New year, New London Plan?

17th December 2020

As London moves into a new tier a week before Christmas, when the restrictions will change again,  the endless toing and froing of the Capital’s COVID-19 position somewhat reflects the position of the Mayor’s Draft London Plan.

Buoyed by his approval to move to the Royal Docks, the Mayor of London sent a letter to the Secretary of State (SoS), declaring that he intended to publish his new London Plan on 21st December (which was originally submitted a year to the day before his most recent letter) and that it would be based on the SoS’ views to date due to his lack of response.

It had the desired effect and less than 24 hours later, the SoS responded on 10th December 2020 but with two further Directions in addition to the 11 set out in March.

The Directions

The first would allow boroughs in exceptional circumstances (whatever they may be), to re-allocate industrial land, even when it is in active use, if they are considering the release of Green Belt and Metropolitan Open Land to accommodate housing. This alteration seems to contradict the Mayor’s protective position on industrial land, as the current draft Plan clearly indicates the aim for there to be no net loss of industrial floorspace.

The second Direction is a requirement for a clear London-wide definition of what a tall building is. The SoS advises that a tall building “should not be less than 6 storeys or 18 metres measured from ground to the floor level of the uppermost storey”. This provides clarity and will be helpful for developers and local authorities alike, which has previously been absent.

Although these changes could delay the Mayor’s decision to publish the Plan, it is understood he is keen to have it adopted as soon as he can. However, when looking at whether a 2021 adoption is likely, there are a number of key factors and planning changes to take note of.


Firstly, Mayoral elections. The election was meant to take place in May 2020 but was pushed back by a year due to the pandemic. Read more about the delays here. This means the purdah period will now come into effect mid-March 2021. Though it is not expected to become a political game of football, the Plan, or lack of, could be used by Conservative candidate Shaun Bailey to question Sadiq Khan’s effectiveness as Mayor.

Secondly, with the Government’s Planning White Paper having only recently been consulted on, will the proposed London Plan be out of date before it is even adopted? Key principles of the Planning White Paper, particularly a new “zoning” approach, set of design principles and environmental assessment system, may fundamentally contradict the aims of the new London Plan. Though it is not expected to prevent its adoption.

Finally, the recent announcement that the Housing Delivery “mutant algorithm” is being abolished could impact the delivery of housing in London. It is expected that the loss of the algorithm will result in the North West and Midlands being allocated the majority of new housing for England. Although the Government still aims to deliver 300,000 new homes each year, how they will be distributed is an ongoing discussion. The precise impact on housing in London and the South-East as a whole, where affordability is still a huge political issue, is difficult to predict.

What’s next?

Given the new impetus, we fully expect to see the London Plan adopted prior to the May 2021 Mayoral elections. This will have little immediate impact on planning applications because the GLA have been essentially applying it as if it were an adopted document for a number of years.

Arguably, the most interesting unanswered question is how recent changes in the Use Classes Order (particularly Class E) and the associated Permitted Development Right proposals, which would allow for the change of use from Class E to residential in Town Centres, will impact decisions for London boroughs? Furthermore, the ramifications of the pandemic on the office and housing market will also be one to watch. As we have had to adapt the way we work this year, the level of requirement for office space is likely to change with it. Will this provide the Mayor with an opportunity to deliver housing? At this stage we can’t be sure, but it is clear that the impact of the pandemic could bring about development opportunities to many.

For more information and for planning advice, please contact our London team.

Geoff Megarity, Senior Planner

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