The 16 July 2026 London Plan consultation draft was published before the publication of the government’s 17 August 2026 National Planning Policy Framework which sets out the tests which strategic development strategies such as the London Plan should meet. In my view, it does not meet those tests. The current consultation process (mainly closing on 15 October 2026 but with a later closing date of 23 October in relation to corrections announced on 11 September to ten boroughs’ proposed brownfield housing targets) does not have the benefit of any explanation of the Mayor’s position vis a vis compliance with the 2026 NPPF nor either any justification for non-compliance or any stated proposal to prepare a further updated draft.
Why does the 2026 NPPF apply?
See Annex 1:
5. Spatial development strategies should be produced in accordance with this Framework.
7. For all plans that should be produced in accordance with this Framework this means the policies in this version of the Framework will apply from 17 August 2026.
8. Any other plans should be produced in accordance with the version of this Framework published in December 2024, unless any of the transitional arrangements in Annex 1 to that Framework apply (in which case those transitional arrangements continue to apply).
There’s no transitional arrangement for SDSs such as the London Plan which may have reached a particular stage short of publication of the final version. Because paragraph 8 says “any other plans” Annex 1 to the 2024 NPPF doesn’t apply.
What does the 2026 NPPF require?
Policy S1 states that SDSs should seek “to meet the development needs of their area, as a minimum” by “providing for objectively assessed needs for housing, business and other uses (including supporting infrastructure), as well as any needs that cannot be met within neighbouring areas, unless:
i. The application of the policies in this Framework that protect areas or assets of
particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. Any adverse impacts of doing so would substantially outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”
Policy HO1 states that the preparation of SDSs should be based on:
a. A housing need assessment that establishes the overall number of homes needed in the area as a minimum over the plan period, using the standard method in Annex D;
b. An assessment of the permanent and transit site accommodation needs of travellers in the area as a minimum over the plan period; and
c. An understanding of any accommodation needs that cannot be met within neighbouring areas.
Under policy HO2, a housing requirement is then established for each local planning authority within the strategy area.
Under policies PM10 and PM11 there needs to be co-operation between plan-making authorities to identify and address cross-boundary measures where, for instance, development needs that cannot be met wholly within a particular plan area could be met elsewhere and this must be demonstrated by statements of common ground. “Where it has not been possible to fully address cross-boundary matters, plan-making authorities should demonstrate that they have taken all reasonable steps to address them”.
Under the soundness test for SDSs (policy PM14.2): “Positive – the strategy sets out a positive approach to delivering growth which, as a minimum, seeks to meet the area’s objectively assessed needs, and is based on effective joint working on cross-boundary strategic matters. A strategy which does not provide for objectively assessed needs should be considered an exception, and only where it is evidenced that stringent efforts have been taken to meet those needs through cooperation with other strategic planning authorities”.
I have emboldened that last sentence, which indeed has footnote 20 against it: “This also applies to the Mayor of London.”
What is potentially in conflict?
There are wider, more fine-grain, issues as to whether the draft London Plan meets the first three requirements of PM6:
a. Only address matters, and include policies, that are necessary and relevant to the plan being prepared, and that avoid unnecessary duplication of other parts of the development plan;
b. Only include policies that extend beyond site or location-specific requirements where these are necessary and where plan-makers consider there is a clear and justified reason for inclusion;
c. Not include policies which duplicate, substantively restate or are inconsistent with the content of national decision-making policies, unless directed by other policies in this Framework
But I wanted to focus for the moment just on the overall housing numbers for which the Mayor of London is planning for in the draft. This is proposed to be a 20 year plan. It is noted in the first chapter: “The government has set the housing need in London at 84,884 new homes per year.” (paragraph 1.9). The plan “sets out how we can deliver 558,000 homes over the ten-year period up to 2037” (paragraph 1.12).
“This is based upon an assessment of what could be feasibly deliverable in the coming decade, taking into account viability and build-out rates, while analysing and optimising what more is possible through the lens of the Plan’s new and ambitious policy framework – representing a step change in the approach to planning for housing in London. This includes policies to boost housing delivery through:
- optimising brownfield sites, building out Opportunity Areas and evolving town centres
- closer integration between land use and transport – leveraging all opportunities from existing and planned transport, using new tools & approaches
- making a step change in the approach to small sites (e.g. London-wide design code) and suburban densification (through the new Optimisation Framework)
- targeting some industrial land release in accessible locations for housing
- using the Green Belt to deliver major new settlements and ensure industrial provision, while increasing access to nature and deliver Biodiversity Net Gain.
- deploying a range of tools such as Local and Mayoral Development Orders to increase certainty in planning system and drive density and delivery in sustainable locations
- managing car parking to maximise land available for housing and other needs (and avoid unacceptable levels of congestion)
- tackling viability constraints through consideration of alternative delivery formats, and other development expectations, including quality place-making and more active public sector delivery role.” (paragraph 1.13)
“The Mayor is very conscious that this does not meet the government’s housing need figure for London. More is possible beyond the initial ten-year period, and the Plan identifies opportunities and capacity to deliver homes up to and beyond the 850,000 – but this requires investment, measures and delivery rates that can only realistically and properly be put in place beyond the ten-year timeframe.” (paragraph 1.14).
Surely, factually, this is a draft which does not meet London’s objectively assessed needs? This SDS is going to be an important precedent for all others coming forward across the country. Is it enough to plan to undershoot in the first ten years on the basis of what “could be feasibly deliverable” in the second decade of the plan:
- without indeed any evidence that I have seen of “stringent efforts…taken to meet those needs through cooperation with other strategic planning authorities”; and
- without stringent testing as to whether higher numbers might be achieved with reduced development management policy requirements or with other policy choices in relation to, for instance, density? And without interrogating for instance the justification for assuming an upturn in economic conditions such that the current London housing emergency measures package is no longer necessary past its expiration?
Wider considerations
To my mind, strategic planning is only going to work nationally if objectively assessed housing numbers are handed down by government to each strategic authority, for that authority to apportion to the LPAs within its area unless it has reached an accommodation with another strategic authority or can show that it at least has made “stringent efforts” to that end. Otherwise, we all know the outcome: many strategic authorities will succeed with special pleading and under this new system we will still end up with a huge national undershoot.
Before this new system goes much further, I think we do need more clarity as to what wriggle room strategic authorities (including the Mayor of London) have in preparing plans which do not meet their areas’ objectively assessed needs. Otherwise many draft SDS examinations will simply get bogged down in debates over housing numbers.
Who knows, it may be that 558,000 homes is the right number for London up to 2027, but that is going to need a lot more by way of testing and consideration of other policy options, in my very humble opinion.
Simon Ricketts, 13 September 2026
Personal views, et cetera
SIMONICITY 