3. Delivering the homes and neighbourhoods Londoners need

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

3.12    LPA housing targets may be planned for at the local level through either a stepped housing trajectory that varies requirements over the 10 years, or through equal division of the target on an annual basis. Housing targets are to be monitored by determining net supply.

3.13    Reflecting the lead-in times for delivery in Green Belt locations, the housing requirement for LPAs that have a greenfield component to their target will be set at the annualised equivalent of the brownfield target only for years 2027/28 to 2029/30. Typically, housing delivery on brownfield land across London should be prioritised over greenfield development in accordance with MBUL1 Spatial Strategy. Where LPAs have a greenfield component to their housing target they should plan for strategic growth to deliver against this assessed capacity. These should be advanced through Green Belt release in line with PV7 - Sustainable development and enhancement of the Green Belt. Any under delivery against brownfield targets should not be off-set at the local level by planning for increased delivery on greenfield land, particularly where this would involve land outside of identified BLGs.

3.14    Given that housing requirements are strongly tied to the viability context in most locations across London, targets are considered to be set at the minimum level and higher numbers are expected to be positively planned for (including in relation to capacity to achieve 850,000 homes)  to enable delivery as viability conditions improve and over the longer term. The GLA will work with LPAs through its General Conformity process, to seek to embed the implementation of the Plan’s approaches to optimise density and ensure that growth is positively planned for.

3.15    The housing targets in Table 3.1 are capacity based, with the evidence supporting the London Plan demonstrating the extent to which the identified housing needs of London can be accommodated (see the GLA’s Strategic Housing Land Availability Assessment (2026) (SHLAA)). As such, when LPAs propose housing requirements in local plans, these should account for all of the identified capacity from the base date of the SHLAA 2026. This means planning to meet any shortfall from under-delivery over the elapsed part of Table 3.1's 10-year period as early as possible so as not to unnecessarily delay meeting identified development needs.

3.16    LPAs are encouraged to use the Land4LDN platform to prepare this evidence, and will be expected to demonstrate clear evidence that the identified capacity cannot be delivered sooner, with no available supply able to be brought forward from later in the plan period.

3.17    Any further sustainable locations or additional greenfield capacity identified above the figures in the brownfield target should be considered additional to the overall housing target in order to protect the Plan’s brownfield first approach.

3.18    Student housing need is a component of general housing need and as such, the ten-year targets for PBSA set out in Table 3.6 of policy HN5 Managing specialist accommodation, are a component of the local planning authority targets in Table 3.1. As non-self-contained accommodation (NSC), PBSA will count towards meeting LPA housing targets on a 2.5:1 ratio, with two and a half bedspaces/units being counted as a single home.

3.19    NSC for older people should count towards meeting housing targets on the basis of a 1:1 ratio, with each bedroom counted as a single home.

3.20    All other NSC communal accommodation should count towards meeting housing targets on the basis of a 1.8:1 ratio, with one point eight bedrooms/units being counted as a single home.

This policy reflects a number of key considerations:

3.21    It is recognised that London has a very high need for housing of multiple types and tenures. However, the ability to deliver new homes is not simply linked to land availability, infrastructure capacity or environmental factors, but is constrained by viability, which is impacted by a wider macro-economic context that changes over time. As such, the SHLAA has taken this into account and derived a housing requirement for London and its constituent LPAs that incorporates assumptions around the potential achievability of representative types of development over the target-setting period.

3.22    The housing targets in Table 3.1 are reflective of the expected delivery associated with following the spatial strategy set out in MBUL1. The contribution which can be made from various brownfield and greenfield sources has been estimated through the SHLAA 2026, and reflects a level of development which meets housing need as far as possible. The Plan follows a brownfield first approach, bringing in greenfield development in a targeted manner to ensure that new development is in sustainable locations, is well connected and can be viably serviced. 

3.23    Although it is typical for Mayoral Development Corporations (MDCs) where they are also the plan-making authority to have their own housing target, this is not the case for Oxford Street MDC – an area that contains limited capacity for new homes. This approach will ensure flexibility in delivery can be maintained across the wider borough.

3.24    In terms of the different ratios used to count NSC against the overarching housing target, this is based on the amount of self-contained housing this form of supply could free up on delivery.

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

3.25    This policy applies to the loss of specialist and supported housing (SSH) accommodation (policy HN5) as well as more conventional housing. Although SSH is more likely to be classed as non-self-contained accommodation, some schemes depending on their individual format or circumstances may be self-contained homes.

3.26    Where evidence produced by the Mayor or the local planning authority indicates either a broader strategic need or a need within borough for such accommodation, its loss is not considered to be justified unless it can be demonstrated that need will still be met, for example through consolidation plans (as part of a wider estates planning exercise) or via absorption by alternative provision, without resulting in a strain on existing resources.

3.27    Policy criteria on the loss of affordable housing apply in all cases, including proposals for Estate Regeneration undertaken by boroughs, housing associations and their partners. Estate regeneration schemes are expected to take into account the Mayor’s Good Practice Guide to Estate Regeneration particularly in relation to considering alternatives to demolition and engaging with residents, including the use of ballots. To secure Mayoral funding, strategic schemes involving demolition of affordable homes will be required (unless exempt) to demonstrate residents’ support via a vote in favour of plans.

3.28    It is expected that existing affordable housing floorspace is re-provided and that additional affordable housing delivery is maximised in estate regeneration schemes. For schemes that meet the criteria in A, and that provide 50 per cent of the additional residential accommodation as affordable housing, viability testing will not be required, and the scheme will be able to follow the fast-track route. Affordable housing that is reprovided as part of redevelopment should be measured by floorspace. Any net additional provision should be measured by habitable room, unless there are demonstrable reasons why measurement by floorspace is more appropriate.

3.29    Where estate redevelopment is taking place as part of a wider programme, it may be acceptable for affordable housing reprovision on individual estates to vary (taking account of the wishes of people who want to return to the estate), if the overall level of provision and tenure is maintained across the programme in accordance with A(1) and A(2), and where the approach is acceptable to the borough and, where relevant, the Mayor.

This policy reflects a number of key considerations: 

3.30    Meeting London’s housing need is not simply about building new homes, it is also about retaining or managing the loss of existing stock where there is a clear rationale for doing so. In the case of self-contained housing, where needs are high for both market and affordable homes, it is not acceptable for loss to occur unless replaced with increased floorspace provision and/ or tenures that are at least as affordable.

3.31    The need for different types of non-self-contained homes is more sensitive to fluctuations over time than that of conventional housing, and requires a more flexible approach. This need tends to be more localised and impacted by factors such as funding streams available and changes in national policy. As such, in the case of redevelopment, it is necessary to require evidence that any loss of capacity can be absorbed by other provision or that a need no longer exists in that location. 

3.32    The Mayor remains committed, in the case of proposals to demolish affordable housing including estate regeneration schemes, that due consideration is given to alternative approaches and that benefits are clearly demonstrated.

3.33    In the case of redevelopment of affordable housing, the requirement that any reprovision be measured by floorspace versus any new provision by habitable room, is designed to account for that fact that existing homes may not meet space standards. Floorspace reprovision would therefore be a sufficient measure to meet policy requirements.

3.34    In terms of temporary accommodation as a meanwhile use, the plan recognises that modular housing may play a role in optimising underutilised land in the short-term, whilst addressing urgent local housing need.

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

3.35    The percentages set out in the Threshold Approach to Planning Applications apply to both market sale and Build to Rent housing.

3.36    The fast-track route through planning does not require a viability assessment to be submitted at the planning application stage. Local planning authorities should not impose additional requirements for applicants in order to meet the fast-track route.

3.37    Where the fast-track route cannot be taken, the viability tested route will scrutinise the viability information provided to assess the maximum possible contribution to affordable housing that a scheme can make. Viability information is expected to be provided in accordance with the Mayor’s Viability guidance, submitted in a standardised and accessible format and treated transparently. Inputs, assumptions and conclusions will need to be fully justified, objective and impartial, recognising the public interest.

3.38    Comprehensive review mechanisms will be applied to schemes to ensure that affordable housing is increased if market conditions improve viability over time. This includes an Early Stage Review for all applications regardless of the route they follow, to incentivise an applicant to build out the permission.

3.39    Applicants are expected to maximise the delivery of affordable housing through grant and other forms of subsidy where applicable and available, engaging in early discussions with the council, RPs and the GLA to explore availability, and improve the design, integration and management of different tenures, reflecting council and RP requirements. Where grant is, or is likely to be available, this should be taken into account as part of the planning application, and the applicant should commit to a higher level of affordable housing.

3.40    Local Planning authorities that fall into location B or C, may explore increasing the threshold through their local plan to the relevant adjacent higher locational threshold if economic conditions improve and it can be demonstrated to be deliverable through robust local viability evidence. Any threshold set should cover the entire extent of the local planning authority boundary and should not exceed the threshold of location A unless there is clear evidence that this can be delivered in practice. 

3.41    The 40 per cent requirement of sites on public sector land set out in Table 3.2, applies to any new portfolio agreements made on or after the publication of this London Plan. Sites permitted within portfolio agreements made prior to this date remain in place and subject to the framework in place at the time of their creation and are not superseded by this Plan.  

3.42    The measurement for affordable housing is expected to be habitable rooms, with habitable rooms in affordable and market homes being of a comparable size when averaged across the whole development. If this is not the case, it may be more appropriate to measure affordable housing provision using habitable floorspace. To enable comparison, applicants are expected to present affordable housing figures as a percentage of total residential provision in habitable rooms, units and floorspace. Where a scheme comprises both market sale and Build to Rent homes, while the relevant parts of the policy will apply to the market or rent element, the scheme will be assessed as a whole, with affordable housing calculated as a proportion of total habitable rooms across the scheme.

3.43    Where in-lieu payments are justified for schemes of 10-35 homes (in accordance with the approach set out in policy) plan-making authorities may set tariff rates for contributions provided they are determined in line with the approach set out in the Mayor's Affordable Housing guidance.  

3.44    When opting to provide a proportion of the affordable housing required for Purpose-built Student Accommodation (PBSA) schemes as an affordable housing payment in-lieu, applications are expected to take the following steps:

(a)    Identify the amount of Net Internal Area floorspace relating to the proportion of floorspace which will be offered as an affordable housing payment in-lieu

(b)    Determine the capitalised value of the floorspace on the basis of both market tenure PBSA and as affordable tenure PBSA

(c)    Subtract the two figures in steps 1 and 2 to identify the difference in value which will equate to the required payment in-lieu contribution.  

3.45    For Large-scale Purpose-built Shared-living Accommodation, payment-in-lieu of affordable housing is expected to typically be provided as an upfront payment to the LPA. It should be calculated in line with the approach to off-site contributions set out in the Mayor's Affordable Housing guidance. Applicants that meet these expectations will not be subject to a Late Stage review.

3.46    Given the extent of affordable housing need identified in the 2026 SHMA, the delivery of a borough’s housing target should not be relied on as a reason for reducing affordable housing delivery or other policy requirements.

3.47    Significant strategic transport infrastructure is defined as the schemes set out in MBUL1 Spatial Strategy. Strategic health infrastructure is defined as schemes that will make a significant contribution, particularly to acute healthcare requirements set out in Annex F (e.g. new hospital facilities).

3.48    The Mayor’s preferred affordable housing tenures are set out below. Other affordable housing products may be acceptable if they are genuinely affordable, meet the definition of affordable housing and can achieve the relevant eligibility and affordability criteria.

• Social Rent
• Key Worker Living Rent
• London Living Rent
• London Shared Ownership

3.49    To ensure affordable homes remain affordable to the households that need them, the following criteria apply:

• Key Worker Living Rent and London Living Rent rents set according to guidance provided on the GLA website
• Intermediate Rent and Sale is affordable to households on incomes up to the maximum threshold published by the Mayor, and homes should be provided for a range of incomes below this threshold
• Annual housing costs including mortgage, rent and service charge, should be no greater than 40 per cent of net household income based on household income limits.

3.50    In terms of priority access to intermediate housing for those on local intermediate registers, whilst this is the expectation for new development and re-lets of intermediate rent homes, it is recognised that it may not be possible for London Shared Ownership re-sales, where this might cause a delay in the sale.  

3.51    In the case of intermediate tenures, LPAs will need to assess affordability in accordance with the above criteria. Eligibility criteria may be supplemented by other eligibility or priority criteria for intermediate homes that reflect local need or circumstance and LPAs should work with housing providers to apply these criteria through any adopted intermediate housing allocations policies and processes. The Mayor also encourages LPAs and housing providers to prioritise key workers who also meet the eligibility criterion above, for intermediate homes. Boroughs may also prioritise those in other occupations for which there is a need locally; and/or give additional priority to those in occupations for which there is the greatest need; and/or prioritise staff of specific institutions for homes developed on land owned by or close to that institution.

3.52    Any additional eligibility or priority criteria will only apply for three months after practical completion of the unit. If a home has not been sold or let to a household who meet additional criteria within that period, it can be made available to any household that meets the London Plan criteria above, to ensure the intermediate homes are not left vacant.

3.53    The threshold levels set out in policy will be monitored and reviewed at appropriate points in time to determine how it is influencing delivery rates. Any changes to the thresholds will be made through London Plan Guidance or a focused review of the London Plan.

This policy reflects a number of key considerations:

3.54    The extent of affordable housing need in London is high, as evidenced by the levels of homelessness across the city,  the vast sums being spent by local authorities on temporary accommodation and the increasing numbers of households, including key worker households, that are very unlikely to secure social rent homes but are priced out of homes for sale or rent on the open market. The SHMA sets out the quantum of affordable housing required to address need over a ten-year period – this demonstrates the importance of developments doing the utmost to maximise levels of affordable housing, particularly when it comes to social rent.

3.55    Not only do sites delivering low levels of affordable housing mean that the gap between need and supply continues to grow, it poses significant opportunity costs which will continue to impact in the medium to long term given land scarcity in London. Moreover, affordable housing’s ability to provide cash flow in a development means that providing higher levels of affordable housing forms a vital part of the strategy to increase overall housing delivery. This reduces a site’s exposure to market absorption sales rates, which ultimately limit the number of market homes that can be sold and therefore the overall rate that a site can be built out.  

3.56    Boroughs have systems in place to allocate social rent homes to those in need of them through their role as the local housing authority. This is however not consistently the case for intermediate housing, whereby opportunities to take up new homes may not be as readily understood by local people that are eligible for them. There is also a lack of parity across London, with only some boroughs having introduced allocations policies and housing registers to better direct intermediate homes towards local need. All boroughs are therefore asked to introduce the relevant systems and processes that will facilitate the future take up of intermediate homes, benefiting many households across the capital, including key workers, regardless of where they currently live.  

3.57    The Mayor’s 50 per cent strategic target for affordable housing reflects a number of factors. It is vital to retain an overarching ambition for the delivery of affordable housing in order to maximise the opportunities for its delivery, particularly in the context of the continued high level of need. It is considered most appropriate to retain this ambition and preferable to relying on a percentage that may fluctuate through unknowable future delivery rates, that are in turn impacted by macroeconomic cycles and land viability. Conversely, reducing the figure to a level that would currently be more generally viable across London would not reflect the realities of need and the Mayor’s duties in relation to inclusion, health and inequality. However, both the level of need (in numerical terms) and the viability context (in relation to threshold affordable housing percentages) are recognised in policy and this aims to strike an appropriate overall balance in the approach. LPAs and applicants are asked to maximise affordable housing delivery with the objective of collectively addressing it.

3.58    The Threshold Approach to Planning Applications, informed by viability testing, recognises what can be achieved in different parts of the city, on different types of land given variations in development values and costs and the potential scope for value growth over the Plan period. This reduces the requirement to provide detailed viability information where affordable housing thresholds are met and is designed to continue to embed affordable housing expectations into land values, deliver certainty to the market, and speed up the planning process by reducing protracted viability discussions, in turn delivering the homes that Londoners need.

3.59    The approach seeks to deliver the highest possible level of affordable housing across boroughs, with the different bands reflecting broader variations in the viability context (and also growth potential over the Plan period). It is led by evidence of viability in the medium term and boroughs could move bands subject to robust evidence of deliverability and if economic conditions improve through the course of the Plan. It seeks to strike a balance between avoiding different requirements in each borough for developers to navigate while allowing scope to reflect key differences across London and potential scope to deliver more affordable housing over economic cycles. The ambition is for London to get back to achieving a minimum of 35% affordable housing on private land across the whole of London, as economic conditions allow.

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

3.60    Targets for new permanent pitches and plots set out in Table 3.4 and Table 3.5 are considered to be a minimum in terms of level of provision sought and LPAs are encouraged to exceed these based on local context.

3.61    An estimated 87 transit pitches are needed across London. Transit provision can comprise permanent transit sites or negotiated stopping arrangements. Which type of provision is most appropriate will depend on local circumstances.

3.62    When planning provision for new pitches it is important to consider the wider context both in terms of what type of accommodation households seek and where provision should be made. For example, culturally suitable accommodation might include a combination of pitches and bricks and mortar homes on the same site or group housing to accommodate extended families. Understanding communities' preferences and needs, including targeted engagement, is key to ensuring new provision is culturally appropriate and meets needs in terms of type of accommodation, design, location and layout.

3.63    Involving residents occupying pitches, sites or plots in planning new provision or any unavoidable re-locations should help ensure satisfactory solutions are achieved.  

3.64    It is unlikely that all of London’s need for pitches can be met on existing developed land. It is therefore expected that Green Belt sites will be needed in some cases, in which case policy PV7 applies.

3.65    To assist boroughs in meeting identified need, Mayoral funding is available through the London Social and Affordable Homes Programme 2026 - 2036 46 for the provision of new sites and pitches and for refurbishment or remodelling of existing sites and pitches.

Table 3.4: 10 year targets (2027/28 - 2036/37) for net additional permanent pitches

Table 3.5: 10-year targets (2027/28 - 2036/37) for Travelling Showpeople permanent plots

This policy reflects a number of key considerations:

3.66    London must plan to meet the needs of all its residents, including Gypsies, Travellers and Travelling Showpeople. Targets for pitches and plots are introduced in recognition that past delivery has been slow and that need exists for Gypsy and Traveller pitches across London, albeit the level varies from borough to borough. Targets are minimum, reflecting a degree of uncertainty regarding Census data for these groups and given the pattern of historical underdelivery that urgently needs addressing.

3.67    There is a growing recognition that meeting Gypsy and Traveller need is not just about delivering pitches, but culturally appropriate accommodation that recognises Gypsies and Travellers’ accommodation preferences. Involving existing or future residents in planning new provision is crucial to ensure that it is fit for purpose.

3.68    Requiring boroughs to consider a range of options for meeting needs, including as part of large scale developments, should make it more likely that suitable sites will be identified and new pitches delivered. It should also assist in facilitating an inclusive approach to development, that seeks to address the needs of all groups. 

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

3.69    A positive approach should be taken towards the provision of PBSA in suitable locations to satisfy targets in Table 3.6. London’s cumulative PBSA target is for 31,500 bedspaces required in the next decade. Updates on bedspace completions from the baseline date of 2026 will be published as part of London Plan monitoring updates. Where completions take place between the baseline date and plan start date, these can be netted off from the relevant borough's target.  

3.70    Targets contained within Table 3.6 will be kept under review, acknowledging that need for PBSA accommodation may be impacted by contextual changes in the higher education sector.

Table 3.6: PBSA requirement by local planning authority from 2027/28 - 2036/37

3.71    Areas that are well-connected to services and higher education providers (HEPs), provide a starting point for both LPAs seeking to allocate sites to satisfy PBSA provision and applicants seeking to ensure that C(1) is met. A travel distance of 30 minutes (via walking, cycling or public transport) is considered to be well-connected to an HEP.  

3.72    Whilst it is incumbent upon the applicant to ensure LSPBSL accommodation and PBSA is carefully located, designed and managed for the positive benefit of mixed and inclusive neighbourhoods, the LPA may wish to use the local plan to define any aspects that might be spatially relevant for an applicant to consider.  

3.73    Where all bedrooms in PBSA schemes are provided at a rental cost that qualifies as affordable student accommodation and are maintained in perpetuity through legal agreement or condition, a Nomination Agreement with a higher education provider is not required. There is also no requirement for the higher education provider linked by Nomination Agreement to Affordable PBSA to be located within the borough where the development is proposed.

3.74    LSPBSL development, as a product offering choice in the housing market, should not be subject to a restriction on the groups or demographics that may wish to live there - for example, students, key workers or those requiring emergency or temporary accommodation. LSBPSL management plans are expected to be secured through a Section 106 Agreement.

3.75    Supported, Specialist and Older Persons Accommodation policy applies to accommodation as defined in the glossary of this plan. LPAs should plan for a range of provision, including market, intermediate and social rented, and may wish to take a local approach including through site allocations to cater for needs.  

3.76    The Supported Housing (Regulatory Oversight) Act 2023 (SHROA) places a statutory duty on local authorities in England to develop and deliver Local Supported Housing Strategies by March 2027. It requires local authorities to assess the current availability of supported housing (including older person’s supported housing) and likely need (including current unmet need) for supported housing for a period of five years from the date that the strategy is published.  

3.77    Until such time as local needs assessments are undertaken in accordance with SHROA, Table 3.7 below is provided for local authorities to address local needs. Boroughs may need to draw on local and other relevant evidence, in addition to Table 3.7, regarding the level and type of older person’s provision to be sought.

3.78    Table 3.7 should be treated as minima as needs figures for older persons housing do not account for needs within the private market (such as private sector retirement housing) which will form part of wider housing need across London. Local assessments are also not expected to capture this type of specialist older person's accommodation need, and this should  be taken into account in any local targets (see the London SHMA). Evidence collected for the Local Supported Housing Strategy, and other relevant evidence47 is expected to be used as a basis for addressing specialist housing needs.  

3.79    The OPDC, as a Mayoral Development Corporation (MDC), is not provided with a needs figure. It is expected that the need for specialist, supported and older persons’ housing be accounted for based on a reasonable proportion of need that would occur within the OPDC area, by liaising with respective housing authorities through the local plan process and where necessary, through the development management process. 

Table 3.7: Additional supported, specialist and older persons’ housing units needed 2025-35

Source: The Supply and Demand for Supported Housing in London, Final Report for GLA, Sheffield Hallam University, 2026

*Older persons’ housing: for people aged 55+ with support needs. Excludes older persons' housing for sale or rent on the private market

N.B Column totals may not match totals displayed due to rounding 
 

3.80    Design and access statements for specialist and supported accommodation are expected to demonstrate how the requirements of the specific user group have informed the design and functionality of the final proposal. 

3.81    London is a diverse city and there is a need to plan positively for some specialist housing needs and manage their impacts, particularly in relation to availability of land for conventional housing.  

3.82    A positive approach to the provision of PBSA will ensure a thriving higher education sector is supported and will offer students choice of accommodation, in turn alleviating pressure on the private rented sector, freeing up homes that students might otherwise occupy. However, both PBSA and LSPBL require careful planning to ensure that schemes are well designed and delivered in suitable locations, to maximise their benefits, and to reduce knock-on effects such as overconcentration in certain areas. To help to achieve this, PBSA targets have been determined through a methodology that seeks to align need from HEPs with appropriate locations for PBSA development, as well as to ensure requirements are appropriately spread across the capital.    

3.83    It is the case that some forms of specialist housing, such as community-led housing, may help to enhance social cohesion and increase well-being. As such the policy seeks a positive approach to its planning at the local level, where relevant.  

3.84    Supported, Specialist and Older Persons’ Accommodation is a varied market comprising many different types and formats of housing that can meet a wide range of needs, as appropriate for a diverse city such as London. For example, provision for those requiring additional support after leaving hospital may be quite different from that for victims of domestic violence. Even housing geared towards those within the same demographic may be wide-ranging – for  example older persons’ housing may or may not have tailored specialist care elements and will vary in its offer as part of providing choice based on a persons’ requirements and socio-economic status.  

3.85    Given London’s ageing demographic, it is important that LPAs plan for a range of provision, both market and social rented, to cater for needs. 

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

3.86    BtR is a type of conventional housing that meets the criteria set out above. As such, it is subject to policies of this plan which apply to residential development including but not limited to HN7 Housing size mix, HN8 Housing design and HN9 Accessible housing. BtR should not be conflated with alternative accommodation offers such as LSPBSL or hostel/houses in multiple occupation (HMO) development.

3.87    The covenant to secure BtR homes for the rental market for a minimum period of 15 years, together with a clawback agreement, should be secured through a Section 106 Agreement. During this period, private rented homes are retained in single ownership and overall ownership of the scheme can only change if the entire scheme remains as BtR. If individual homes are sold the covenant is broken and a clawback review is triggered. A valuation of the market and affordable homes is expected to be included within the Section 106 Agreement to enable the level of clawback to be calculated in the event the covenant is broken. Affordable homes proposed as part of any BtR scheme should also be secured via a Section 106 agreement.

3.88    Development proposals for BtR development are expected to carefully consider service charge costs at the design stage in accordance with policy HN8 Housing design. BtR development can come in various formats and providers should consider how affordability can be increased through offering differing levels of amenity or opting for lower maintenance provision to reduce expenditure.  

3.89    Further information on BtR development is set out in the Mayor’s London Plan guidance.  

This policy reflects a number of key considerations:

3.90    BtR will need to play an important role in London’s housing market over the coming decade.

3.91    BtR is a type of conventional housing that addresses identified housing needs, providing greater choice for Londoners. Crucially, it also works to diversify sites and in turn speeds up their build out – helping deliver against identified housing targets. This is due to BtR’s ability (as a rental product) to reduce a development’s exposure to market absorption sales rates which limit the number of market homes that can be sold and slow the overall rate of site build out. BtR is expected to continue to play an important role in London’s housing market over the coming decade. 

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

3.92    Applicants, decision makers and plan-makers are expected to take a pragmatic approach to determine housing size mix, reflecting London’s strategic evidence as well as the site’s surrounding context described through the requirements set out in MBUL2 and set out in any accompanying design and access statement.  

3.93    While London’s strategic evidence should be relied upon to understand housing need overall and the approach to market housing, housing registers for affordable tenures (in offering a live picture of local need) provide a firm basis for any LPA producing supporting guidance and/or discussions over appropriate size mix with respect to affordable housing.

3.94    Town centres or highly accessible locations may better serve higher concentrations of smaller homes, but thought should still be given as to how family-sized homes can be incorporated into any scheme for best effect. In lower density areas, size mix may provide opportunities to redress any overconcentration of homes of the same size, introducing more choice into the local market.  

This policy reflects a number of key considerations:      

3.95    London is a single housing market area and the majority of London’s need lies in one and two bed homes that can more adequately provide for those wishing to form new households or downsize across London. The need for larger homes is significantly lower overall.  

3.96    However, family-sized housing accounts for a much larger proportion of need in affordable tenures than in market homes. Boroughs (through their responsibility as the local housing authority) will hold key information on affordable housing need and can play a key role in addressing it through their allocations process. The focus in the policy is therefore on enabling local flexibility and variation with respect to affordable housing,  

3.97    This does not apply with respect to market housing. With the need to optimise sites and deliver against high housing targets, and challenging viability, imposing extra local requirements would risk undermining viability and deliverability, without any clear basis in evidence.  

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

3.98    When designing residential development, designers should consider the layout of individual buildings and the dwellings within them. Careful design can ensure that shared areas are a pleasant, inclusive and sociable extension to the home and help build supportive communities. Shared entrances should be safe, visible and identifiable from the public realm while offering shelter to users. It is also important that that there is sufficient space and storage in the home near the entrance (threshold space) to enable storage for items such as buggies, walkers and coats and a space to sit and put on shoes. The height of ceilings, doorways and other thresholds should support the creation of an inclusive environment and therefore be sufficiently high to not cause an obstruction. Engaging in early discussions with the Registered providers will help improve the design, integration and management of different tenures within the development. 

3.99    The following should be taken into account when considering the provision, location and design of single-aspect dwellings in a development:

• single-aspect south-facing dwellings are most affected by solar gain/overheating while single-aspect north-facing dwellings can suffer from a lack of direct sunlight during the winter months 
• dual-aspect can provide some mitigation when the dwellings face onto particularly noisy or polluted environments, by providing the option to open windows on a quieter side of the building  
• increased ceiling height and/or having bay windows can optimise daylight and sunlight and allow buildings to be closer together than they might otherwise have been.  

3.100    In determining comfortable levels of wind and traffic noise in outside communal spaces applicants are encouraged to use up to date wind and microclimate standards such as the Lawson Wind Comfort Criteria and the World Health Organization’s (WHO’s) Environmental Noise Guidelines.

3.101    The GLA provides a tool for estimating population yield from new housing development and an indication of the possible number and ages of children that could be expected to live in a new housing development of a given bedroom or tenure mix. Formal play provision should normally be made on-site and provide at least 10 square metres per child. This space may be provided on podiums where that is the most appropriate location for it. Where development is to be phased, there should be an early implementation of play space.

3.102    Off-site provision, including the creation of new play facilities or improvements to existing provision, secured by an appropriate financial contribution, may be acceptable where it can be demonstrated that it addresses the needs of the development whilst continuing to meet the needs of existing residents. This is likely to be more appropriate for the provision of play facilities for older children, who can travel further to access it, but should still usually be within 400m of the development and be accessible via a safe pedestrian route from children’s homes. Schools, school playing fields and other facilities can also provide an important contribution to play and informal recreation facilities and should be encouraged to allow community access to facilities out of hours.  

3.103    The design stage is crucial to the costs of maintenance and, as a result, for service charges for residents throughout the lifetime of the building. Where appropriate and practical, the following can be considered and implemented in the design of the development:  

• design features that minimise ongoing cost to the residents, even though they may have a higher initial cost
• ensuring components and assets used in the development are of sufficient quality to ensure maximum lifespan for replacement and minimal repair costs
• balancing the number of residents who will benefit from a service with the cost of maintenance and replacement.   

This policy reflects a number of key considerations:

3.104    Good residential quality is not just a matter of comfort and safety; it is essential for maintaining both mental and physical health. This involves designing homes that cater to residents’ lifestyles and degree of choice, as well as fostering a sense of comfort and belonging.

3.105    This Plan supports higher densities in appropriate locations to make the best use of land and accommodate more housing. The housing design requirements of this policy will be a vital means of ensuring that these new homes are of good quality, and fit for purpose and meet the needs of residents now and in the future.

3.106    Given the vast majority of new homes delivered over the Plan period will need to be flats, it is particularly important that shared indoor and outside spaces are well designed.

3.107    The overarching requirement to optimise sites and layout means that it is not always possible to deliver dual-aspect homes, but it is important – within these constraints – to maximise their provision given that they have many inherent benefits over single-aspect dwellings. These include better daylight, a greater chance of direct sunlight for longer periods, natural cross-ventilation, a greater capacity to address overheating, pollution mitigation, a choice of views, access to a quiet side of the building, greater flexibility in the use of rooms, and more potential for future adaptability by altering the use of rooms. Single-aspect dwellings are more difficult to ventilate naturally and can be more susceptible to overheating.  

3.108    The requirements for minimum internal and private outside spaces and higher ceilings  than the NDSS are particularly important in London given its dense urban environment, the predominant and unique flatted nature and higher density of new build housing provision. The minimum area and dimensions for the private outside space in the new policy are to ensure the space provided is functional and accessible. The minimum floor-to-ceiling height of 2.4m in new housing helps ensure they provide adequate quality, especially in terms of daylight penetration, ventilation and cooling, and sense of space. This context also means it is particularly important that shared indoor and outside spaces are well designed.

3.109    The level of service charges over time is of particular importance for affordable homes but it can also be a significant factor for leasehold flats. 

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

Table 3.8: Minimum gross internal floor area for wheelchair-user (M4(3)) dwellings

3.110    When calculating the proportion of wheelchair user homes required, figures should be rounded up to the nearest integer. It is expected that planning conditions will be used to secure M4(2), and M4(3)(2)(a) and M4(3)(2)(b) dwellings by tenure. Planning conditions are expected to specify the:  

• number and/or percentage of dwellings by tenure that should comply with Part M4(2)
• number and/or percentage of dwellings by tenure that should comply with Part M4(3)(2)(a) wheelchair adaptable standards    
• number and/or percentage of dwellings by tenure that should comply with Part M4(3)(2)(b) wheelchair-accessible standards.  

3.111    Each application for residential development will be expected to confirm the above information at both approval and completion stages. Information at completion stage should also be provided on the accessibility standard achieved per size typology (that is x number of y bed units) and by tenure.

3.112    In requiring at least 10 per cent of market homes to meet Building Regulation requirement M4(3)(2)(a) ‘wheelchair-adaptable dwellings’ this should be seen as a baseline requirement. It does not preclude provision of M4(3)(2)(b) 'wheelchair-accessible' market dwellings where a developer or applicant considers scope exists to do so (either as part of the 10% or in addition to it). Priority should be given to locating M4(3) wheelchair user dwellings on the ground floor as far as possible. Where there are two or more lifts, provision is supported throughout the building, including on higher floors. For buildings with only one lift, priority must be given to locating M4(3) on the ground floor wherever possible, however wheelchair user dwellings on lower floors (typically defined as floors 1 – 6) may be acceptable, with preference given to the lower of these floors.

3.113    As part of ensuring the occupation of M4(3) homes by disabled people, Section 106 agreements for new major residential developments are expected to include the marketing requirements set in policy. This may include information in all general marketing on the specific accessibility features of the M4(3) dwellings for all sales and lettings (first and subsequent). Marketing plans are expected to be approved by the LPA, prior to the commencement of marketing activities for the development or commencing superstructure works (whichever is sooner). A marketing compliance completion report is also expected to be approved by the LPA prior to homes being sold or let.  

3.114    Private outdoor space should be provided in addition to the minimum gross internal floor areas set out in Table 3.8.

3.115    It is recognised that over time the definition of a ‘wheelchair user home’ has changed. However, where development proposals will result in homes being demolished, it is expected that the applicant will make a demonstrable effort to determine whether existing stock comprises wheelchair user dwellings and ensure replacement as part of any new build, providing information which justifies the approach though a planning application.  

3.116    It is recognised that there may be some exceptional circumstances where this policy may need to be flexibly applied where it is not possible to achieve step-free access to a dwelling entrance, for example due to site constraints or limited/no scope to install a lift. These circumstances include, e.g. on upper floors, in blocks of four storeys or less; some small-scale infill developments; flats built above existing commercial units or garages; and stacked maisonettes where the potential for decked access to lifts is restricted.

3.117    The best practice levels set out in policy for maximum impact sound transmission, should be explored and met wherever possible. This expectation is for self-contained and non-self-contained accommodation.  

3.118    It is expected that planning conditions will be used to secure noise levels set out in policy, and if achieved, will mean that post-completion testing is not required.  

3.119    Figures 52 and 54 and 31 and 32 of the BS8300:2:2018-2 provide assistance to applicants in delivering wheelchair accessible student bedroom requirements.

3.120    LSPBSL wheelchair accessible units should meet Part M volume 2 of the Building Regulations and:  

• include kitchenettes that meet Diagram 16 in Part M volume 2 of the Building Regulations; and  
• have wheelchair accessible kitchen facilities on the same floor, meeting 19.1 of BS8300:2:2018-2 and containing at least one additional wheelchair accessible oven, positioned 1050 to 1080mm from finished floor level to the oven centre, with a pull-out shelf underneath, with 700 to 750mm clear knee space underneath.

3.121    The design and access statement is expected to:  

• demonstrate how relevant engagement has been taken into account in accordance with MBUL8 Inclusive Design, part C(3);  
• include floorplans demonstrating accessible layouts, and the gross internal floor areas of all units, including by dwelling type and number of bedrooms/bedspaces;  
• consider relevant standards and good practice relating to accessible housing, such as that set out in 3.119; and  
• explain how the same, or greater levels of access will be achieved, where alternative solutions are proposed.

3.122    To ensure that residential development proposals meet the accessible housing requirements set out within this policy, decision-makers may wish to secure through legal agreement the involvement of an access professional to support compliance.49

3.123    Publicly available management plans for all residential development secured by condition or legal obligation are encouraged.

3.124    All residential development is encouraged to meet standards and good practice, such as the BS8300:2:2018 Design of an accessible and inclusive built environment and Habinteg’s 2024 Inclusive Housing Design Guide.  

3.125    Accessible housing requirements may need to be balanced against other considerations, such as heritage or security. In achieving an appropriate balance, decision makers should consider barriers to access to and use of buildings, the advice of local authority officers and access professionals50 and the views of local access groups.

3.126    All major residential developments are encouraged to complete a post-occupancy evaluation with occupants within 12 months of occupation to remove barriers, provide learning and improve design. 

This policy reflects a number of key considerations:      

3.127    Ensuring housing choice for those with accessibility requirements is vital in meeting the needs of disabled and older Londoners and ensuring a genuinely inclusive city. This means supporting disabled Londoners housing needs to be met, through ensuring that adaptations are considered as part of the build – and so improving disabled people’s and carers’ wellbeing, employment opportunities and spending power.

3.128    Notwithstanding the prioritisation of wheelchair user homes on the ground floor of development, in residential developments with two or more lifts provision of wheelchair user homes may be catered for across developments to ensure wheelchair users are afforded choice in their accommodation. However, the impact of lift failure, whether resulting from a power cut or mechanical fault, on the safety and welfare of disabled people who rely on lifts to access their homes should not be underestimated. It can also impact the ability to let M4(3) homes on upper floors.  

3.129    By better matching provision to need, the approach should help optimise the use of land, since wheelchair user dwellings are larger on average than other dwellings, and it is more likely that they will be occupied by wheelchair users and other disabled people who need them.

3.130    Given London’s predominance of higher-density and flatted development, and the proportion of Londoners experiencing social difficulties, improving the acoustics of new homes in London will help to meet the needs of neurodivergent Londoners, improving wellbeing and minimising health impacts. This will help to ensure that the Mayor meets the aims of the Public Sector Equality Duty.

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

3.131    The Audit of London Burial Provision (2026) should be regarded as up to date evidence for the boroughs covered by it. For those not covered by it, or for which there are data gaps, LPAs should produce equivalent evidence. This includes accounting for the needs of particular faith groups that require burials.

3.132    In identifying opportunities for additional provision, grave re-use should be considered51, starting with graves known to be more than 100 years old. There may also be other opportunities for intensification and expansion of existing sites. Design for re-use may include providing for double or even triple depth burials where ground conditions allow. Provision for re-use may also be reflected in management practices such as lease length and transparency regarding its potential. Faith-specific considerations may also apply, for instance, ensuring that any re-use is only for persons of the same faith. It may be more difficult to provide for faith-specific needs (e.g. regarding orientation to Mecca; and re-use only of graves within the same faith in re-use and intensification situations).

3.133    In considering these options, compatibility with environmental strategies (particularly those relating to nature recovery, green infrastructure, publicly accessible green space and the management of surface-water flood risk and water quality) should be carefully assessed. Strategies for managing the historic environment may also be relevant. Proposals for new provision should also reflect these considerations and opportunities for green infrastructure enhancement.

3.134    It is therefore expected that grey-belt and Green Belt sites will be needed in many cases, in which case policy PV7 applies. Accessibility is here defined by distance and journey time, most commonly by road. However, where assessing alternative site options, differences in accessibility may be evident, and a choice of means of access within reasonable journey time will always be preferable.

This policy reflects a number of key considerations:

3.135    The Audit of London Burial Provision establishes a strategic need for burial space. It sets out the uneven distribution of burial space, the pressures on capacity, and the challenges in making more space available. The policy addresses these issues in the context of making best use of land, setting out how boroughs should use their powers as burial authorities52, plan-makers and LPAs.  

3.136    The policy seeks to ensure that boroughs plan pro-actively and collaboratively for the expansion, reuse, and long-term provision of burial space, recognising cultural and faith needs; and address strategic land shortages by considering burial provision within the Green Belt and other areas where appropriate. In doing so it recognises that burial spaces can form part of London’s green infrastructure and historic environment and that this presents opportunities not just constraints. It also supports independent proposals where these align with the approach.