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Reflections on FOOTPRINT+ 2025

Reflections on FOOTPRINT+ 2025

Sophie Bisby 22 May 2025
Last week I was lucky to attend the annual FOOTPRINT+ conference which took place just a stone's throw away from our London office. FOOTPRINT+ is a leading net zero and decarbonisation conference that brings together industry professionals across the property sector including developers, architects, designers and engineers.
Although the transition to net-zero remained the central focus of the conference, since FOOTPRINT+ 2024 the industry is operating in a different political and economic context. A new Labour government, a revised NPPF, and the launch of consultation on the new London Plan meant much of this year’s discussion focussed on how national and strategic policy is keeping pace with the race to net-zero by 2050 and how this plays out on the ground.
Several key themes emerged throughout the day; reflecting both progress on the drive towards net-zero and the pressing challenges that remain. This blog seeks to summarise the key messages from the industry and what this means for planning.

 

Net-Zero Policy: the industry in the driving seat?
One of my strongest takeaways from FOOTPRINT+ was the recognition that the industry views itself as being increasingly in the driver’s seat when it comes to setting ambitious net-zero targets which is in turn shaping and driving policy at the local level. One speaker from the City of London sustainability team noted that emerging exemplary retrofit schemes coming forward in the Square Mile, were helping to shape guidance on retrofit and circularity through innovative design solutions and embodied carbon saving.
As we have already observed, local authorities across London are beginning to introduce supportive and ambitious policies to encourage the re-use of existing buildings and materials to reduce emissions. Attendees at FOOTPRINT+ set out a view that there may be a need for firmer policy within the NPPF and new London Plan.
The revised 2024 NPPF includes stronger references to climate change adaptation and mitigation, as well as increased emphasis on design quality, brownfield development, and biodiversity net gain. But when it comes to net zero, many attendees felt it falls short of setting the kind of clear strategic direction that’s urgently sought.
The Towards a new London Plan consultation document published earlier this month reaffirms the Mayor’s commitment to delivering net zero in London by 2030 and a ambition for the next London Plan to go beyond national standards to speed up the transition; with a particular focus on streamlining implementation and avoiding unnecessary delay or cost.
Notwithstanding the momentum displayed by local policy and the industry there is also a growing tension arising from an increasingly fragmented approach to climate policy. FOOTPRINT+ underscored the urgent need for better alignment between national, regional, and local policy to knit together the current patchwork of local guidance and expectations.

 

Materials Reuse: the new norm
Circularity, particularly material reuse, was a major talking point. With a shift in focus from the impacts of operational carbon to embodied carbon there’s growing interest in how planning policy can encourage retention and reuse of existing structures and materials to improve circularity and ultimately reduce embodied carbon.
While London Plan policy, and many LPAs, now require submission of a Circular Economy Statement at the planning stage, FOOTPRINT+ highlighted several innovative tools and platforms facilitating this process—such as material donor and recipient exchanges, and AI-driven building audits.
Several local authorities are now developing validation checklists that require applicants to show how material reuse has been considered—a trend we expect to see spread beyond London. The NPPF is still relatively silent on the issue, but the industry clearly sees material reuse as central to net zero delivery.
The key message here was that material reuse needs to be considered in the early stages of the design process to have a clear understanding of a building’s makeup; and also allow collaboration with neighbouring design teams to avoid circular economy practices happening in silos. There is also a role for the GLA and Local Authorities to develop a framework to facilitate material exchanges across the capital.

 

The Future of Heat Networks
Decarbonising heat was a hot topic at this year’s conference. While these systems offer significant potential, particularly in densely developed areas like London, there are still planning-related uncertainties around how they will be delivered and funded, safeguarding for future connection, and how they could be retrofitted into existing settlements.
Some attendees noted that policy updates to reflect the role of decentralised energy and local grid coordination may be needed.

 

The City of London: A Retrofit Powerhouse
The City of London, a front-runner in decarbonisation and retrofit first policy, featured prominently in discussions. Its extensive stock of post-war concrete office buildings presents a prime opportunity for retrofit. As commercial lease lengths shrink and occupier needs shift toward flexibility and ESG credentials, the City’s approach to adaptive reuse and refurbishment was seen as becoming more relevant. The City has embraced this challenge, encouraging developers to prioritise retrofit over rebuild, while balancing this with heritage and other sustainability and technical objectives.

 

Key messages for Planning
Throughout the day it was interesting to hear about the novel approaches and technologies which the industry is adopting to help the development industry in its drive towards net zero. However, there was recurring message that net-zero policy continues to lack definition and a joined up approach at a national, strategic and local level which may be frustrating some of these efforts.
From our project work across London and research into the policy context we have seen some emerging examples of clear policies emerging, for example through the London Plan, and that we look forward to reviewing how the new Labour Government may influence the direction of travel over the coming years.

 

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The Changing Nature of BESS Developments in Scotland: Workable Conditions
As the UK moves away from large coal and gas power-stations that had built in measures to regulate the flow of energy on to the national grid, in favour of low and zero-carbon sources that can have peaks and troughs of output, Battery Energy Storage Systems (‘BESS’) are important to ensure that the maximum amount of energy generated is utilised. The decarbonisation of the energy sector is an important part of our just transition away from carbon rich energy sources and provides environmental and economic benefits, such as clean and reliable energy at low cost to customers.
Anyone involved in the renewable energy industry will know firsthand the nature of the rapidly evolving technology and the challenges this presents for applicants and decision makers. The time elapsed from the submission of a planning application, to planning permission being granted and to construction of the development commencing can mean that the technology has moved on such that schemes need to be varied before implementation. Often the BESS ‘kit’ that has planning permission is no longer available on the market or new and improved ‘kit’ is now available.  To that end, it would be beneficial to find a consistent way of managing this that enables the control of consented development schemes without requiring new applications to deal with relatively minor but potentially still material changes to layout or the dimensions of the BESS ‘kit’.
The Scottish Government has highlighted the role of planning conditions for energy schemes by publishing their standard ‘consent conditions’ for consideration in terms of onshore wind Section 36 consents (electricity generating stations over 50MW). Within this, there is a standard condition (set out in full later in this blog) in respect of energy storage facilities associated with a wind farm and a condition for micro-siting that could be applied/adapted for BESS schemes. Lichfields believes such an approach would be suitable for planning applications relating to BESS schemes of less than 50MW granted by Planning Authorities as well as larger Section 36 consents from the Scottish Government.
From our experience working on renewable energy projects, non-material variation (‘NMV’) applications are often utilised to secure amendments to permissions when there are no appropriate conditions against which to introduce changes. However, what is considered to be a ‘non-material’ amendment will vary from council to council. Please note that there are no minor material amendment applications in Scotland. To this end, conditions that provide a degree of flexibility but also provide the local authority with control would be beneficial.
At a time when local authority planner capacity is stretched, we believe that well-crafted planning conditions can provide appropriate control and comfort to the local authority whilst still allowing the developer to account for the changing nature of BESS “kit” without the need for new applications. With this in mind, we set out the following conditions, the use of any one of them could build in necessary flexibility:

 

1. A condition that lists out the approved drawings

While there has been a move away from conditions which list out approved drawings as planning permissions now include schedules, a condition which lists out the approved drawings provides inbuilt flexibility as Section 42 of the Town and Country Planning (Scotland) Act 1997 (comparable to a Section 73 application in England) allows for applications for non-compliance with conditions attached to a planning permission to be made. In practice, this means that an application could be made to swap approved drawings for new drawings for an already consented development. Most importantly, a Section 42 application can consider ‘material’ changes.
 

2. A condition that requires final details of external equipment to be agreed post permission

Below is the proposed standard condition (10) from the Scottish Government for onshore wind farms, which we believe could be utilised widely for BESS developments.  Not all standalone BESS schemes will be EIA developments, and this condition should be amended accordingly by removing the text which is bold where EIA does not apply.  There will also be an amendment to the “Reason” in such circumstances, but this could be achieved by replacing ‘the EIA Report’ with ‘the application’ as shown below.
 
Even where details have been submitted as part of a detailed application, these are often subject to change before implementation.  This condition or a version of it would allow changes to the BESS ‘kit’ to be assessed and approved by planning authorities after detailed permission was granted, reflecting the nature of these developments.
 
     
 
Design of Energy Storage Facility
(1) There shall be no Commencement of Development on the energy storage facility until details of the location, layout, external finishes and appearance, dimensions and surface materials of the energy storage facility, inclusive of battery containers, substation(s), control buildings, external above ground electrical equipment, associated compounds, construction compound, boundary fencing and other enclosures, external lighting, security cameras and parking areas have been submitted to, and approved in writing by, the Planning Authority.  For the avoidance of doubt the details of the energy storage facility shall not exceed the parameters assessed in the EIA Report
(2) Thereafter, the battery energy storage facility shall be constructed in accordance with the details approved under part (1) and the infrastructure shall be maintained in the approved colour, free from rust, staining or discolouration until such time as the Development is decommissioned.
Reason: To ensure that the environmental impacts of the energy storage facility conform to the impacts assessed in the application and in the interests of the visual amenity of the area.
 
     
We have in fact encountered a version of this condition attached to a BESS planning permission and found it to work very well. Discharge of condition applications are material considerations, and the example condition secures control for the local authority while ensuring there is flexibility for the developer should some external kit need to be altered.
 

3. A condition which takes into consideration potential siting variations

Below is the proposed standard condition from the Scottish Government for onshore wind farms regarding micro-siting, which we believe could be amended for BESS developments. We have deleted the text that would not apply to BESS developments to leave an acceptable potential condition.
     
 
Micro-siting
(1) All battery containers, transformers, buildings, masts, areas of hardstanding, associated infrastructure and tracks shall be constructed in the locations shown on plan reference [xxx]. The locations of battery containers, transformers, buildings, masts, associated infrastructure, areas of hardstanding and tracks may be adjusted by micro-siting within the redline boundary shown on plan reference [xxx]. Any such micro-siting is subject to the following restrictions unless otherwise approved in advance in writing by the Planning Authority
(a) No battery containers, transformers, buildings, masts, hardstanding or associated infrastructure shall be moved more than XXm from the position shown on plan reference [xxx];
(b) No access track shall be moved more than XXm from the position shown on plan reference [xxx];
(c) No micro-siting shall take place with the result that infrastructure (excluding floating tracks or hardstanding) has a greater overall impact on peat than the original location;
(d) No micro-siting shall take place which will bring the infrastructure closer to [xxx] as shown on plan [xxx].
(2) All micro-siting permissible under this condition shall be submitted to, and approved in writing by, the Ecological Clerk of Works (“ECoW”) in advance of any works or development associated with the micro-siting request being implemented. (this clause only applies where and ECoW is required by another condition)
(3) No later than six months after the date of commencement, an updated site layout plan showing the final position of all battery containers, transformers, buildings, masts, areas of hardstanding, tracks and associated infrastructure forming part of the Development shall be submitted to the Planning Authority. The plan shall also specify areas where micro-siting has taken place and, for each instance, be accompanied by copies of the ECoW or Planning Authority’s approval, as applicable.
Reason: to control environmental impacts while taking account of changes to technology.
 
     
Following on from this and set out below is an adapted condition that we have seen utilised on other renewable energy projects that would do a similar job.
‘BESS containers, buildings, compounds, areas of hardstanding, the internal road network and access shall be constructed in accordance with the Approved Layout. A variation of the indicated position of any BESS Containers or other development infrastructure detailed in the Approved Layout shall be submitted to and approved in writing with the planning authority. The position will only be acceptable where it is compatible with the other conditions attached to the permission’.
These potential conditions reflect the fact that BESS developments are practical developments, often in close proximity to existing substantial pieces of infrastructure (electricity substations, pylons, etc). As such, once the principle of development has been established and assuming all other matters (e.g., visual, noise, drainage, etc.) are acceptable, variations should be acceptable within set parameters.

 

Conclusions
Flexible conditions are a more consistent and transparent way to manage potential variations to consented BESS schemes compared to NMV applications. They can also accommodate material changes. This is important as we consider it is unreasonable to expect completely new applications for minor/moderate changes just because there are no suitable conditions to do this, when the principle of development has been established. In a worst-case scenario, this could lead to a perpetual cycle of application, permission, and non-implementation due to changes to the ‘kit’.
We would encourage all applicants for planning permission to engage the local authority regarding suitable conditions. We would also encourage case officers to familiarise themselves with the day-to-day realities of BESS projects in the way this has been done for Wind Energy projects and build in flexibility to conditions even where it has not been explicitly requested. Conditions must reflect that the BESS units applied for can quickly become outdated technology and/or may not be procurable and implementable when construction is scheduled. Inevitably, there will be variations in size and the efficient siting of new ‘kit’, which would mean it does not match exactly with the consented scheme.  This should not preclude the development coming forward and should not necessarily result in the need for a new planning application.
Lichfields’ Edinburgh offices work with BESS developers all over Scotland and have an excellent track record in gaining planning permissions and collaborating with existing commissions to enable development.
If you want to discuss an energy project, please get in touch.

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Urban living alternatives to HMOs in London housing rental market
In recent years, London has seen a surge in Co-living, Build-to-Rent, and Purpose-Built Student Accommodation (PBSA) developments. But what exactly are these housing types, and how do they differ from traditional shared rooms in Houses in Multiple Occupation (HMOs)? In this blog, I will explore the key differences between these new urban living products and conventional HMOs, highlighting their benefits and role in London’s housing market —from offering tenants relatively affordable, high-quality living experiences, to easing pressures of the housing market and creating new development opportunities in suitable locations.
Finding good-quality accommodation to rent in London is a significant challenge for recent graduates like myself, and many young professionals starting their careers in the city. As a student studying in London, I’ve experienced the convenience and reliability that student accommodation can bring. A professional management company ensured that any issues, such as a faulty boiler or broken appliances, can be resolved promptly, often by the next day. Communal spaces like hallways, lifts, and shared amenities such as kitchens and lounges were consistently well-maintained, thanks to regular visits from professional maintenance team.
However, after graduating and moving into the private rental market, I quickly discovered that high quality management is not always guaranteed. Unlike professionally managed student housing, HMOs are not always maintained to the same high standards. For instance, a faulty boiler might take a week to be repaired. Shared spaces are often minimal because landlords convert living rooms into additional bedrooms to maximise rental income. These communal areas are frequently neglected, sometimes left untidy or unclean by other tenants, with little to no intervention from the landlord.
What I experienced was not an isolated incident. Data from the English Housing Survey (2021–2022)[1] revealed that 23% of private rental properties in England fail to meet the Decent Homes Standard. This standard requires a property to be in a reasonable state of repair, offer modern facilities, and provide a reasonable degree of thermal comfort. The situation is particularly severe in HMOs, given that landlords are often reluctant to invest in maintenance, as HMOs tend to incur higher upkeep costs by wear and tear than traditional buy-to-let properties due to a higher number of occupants. 
Living rooms in shared houses could also be converted into additional bedrooms, and in some cases, multiple occupants share a single bedroom in order to reduce their rental costs. This significantly reduces the availability of shared amenities, creating cramped and uncomfortable living conditions. An article by the Guardian[2] highlighted that as many as 11 people could be living in a four-bedroom house. Analysts estimate that there are at least 32,000 hidden large-scale HMOs across the country, underscoring the widespread nature of the problem.
Furthermore, many HMO properties are often created as a result of repurposing existing family homes, decreasing the available family homes in an area. News reports[3] have shown that in certain highly sought-after areas in London, entire streets have been converted into HMO properties, causing serious concerns among existing household residents about noise pollution, waste disposal, and insufficient parking spaces, and ultimately, leading to fewer large properties being able for families to rent or buy.
To manage and restrict the growth of low-quality HMO accommodation, many councils in London have enacted Article 4 directions, removing the permitted development rights of converting conventional housing (use class C3) into HMO housing (use class C4) under Permitted Development Rights Class L. As in London today, many boroughs have fully/partially adopted article 4 directions to restrict this conversion:

Figure 1 Status of Article 4 directions in London Boroughs that restrict the conversion from use class C3 to C4 housing.

 

Despite the poor quality of accommodation in some HMOs, demand for these properties remains high due to their relative affordability. Data[4] from the room-rental platform SpareRoom shows that as of March 2025, an average of 3.1 individuals are competing for a room to rent in London. Some boroughs like Barnet and Kingston Upon Thames have seen 12.6 and 8.5 persons competing for a room respectively, highlighting the significant mismatch between supply and demand. This stark imbalance demonstrates that there is a significant need for good quality rented accommodation, and the restriction of HMOs through Article 4 directions cannot be the sole solution to addressing issues of low-quality and poorly managed accommodation in London. A more comprehensive, alternative approach needs to be in place to balance between the objectives of providing more housing supply, while upholding the quality and standard of housing in London. 

 

Co-living, Purpose Built Student Accommodation (PBSA) and Build-to-Rent
As the above demonstrates, there is an acute need to provide a diverse range of high quality housing options alongside HMOs in order to better meet the housing needs in the capital. Over the past decade, London has been at the forefront in the country for providing alternative urban living products, including Co-living, Purpose-Built Student Accommodation (PBSA), and Build to Rent developments. Many London boroughs are actively supporting these residential typologies, introducing broadly supportive planning policies designed to encourage their growth and guide appropriate delivery, as highlighted in our recent research and commentary on Co-living, Build to Rent and PBSA.
A key differentiator of these alternative urban living products from HMOs is that they operate under unified ownership (a planning policy requirement) and benefit from professional on-site management. This offers advantages over traditional rental properties and HMOs, including greater tenancy security and flexibility—ensuring tenants are not forced to leave on short notice, and enhanced protection against risk of crime. Importantly, these urban living products help alleviate the demand on HMOs, thereby reducing the conversion of family homes and preserving much-needed housing for families.
For developers, these urban living products present a valuable investment opportunity if they are being developed in suitable locations, especially in well-connected locations with supportive policies and Article 4 restrictions on HMO conversions, reducing the reliance of low-quality HMO accommodation in the rental market. These typologies can also contribute to the creation of mixed and balanced communities through the communal facilities that is provided, fostering social interaction, thereby enhancing the overall well-being of local residents.

 

Co-living
As explored in Lichfields’ recently published Insight Focus, Co-living is a type of living product that provides individual rooms with a size from 18-27 square metres[5]. The development would provide a range of dedicated facilities, supplemented by a range of high quality communal facilities throughout the building which residents are encouraged to use, including large shared kitchens, various living, dining and working spaces, and often gyms, games rooms and cinema rooms. Unlike rental properties in the Private Rented sector (PRS), all units fall under a unified ownership, providing on-site professional management. These features make co-living appealing to a wide range of people from different ages, including those who are new to London and may be unfamiliar with renting in the city, people going through a change in circumstance or those looking to meet other people in a safe and managed environment as discussed below.
The rental price of Co-living units includes council tax, utilities, WiFi, and typically access to these communal facilities such as co-working spaces and gyms. When factoring in these amenities, Co-living units can be up to 20% cheaper[6] than comparable studio flats or flat shares in the same area. This makes them a cost-effective option while maintaining high-quality living standards and security.
In planning terms, Co-living developments fall under the Sui Generis use class, distinguishing them from HMOs. Within London, Co-living schemes are subject to specific planning policy requirements set out under London Plan Policy H16 (Large-scale purpose-built shared living). These include locational criteria in well-connected areas, minimum space standards, room sizes, external spaces, cycle parking, and inclusive building design.
Co-living can play a significant role in expanding housing supply in the capital. This is acknowledged by the Large-scale Purpose-built Shared Living LPG (LPBSL LPG), which equates 1.8 co-living units to 1 home[7].
Contrary to the common perception that co-living is primarily for young professionals and recent graduates, their appeal can attract a broad demographic. According to the research by Harris Associates[8], the average age of a Co-living resident is 28, with over a quarter of residents aged 35 or older. The report also identified the main attractions of Co-living schemes as the convenience of all-inclusive bills (mentioned by 47.7% of survey respondents), opportunities for social interaction (21.5% of respondents), and flexible contract terms (12.3% of respondents). As such, rather than creating a demographic imbalance, co-living supports a diverse and well-balanced population in the areas where they are built.
Moreover, Co-living developments can play a key role in addressing London’s affordable housing needs. The higher values that these schemes can attract allows for cross-subsidisation that supports the delivery of much-needed affordable homes either on site or through a payment in lieu.
It is no wonder that the development of Co-living schemes are highly regarded and supported by the GLA and the LPBSL LPG, which highlights the critical role that Co-living plays in addressing the acute housing shortage in the capital and actively supporting future developments.

 

Purpose Built Student Accommodation (PBSA)
Purpose-built student accommodation (PBSA) developments are designed specifically to meet the needs of students, offering a variety of communal spaces such as large shared kitchens, living and dining areas, and study spaces, where students can both work and socialise. Similar to co-living developments, PBSA falls under the Sui Generis use class and is subject to a range of planning policy requirements outlined under London Plan Policy H15 (Purpose-built student accommodation) and the PBSA LPG (October 2024). This document includes detailed guidance on location in well-connected areas, design standards, management practices, affordable housing provisions, and nomination(??) agreement requirements.
With the UK student population reaching a record 2.27 million in 2021/22[9] and is continuing to grow, increasing the availability of high-quality, high-density student accommodation is crucial. PBSA developments help alleviate pressure on the wider housing market, particularly for non-student renters, and contribute to preserving family housing by reducing the demand for HMO conversions.
The PBSA LPG supports the development of PBSA developments in appropriate locations, recognising the importance that PBSA play in providing accommodation for the needs for the rapidly growing student population and alleviating the pressure on the private rented sector and HMOs. Key points and analysis of the PBSA LPG can be found in this Lichfields’ commentary.

 

Build to Rent
Build-to-Rent developments provide a large supply of rental properties within a single development, offering comparable levels of affordability to the Private Rented Sector across all household types, significantly addressing the imbalance between supply and demand in the rental market. Unlike typical Private rented sector housing, Build-to-Rent developments need to comply with the policy requirements outlined in Policy H11 (Build to Rent), which includes unified ownership and on-site professional management. Additionally, these developments often offer communal amenities, enhancing the overall living experience for residents.
Although not specifically designed as a shared living product, according to the latest research on Build to Rent by the British Property Federation (BPF), Build-to-Rent properties are more likely have attracted a higher proportion of couples and sharers, with 59% of tenants fitting this demographic compared to 41% in the private rented sector[10]. Moreover, Build-to-Rent housing is relatively more affordable, with tenants spending a lower average percentage of their gross household income on rent compared to those in the wider private rented sector, providing a more accessible and higher-quality alternative.

 

Summary
In my view, expanding the range of urban living options —is crucial to tackling London’s acute rental housing shortage. These types of living products can significantly increase the supply of high-quality rental homes, reducing reliance on often substandard and poorly managed HMOs. In turn, this shift allows HMOs to be reconverted into family homes, restoring them to their original purpose-built use.
In my role at Lichfields, I hope to contribute to bringing forward schemes which will genuinely contribute to easing housing pressures in the capital. Lichfields possesses extensive experience in securing permission for various types of Urban Living products in London and throughout the UK. We have been actively advising on many of London’s largest and most high profile co-living, PBSA and BtR developments, gaining unmatched expertise in the planning matters common to these urban living products in the capital. Our work has given us a strong understanding of relevant policies and the unique political dynamics of each borough.
For a more detailed analysis of Build to Rent, Co-Living, and PBSA please see our recently published Insights and commentary, and don’t hesitate to get in touch.

 

Footnotes

[1] One in four private rentals in England fail to meet decent home standards (The Guardian)

[2] ‘There’s no space’: rogue landlords double income by ignoring overcrowding rules (The Guardian)

[3] Residents of St Barnabas Road, Woodford Green, say HMOs are holding their 'whole street hostage' (The Guardian Series)

[4] Too many renters, not enough rooms in Smethwick, Solihull and Stockport (Spareroom)

[5] Large-scale purpose-built shared living London Plan Guidance - Feb 24

[6] The True Cost of Co-Living in London (Folk Co-living)

[7] Large-scale purpose-built shared living London Plan Guidance - Feb 24

[8] Co-living REPORT (Harriet Associates)

[9] Purpose-Built Student Accommodation: More than bricks and mortar (British Property Federation, 2024)

[10] Who lives in Build-to-Rent? (British Property Federation, 2024)

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Towards a new London Plan – doubling down on housing?

Towards a new London Plan – doubling down on housing?

Ross Raftery & Sally Furminger 12 May 2025
For the next six weeks, the GLA is seeking views, evidence and experience to shape the next London Plan. The consultation document considers ways that the Mayor could address the Plan’s most significant challenge – more than doubling housing delivery to achieve c.88,000 homes per year.
In this blog, we explore what the Mayor’s approach to delivering that scale of new homes in London should include. However, there is still a lot of detail to digest and consider – not least how the GLA will distribute those 88,000 homes across its boroughs and what their approach could be for other housing tenures. Those will be matters for us to explore in separate blogs.

 

Housing in London – context and challenges

The new London Plan will set borough-by-borough housing targets for the next ten years, to meet the Government’s new standard method result of c.880,000 homes over that period. The Mayor recognises that this is a huge increase, which is needed to accommodate future growth and to address the chronic shortage of homes, and that some potentially difficult choices will be required.

 

The Mayor notes that there are also substantial challenges affecting housing delivery in London, including increasing construction costs, higher interest rates and regulatory changes. These are well-rehearsed[i] [ii] and the GLA acknowledge that the London Plan is being produced at a time when these challenges will remain.

The effect of these challenges, including the policy burdens of the current London Plan, have been reflected in significant levels of under delivery. Both consents and completions have continued to fall and will need a significant reversal to come close to the new housing target. In 2023/24, just 43,600 homes were approved[iii] and only 33,000 homes were completed – stark figures in the context of the new housing target.
The clear recognition by the Mayor of this context is both positive and crucial to addressing the challenge. While it is an early stage, it is somewhat reassuring that the Mayor indicates that the overall burden of ‘planning policy requirements’ on development will not increase, and that opportunities to streamline planning requirements will be taken. However, it is hard to know what further policy requirements could be applied and it would be more reassuring if there was an indication that policy would be applied more flexibly to respond to the challenges that face the development industry in London.
 
…we must get plans in place now to build towards delivery and bring forward as many homes as possible as early as possible.

Sadiq Khan, Mayor of London

Where will the homes be delivered?
It is clear that the number of homes London needs to deliver will require the GLA and its boroughs to consider and optimise all available options. These include brownfield, greenfield, and other opportunities to diversify housing sources and this is recognised by the Mayor.

Brownfield

Consistent with the current London Plan and national policy, there remains a clear focus on prioritising the use of brownfield land. This will require development at higher densities, with the Mayor recognising that the quality of places needs to support higher density living. The consultation document recognises the need to densify our town centres and high streets; retail parks and car parks; and small sites in suburban areas. Invariably this will mean taller buildings, a need for greater flexibility on policy demands[iv], and a willingness from existing residents to accept such development.
Opportunity Areas are a fundamental part of the current London Plan, accounting for some 497,000 homes of the total 523,000 target. However, many of these have been predicated on strategic transport infrastructure which has either not materialised or has been delayed. While the Mayor recognises that OAs have permission for over 200,000 homes yet to be built, it is clear that there needs to be streamlining and unlocking of OAs. OAs can be a powerful tool to support growth, however their reliance on investment in infrastructure means that they are long-term opportunities for growth and are highly sensitive to external factors, such as delays in infrastructure investment.  
Quite rightly, in our view, the consultation document makes it clear that achieving higher rates of housebuilding depends on funding for transport improvements. This is a strong theme throughout the consultation document and sends a clear message to the government that funding commitments are needed to achieve this level of growth. This is precisely the area within which the London Plan should seek to operate – as a strategic document that can enable cross-boundary infrastructure delivery to unlock growth.
The current London Plan gives industrial land substantial[v] protection from alternative uses, including new homes. This was a policy area that the previous Government challenged the Mayor to urgently review[vi]. The consultation document continues to recognise the importance of providing sufficient industrial capacity but, now recognises that this could be a source of new homes, particularly through the opportunity to swap land and create alternative industrial capacity in London’s grey belt (see below). For housing delivery to be accelerated outside of local plan cycles, it will be crucial that such policies can be used through the development management process.
 

Greenfield

Given the failed delivery rates in London (as above), against the current London Plan’s capacity-based target of c.52,300 homes a year, the document rightly and necessarily acknowledges that ‘even a big increase from brownfield supply’ will not meet London’s need of c.88,000 homes a year, wholly within London’s existing urban area.
Now, for the first time, in line with national policy the document makes clear that the new London Plan will be supported by a London-wide strategic Green Belt review, which will also include the identification of ‘grey belt’ land – a clear and welcome step change from the current London Plan, which expects all housing supply to come from land not designated as Green Belt (and MOL).
The long-awaited need for this strategic Green Belt review is well documented and rehearsed, indeed the Inspectors’ report into the current London Plan considered a review of Green Belt to be the only realistic way to meaningfully close the gap between London’s need and supply. Key criteria for Green Belt release will include: sustainability and access to active travel options; delivery of or improved access to green space; and, nature and biodiversity gains. The document confirms that Green Belt sites will be expected to meet the NPPF ‘golden rules’ and, helpfully, to make the best use of land, they must be focused on ‘achieving densities’ that support public transport and a local economy.
Opportunities for large-scale development (10,000+ homes in each location) in London’s Green Belt are to be considered in areas with good public transport access (or where this could feasibly be delivered through potential strategic level new public transport). This will inevitably involve high density development to support the necessary public transport infrastructure and optimise the use of land.
Such Green Belt release will be crucial for London to come close to meeting its housing needs in a sustainable way. Notwithstanding the Government’s remit on New Towns, the Mayor makes clear the intention that these homes would need to count towards meeting housing needs. While reference is made to engaging with the Government’s New Towns Taskforce, this differs with the understood position that New Towns should be treated as being additional to meeting housing needs. Given the scale of contribution that these sites could make to meeting London’s housing needs, this position will need to be resolved. It could also indicate that the GLA’s preference is for large scale urban extensions, rather than official ‘New Towns’ as selected by the Taskforce.
The current London Plan links Metropolitan Open Land (MOL) to national green belt policy. However, with reference to the December 2024 NPPF updates, ‘which could be interpreted as requiring London’s MOL to be released for housing and other development’ - the GLA's intention is to redraft the London Plan to distinguish between MOL and Green Belt. This shift would ‘protect’ MOL from Green Belt reviews. Similarly, the document infers that the release of large-scale urban extensions (as above) could enable GLA to ‘enhance, expand or establish regionally protected parks (MOL)’ and other open accessible spaces for Londoners. Notwithstanding, the document does refer to ‘some very specific circumstances’ where certain MOL - such as golf courses - could be considered for release to deliver housing, via a landscape-led approach.
While much of the MOL is valued and important, meeting the intended MOL functions in full, there will be parcels of designated land that do not. It follows that not undertaking a London-wide Green Belt and MOL review is a missed opportunity in the context of meeting housing needs.
What else can we look for?
We know, from working on projects across London, that certain policies within the London Plan cause frequent challenges for the delivery and/or viability of residential projects, in particular:
 
  • Density - in the document the Mayor notes that while there has been an increase in the scale and density of development in London in recent years, it is still less dense than many other comparable cities. As such, he is contemplating that the next London Plan could take a different approach to London’s development potential. For example, it could set out the building heights that should be acceptable in principle in all locations across London that share certain characteristics.
     
  • Tall buildings - the Mayor also notes that tall buildings in suitable locations will play an important role in delivering the new homes but that some boroughs have not identified locations that are suitable for tall buildings (as is required by current Policy D9). He also notes that there have been some challenges implementing the current policy as all tall buildings should be assessed on their individual merits irrespective of their location. As such, consideration is being given to whether the new Plan could take a more active role in identifying and defining tall building clusters. This could allow more strategic consideration of tall buildings, but would also require a decision about what height is meant by a tall building cluster and whether this could be a higher threshold of 20 storeys/60 metres. The policy would also need to be clearer about how planning applications for tall buildings should be assessed outside these defined clusters. The Mayor recognises that “this would provide greater confidence about the approach” which would be welcomed.
     
  • Small sites – the current London Plan has ambitious aims for small site development, but the GLA recognises that this has not been realised. To assist, the consultation indicates the potential to set a minimum height benchmark for small sites alongside the possibility of a ‘Design Code’. Whilst a benchmark could be useful, this would need to be carefully developed, considering viability issues with medium-rise buildings (given fire safety requirements) and how boroughs implement this in the context of heritage assets that are commonplace within London. We question how a ‘Design Code’ would work in practice and whether it is appropriate for an SDS to contain this level of detail.
     
  • Dual aspect – this requirement can contribute to the creation of less efficient layouts and limit the layout of buildings, sometimes with the effect of limiting the number of homes delivered. The consultation document suggests that bespoke policies such as this could be removed, instead relying on national building regulations to deal with ventilation and overheating. Given the constraint that dual aspect requirements can place on layouts, this could be a significant move in both optimising density and enabling innovation in design approaches.
     
  • Cycle parking – the London Plan sets significant requirements for residential cycle parking, which adds significant costs to schemes and are not always well used, becoming an inefficient use of space. The consultation document states that the GLA will review these standards – a more pragmatic approach would be another significant move to help deliver more efficient housing schemes.
Hope for a slimmed down London Plan?
Positively, there is indication from the GLA of an intention to make the London Plan more streamlined and focused, including removing areas of duplication with national requirements. We have previously[vii] highlighted the importance of slimming down the London Plan and returning to its strategic role for the capital. This alone would make the process simpler for applicants and planning officers and help accelerate the delivery of new homes.

 

Concluding thoughts
The direction that is being set within this consultation document is a great intention. Meeting the new standard method for London will be a significant and unprecedented challenge, in the face of significant headwinds. Coming close to achieving this will require radical policy changes for London and, it appears, that the Mayor is willing to consider all available options.
The new London Plan will need to deliver these policy changes holistically – increasing density; supporting more tall buildings; refining OAs; reviewing and releasing Green Belt for housing; and giving greater flexibility for new homes on industrial land.
While these intentions are positive, they now need to be translated into proportionate and flexible policy requirements, with a real commitment from the GLA and boroughs to deliver these objectives through planning decisions and new local plans. Only time will tell how these materialise, but key now is for all involved in delivering new homes in London to submit our evidence and experience to help shape an effective and proportionate new London Plan.

 

Footnotes

[i] Testing times for Engalnds big cities - an extended reach for the presumption and other nppf changes, Lichfields 

[ii] Housing Delivery and a New London Plan – Déjà vu?, Lichfields

[iii] Residential approvals dashboard, London Datastore

[iv] For example, with a defined site area, there will need to be flexibility in open space requirements which would otherwise constrain the total number of homes on a site.

[v] In some instances it is effectively a complete protection, requiring the release of industrial land to be plan-led only.

[vi] https://assets.publishing.service.gov.uk/media/65f8030aaf6a0daea190d4ff/SoS_DLUHC_to_the_Mayor_of_London_-_housing_delivery.pdf - although the need for this review was subsequently removed by the Labour Government.

[vii] Housing Delivery and a New London Plan – Déjà vu?, Lichfields

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