2. Making best use of land and achieving Good Growth

In implementing this policy, applicants, plan-makers, decision-makers and others (as relevant) should take account of the following:

2.9    Statutory Development Plans will need to address the different components of growth and change locally to make best use of land, as set out on the key diagram (as well as through small sites and windfall opportunities).  

2.10    Specific strategic opportunity will relate to sustainable access (including to town centre facilities), connectivity within and beyond London, the presence of strategic economic clusters, the scale of opportunity sites and/or planned changes to any of these. It includes making the most of opportunities around stations (as emphasised in the NPPF), across London, and capitalising on key gateways in the CAZ.  

2.11    Some aspects of strategic opportunity may be more evident in the thematic sub-diagrams and also BFOA visions in Annex E. While this strategic opportunity is predominantly brownfield, some extends into the Green Belt and, may also interact with opportunity that extends beyond London given shared transport corridors and natural corridors and catchments that cross boundaries.  

2.12    This will include instigating managed release of employment land and Green Belt as set out in policies GLE2 and PV7 Sustainable development and enhancement of the Green Belt. This policy establishes that the Green Belt release associated with those BLGs is acceptable in principle because it is necessary to meet objectively assessed needs for homes and employment-generating uses.

2.13    Safeguarded land is land that is not yet formally allocated; a future version of the plan will confirm further spatial development requirements in order to continue the trajectory to 850,000 homes. In the interim, it is to be protected from speculative development that could undermine its optimisation. Much will be contingent on the scoping and development of further transport infrastructure interventions and other work to address further mitigation of key constraints.

2.14    In referring to the need for intensification, this includes both urban form, but also the extent to which land, infrastructure and buildings are used across the 24-hour period, the week and the calendar year. As such reference to intensification in A(2) and B(4) includes intensification of the existing use, as well as land use change, which may include (pro-active) loss of certain uses that are poor uses of well-connected land such as carparks.

2.15    Supporting places to renew and evolve means making the best use of land and existing and emerging assets, particularly where there are enhancement/public benefit opportunities. This will typically involve the development of positive place-visions that factor in place assets. These include natural, cultural, historic, infrastructural, (including the strategic sustainable transport and environmental opportunities highlighted in A(1)) and economic (such as the successful economic clusters that are a key link to London’s Growth Plan) assets.  

2.16    In some cases, associated policies, and updates to the strategies and action plans referenced will refine the infrastructure requirements listed and shown on the key diagram(s) or as subsequently updated via the Annual Monitoring Report (AMR). It is also expected that the London Infrastructure Framework will be updated to account for the over-arching needs of the additional growth planned, so should be referred to when published. Where infrastructure capacity is referenced, the role of adequate management and maintenance of existing assets alongside new ‘kit’ will also need to play an important role. Infrastructure needs for good growth also include those that benefit resilience, carbon, air quality, health, inclusion and equality of opportunity.

2.17    The cumulative impact of policy and site-based expectations and CIL charging schedules can make a difference to overall viability and speed of build-out as indicated by the London Plan viability testing. Plan-making authorities should be mindful in the round of cumulative impacts on viability and there should be a proportionate and prioritised approach that avoids undermining delivery, which is reflected in A(4), A(5) and B(8). For instance A(5) reflects that in some cases specialist housing (Purpose-Built Student Accommodation  (PBSA) or Large-scale Purpose-built shared-living (LSPBSL) accommodation without their applicable affordable housing requirements in early phases may help build scheme value and deliverability; and that CIL charging schedules can presently penalise higher-density development. It also highlights the need to ensure and enable efficient layouts e.g. in terms of net to gross ratios.

This policy reflects a number of key considerations:  

2.18    It sets out London’s overall vision for good growth, and the different requirements and components of change that must be part of the spatial strategy if we are to meet objectively assessed needs. It highlights the key parameters to be attended to, and – where prioritisation is necessary – what this should reflect.  

2.19    This approach is necessary to ensure that London’s growth is sustainable and minimises adverse impacts. If growth does not make the best use of land, does not happen in the right locations and is not underpinned by the requisite infrastructure it will result in the loss of much more Green Belt land; far higher levels of congestion; significant environmental costs; and ultimately, less housing overall.  

2.20    It is important that all plans work together to secure delivery of the scale and nature of growth intended. The infrastructure requirements listed are as specific as best available information allows, including impact testing of the Plan and other evidence and linked to the Plan’s Good Growth Objectives.

2.21    As well as providing for the 10-year growth against which housing targets are set and other growth is aligned, the policy puts in place a direction of travel for longer-term growth. This is intended to support positive planning for future capacity, around which firmer propositions can be built over time and integrated in future plan iterations.  As set out in chapter 1, it is not possible to go further than this at this stage.

2.22    In some cases, longer-term growth may be focused on corridors where improvements will benefit an area that extends beyond London. The Mayor is keen to work with neighbouring authorities e.g. in order to make the most of transport investment but given the Mayor’s jurisdiction is limited to the administrative boundary, it may be most appropriate for the government to facilitate cross-boundary coordination.  

In implementing this policy, applicants, plan-makers, decision-makers and others (as relevant) should take account of the following:  

Optimisation 

2.23    The Optimisation Framework uses the SAM (see Figure 2.4) and character settings shown on the London Context Map (Figure 2.5). The SAM level and setting of a site can be found using these maps which are online at Planning Data Map.21

The SAM is a measure of different travel times to jobs, services and amenities by public transport and walking. It was developed by TfL to inform land use policy and ensure integration with transport planning within London.

2.24    The Optimisation Framework provides a recommended net residential density range (in habitable rooms per hectare) that is expected for different settings and SAM levels within London. The density range is complemented by an indicative height range (in storeys) for the different locations within Table 2.1 as well as guidance below on site coverage. There may be site-specific design responses that achieve the requisite overall densities in different ways. 

2.25    Net residential densities should be calculated in line with the government’s Design and Placemaking Planning Practice Guidance; and should not be used interchangeably with gross densities. If comparisons between net and gross densities are desired, the net densities in Table 2.1 will need to be adjusted to accommodate a site’s gross site area.

2.26    The appropriate density and height for development within the range will be informed by a number of factors, such as how sensitive to change an area is. There may also be more granular aspects of transport connectivity and development viability than can be reflected in the Optimisation Framework that might influence form and density. Boroughs may assess certain areas as more sensitive to change, with appropriate densities potentially towards the lower end of the range, but it is not expected that this is a default position across large parts of a borough, and it must be informed by a robust assessment.

2.27    Sites within OAPFs, designated tall building areas and areas being masterplanned may support higher densities and building heights than those in the Optimisation Framework for that location. 

2.28    The density range is the product of the indicative height and typical site coverage for the relevant location. The density range will not be relevant for non-residential sites or forms of non self-contained residential accommodation. For these sites the indicative height range and guidance on site coverage stated in the Optimisation Framework should guide site optimisation.

The London Context Map and local character studies

2.29    The London Context Map categorises each built-up area of London into one of six overarching settings (locations with a predominantly similar character) which provides a high-level description and understanding of London’s character. The mapping takes a typological approach to character, it does not differentiate between areas of the same setting which are more or less sensitive (such as the presence of heritage assets). 

2.30    While the settings have been defined and mapped on the London Context Map, the boundaries of these settings may change over time (or as a result of evidence base updating by plan-making authorities).

2.31    LPAs can complement this through more detailed local studies (or revise existing character studies where needed to provide more detail, improve precision and reflect changes due to recent development). These studies can further inform planning for growth and identifying the varying sensitivity of different areas, but they should not seek to reduce ambition or deviate from the overall scale of ambition needed. 

2.32   New development should be designed to achieve a compact and connected form of development that supports walkability and contributes to successful, well-functioning places. This involves having an efficient building layout, which can reduce overall development costs and improve viability. The following illustrations in Figure 2.6 are indicative only and show how this may be achieved at different levels of public transport connectivity. 

2.33    For schemes that provide car parking, the use of podiums and basements may be appropriate in order to reduce impacts on the walkability and public realm of a scheme. Where this is designed in, the building frontage should be kept active and not dominated (visually or physically) by cars. 

Small sites design code

2.34    The Mayor will be producing and consulting on a London Small Sites Design Code, that when finalised will apply in line with this policy. It will identify site types common across London which are suitable for residential intensification. To provide clarity on acceptable design responses, the London Small Site Design Code will set a number of design requirements to be met for each site type.  

2.35    The coding parameters in the London Small Site Design Code will have focus on the strategic design requirements for each site type. They do not assume a specific architectural style.

2.36    To streamline the planning process, LPAs are encouraged to make LDOs that embed the London Small Sites Design Code (or locally specific code) within them. This provides planning permission for sites covered by the LDO, when applying the design code that is contained within the LDO.  

2.37    Where it is considered necessary, plan-making authorities may choose to issue a local design code for small sites that more directly applies particular design aspects for their plan area. This may be because a local authority may wish to take into account locally specific characteristics and contexts that aren’t addressed in the London Small Site Design Code. LPAs may also choose to code for a specific architectural style that relates to the specific character type in which it is located. Where an LPA produces a design code or guide, these should not be overly long or complicated or add undue burdens to development. Where a more detailed approach is sought, this should generally be brought forward via an LDO. 

This policy reflects a number of key considerations:  

2.38    This policy sets out what site optimisation means in different contexts across London, building on the approach to optimisation established in the NPPF. It does this primarily via the Optimisation Framework which provides a strategic approach to the optimisation of sites within the existing built-up areas of London. This is the crux of the spatial strategy and the ability to make best use of land.  Its application is key to the deliverability of the housing targets and ensuring that development is sustainable.  

2.39    The strategic approach is critical in order to make the most of all the opportunities on brownfield land. The densities in the framework necessarily go beyond the minimum set in the NPPF (as allowed and supported by that policy) in order to reflect both the greater opportunities and housing needs in London. The Optimisation Framework also sets a more generally applicable approach across boroughs to ensure that all parts of London play an appropriate role in meeting housing need. Otherwise, it is likely that individual boroughs – acting separately and from their local perspective – would not optimise these opportunities that collectively are vital to help meet housing need for London as a whole and to do so in a way that avoids disproportionately impacting on some areas and communities.

2.40    The minimum densities and indicative heights and density ranges in the Optimisation Framework embed the link between density and transport connectivity. It utilises the Sustainable Access Measure which is a London-specific connectivity tool to direct higher density development to the most appropriate locations based on access to services and amenities by sustainable transport. It has been developed to account for London’s particular circumstances and indicates that minimum densities in London should exceed those set out in the National Planning Policy Framework

2.41    The framework provides greater clarity and certainty to developers and decision makers on the scale of development that is acceptable and expected in different locations across London and builds on the approach set out in national policy to promote development near rail stations. It should help speed up planning process and avoid underutilisation of development sites.    

2.42    Mid-rise development of four to nine storeys is a key focus in the Optimisation Framework and will need to be delivered across many more parts of London. This form of development has many advantages over other types (and scales) of development; and has a vital role in sustainably delivering more homes in London. These advantages include the ability to create walkable and dense neighbourhoods, while being able to integrate well into London’s existing streets and neighbourhoods. They can work well for families with young children; and can have lower construction and maintenance costs compared to taller buildings.

2.43    The production of a London Small Site Design Code aims to reduce delays and risk of small site development across London and maximise their potential as a source of new housing. In line with the NPPF it uses common design principles that illustrate opportunities for making more effective use of land. By establishing consistent development parameters across London, the Code will seek to ensure that the collective potential of these sites is realised through coordinated, high-quality development rather than ad-hoc, piecemeal delivery. By having a design code that clearly covers the site types found in London, it is possible to provide a greater level of clarity and certainty to applicants and decision makers on the redevelopment of these sites rather than a generic approach to small sites which does not take into account the differences in the types of small sites across London and the potential of these sites.  

2.44    If we do not make the most of all the opportunities on brownfield land there will be pressure to release further Green Belt land and adverse environmental, congestion and health impacts will increase.   

In implementing this policy, applicants, plan-makers, decision-makers and others (as relevant) should take account of the following:

2.45    This policy measures tall buildings from the ground level to the roofline of the building, including any rooftop equipment (see Figure 2.7). Where a proposal is submitted at the planning application stage, the height above ground level can be supplemented with heights expressed as an Above Ordnance Datum (AOD) level. 

2.46    Three tiers of metropolitan tall building clusters are identified:

• metropolitan tall building cluster – established or emerging confined skyline feature  
• major metropolitan tall building cluster - major skyline feature  
• international tall-building cluster – significant skyline feature and London’s globally recognised primary financial and business locations. 

2.47    Plan-making authorities are responsible for identifying the location of buildings between 30 and 100 metres. In identifying appropriate locations, the sensitivity analysis undertaken as part of character studies helps identify where taller buildings will be more or less appropriate. Plan-making authorities can use this evidence as well as local and strategic views (see PV8 Strategic and local views ) to identify where the development of buildings of 30m and above in height may be appropriate. Where the prevailing building height is near or above 30m plan-making authorities can use a higher building height threshold to plan for.   

2.48    In undertaking this process, plan-making authorities should utilise the assessment of areas that are more or less sensitive to tall buildings required by Part A(1), to articulate any harm that could be caused by buildings outside of those areas deemed appropriate, so that it can be used in the decision-making process. 

2.49    The use of 3D modelling software can support in determining the potential impacts of tall building development, both at a plan-making and development proposal stage. This helps to understand the visibility of a building from its surroundings, and to determine appropriate locations and their heights.

2.50    Where the London Plan or a local plan has identified a location as appropriate for tall buildings, this does not mean that all buildings up to this height are automatically acceptable in the identified locations. Such proposals will still need to be assessed in the context of site circumstances and other development plan policies to ensure they do not lead to unacceptable impacts on the local area.

2.51    The cluster-specific guidance in Table 2.2 sets out the area covered for each location. Where the plan-making authority has identified locations for buildings 100m and above in height in its current local plan within the locations identified in Table 2.2 these should be used as the boundary of the metropolitan tall building clusters, until any revisions are made to them through a new local plan.

2.52    For some locations Table 2.2 highlights specific constraints from strategic views, but it does not identify all implications of strategic views. Other metropolitan tall building locations are near to or overlap locations covered by London's strategic views. In these instances, metropolitan tall buildings may be appropriate providing they do not conflict with the London View Management Framework (LVMF) (see PV8 Strategic and local views).

Table 2.2: Locations where metropolitan tall building may be appropriate 

2.53    In addressing the design requirements in part B(4) the greater the height of the building, the more important meeting these requirements becomes and the greater the level of scrutiny that is required for its design.  

2.54    Any external lighting for tall buildings should be minimal, energy-efficient and designed to minimise glare, light trespass, and sky glow, and should not negatively impact protected views, or the amenity of nearby residents. The internal lighting within tall buildings should also be carefully designed to minimise light pollution and positively contribute to nighttime views.  

2.55    Where publicly accessible areas (including viewing areas on upper floors of buildings) are provided as a public benefit of the development, they should be freely accessible and in accordance with the Public London Charter; and in addition to any street level public realm requirements.

This policy reflects a number of key considerations:  

2.56    A contributing factor to London’s global image is its landmarks and skyline. Tall buildings that are of exemplary architectural quality, in the right place, can make a positive contribution to London’s cityscape, and many tall buildings have become a valued part of London’s identity.  

2.57    However, in inappropriate locations and/or where they are of poor-quality design, they can also have detrimental visual, functional and environmental impacts so a framework for managing these buildings is important.

2.58    Therefore, to ensure that tall building development is in appropriate locations and designed to be of the highest architectural standard, this policy sets out a framework for managing the location and design of these buildings. Buildings over 100m in height are of strategic importance because of their wide visual impact and the influence they have on London’s skyline and global impact. This policy directs these tall buildings to the most appropriate locations. 

In implementing this policy, applicants, plan-makers, decision-makers and others (as relevant) should take account of the following:

2.59    The policy reflects the concept of strategic sufficiency which takes a systems perspective requiring attention to both demand and supply, as well as the need for flexibility and resilience - looking beyond the short term and immediate site needs.

2.60    Certain plans and strategies already use a whole systems approach (e.g. IWMS and LAEPs), but it should also be applied to digital connectivity. This means for instance, considering how mobile and full-fibre connectivity and resilience deficiencies (particularly not-spots) can be addressed through additional mast and signal- boosting infrastructure on taller buildings and in the public realm; and fibre-optic routing that enables connection through and beyond the site as well as to it.

2.61    It is important that the outcomes of such integrated approaches are embedded into development planning for sites and wider areas from the outset, given they are key to their delivery. This is preferably plan-led through incorporation in local plans, which will require plan-makers to engage with providers and coordinators as well as other information and strategies indicated. Local plans will need to ensure for instance, that adequate space and access is made available for infrastructure upgrades, as well as addressing remaining constraints through phasing and the planning and bringing forward of additional utilities capacity.    

2.62    As such, local plans, relevant London Plan specifications (in Box MBUL4 and other cross-referenced policies) and other self-serve information and (in the absence of up to date local plans) strategies signposted will be most important for scheme developers to engage with in preparing their proposals. Such proposals should demonstrate where measures benefit the wider system as well as their immediate site needs. This could be for instance, enhancing the energy system’s resilience by addressing building level demand, local generation and load shifting.  

2.63    However, where the local plan has not anticipated a particular scale or type of development or where it is of the scale/type indicated in Table 2.3, applicants may also need to undertake engagement with providers and coordinators to inform their proposals and measures such as phasing. 

Table 2.3: Utilities and expected engagement

2.64    The range of measures highlighted should be considered and incorporated as appropriate to proposals, meeting the technical standards specified. Appropriateness will primarily be established by following the published template relating to particular scales and types of development; and meeting the requirements of detailed policies that are cross-referenced. For the most part, this is likely to be about setting out a clearer audit trail of how utilities considerations have informed design. While for local plans it will be about ensuring at the plan-making stage that plans are clear about where specific utilities infrastructure anticipated through this process (and Policy MBUL1) should be accommodated.  

2.65    In areas of little/no existing utilities infrastructure but where growth is planned, measures might include a utilities strategy for that area that brings together utilities planning in an integrated way. This will require pro-active interaction with all the utility providers responsible for the relevant infrastructure systems and as such is preferably part of plan-making activity, but may also be necessary for other large-scale development when this is in advance of plan-making.

2.66    In respect of digital infrastructure, it should be noted that provision for continuity of service means there is an expectation that Notices to Quit should not be issued without other arrangements being put in place to ensure service continuity during construction and beyond, in dialogue with affected providers.  

2.67    It is also expected that through this process, plan-making bodies establish where the rollout and upgrade of utilities infrastructure has been affected by the difficulty of achieving its compatibility with heritage and other place-based sensitivities. This is known to be a particular issue with digital connectivity infrastructure and many conservation areas for example and is thought to be affecting London’s overall mobile connectivity.  Where this is the case, plan-makers should engage positively with the relevant industry and together establish suitable expectations and site-based opportunities whereby impacts may be minimised. These should then be set out in local plan policies and site allocations.  

2.68    Making data available to inform utilities planning should be done by ensuring the required fields are filled in (and updated as necessary) in the Planning for London Data return, which will in turn be shared with relevant providers and coordinators.  

This policy reflects a number of key considerations:

2.69     Given the importance of utilities to underpin growth and enable its delivery, it is vital to proactively and strategically plan and design for them across the full range of utility types. A systems approach is needed as part of making best use of land to ensure all opportunities to address system growth needs are taken, ensuring that this happens in a cost-effective and space-efficient manner aligned with wider good growth objectives.

2.70    While this approach is ideally plan-led, (and the Utilities Impact Assessment and this policy is the first stage of that), imperfections in the ability of regulated utilities to engage with growth before it is more certain, and commercial sensitivities in the case of telecoms infrastructure, mean that some aspects are necessarily deferred to the development management process where they are not addressed in local plans.  

2.71    Provision of consistent, high-quality planning data to utilities (for example on phasing, demand profiles and efficiency assumptions) at an early stage will help to inform planning and investment decisions. Better upfront alignment reduces late-stage infrastructure redesign, abortive cost and delivery risk.    

2.72    The policy also recognises (in line with engagement feedback) that upgrades to London’s utilities infrastructure to meet good growth needs have sometimes been constrained by other policy concerns, (notably heritage conservation) rather than a positive way forward being identified and signposted through plans.  

2.73    The approach also addresses the unintended consequences of development on utilities infrastructure sufficiency that can occur even when immediate site needs are met. This is a particular issue with digital infrastructure, for instance, where development may result in ‘notices to quit’ that have eroded London’s overall mobile connectivity compared to other equivalent cities. 

In implementing this policy, applicants, plan-makers, decision-makers and others (as relevant) should take account of the following:

2.74   If development proposals are referable to the Mayor, applicants are recommended to engage early with TfL through the pre-application process.30

2.75    Mitigation of the impact of developments may include financial contributions (such as funding for bus services) or direct provision of infrastructure (such as additional bus stops or driver facilities). Where development proposals may directly impact existing or future transport, such as bus or rail operations or cycleways, protection and mitigation may include specific building or street design, site layout mitigations, or safeguarding of land.  

2.76    Where a scheme in MBUL1 Spatial Strategy and Annex D could potentially be affected by a proposal, applicants should consult with TfL (and other relevant authorities) at an early stage to understand the latest status of the scheme and identify impacts.

2.77    Local car parking standards that are more restrictive than those set out in GHR11 are supported and should be adhered to.  

2.78    Measures to support the use of sustainable modes for local deliveries might include:

• urban logistics hubs to support place-based consolidation and last-mile delivery
• development based consolidation and reception facilities, such as parcel lockers, concierge and storage facilities and
• optimising site layouts to facilitate connections to existing or planned railheads or wharves. 

This policy reflects a number of key considerations:

2.79    To meet housing and economic needs and ensure good growth, there is a need to take every opportunity to lift connectivity by sustainable modes, add public transport capacity and enable reliable operations of those services. The deliverability of the 850,000 homes is limited by insufficient transport infrastructure which will need to be addressed through the Plan period.

2.80    Scarce road capacity needs to be carefully managed to prevent congestion becoming a brake on growth. Alongside the support for people to use public transport and to walk and cycle there is a need to restrain car parking in new developments and to resist non-strategic car-centric uses that otherwise would induce more car trips and impact on vital freight and other journeys.

2.81    To achieve this, TfL and boroughs will need to work closely together to maximise the benefit of the city’s collective land-use and transport planning powers. Interventions can be tailored to the local context but need to be set within a consistent, coordinated framework to gear London’s overall transport network towards facilitating good growth.

2.82    Assessment and mitigation of transport impacts ensures that development helps work towards meeting the Mayor’s Transport Strategy aim for 80 per cent of all trips in London to be made on foot, by cycle or using public transport by 2041. It also ensures that essential transport operations (including the expansion of the network) are effectively facilitated.

2.83    Freight journeys comprise an increasing proportion of traffic on London’s roads, particularly light goods vehicles. To support a shift away from road-based freight, development plans and proposals should identify and provide the necessary infrastructure to reduce unnecessary freight journeys, including missed deliveries. 

In implementing this policy, applicants, plan-makers, decision-makers and others (as relevant) should take account of the following:  

2.84    Particular attention should be paid to the design of the parts of a building or public realm that people most frequently see or interact with in terms of their legibility, use, detailing, materials and location of entrances. Creating a comfortable pedestrian environment with regard to levels of sunlight, shade, wind, and shelter from precipitation is important. Designing to address air quality concentrations and exposure in line with Policy GHR10 will also be relevant.  

2.85    The design of buildings needs to respond to the changing climate. External shading (such as awnings and shutters) is an important design measure to minimise overheating risk and is expected to be incorporated in buildings’ design (see Policy GHR4 Heat Risk).

2.86    In the context of London’s density, mix of uses and growth pressures, the Agent of Change principle, as set out in national policy and guidance and policy GLE4, protects existing and permitted activities, which generate noise, light and other impacts, from new sensitive development proposals in their vicinity. These impacts are particularly relevant during their operational hours and also apply along their access routes. Where those existing and permitted activities are expanded, intensified or substantially modified, there are opportunities to reduce their impacts.  

2.87    Negative impacts to be anticipated and avoided through infrastructure design, construction and management proposals should be those on public realm functionality and inclusiveness, and wider neighbourhood amenity by way of noise, odour and disruption. Designing infrastructure for security includes ensuring the risk of vandalism and damage by individuals is minimised. Design for multi-benefits may include incorporating green infrastructure, sustainable drainage, play and resting spaces and digital connectivity infrastructure for instance.

2.88    The level of design scrutiny undertaken in a design review will be proportionate to the scale and/or impact of the proposed development. LPAs are encouraged to use design review to support the scrutiny of major development proposals.  

2.89    The London Design Review Charter includes guidance on how panels and processes should be managed and records kept. It also clarifies that the purpose of the design review process is not to dictate the design of a scheme or contradict planning policy, but to guide better design outcomes. This process may be supported by specialist advice and processes, including Health Impact Assessments, to draw out considerations set out in national policy whilst ensuring London-specific current and future health risks – many of which will be related to climate and health inequalities – are accounted for.  

This policy reflects a number of key considerations:    

2.90    Good planning and good design are intrinsically linked. Poor quality design can have long lasting implications for people’s health, well-being and quality of life. In London, due to its densely built-up form, both above and below ground, and the competing pressures for land, as well as its microclimatic conditions arising from its location and exacerbated by its built form, the impacts of development from future growth require specific design mitigations.

2.91    As part of managing growth and change, future proofing involves consideration of functionality in light of both risks and opportunities in order to support continued quality and functionality as well as other objectives relating to resource efficiency, improving health and climate change resilience.

2.92    As London grows and intensifies each development should be seen as an opportunity to address different needs in a cost-effective way, alongside its primary purpose, as well as minimising impacts on other uses and users of land through design and operation.  

2.93    The form and character of London’s buildings and spaces should be appropriate for their location, fit for purpose and respond to changing needs of Londoners and the city overall. This will help to ensure their ongoing success and positive role as London evolves.

2.94    Developments that show a clear understanding of, and relationship with, the distinctive features of a place are more likely to be successful. These features include buildings,  open spaces, public realm and the underlying landscape. Development should be designed to respond to and evolve the special characteristics of these features .  

2.95    The London Design Review Charter promotes a consistent approach across London’s design review sector and promotes transparency of process. The higher the intensity of development, the greater the level of scrutiny there should be on the quality of the proposed development and its interaction with its surroundings, including its built form, massing, site layout, external spaces, internal design and ongoing management. This is important because these elements of the development come under more pressure as the density increases. Meanwhile, the housing minimum space standards set out in HN8 Housing Design help ensure that as densities increase, quality of internal residential units is also maintained. Development proposals required to undergo design review as set out under Part D of this policy will form a small proportion of overall planning applications in London. 

In implementing this policy, applicants, plan-makers, decision-makers and others (as relevant) should take account of the following:  

2.96    This policy builds on the framework of heritage policies at national level which should be appropriately applied in the London context, including providing a Heritage Impact Assessment where required. Particular regard should be given to London’s WHS.  

2.97    The GLHER includes over 223,000 records relating to heritage assets and the wider historic environment. The GLHER is used to assess archaeological potential. Up-to-date Archaeological Priority Areas (APAs) are classified using a tier system recognising their different degrees of archaeological significance and potential as presently understood (see Figure 2.9). The Greater London Archaeological Advisory Service publishes guidance on best practice for archaeological investigations affecting the capital’s diverse range of sites and assets of archaeological interest, and securing the public benefit arising from their conservation and investigation. 

2.98    There are opportunities for the creative re-use of heritage assets and the historic environment as well as the enhancement, repair and beneficial re-use of heritage assets that are on the At Risk Register. In particular, local heritage strategies can be used to identify opportunities for positive change, with tangible actions and priorities. Topics they can address include the identification of and approaches to: local character and distinctiveness, town centres and high streets, aspirations for key development sites, public buildings and spaces, designated and non-designated heritage assets, conservation area appraisals and management plans, archaeology, heritage at risk, local lists, museums and archives, intangible heritage, funding sources and marketing.

2.99    The setting of London’s WHS consists of the surroundings in which they are experienced and is recognised as fundamentally contributing to the appreciation of a World Heritage Site’s Outstanding Universal Value. The fundamental contribution made by the setting of London’s WHS, including any buffer zone, to their Outstanding Universal Value and the ability to appreciate it should be set out in each of the site’s WHS Management Plan and/or Setting Studies. As all four of London’s WHS are located along the River Thames, the setting of these sites includes the adjacent riverscape as well as the surrounding cityscape. Changes to the setting can have an adverse, neutral or beneficial impact on the sites’ Outstanding Universal Value and the ability to appreciate it.  

2.100    The consideration of views is part of understanding potential impacts on the Outstanding Universal Value of the WHS from change within their settings. Many views to and from WHS are covered, in part, by the London Views Management Framework. However, consideration of the attributes that convey their Outstanding Universal Value is likely to require other additional views to be considered. These key views should be identified in World Heritage Site Management Plans and supported wherever possible by the use of accurate 3D digital modelling and other best practice techniques.  

2.101    Part C of this policy is to be applied where impacts, including but not limited to visual impacts, from developments could occur. It is expected that relevant boroughs'31 local plans should contain such necessary policies to protect the Outstanding Universal Value of WHS. The Mayor will support steering groups in managing the WHS and will actively engage with stakeholders in the development and implementation of WHS Management Plans. It is expected that the boroughs with WHS, GLA, Historic England and neighbouring boroughs will be part of the World Heritage Site Steering Groups that contribute to the management of the sites, including the drafting and adoption of Management Plans.  

2.102    In exploring energy-efficiency, decarbonisation, renewable microgeneration and measures to minimise overheating (including external shading), applicants are encouraged to consider the full range of measures that can be incorporated as part of the planning application. This includes improvements that can be made to the significance of heritage assets by reinstating original features when carrying out these improvements. Applicants and local authorities are encouraged to use the latest Historic England guidance.   

This policy reflects a number of key considerations:    

2.103    London’s heritage assets and historic environment are irreplaceable and an essential part of what makes London a vibrant and successful city, and their effective management is a fundamental component of achieving good growth. London’s diverse range of designated and non-designated heritage assets contributes to its status as a world-class city. It is therefore appropriate for this Plan to include a strategic approach to heritage assets.

2.104    Designated assets currently include four WHS, over 1,000 conservation areas, 19,000 list entries for historic buildings, 150 registered parks and gardens, 160 scheduled monuments, and one battlefield. Non-designated assets cover an even wider range of features including buildings of local interest, most archaeological remains, canals, docks and waterways, historic hedgerows, ancient woodlands, and ancient and veteran trees. Given the number of heritage assets in London they play an important role in climate change mitigation and adaptation.

2.105    Having wide-ranging and inclusive conversations with Londoners should ensure that heritage strategies are informed by a robust understanding of what people value about their local places and how communities and partner organisations can be involved.

2.106    The UNESCO WHS at Maritime Greenwich, Royal Botanic Gardens (Kew), the Palace of Westminster and Westminster Abbey (including St Margaret’s Church) and the Tower of London are among the most important cultural heritage sites in the world and are a key feature of London’s identity as a world city. The qualities of each are conditioned by the character and form of its surroundings as well as other cultural, intellectual, spatial or functional relationships.  

2.107    This policy applies not just to the World Heritage Site, but also the surrounding environment. This is to ensure that the attributes of the WHS that convey their Outstanding Universal Value are protected and enhanced, while allowing the surrounding area to change and evolve as it has for centuries. 

In implementing this policy, applicants, plan-makers, decision-makers and others (as relevant) should take account of the following:  

2.108    Where lifts are proposed in a new building to enable level access to different floors of the buildings, the policy requires that an evacuation lift is provided to allow people who require level access to evacuate from the building safely and with dignity when above or below the entrance level. The fire evacuation lift(s), and associated provisions are expected to be appropriately designed, constructed and include the necessary controls suitable for the purposes intended. The requirement for evacuation lift(s) applies to a core in which the development proposal includes a lift. Where a core is proposed with only a stairway and no lift, no evacuation lift is required to meet this policy requirement. For the purpose of this policy new buildings include substantial redevelopment of existing buildings (requiring planning permission).

2.109    The detail and extent of the information provided to meet the requirements of Part B will be proportionate to the scale and type of development, and will include details of any specialist advice and/or design review feedback and outcomes (see also MBUL6 High quality design for a growing, changing city for design scrutiny requirements)  

This policy reflects a number of key considerations:

2.110    London is a diverse city and it is important that all Londoners are able to access and enjoy the homes, places and opportunities it offers and feel welcome in its public spaces.

2.111    London is home to more than a million people with disabilities and it contains around 70 per cent of the UK’s high-rise buildings and four times the national average of high-rise homes. The policy requires that that people who require level access can access all areas of a development in an inclusive way, and in terms of vertical circulation, this is often achieved via the provision of lifts.

2.112    All building users should be able to evacuate from a building with dignity and by as independent means as possible. Emergency carry down or carry up mechanical devices or similar interventions that rely on manual handling are not considered to be appropriate, for reasons of user dignity and independence.  

2.113    At the current time there is no equivalent requirement to this policy for evacuation lifts in the Building Regulation as set out in this policy. If such a requirement was introduced in the future it would remove the need for this particular part of the policy and the Mayor will make this fact clear in a formal statement.        

2.114    It is important to consider the development’s contribution to the creation of an inclusive built environment at the earliest possible stage in the development process – from initial conception through to completion and, where relevant, the occupation and on-going management and maintenance of the development.  

In implementing this policy, applicants, plan-makers, decision-makers and others (as relevant) should take account of the following:

2.115    The public realm should be seen as a series of connected spaces that facilitate safe and inclusive social interaction, leisure, play, and movement. The specific balance between the different functions of any one space, its local context, including socio-demographic and heritage, should be at the heart of how the space is designed and managed.

2.116    Transport for London has guidance and toolkits on the Healthy Streets Approach, as well as wider streets planning and design guidance32 and the Department for Transport's Inclusive Mobility33 and TfL's pedestrian comfort guidance34 set out recommended minimum footway widths which may be useful in assessing footway clutter.

2.117    The Mayor's Good Growth by Design35 programme has guidance including Making London Child-Friendly36, Expanding London's Public Realm37, Safety in Public Space38 and Designing with Disabled Experience.39 GLA Public Art Commissioning guidance40 sets out best practice commissioning processes for public art. Mayor's guidance on Safety in Public Space: Women, Girls and Gender Diverse People41 provides tools for design and engagement.

2.118    Developments that provide significant new public realm are not expected to provide public toilets and drinking water fountains so long as there are agreements in place, visibly displayed, for free use of toilets and water fountains within walking distance.

This policy reflects a number of key considerations:

2.119    The quality of the public realm has a significant influence on people’s quality of life, including their health.  

2.120    About 80 per cent of public realm in London is in the form of streets and it is important that every development contributes towards their improvement to provide cumulative social and environmental benefit in line with Healthy Streets Approach42. The Approach addresses London’s inactivity crisis, improves air quality and reduces other health impacts by planning street networks that work well for people walking or cycling. It also ensures that streets become social spaces.  

2.121    The policy focuses on safety for all people during day and night, but at the same time acknowledges that the design of public realm can in particular affect the real and perceived safety of women and girls and gender diverse people and can discourage them from using the public realm and public transport. The role of the built environment in preventing Violence Against Women and Girls is clear and opportunities to tackle it must be reflected in plan-making, development proposals and planning decisions.  

2.122    Access to public toilets and drinking water fountains are essential for people to be able to stay and socialise in the public realm.  

In implementing this policy, applicants, plan-makers, decision-makers and others (as relevant) should take account of the following:  

2.123   By considering security at the start of the design process new developments, including streets and public spaces, can address policy criteria when it is most cost effective to do so, and incorporate elements to deter and disrupt hostile activity, assist detection and help mitigate effects without compromising good design.  

2.124    Planning officers are not experts in fire safety. Therefore the onus is on the applicant for the development, through the use of fire safety professionals, to demonstrate compliance with Part C of this policy. The role of planning officer is to ensure information which demonstrates compliance with part C has been provided.  

2.125    A competent fire engineer is one that is registered with the Engineering Council as an Incorporated Engineer (IEng) or Chartered Engineer (CEng), and a member of the Institution of Fire Engineers or other (fire relevant) professional engineering institution. Further details can be found on the Institution of Fire Engineers website43. Non-combustible materials are only materials that are Class A2-s1d0 rated and above under the European classification system (as set out in the standard BS EN 13501-1 and as reflected in UK Building Regulations), except for the exempt elements as set out under Regulation 7(3) of Approved Document B.

2.126    The Mayor will actively monitor changes in national fire safety requirements and will publish a formal statement of supersession when part C of this policy is no longer deemed necessary.

This policy reflects a number of key considerations:

2.127    The safety of residents and those working in and visiting London is an issue of strategic importance and ensuring a safe and resilient city is a key concern when planning for new development.  

2.128    While the matter of fire safety compliance is covered by Part B of the Building Regulations, the Mayor currently has some concerns around the scope and standards of these Regulations in particular with regard to fire safety in residential accommodation. London’s uniquely dense built environment, which includes the majority of the country’s tall buildings, makes it particularly susceptible to fire safety risks.

2.129    The restriction on using combustible materials in external walls is to support public confidence in the quality of residential accommodation, in the context of London’s dense urban environment and disasters such as the tragic Grenfell Tower fire by applying the precautionary approach to buildings that provide sleeping accommodation. It also helps ensure the highest standards of fire safety for residential accommodation.