4. Growing London’s economy in a way that benefits all

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

4.11    The GLA’s strategic evidence54 identifies demand for offices, research and development, life sciences laboratories, retail, leisure, industrial uses, storage and distribution floorspace, and cultural infrastructure (including nightlife uses).

4.12    To ensure a sufficient and appropriate supply of employment space, local plan-making policies may need to be supported by targeted Article 4 Directions to remove commercial to residential permitted development rights, particularly in locations such as the CAZ, NIOD, town centres, high streets and industrial areas. Article 4 Directions should sit alongside a clear and positive route through planning permission for housing delivery in the Mixed CAZ (see PV2 Central Activities Zone (CAZ)) and the NIOD, and in town centres and high streets.

4.13    The design, type, and level of fit-out of commercial uses (including those in mixed-use development) should be fit-for-purpose, inclusive and adaptable, with flexible layouts with few columns or risers, be of a suitable depth to accommodate back-of-house functions. This is to support the long-term viability and adaptability of commercial, social spaces and high streets, ensuring their longevity and resilience to changing economic circumstances. The Mayor’s Designing Space for Culture toolkit provides guidance to support the delivery of high-quality, inclusive and effective space to accommodate different types of creative and cultural workspace.

4.14    Planning Use Class E supports a flexible approach to commercial, business and service uses and LPAs should only limit this flexibility through planning conditions where there are sound planning reasons for doing so. Examples of where planning conditions could be justified and necessary to maintain a balance of uses appropriate to an area include restrictive conditions on new (Class E) light industrial or research and development located in a SIL or Locally Significant Industrial Site (LSIS). Conditions may also be appropriate to safeguard provision of health uses, indoor sport and recreation and creative workspace in other locations such as CAZ, town centres and high streets, where they may be vulnerable to loss to other commercial, business and service uses.

This policy reflects a number of key considerations:

4.15    Planning has a key role to play in delivering the ambitions set out in the London Growth Plan, particularly by supporting employment generating development and growth sectors including financial, professional and business services and technology, Creative industries and technologies, International education, Frontier innovation including life sciences, and the experience economy.

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

4.16    The local need for industrial capacity includes space requirements for industrial uses to serve residents and businesses, including those that contribute to locally significant sectors such as those identified in the London Growth Plan.

4.17    Additional need for different sui generis industrial uses can only be determined by the plan-making authority based on local circumstances and key sectors locally as well as strategic demand and opportunities to provide for a range of infrastructure uses. Engagement with infrastructure providers is important, as per policies MBUL4 and MBUL5. For example, land for public transport will be required as network capacity has to grow to meet need. Engagement and agreement with TfL is needed to ensure operations can be carried out effectively.

4.18    Land that benefits from the agglomeration of industrial uses, the potential for 24/7 operations and good connectivity to strategic freight transport corridors (including water and rail) is particularly suitable for industrial designation. Where such land is designated but currently vacant, is occupied by non-industrial uses or otherwise lacks suitable premises and supporting infrastructure, a site allocation may help positively support industrial use. Site allocations also represent a suitable mechanism to facilitate new designations (see policy parts D-E) and intensification opportunities (see policy parts G-H).

4.19    SIL and LSIS focus on accommodating uses that are dependent on industrial land due to the nature and impact of their activities on sensitive uses; the introduction of non-industrial uses in these areas is not supported. The introduction of non-industrial development in SIL and LSIS will be supported only if set out in an adopted or emerging (Regulation 19) Local Plan at the time of publication of this draft Plan and in agreement with the GLA as part of a coordinated masterplanning process. Data centres are covered in Policy GLE3 Data centres; this policy does not apply to them.

4.20    For Class Eg(ii) and Eg(iii) a mechanism to retain the industrial use over time would ensure they can be counted towards meeting industrial need. Potential mechanisms to help ensure that these uses remain in industrial use over time include planning conditions and design requirements that are necessary for industrial operations.

4.21    Local monitoring arrangements are needed to provide a transparent understanding of performance against identified needs and compensation for any release (see PV5 Industrial land supporting housing growth).

4.22    The benchmarks for additional storage and distribution demand in Table 4.1 include shorter-term figures as the basis for monitoring; while plan-making authorities should positively plan for the longer-term figures by ensuring suitable additional capacity in identified broad locations is at least safeguarded as per MBUL1.

Table 4.1: Storage and distribution demand benchmarks by PMA

4.23    The benchmarks are based on evidence (Economic Uses Demand and Supply Study)57, which also includes an indicative borough breakdown. The demand benchmarks assume that increasingly ambitious efficiency savings are realised through, for example operational improvements such as automation, layout optimisation and digital inventory management; increasing floor heights; and industrial intensification in suitable locations (see Part G). This means that proportionately less land will be required for storage and distribution over time, and this can be promoted by plan-making authorities. An Industrial Collaboration Working Group for plan-making authorities will facilitate and coordinate the meeting of needs on a PMA basis, including additional needs that are likely to arise due to industrial release (see PV5 Industrial land supporting housing growth).

4.24    Given the relatively high benchmark for the Central Services Area (CSA), the need to service the international hospitality and leisure sectors and the limited supply of available land for industrial use, plan-making authorities may seek to work with other PMAs to accommodate a proportion of their need. Any such alternative provision should minimise freight vehicle distance to/from the new industrial location, in particular for activities supporting the servicing of the CAZ. Within the CSA, space to accommodate urban logistics hubs is particularly important.

4.25    For land in SIL or LSIS that is currently occupied by non-industrial uses, plan-making authorities could consider:

• release from industrial designation, where the criteria in Policy PV5 Industrial land supporting housing growth are met
• retention as SIL or LSIS and repurposing for industrial provision. 

4.26    Individual development proposals for industrial uses in the Green Belt within and outside broad locations for growth are covered in PV7 Sustainable enhancement and development of the Green Belt. 

This policy reflects a number of key considerations:

4.27    London lost 18 per cent of its industrial land between 2001 and 2020. As a modern economy, it cannot function without planning for sufficient land to service its residents, businesses and visitors. Many sectors require close and timely access to their supply chain, access to storage for goods and materials and access to their customers. London is too large to be serviced sustainably solely from its periphery or from outside its boundaries.

4.28    There is a range of strategic needs for businesses, services and infrastructure uses in London that rely on industrial land due to the nature and impact of their activities on sensitive uses. SIL and LSIS focus on accommodating such uses. The construction sector, and strategic infrastructure uses such as waste management and public transport in particular are vital to effectively support London’s growth.

4.29    The character of industrial areas varies across London. Industrial spaces are important to keep London innovating by supporting e-commerce, key environmental services, technology start-ups and many of London’s creative talents.

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

4.30    The types and scale of data centres are evolving rapidly and so are their impacts. Data centre operators tend to benefit from clustering, where existing data centres are already established. There is significant uncertainty over the scale of demand for data centres, but London’s Data Centre Future Growth Forecasts and Strategic Insights study58 provides relevant evidence for plan-making authorities to consider, alongside an expected National Policy Statement on data centres and a Data Centre Strategy, as well as up-to-date information from the NESO, the National Grid and the Distribution Network Operators.

4.31    Plan-making authorities will monitor the scale and cumulative impacts of multiple data centre developments within suitable locations and keep re-assessing them based on the criteria set out in Part A.

4.32    LAEPs set out the decarbonisation pathway for an area, including current and projected availability of electricity and any increases in distribution capacity, to meet future need. They also show local heat demand, locations of existing local heat networks and any opportunities to develop new networks.

4.33    Innovative approaches to cooling are evolving and can help to improve Power or Water Usage Effectiveness ratios.

4.34    The latest best practice relating to generator testing and emissions reduction and mitigation (see Part G) refers to guidance produced by statutory and professional bodies, including the GLA and the Environment Agency. While manufacturer requirements may provide a baseline for safe operation, testing protocols should be restricted to the minimum extent necessary to ensure safe, reliable, and consistent operation. This includes testing the smallest practicable number of engines at any one time. Innovation in relation to digital monitoring and predictive maintenance is rapidly evolving, allowing for reduced testing times and frequencies, and the emergence of ‘no-activation’ health checks. It is expected that this will be reflected in such guidance in due course. In consideration of human exposure and cumulative impacts, it is recommended that any required back-up generator testing avoids periods of moderate or higher pollution episodes (defined by London’s air quality monitoring network)59.

4.35    Environment Agency advice states that screening for impacts of emissions on habitats of international significance should consider a 10km zone of influence around the stack60. However, local air quality evidence base work may refine this to particular areas of concern as per Policy GHR10. Plan-making authorities will need to satisfy themselves that any data centre location identified within such an area will be compliant with Habitat Regulations. This approach will not be relevant if alternative back up power sources without such emissions impacts become the norm.

4.36    Data centres are not included in the definition of industrial land for the purpose of this Plan. If a data centre proposal comes forward on designated industrial land before the plan-making authority has identified suitable locations within its Local Plan, the criteria for suitable locations should be applied in the interim.

4.37    As set out by policy PV7, when considering data centres proposals within the Green Belt, grey belt land or the edge of BLGs in the Green Belt (see Part B(2) above) may be prioritised where the other requirements of this policy are met. This differs from the approach to industrial uses, such as storage and distribution, where increased operational impacts such as HGV trip generation mean that a more targeted, strategic focus within identified Green Belt industrial BLGs is required.

4.38    Appropriate benefits for local communities will relate to wider policy objectives, including potentially suitable ancillary uses and affordable workspace, access to affordable computing, support for local skills development, targeted environmental, transport or other infrastructure improvements. They will depend on local circumstances - but would help to mitigate impacts on affected communities and help to ensure that data centres play a positive role in local areas.

4.39    In urban design terms, benefits could be achieved from flexibility to enable future upgrades or reuse, where possible, and from mitigating the scale/massing of larger data centres to facilitate integration into their surroundings without compromising essential security requirements. 

4.40    Outside of suitable locations, development proposals should demonstrate the need, including for example proximity to (latency requirements of) specific end-users, and suitability in the specific location. This may need to be supported by infrastructure investment, for example the provision of a necessary substation or fibre connection.

This policy reflects a number of key considerations:

4.41    London is home to Europe’s largest data centre cluster. They support the growth of important data-driven sectors and AI. But this growth will only deliver real benefits for London if the infrastructure that enables it is clean, efficient and aligned with the Mayor’s climate goals. Therefore support for the growth of data centres in London will focus on clean, green and efficient facilities that embrace innovation and benefit Londoners.

4.42    Epping Forest SAC is known to experience adverse impacts of nitrate and ammonia deposition. Mitigations and modelling are focused on impacts derived from vehicular combustion engines and traffic congestion. They do not account for back-up generators and their testing regimes, therefore this policy is intended to minimise any such impacts.

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

4.43    London’s strategic town centres contain night-time economic activities that function at different scales and have different catchments. They have been classified, as set out in Annex B Town centre network, Table B1, into four broad categories:

• NT1 – Centres of international or national significance
• NT2 – Centres of regional or sub-regional significance
• NT3 – Centres with more than local significance
• NT4 – Centres with local significance

4.44    The Agent of Change principle protects existing and permitted activities from new sensitive development proposals in their vicinity. A technical assessment should detail the potential nuisance generated by relevant nearby night-time activities including on their access routes and set out design measures taken to avoid or minimise their impacts to acceptable levels for neighbours. This should also demonstrate the effectiveness of mitigations, which should be secured through planning conditions. Planning and licensing are separate but complementary regimes. Applicants should engage early with both services where proposals may affect existing pubs, music venues, cultural spaces, events or nearby noise sensitive development.

4.45    Policies should ensure inclusion, safety, and representation in the broader planning of our city for hours of darkness.

4.46    The loss of public houses; (both the specific building/establishment itself and the use) can have a detrimental effect on an area, particularly when they serve a social and cultural function. Where there is a risk of such detrimental impacts through the loss of valued public houses and their associated uses (such as restaurants and theatres), boroughs may also wish to consider the use of other tools such as nominations to designate as an Asset of Community Value (ACV) which can be a material planning consideration.

This policy reflects a number of key considerations:

4.47    Night-time uses are a key part of London’s economic and social functioning, and occur between 6pm and 6am. The night-time economy consists of nightlife activities and spaces for Londoners to participate in, as well as the wider range of economic operations and services that support the city’s role as a 24-hour city.

4.48    There will be housing growth across London in line with MBUL1. Planning for the growth in night-time and nightlife uses should recognise this context, and seek proportionate measures that would future-proof these uses and centres of night-time activity from sensitive uses.

4.49    The night-time economy and nightlife need to be protected and planned with due regard to equality considerations. Many Londoners — particularly women, LGBTQ+ people, disabled people, and night workers — experience barriers to accessing and participating in the city at night.

4.50    Given the broad nature of the national Agent of Change principle, this policy seeks to improve certainty and ensure a consistent approach across London to address challenges that existing and permitted night-time uses or clusters of those uses are facing in the context of the high/increasing development densities in many parts of London.

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

4.51    Boroughs are encouraged to assess and evaluate the supply and demand of cultural and creative uses and facilities making use of the Mayor’s Cultural Infrastructure Map and consider how and where cultural consumption and production spaces need to be promoted and protected including through site allocations to meet demand. This should take into account demographic changes, the potential to support placemaking and integration with wider networks.

4.52    Boroughs will be responsible for defining CEZs in their Local Plans and developing local policies to address and maintain the objectives of the Zone. Designation of CEZs will support the provision of suitable and affordable creative workspaces and associated users.

4.53    The protection of cultural uses and facilities benefits significantly from the application of the national Agent of Change principle, given that these may often by their nature generate noise and other impacts. See GLE4 Night-time economy for further details.

4.54    Where there is a risk of detrimental impacts through the loss of valued cultural facilities and uses, boroughs may also wish to consider the use of other tools such as nominations to designate such facilities as an Asset of Community Value which can be a material planning consideration.

4.55    In the replacement of cultural facilities, boroughs are encouraged to consider the importance of continuity of use, right of first refusal for the existing operator, the reprovision of appropriate space for the user group and that the space would be financially viable and sustainable for the operator to ensure that the cultural offer is not lost during redevelopment or unable to be realised post-development.

4.56    An Equalities Impact Assessment should be undertaken if the development proposal would lead to impacts on protected characteristics groups, and this should inform the reprovision of space. The Mayor’s Designing Space for Culture (2022) guidance should be considered to ensure that cultural spaces are designed fit for purpose, and the Mayor’s Securing Cultural Infrastructure and Workplace61 planning practice note should be used to help secure these provisions.

This policy reflects a number of key considerations:

4.57    Culture includes a range of uses and activities such as music and performance venues, visual arts, fashion, film, design, crafts and making, cinemas and museums. Culture, cultural venues and creative industries play a hugely important role in the economy and society – and nowhere more so than London. London’s rich cultural offer delivers significant economic and social benefits for London and its diverse communities.

4.58    However, London’s cultural venues and creative spaces face a range of threats, including the loss of premises to alternative uses and affordability. Finding new premises can be difficult due to the availability of appropriate space at an affordable price. The loss of cultural spaces can have a detrimental effect not just on an area but also more widely – they often form part of a locally or strategically important eco-system as well as serving a local community function.

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

4.59    A positive approach should be taken to supporting new serviced visitor accommodation in sustainable locations including the CAZ, town centres, high streets and other locations that are well-connected by public transport. It is recognised however, that in some localised instances, there can be tensions with other important land use objectives including housing supply and capacity for other employment uses. When considering whether capacity for other uses could be compromised by new serviced visitor accommodation, regard should be given to evidence in strategic and local assessments of demand and supply, local market conditions and development monitoring.

4.60    Serviced accommodation developments should include, as a minimum, accessible and inclusive design measures in line with Approved Document M: access to and use of buildings. To implement Part E of London Plan policy, wheelchair-accessible rooms should be designed in accordance with Figure 52 incorporating either Figure 30 or 33 of British Standard and BS 8300-2:2018 Design of an accessible and inclusive built environment Buildings Code of practice. Accessible rooms should be designed in accordance with the requirements of 19.2.1.2 of British Standard BS8300-2:2018.

This policy reflects a number of key considerations:

4.61    London is a world-leading visitor destination, and it is important to strengthen this role through enhancements to its attractions, visitor accommodation and other supporting infrastructure whilst spreading the economic and regeneration benefits of tourism to sustainable locations across the city in line with the London Growth Plan.

4.62    Research has shown that there is need for accessible hotel bedrooms to meet the needs of visitors with accessibility requirements. The provision of accessible transport, public realm, and sporting and cultural venues needs to be complemented by the availability of accessible serviced accommodation to ensure that all visitors can stay in London and experience its visitor offer.

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

4.63    Affordable workspace is defined here as workspace that is provided at rents maintained below the market rate for that space for a specific social, cultural, or economic development purpose. Plan-making authorities are encouraged to supplement their local plan policies, where appropriate, with a local affordable workspace strategy setting out more detailed matters to support implementation. Where permission is sought for flexible Class E development, decision-makers should apply the policy if the physical configuration and/or intended use of the space is expected to include Class E(g) uses.

4.64    When considering need, affordability and the appropriate average discount on rent in local plan policies and at scheme level, relevant factors may include the location; the availability and take-up of existing affordable workspace and other lower-cost secondary business space in the general vicinity; the type and quality of the affordable space; the intended provider; and end-users. Other factors that affect affordability for end-users, include service charges, fit-out costs, lease and rent structures and business rates. Flexibility for variable percentage levels of floorspace and variable percentage levels of rental discount should be supported where this addresses the needs of particular end-users and locations.

4.65    Off-site provision and payments in lieu may be particularly suitable for data centre and B8 storage or distribution development and to secure greater benefits such as affordable workspace contributions from new Class Eg(i) office development in prime locations in the CAZ (to be determined locally) or to support communal off-site affordable workspace hubs for example, including in town centres, Strategic Economic Clusters and CEZs (except those in Strategic Industrial Locations). On-site provision can help to sustain a mix of business, leisure or cultural uses which contribute to the character or function of an area including, for example, affordable independent food and beverage uses on the ground floor or office buildings to support active frontages in the CAZ. For research & development uses, on-site provision would typically be preferable to support shared use of facilities.

4.66    Affordable workspace should be secured through a planning obligation in perpetuity (or, where this is not feasible or viable, for a period of at least 15 years) and should include mechanisms to ensure its timely delivery. Flexibility on the amount of affordable workspace as a percentage of total proposed Class E(g), data centre and/or B8 storage or distribution use may be appropriate where this delivers greater benefits in terms of higher rates of discount on rent and/or a longer period of time for the affordable workspace provision.

4.67    A scheme-level affordable workspace strategy and management plan can set out how the affordable workspace will be delivered, configured (in relation to the open market space if on-site), fitted out for occupation, marketed, managed and monitored. Affordable workspace strategies and management plans should make clear the intended social, cultural or economic development purpose of the space, its contribution to wider social value and the intended beneficiaries or target groups.

4.68    Applicants are encouraged to engage with workspace providers at an early stage in the planning process to ensure that the space is configured, fitted out and managed efficiently. Arrangements for engaging a provider, how the space will be owned or leased and the process for review, changes in terms, disposal or termination, should be agreed with the local plan-making authority. Leases or transfers of space to workspace providers should be at rates that allow providers to manage effective workspace with sub-market rents, meeting the objectives of this policy over the affordable workspace term. The Mayor’s Securing Cultural Infrastructure and Workspace62 planning practice note provides guidance to help secure these provisions.

4.69    Where a site is to be used for temporary affordable workspace, this will generally be more appropriately secured through a temporary planning permission and must not prevent sites from being brought forward for development in a timely fashion. Parameters for any temporary or meanwhile use, particularly in relation to length of time for the temporary affordable workspace provision and associated obligations, should be established from the outset and agreed by all parties.

This policy reflects a number of key considerations:

4.70    The provision of workspace across London that is affordable for end-users for specific social, cultural, place-making or economic development purposes plays a key role in supporting a more inclusive economy. Policies to support its delivery across a range of uses are important to support the London Growth Plan ambitions and provide opportunities for Londoners to start-up and run a business.

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

4.71    Employers associated with new development are encouraged to work towards and achieve the objectives of the Mayor’s Good Work Standard63.

4.72    Planning obligations should be used to secure these arrangements and include, where appropriate, financial contributions towards local employment, skills, apprenticeship and training initiatives.

4.73    Employment and training targets included in planning obligations should be based on the number of new employment opportunities (measured on a full-time equivalent basis, in the construction and completed-use phases of development) and apprenticeship and training starts and completions. Take-up of employment and training by London’s out of work, under-employed and under-represented communities in the workforce in relevant sectors appropriate to the development should also be reflected in targets and monitoring. Evidence related to under-represented groups in the labour market can be sourced from the Inclusive Talent Strategy (ITS) and Get London Working Plan64 evidence base.

4.74    Reciprocal arrangements between local authorities are encouraged to open up opportunities, including those created via planning obligations, to residents from adjacent boroughs and across London to enable training to be completed and necessary experience for qualifications to be gained across multiple development sites.

This policy reflects a number of key considerations:

4.75    As set out in the London Growth Plan65 and the ITS66, skills are a key driver of growth and opportunity in London. However, the benefits of economic success are not shared evenly across the capital and some Londoners find it harder to gain genuine access to work than others. The difference in the proportions of people in employment between female and male Londoners is eight percentage points. The difference between disabled and non-disabled Londoners is 21 percentage points and the difference between White Londoners and Black, Asian and minority ethnic Londoners combined is 11 percentage points.

4.76    Good-quality employment is promoted through the Mayor’s Good Work Standard67. New developments provide employment opportunities for Londoners both during construction and once completed.

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

4.77    The London Plan is important and relevant to the determination of an application for development consent alongside the NPPF and relevant local plan policies, with the Airports National Policy Statement (ANPS) as the primary decision-making framework.

4.78    New heliports (except for emergency services) should be restricted, as should the shift in the mix of operations at other airports (such as the introduction of scheduled flights at airports not generally offering such flights) so as not to allow proliferation of aviation activity that does not contribute to strategic and sustainable economic growth.

4.79    Future regulatory and technology improvements have the potential to reduce an airport’s environmental footprint and can allow for more flights without any increase in environmental impacts. These and any other benefits from the aviation sector should be fairly shared with communities.

4.80    AAM is an emerging technology and understanding of its operations and implications will increase over time. The principles set out in policy provide an initial framework for considering any AAM-related proposals to minimise harm and maximise benefits.

4.81    Until any future legislation, AAM proposals can be considered sui-generis use class, and assessed on a case-by-case basis through the policy and any future guidance.

This policy reflects a number of key considerations:

4.82    London’s six main airports (Heathrow, Gatwick, Stansted, Luton, City and Southend) play a vital role in supporting London as a global city and engine for economic growth. Heathrow is classified as a strategic economic cluster in this Plan.

4.83    However, there can be significant environmental and health impacts associated with aviation from air pollution (including ultrafine particles); noise (both averaged over a period and from individual events); and greenhouse gas emissions (from flights and airport ground operations, and trips to and from the airport). The policies require that these environmental and health impacts should be fully assessed and effectively addressed.

4.84    Any expansion or increase in operations will also generate increased passenger, staff and/or freight traffic, which can lead to congestion and public transport crowding. As such, it is essential to improve public transport connectivity in order to reduce highway trips.

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

4.85    Safeguarded wharves can only be released from their safeguarding designation as part of a Safeguarded Wharves Review and subsequent revocation direction. The timing of these relative to Local Plan timetables may mean it is appropriate for such plans to reflect the latest review even if a subsequent safeguarding direction or revocation has yet to be issued.

4.86    Redevelopment proposals for other land uses on safeguarded wharves will need to be embedded in a plan-led process that can interface with this process or produce equivalently robust viability evidence. The scale and form of compensatory capacity assessed to be adequate would typically relate to functionality for handling ‘heavy goods’ freight (as opposed to that transportable onward by LGV) as well as volume. It should be within the same river sector (as defined in the GLA’s wharves evidence) which affects berth/access depths and property market areas. The Mayor has, and will continue to, keep the network of safeguarded wharves under regular review given many are in areas where land is highly desirable for a number of competing uses.

4.87    Alternative use of a boatyard site should only be accepted if the facilities of the site are re-provided at a site with equivalent or enhanced facilities in Greater London. Proposals for new strategic-scale boatyard sites, at an appropriate site within London, will be supported.

This policy reflects a number of key considerations:

4.88    Since 2000 a network of wharves in London has been subject to Safeguarding Directions issued by the Secretary of State for Housing, Communities and Local Government. The Safeguarding Directions mean that prior to the grant of planning permission on a Safeguarded Wharf, the Mayor must be consulted, with the London Plan protecting them for waterborne freight handling. This recognises the value of waterborne transport in removing lorries from roads and efficiently importing materials such as marine-won aggregates.

4.89    Evidence68  indicates that there will be a shortfall in wharf handling capacity over the London Plan period, making it important that capacity is protected, enhanced and promoted in order to meet identified need through this policy. Supporting infrastructure forms part of this protection and promotion, enabling vessels to be appropriately maintained close to where they are used with the efficiency benefits this brings.

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

4.90    Table 4.2 sets out a range of strategic targets which support aims to conserve resource, reduce waste and promote material reuse and recycling across London. On an individual application, these are helpful as benchmarks against which to assess the proportionality of what is proposed alongside wider justification, except on referable development where experience shows they should be more achievable.

4.91    All development proposals should be able to demonstrate some consideration of how they can advance circular economy objectives. Referable applications should provide a commitment and provide evidence that demonstrates how they will meet and where possible, exceed these targets. The actual performance against these targets should be reported by applicants as part of the post-completion reporting.

4.92    CES are required for referable applications only, although they may provide a useful framework for other proposals to consider circular economy opportunities.

Table 4.2: Strategic waste stream targets

4.93    The CES process should be iterative and help inform design. As such it is helpful for them to be prepared and submitted at pre-application stage for large-scale multi-phased development, developments that involve substantial demolition or masterplan-led schemes.

4.94    The circular economy principles that should be taken into account through demolition, construction and in-use phases are: 

• building in layers – ensuring that different parts of the building are accessible and can be maintained and replaced where necessary
• designing out waste – ensuring that waste reduction is planned in from project inception to completion
• designing for longevity
• designing for adaptability and flexibility
• designing for disassembly
• using systems, elements or materials that can be reused and recycled.

4.95    Development proposals should seek to manage as much waste on site as possible, and strategies which prioritise retention of existing structures should be robustly considered. Further guidance can be found on the GLA website70, which will be updated as appropriate to account for best practice.

4.96    There is a close relationship between the circular economy statement and the Whole Life Carbon Assessment. It should be ensured that where metrics/criteria overlap, the same are used in both assessments.

This policy reflects a number of key considerations:

4.97    While the importance of supporting a more circular economy is acknowledged in national policy, it is not set out how this should happen. This policy seeks to address that gap in the London context.

4.98    This is important in delivering the Mayor’s London Environment Strategy which includes objectives to support a transition to a circular economy, cut waste and boost recycling. The policy seeks to ensure that circular economy principles – and a whole life cycle view – are incorporated into the design of referable developments and that it supports the provision of circular economy infrastructure.

4.99    The Mayor views waste as a resource to be managed rather than a problem to export. Cutting waste and recovering more value from it through applying circular economy principles can have positive environmental and economic benefits for London, including but not limited to job creation, saving resources, increasing resource efficiency of London’s businesses, and helping to reduce carbon emissions.

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

4.100    A waste site is defined as either:

• a site whose primary activity is a waste-management operation that is authorised by the Environment Agency
• a site that has a lawful planning use as a waste site.

4.101    Strategic waste-management capacity is defined as sites that are critical to the management of London’s waste – such as dry mixed-recycling facilities; facilities that handle food waste; waste-transfer sites; or waste sites linked to wharves and railheads.

4.102    Environmentally appropriate capacity maximisation will largely be determined by separate nuisance legislation, but the evolving nature of a place should also be taken into account, given that the Agent of Change principle only applies to established use intensity.

4.103    Table 4.4 shows estimated projections of arisings for household, commercial and industrial waste for each borough, that underpin the overall apportioned quantums that should be planned for. In addition to apportioned waste, waste-planning authorities should ensure that their plans seek to meet the demand for waste streams that are not apportioned, and other infrastructure that could include, but is not limited to, hazardous waste, waste transfer sites and CD&E waste. The policy identifies locational criteria that should be considered in identifying the suitability of a proposed or potential waste site.

Table 4.3: Borough-level apportionments of household, commercial and industrial waste 2024-2050. Rounded to the nearest kilotonne

*Apportionment is per cent share of London’s total waste to be managed by borough

**NB. Totals do not add up to exactly 100 per cent or total tonnage due to rounding

Table 4.4: Forecast (kilotonnes) arisings of household, commercial and industrial waste by borough 2024-50

4.104    MDCs should cooperate with host boroughs to support them in meeting identified waste needs. Where appropriate, MDCs are encouraged to join the relevant waste planning group.

4.105    A borough’s ability to meet its apportioned waste needs in full is key to supporting a move towards overall waste net self-sufficiency. Waste plans should be responsive to strategic opportunities within their areas to optimise capacity on existing waste sites, or that help to unlock investment in developing new waste sites or meeting other needs. As such, any proposed release as part of a plan-led process should robustly demonstrate that the loss would not impact on the ability to meet this apportionment target directly (for the borough in question) or indirectly (where it may be a site of interest to other proximate boroughs to meet their apportionment needs). If it is confirmed that it is needed by another proximate borough, a borough in the same waste planning group and/or where there is an existing waste flow, then that should be reflected in the respective waste plan(s). Alternatively, should a waste site be proposed to be released, and a borough is not meeting its identified waste needs, then compensatory capacity is required to be secured through the plan.

4.106    Where required, compensatory capacity should be at the same level or higher within the waste hierarchy, and at least meet (and should exceed) the maximum achievable throughput of the site proposed to be lost. This should be provided prior to the loss of the existing waste site. If a site is not operational at the time that a planning application has been submitted, the maximum throughput over the five years preceding the closure should be used. Where a strategically important waste infrastructure is proposed to be lost, like-for-like compensatory capacity must be secured, i.e. the same waste infrastructure type/specialism, and at least the same capacity, as the waste site proposed to be lost. Where compensatory capacity is to be provided at an existing waste facility, then it should be demonstrated that this is in addition to any capacity that has been identified as meeting apportionment targets and/or waste needs for the borough in which the facility is located.

4.107     Compensatory capacity should be located as close as possible to the existing waste site, taking into account relevant planning designations, waste planning and property market areas, plus the wider spatial strategy approach of providing for some industrial land needs in the Green Belt. Consideration should also be given to the proximity principle, and transportation routes (including by road, rail and water), when identifying compensatory capacity. Where it is provided outside of a borough or waste plan area, the host borough should be notified to ensure that this is taken into account when reviewing waste plans and/or monitoring requirements.

4.108    New waste sites in appropriate locations, as identified in the policy, should be supported. Clear evidence should be provided on how the development proposal is delivering against the policy criteria. Applications should also set out whether the proposed waste site is contributing towards a borough’s apportionment target, and/or how it is otherwise meeting an identified waste need. For new waste sites coming forward, applicants are strongly encouraged to ensure that they achieve a carbon positive outcome. Where waste heat will be generated, proposals should take into account the GHR2 Low-cost low-carbon heat.

This policy reflects a number of key considerations:

4.109    As required by the National Planning Policy for Waste, the policy sets out the apportionment requirements for each of the London boroughs. The Mayor’s London Environment Strategy identifies that the Mayor wants to retain the economic value of London’s waste within London, and ensure that London can manage net 100 per cent of its waste within the city. To support achieving this, sufficient waste sites to meet apportionment requirements must be safeguarded through relevant development plan documents.

4.110    Acknowledging that waste streams are not confined by borough boundaries, and are influenced by market conditions and/or land availability, the policy encourages boroughs to pool requirements and, where necessary, share surplus capacity to achieve the London-wide ambition of waste self-sufficiency. To ensure that there is no loss in waste capacity whilst also allowing for flexibility for a waste site to be redeveloped (should it be required to meet other strategic objectives) e.g. housing, compensatory capacity must be provided to ensure that there is no loss in waste capacity.

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

4.111    All of London’s boroughs, together with the MDCs, are Mineral Planning Authorities (MPAs). On behalf of all London MPAs, in recent years, the Mayor has conducted the Local Aggregates Assessment (LAA), which regularly reviews the demand and supply of aggregates in the capital (now and into the foreseeable future) against London’s landbank requirements. As such, the most up-to-date version should be used to help boroughs in plan-making to ensure a steady and adequate supply of aggregates. Most of the policy relating to minerals and aggregates is contained in the NPPF; as such, this policy should be read in conjunction with it. There is also a close relationship with MBUL5 Sustainable Transport to enable London’s growth; GLE10 Safeguarded Wharves, which will support additional supply from imports; and GLE11 Circular Economy which supports the supply for secondary and recycled aggregates.

4.112    The Mayor will continue to work with boroughs, and the London Aggregates Working Party to prepare LAAs on behalf of all MPAs in London.

4.113    There is a moratorium on issuing any further hydraulic fracturing licences nationally, until compelling new evidence is provided which addresses the concerns relating to the prediction and management of induced seismic activity. This precautionary approach should be mirrored in respect of planning consents, given such risk is at odds with many planning considerations relating to health, the environment, housing capacity and protection of vital infrastructure and economic activity. The Mayor will actively monitor future changes in national policy and legislation with regard to fracking and will publish a formal statement of supersession when part B of this policy is no longer deemed necessary.

This policy reflects a number of key considerations:

4.114    There is a statutory requirement for MPAs to maintain landbanks (permitted reserves) of at least seven years for sand and gravel.

4.115    The apportionment targets are both justified and realistic, contributing to the national Managed Aggregate Supply System. Whilst only four boroughs have apportionments identified, other London boroughs are encouraged to bring forward supplies of aggregate.

4.116    London is in an area that is unlikely to be geologically suitable for fracking and is not within an area found to be commercially viable for fracking but has nonetheless had some licensing interest in the past. At present it is not possible to determine that fracking can be undertaken safely in the UK, due to the British Geological Society findings highlighting that the risk of possible seismic activity cannot be reliably predicted, as set out in Written Ministerial Statement from 2022, and reiterated in 2024. Given that risks would be magnified in London due to the density of population, economic activity and infrastructure, the extensive Source Protection Zones where groundwater must be protected, and the Mayor’s broader climate change obligations, it is clear that fracking is not compatible with the Mayor’s Good Growth objectives from a planning perspective.