, and servicing. The planning system has not fully caught up with this hybridisation of retail and logistics. Local planning authorities will need to carefully balance economic benefits with community impacts, particularly in areas not traditionally associated with logistics uses.

 

Looking Ahead

 

Image credit: Unsplash

Amazon’s approach to rapid grocery delivery so far appears cautious, perhaps unsurprisingly given recent experience with Fresh. However, a need for density and efficiency to meet consumer demand, coupled with a highly competitive market has seen it capitalise on its existing logistics expertise while managing risk.
Five years ago, the idea of groceries arriving in under half an hour felt futuristic. Now it’s becoming the new normal (certainly in cities) and is now part of how we shop not only for comparison, but convenience goods.
There are lots of examples of these last-mile operators[4] in smaller, multi-let industrial units already and this has extended to include railway arches, retail units, and other non-traditional spaces, that may previously have struggled to attract tenants. However, with Amazon in this market, competition will increase for easily accessible space which is likely to spill over into the high street.
From a planning perspective, this growth of rapid delivery raises important questions around land use, amenity, and the intensification of logistics activity in urban areas both for main shopping areas and for residents who live there.
Ultra-fast delivery through logistics is increasingly shaping our cities and towns. When convenience is king, the line between shop and warehouse is rapidly blurring. The key question is how it can be integrated in a way that complements, rather than competes with, this fast-evolving sector.

 

Footnotes

 

[1] Amazon Now | Local E-bike Deliveries | Amazon Flex

[2] 'We had people come just to see it': Amazon delivers its first UK parcels by drone - BBC News

[3] What Is Omnichannel Retailing and How To Implement It? | Retail Bulletin

[4] https://www.thegrocer.co.uk/promotional-features/dark-store-trends-and-the-consumer-demand-for-groceries-in-minutes/665822.article

 

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