5. Creating a greener, healthier, and resilient city

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

5.12    Clauses B-D apply to major developments.

5.13    EUI is the total energy (regulated and unregulated) used by a building over a year, measured in kWh/m2/yr. SHD is the amount of heat energy needed to heat a building over a year measured in kWh/m2/yr. The design of a building’s form, fabric and ventilation systems affect SHD.

5.14    Specific EUI targets have been set for the most common building uses that have broadly predictable energy consumption at planning stage. Uses not covered by the typologies set out in Part B(1) should still aim to design for efficiency in-use and submit information on EUI and SHD, with reference to industry benchmarks (such as Low Energy Transformation Initiative (LETI) and the UK Net Zero Carbon Building Standard (UKNZCBS) where relevant.

5.15    Design decisions to meet this policy should be considered alongside other relevant policies, such as GHR3 Whole-life-cycle-carbon which covers upfront embodied carbon and whole-life-cycle carbon (WLC); GHR4 Heat risk and GHR2 Low-cost low-carbon heat, which sets out requirements for determining the optimum heating strategy for a development. Information on how the elements of the policy have been addressed should be set out in an energy statement or proforma in line with the Energy Assessment Guidance alongside a low-carbon heat appraisal where required by GHR2.

5.16    Different policies may require use of a building’s roof area for different purposes, such as green roofs, amenity spaces, solar photo-voltaic (PV) and other building plant. Proposals should consider any overlapping roof-space needs and aim to optimise designs for maximum benefits. Where elements cannot be co-located, designs should prioritise measures that result in localised benefits e.g. green roofs that deliver identified local biodiversity priorities, or PV that delivers direct benefit to building occupiers.

5.17    To ensure that the policy is effective and that buildings perform as designed, post-construction, in-use energy monitoring data should be reported to the GLA for at least five years post occupation in line with energy monitoring guidance. Information reporting requirements for applications will be streamlined and set out in energy strategy guidance.

This policy reflects a number of key considerations:

5.18    The Mayor of London has specific legal duties in relation to climate change. The GLA Act 1999, (as amended by the GLA Act 2007 and Climate Change Act 2008) requires mayoral strategies to contribute to mitigating climate change (i.e., reducing greenhouse gas emissions).  London’s homes and workplaces are responsible for producing approximately two-thirds of the city’s greenhouse gas emissions. If London is to become a resilient, net-zero carbon city, new development must be as efficient as possible, also helping to ensure that buildings are fit for purpose over the lifetime of the development and reducing the future burden and cost of retrofit.

5.19    The London Plan therefore sets standards that go beyond those in national Building Regulations. In doing so the Mayor is cognisant of the context of the draft NPPF which seeks to standardise energy-efficiency requirements at the national level. However reverting to national standards would not only undermine progress towards net zero and the fulfilment of his legal duties, but would represent a worsening of the current position in London which seems untenable in the context of the climate challenges facing the city. London has consistently and effectively achieved higher standards than those set by national requirements74. 

5.20    Recognising the aims of the NPPF to streamline planning and reduce complexities and burdens on development (particularly given viability challenges), the London Plan policy sets standards (using industry recognised metrics) which are intended to apply London-wide - thereby avoiding a multiplicity of separate standards and a ratcheting up of requirements and costs on development. In weighing up the different objectives and considerations, the Plan has struck a careful balance between the need to reflect the particular context of London while aligning as far as possible with the intent of the NPPF.

5.21    This Plan sets a streamlined approach to carbon and energy and the effect of all related policies need to be considered in combination. The focus on very good energy-efficiency standards is considered to be particularly important for London given the technology-neutral approach to low-carbon low-cost heat, introduced in GHR2 and the removal of carbon offsetting policy.

5.22    Furthermore ensuring new development has low energy demand can also help to mitigate overall impacts of growth on energy infrastructure. This is particularly important given constraints on development being experienced at present levels of growth (e.g. in West London) and already significant increases in demand expected in any scenario as part of overall electrification.

5.23    The approach will also help to continue to drive innovation in sustainable design. Innovation of cities such as London not only provides essential experience and data, it also builds the demand and deployment of low carbon materials and products that help to drive the green economy – a key growth sector for the UK.

5.24    Use of the SHD and EUI metrics ensures that a building’s design prioritises minimising energy use and allows performance to be more accurately and easily compared against in-use performance. The policy sets both baseline and aspirational targets for SHD and EUI to allow flexibility to adapt to changes in modelling methodologies (e.g. to accommodate updates to Part L Building Regulations methodology) and technological solutions, and to set appropriate levels of ambition over the lifetime of the Plan.

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

5.25    The optimal heating choice will be affected by a combination of technology, development scale and location, and fabric efficiency. It comprises assessment of both communal versus individual systems, and different heat source technologies. The Low Carbon Heat Appraisal template draws these considerations together so that options are evaluated on a level playing field. The process is designed to interface with emerging national positions on heat networks, including the outputs of the government’s heat network zoning model which identifies areas where heat networks will be the lowest cost, low carbon option for many developments. If the national process mandates connection and that is what the development has proposed, a heat appraisal will not be required.

5.26    LPAs and, in time, Zone Coordination Bodies will be important intermediaries between heat users, heat network operators and heat generators, with their advice drawing on their LAEPs. Engagement with these bodies as per the requirement in MBUL4 should help inform the heating solutions that are appraised as well as infrastructure provision to best capture waste heat.

This policy reflects a number of key considerations:

5.27    The policy requirement for Low Carbon Heat Appraisals will establish the lowest-cost, lowest-carbon heating solution for individual proposals and help decision-makers determine whether individual or communal systems are most appropriate; and which heat source is best suited. This is intended to provide more flexibility and an objective approach to identifying the best solution.

5.28    The policy aligns London with the national approach; with the above applying unless a specific approach is mandated by the government heat network regulations. It also brings considerations around heating system and fabric efficiency together, given that these will affect running costs.

5.29    Development proposals that generate heat should be considered for their suitability to connect and contribute to local heat networks; the LPA (zone coordinator) is best placed to advise on this.

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

5.30    Where development takes place on sites with existing buildings and structures, there are opportunities to reduce embodied emissions by making use of those buildings where feasible. Retaining existing built structures for reuse and retrofit, in part or as a whole, should be prioritised before considering substantial demolition, as this is typically the lowest-carbon option. Significant retention and re-use of structures also reduces construction costs and can reduce the overall timescale for the development process.

5.31    These options, however, need to be considered in the context of ensuring that the site capacity is optimised in line with the requirements of MBUL2, Optimising the use of land and site capacity, and the delivery of suitable high quality commercial space commensurate with the strategic functioning of CAZ in line with PV2 Central Activities Zone, and should not be used as a means of blocking appropriate redevelopment.

5.32    This will also include assessment of the carbon associated with the energy a building uses over its lifetime and weighing up benefits of the improved energy-efficiency of a new building with the embodied carbon benefits of building retention.

5.33    Considerations of building retention should be set out as part of a pre-redevelopment audit that considers alternative development options for the site and aligns with requirements of GL11 Circular Economy and related WLC and CE guidance.

5.34    Alongside the submission of a WLC assessment, with data on how the upfront embodied carbon emissions targets have been met, applicants should provide information on how the building structure and other elements have been designed to minimise embodied carbon, the building form factor (exposed external surface area/GIA); any high-carbon design elements (such as basements, podiums, large cantilevers, non-typical structural interventions); and wall and superstructure proposals. It is also important to consider WLC emissions to inform design choices that may have an impact over the lifetime of the development.

5.35    Class E covers a wide range of uses and differing building typologies. The upfront embodied carbon targets are considered to be appropriate for the majority of schemes, but it is recognised that the baseline may be more challenging for some important economic uses on highly constrained sites. Applicants should demonstrate how the principles in policy GHR3 have been applied to minimise upfront embodied carbon and set out clear justification where targets are not met.

5.36    The approach to calculating upfront embodied carbon and WLC emissions, including what they should contain and how information should be reported, is set out in WLC guidance. In-use energy should be reported using the same methodology as is used for reporting operational emissions in line with GHR1 Energy-Efficiency.

This policy reflects a number of key considerations:

5.37    To fully capture a development’s carbon impact, a WLC approach is needed to capture its embodied emissions (i.e. those associated with raw material extraction, manufacture and transport of building materials and construction; emissions associated with maintenance, repair and replacement; and dismantling, demolition and eventual material disposal) alongside its operational emissions.

5.38    As the electricity grid decarbonises and operational emissions reduce, embodied carbon has become a larger proportion of the carbon emissions associated with the built environment. As such, tackling embodied carbon is relevant as part of the Mayor’s duties in relation to climate change. There is no national regulation or policy requirement for embodied carbon, however there are significant opportunities to influence embodied carbon through the design and planning process. Minimising upfront embodied carbon can lead to leaner, more efficient design and form; and lower carbon materials.

5.39    The London Plan has helped lead the way in setting standards that have subsequently informed the national approach in relation to climate change. Innovation of cities such as London not only provides essential experience and data; it also builds the demand and deployment of low-carbon materials and products that help to drive the green economy – a key growth sector for the UK.

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

5.40    Applicants should demonstrate how heat risk has been considered holistically for the whole of the development (including in public and communal spaces) to mitigate UHI impacts - for example by providing shaded areas, and additional green infrastructure or water spaces. Conditions should be used to secure these strategies and features where appropriate.

5.41    Minimising extraneous glazing to prevent overheating needs to be considered alongside other design objectives - including those related to views out and providing adequate daylight and sunlight to ensure good quality spaces for occupants – particularly in residential buildings. Glazing should also be designed to reduce overheating risks and minimise cooling loads in commercial buildings.

5.42    External shading can reduce overheating risk and can be provided in many forms and positions on the facade. It is expected that external shading of windows will be used on facades that receive direct sunlight. Shading needs to be functional and usable and allow windows to also deliver ventilation.  The appropriate choice of shading will depend on the orientation of the facade and overall building design. Vertical shadings (such as shutters) should be movable by the occupant to allow user control. On the upper storeys of tall buildings external shading may not be practical and other measures can be used to reduce solar gain.

5.43    Dynamic overheating modelling should be undertaken, and the results provided to demonstrate how passive measures have minimised internal overheating. The principle of using dynamic modelling is to better understand the risks of overheating (particularly in future climate scenarios) and mitigate them as far as possible through passive measures. This should include the potential contribution from design, layout, orientation, materials, shading and the incorporation of green infrastructure.

5.44    The Chartered Institution of Building Services Engineers (CIBSE) has produced guidance on assessing and mitigating overheating risk in new developments, which can also be applied to refurbishment projects. TM 59 (Design methodology for the assessment of overheating risk in homes) should be used for domestic developments and TM 52 (Limits of thermal comfort: avoiding overheating) should be used for non-domestic developments. In addition, TM 49 (Design summer years for London) guidance and datasets should also be used to ensure that all new development is designed for the climate it will experience over its design life. Further information will be provided in guidance on how these documents and datasets should be used.

5.45    This policy does not prevent the use of air conditioning in new buildings, and it is likely that it will need to be provided in heat-sensitive uses such as hospitals, care homes, and schools. Once passive measures have been prioritised, then lower energy and cost mechanical measures utilised, active cooling systems (such as air conditioning systems) should be considered after demonstrating need, using CIBSE overheating assessments. If this assessment does not show a need for active cooling but applicants want to include it, they should demonstrate all feasible passive measures have been incorporated into the design of the development, thereby minimising energy costs for residents/occupiers (and providing more comfortable temperatures for everyone – including those who might not be able to afford to use air conditioning). Active cooling measures should be designed to maximise efficiency and should aim to reuse the waste heat they produce. Designs of these systems should particularly avoid purging hot air close to residential buildings and amenity spaces.  The energy use associated with active cooling should be clearly set out.  Applications for residential development should also submit a Good Homes Alliance (GHA) ‘early stage overheating risk tool’ checklist.

This policy reflects a number of key considerations:

5.46    The urban heat island effect is a strategic matter for London and all types of development are affected by and can exacerbate it. Londoners have greater exposure and vulnerabilities related to heat and extreme weather scenarios and the health impacts (e.g heat-related hospital admissions resulting from future warming are disproportionately concentrated in London)77.

5.47    There is a need to consider the particular characteristics of London, for example in relation to density, building typologies, noise and air quality constraints, and ensure buildings are designed for the temperatures they are likely to experience over their lifetimes.

5.48    It is therefore important that this is addressed through design principles that can mitigate the impact of increasing urban temperatures and minimise energy demand from active cooling. The design stage of a development is the most important opportunity to reduce the risk of current and future overheating, by incorporating passive design measures to minimise the cost of active cooling for the occupier.

5.49    These design measures require little to no energy or cost to operate, whereas active cooling and air conditioning systems consume significant amounts of energy and under conventional operation, expel hot air outdoors, contributing further to the urban heat island effect as well as to energy demand (adding pressure on the electricity network as well as increasing costs for occupants).

5.50    Therefore, the policy ensures passive measures are incorporated into the building design to minimise the need for active cooling. Given the challenges, this policy is applied to all building uses (current Building Regulations on overheating only apply to residential uses). Furthermore, addressing overheating at the planning stage allows building design to be adjusted more effectively to maximise passive design measures. In contrast, leaving consideration of overheating to the building control stage limits the available solutions, as the building design is largely fixed by that point.

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

5.51    Evidence relevant to planning and prioritising surface-water flood risk mitigation will be found in a combination of strategic flood risk appraisals (including the Regional FRA 2026), the London Surface Water Strategy 2025, SuDS opportunity mapping81, forthcoming revised Critical Drainage Area mapping, Catchment Plans and Integrated Water Management Strategies82, Flood Asset Registers and related infrastructure plans. Spatial information regarding particular vulnerabilities – which may relate to protected characteristics or dwelling/infrastructure types – should also be drawn on. The latest available evidence and tools should be used, including information drawn from Rainwater Management Platform and updates to Flood Asset Registers. This information should be used to identify priority locations for interventions, and delivery pathways linked to planning. This will include off-site payment mechanisms as in many cases mitigation will be on highways and public land outside of individual sites.

5.52    In addition, it should be recognised that in areas of significant change (typically BLGs that may or may not align with catchments) there may be particular opportunities to address issues more extensively and holistically. This would be through a variety of planning-based levers achieving cumulative and in-combination benefits, by ensuring that they are delivered in an integrated manner. Even if the neighbourhood accounts for only part of a catchment, the wider catchment evidence referenced above should help inform interventions specified.

5.53    All development proposals should be contributing to tackling London’s surface-water flood risk. Responses to it should be set out in design and access statements where separate assessments are not required. Doing this in a manner consistent with an integrated water management approach means concurrently addressing flow pathways that may also affect fluvial and/or sewer flooding, and the management of drought and other growth-related water supply pressures. For instance, source control and attenuation may enable reuse or storage for later use as well as managed release, which in turn can result in eligibility for water company environmental incentive payments83.

5.54    For referable applications, expectations are higher – given opportunities linked to scale and/or location, with the Qbar metric specified for consistency reasons. While some onsite measures are expected in line with part B(1), it may not be possible to achieve the greenfield run-off rate wholly on site, and indeed it may not be preferable to do so. For example,  off-site green interventions may have wider benefits than onsite grey measures. Proposals should tie-in to wider area-based approaches and priorities, including where necessary through one-off off-site in-lieu contributions.

5.55    These should be calculated using the latest London-wide reference rate as published by the GLA; or at a locally-established rate agreed in consultation with the GLA and set out in a Local Plan. Where the full calculated offsetting contribution would not be viable, the level of contribution should be prioritised relative to other environmental off-site contributions in areas of priority intervention identified in Local Plans or post-2025 Critical Drainage Areas. The extent to which this enables the proposal to reach the greenfield runoff rate should be weighed in the planning balance.

5.56    For all schemes considering surface-water management the drainage hierarchy expresses a sequential preference for schemes that deliver multi-benefits, and for many a blue roof or minimal alterations to landscaping and urban greening should be an option if incorporated early in the design process84.  Where an additional off-site contribution is proposed to help address the policy requirement, this should be robustly justified in light of the site’s density, context, viability or wider strategic considerations (which may include how those contributions better deliver area-based approaches).

5.57    Any SuDs proposed should be detailed on the SuDS proforma so that it can be shared with relevant bodies including the Lead Local Flood Authority, and as built information should also be secured in order to build up an understanding of mitigations and assets overtime. Design should also account for water quality needs as per Policy GHR9 Clean and Healthy Waterways. It should also be noted that that policy addresses riverside aspects of fluvial flood where additional to NPPF provisions.

This policy reflects a number of key considerations:

5.58    Flood risk, especially from surface-water, is very significant in London and is not fully addressed by national policy. As demonstrated by the Regional Flood Risk Assessment, much of London’s existing infrastructure and many neighbourhoods are at risk, as well as new development. This risk is increasing with climate change and could also be expected to further increase with continued urbanisation.

5.59    This policy takes forward actions from the London Surface Water Strategy (2025) for development to reduce flood risk and improve resilience through sustainable drainage systems and flood-resilient design. It recognises that development designed well from the start can instead mitigate that risk and bring wider area benefits.  Greenfield runoff rate is the established metric by which adequacy of response is assessed.

5.60    While the NPPF assumes that on-site provision of SuDs is the route to addressing surface-water flood risk, this is not always compatible with London’s typical development plot, density, context and viability profile. It may also in some cases be strategically preferable to contribute to off-site green measures that have wider benefits where wholly on-site green solutions are not achievable. As such a mechanism for off-site contributions is set out, with a London Reference Rate per cubic metre of water storage established. This is derived from the SuDs Opportunity Mapping costings and consideration of a SuDs hierarchy consistent hypothetical approach.

5.61    Viability testing has indicated that, while a full offset payment may not be viable, some level of contribution could form part of the package of assumed developer contributions tested. Moreover, from a delivery perspective greater flexibility is to be supported, and impact-wise taking at least some opportunity to address surface-water flood risk is better than doing nothing.

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

5.62    Opportunities to increase London’s canopy cover should be considered strategically, e.g. where trees deliver the greatest co-benefits, including in/along streets and transport corridors, parks and open spaces, waterways, heat-vulnerable neighbourhoods, areas with low canopy cover and high deprivation, and areas with existing trees that are highly vulnerable to climate change (i.e. where there is a need for succession planting)89.

5.63    Tree planting contributes significantly to UGF scores, especially large-canopied species. Tree planting should be designed to integrate with SuDS, maximising rainwater capture and infiltration. Designing tree pits to capture rainwater can reduce the need for separate drainage infrastructure.  The retention of trees of value reduces the total number of biodiversity units to be delivered in meeting BNG requirements, while new tree planting contributes to onsite units.

5.64    Planning conditions or S106 agreements may be used to secure establishment of any new trees and adequate monitoring and replacement of failures during the establishment period (at least three years).

5.65    Adequate replacement, in cases where full on-site equivalence is demonstrably unachievable, may be considered through partial on-site replacement supplemented by off-site planting in locations identified by the borough (e.g. in the vicinity of the development, heat vulnerable neighbourhoods, deficiency areas for canopy cover/access to nature, and/or a financial contribution secured through a planning obligation (s106) to fund strategic planting, establishment and early-years maintenance that achieves equivalent value to the loss identified through the valuation.

5.66    SINCs comprise:

• Sites of Metropolitan Importance – strategically-important conservation sites for London
• Sites of Borough Importance – sites that support habitats or species of value at the borough level
• Sites of Local Importance – sites that are important for the provision of access to nature at the neighbourhood level.

5.67    Several Sites of Metropolitan Importance also have statutory nature conservation designations. The level of protection afforded to SINCs should be commensurate with their status and the contribution they make to wider ecological networks. When undertaking comprehensive reviews of SINCs across a borough, or when identifying or amending Sites of Metropolitan Importance, boroughs should follow principles set out in the GLA’s SINC advice note90.

5.68    The potential impact of development proposals that are adjacent to or near SINCs could include indirect effects to the site, such as noise, shading or lighting. There may be opportunities for new development to contribute to enhancing the nature conservation value of an adjacent SINC or green corridor by, for example, sympathetic landscaping that provides complementary habitat.

5.69    The LGIF and London LNRS provide an overarching framework and evidence base for London’s green infrastructure; providing spatial data across the full range of benefits that green infrastructure provides. The LNRS has informed the nature recovery element of the LGIF. The two should be considered alongside each other to fully understand the types of opportunities for nature. Plan-making authorities should make use of these as part of the evidence base for green and blue infrastructure planning and designations, including consideration of how development can contribute to delivering LNRS priorities beyond those mapped on the Local Habitat Map. Planning applicants should use this information to guide habitat creation proposals.

5.70    LNRS are spatial plans (mandated across England) designed to restore biodiversity by identifying local priorities (within the Statement of Biodiversity Priorities) and mapping key locations for nature enhancement (within the Local Habitat Map). The priorities are the 'what' and 'how', while the Local Habitat Map is the 'where'. The key layers of the Local Habitat Map (as set out by national guidance) are the areas of particular importance for biodiversity (known as ‘APIB’), and areas that could become of importance for biodiversity (known as 'ACB'). BNG units delivered in either area will be subject to the 'strategic significance' uplift.

5.71    Proposals for green infrastructure and habitat creation should consider future climate scenarios in their design and species choice, for instance by including planting that is more resilient to heatwaves and drought.

5.72    London’s water spaces make up an important set of habitats in London. GHR9 Clean and Healthy Waterways addresses the protection of water spaces, with a particular priority for improving and restoring them. The habitat value of waterways is a key element of their future management.

5.73    The London Geodiversity Partnership91 provides information about sites of geological value to help identify and conserve London’s geodiversity.

This policy reflects a number of key considerations:

5.74    London has a wide variety of important wildlife habitats, including a number of sites that have national and international protection. These habitats range from semi-natural features such as chalk grasslands and ancient woodlands to more urban habitats such as reservoirs and vegetated railway corridors. The connections between protected sites – green corridors – are often critical in helping to sustain wildlife populations that would be vulnerable if they were confined to isolated areas of habitat.

5.75    The wildlife value of these sites needs to be protected and appropriate maintenance regimes established to maintain and enhance the wildlife value of sites, recognising the additional pressure some sites may experience due to London’s projected growth.

5.76    Development can bring opportunities – for example by securing, where appropriate, Improved access to wildlife sites in a way that benefits both people and wildlife, so that Londoners can better experience and appreciate the natural environment within the city.

5.77    Geodiversity is a fundamental cornerstone of Londoners’ everyday lives. Geology affects where we build, how we construct buildings and how we deliver associated services. It influences the design and layout of infrastructure, filters our drinking water and underpins the landscape around us. Geodiversity cannot be replaced or recreated (other than on geological timescales).

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

5.78    Plan-making authorities should use evidence, including the strategic level LGIF and LNRS and local green infrastructure strategies, to inform the identification and designation of GI assets and to identify where green infrastructure interventions can address priority environmental and social needs. Developers may also refer to this evidence where it has not yet been incorporated into Local Plans.

5.79    This should include opportunities for enhancements to existing infrastructure, better connections between infrastructure to build networks; and the development and designation of new assets.

5.80    Planning conditions or planning obligations may be used to secure management and maintenance of any proposed greening.

5.81    Applicants should use London Plan greening factors and methodology to calculate factor scores. The UGF for a proposed development is calculated in the following way: 
(Factor A x Area) + (Factor B x Area) + (Factor C x Area) etc. divided by Total Site Area.

5.82    A worked example: an office development with a 600 sqm footprint on a site of 1,000 sqm including a 600 sqm green roof, 250 sqm car parking, 100 sqm open water and 50 sqm of amenity grassland would score the following: 

(0.7 x 600) + (0.0 x 250) + (1 x 100) + (0.4 x 50) / 1000 = 0.54

5.83    Existing green cover retained on site should count towards developments meeting the target scores, based on the factors set out in Table 5.1.

5.84    In addition to a landscape masterplan, UGF calculations should be submitted as a separate stand-alone drawing and should include:

1. a UGF masterplan that is colour-coded according to surface-cover type
2. a completed UGF table.

5.85    UGF targets establish the overall quantity and quality of greening that should be provided, applicants should use relevant information in the LGIF, London’s LNRS and local green infrastructure strategies and nature recovery plans where available to identify which types of greening are particularly relevant to addressing green infrastructure priorities in the locality of the development site. For example, maximising broad-canopy trees to provide shading in areas where that experience higher heat risk, or using green sustainable drainage measures to address flood risk.

5.86    UGF and BNG approaches are complementary, and greening included as part of development will also count towards BNG requirements. These should be assessed and reported separately in accordance with relevant GLA and government guidance.

5.87    Applicants should ensure that any use of green walls complies with relevant fire safety regulations and MBUL10 Security and safety.

Table 5.1: Urban Greening Factor

For definitions see Urban Greening Factor guidance94. 

This policy reflects a number of key considerations:

5.88    A green infrastructure approach recognises that the network of green and blue spaces, street trees, green roofs and other major assets such as natural or semi-natural drainage features must be planned, designed and managed in an integrated way.

5.89    The policy uses appropriate evidence to identify green infrastructure assets to protect along with areas for enhancement and seeks to secure multi-functional urban greening of sites and buildings.

5.90    The UGF is a tool used to evaluate the quality and quantity of natural features proposed as part of a development application, such as planting, waterbodies and green roofs, collectively referred to as urban greening. It enables developments to demonstrate how they have included urban greening as a fundamental element of site and building design in line with wider environmental objectives, notably those concerned with climate change resilience.

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

5.91    Local plan public open-space designations may be updated to clarify which areas meet the AGS definition set out in the glossary, while civic spaces and other areas of public realm may still retain designation as public open space.

5.92    Natural England’s Green Infrastructure Framework will be a useful starting point for considering whether local standards are needed and if so how to derive them96. The GLA will also work to support boroughs with this during plan-making. Local AGS standards may apply not only to residential, but also to other major uses, such as offices, healthcare and visitor facilities that significantly increase daytime or residential populations.

5.93    Quantity standards for AGS should be separate to requirements for dedicated play-space (see HN8 Housing design) and sports provision, although all such types of infrastructure may often be delivered in a spatially integrated manner. Where a borough includes land within the zone of influence of a designated Special Area of Conservation, such as Epping Forest, quantity standards, site allocation specifications and off-site contribution rates may require adjustments to account for the need for Suitable Alternative Natural Greenspace (SANGs). It may be particularly important to maximise areas of semi-natural greenspace and consider connections to existing SANGS where appropriate.

5.94    In places with limited opportunities for new recreational AGS, enhancements relevant to this policy could include other forms of multi-benefit greening, such as SuDS, street trees, or planting and other improvements to walking and cycling routes or existing (less green) public open space. Improvements to the connectivity of green spaces (including cross-boundary) may also be beneficial, which can also support low cost active travel, offer places for rest and contribute to wildlife corridors. This may partly be achieved through the Healthy Streets approach set out in Policy MBUL9 or as part of the regional parks opportunities highlighted on the environment sub key diagram. The LGIF may help identify local priority intervention types.

5.95    Table 5.2 sets out categories of AGS according to scale and establishes standardised proximity criteria for boroughs to use when assessing deficiency, grouping AGS into two Area of Deficiency (AoD) categories; walkable and strategic. AGS that is of metropolitan significance, has the potential to meet the Metropolitan Open Space (MOL) criteria and so may be designated accordingly. Determination of which designation is the most suitable for a site will depend on its characteristics and significance (see PV6 Metropolitan Open Land (MOL)). Many publicly accessible MOL sites will contribute towards a local area’s open space needs and should be incorporated into calculations for AoD. Figure 5.2 illustrates the current extent of these areas, which will change over time as new spaces are created, public access is expanded or data is improved, hence the requirement to update these during plan-preparation.

Table 5.2: Public green space categories and access criteria

This policy reflects a number of key considerations:

5.96    All types of green space are valuable in connecting Londoners with nature; some are more accessible than others, and their size and catchment varies considerably. A focus upon AGS reflects the critical value that access to nature plays for Londoners’ health and wellbeing.

5.97    The policy is designed to provide a London-wide consistent approach to improving (and monitoring) AGS provision while allowing for some local variation as per the NPPF. This should help to make expectations clearer for developers, while acknowledging the significant amount of cross-boundary provision and use in London, and more limited scope for certain types of provision in some areas relative to others.  The focus is on AGS rather than public open space more generally, due to the importance of urban greening as part of Good Growth objectives (such as those linked to health, resilience and wider environmental objectives). Ensuring appropriate long term management is essential to maintain these benefits and limit conflicts between different uses.

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

5.98    The term ‘waterways’ refers to the River Thames, its tributary and other rivers and canals, and also to other water spaces including docks, lakes ponds and reservoirs.

5.99     The emerging Clean and Healthy Waterways Plan has identified strategic locations for water quality and accessibility improvements, which are reflected within the environmental opportunity areas in the London Plan.

5.100     Setting boundaries for the Thames Policy area should be done in consultation with neighbouring boroughs, including those across the river. When defining boundaries, consideration should be given to the following criteria:

• proximity to the Thames
• clear visual links between areas, buildings and river
• specific geographical features such as main roads, railway lines and hedges
• the whole curtilage of properties or sites adjacent to the Thames
• areas and buildings whose functions relate or link to the Thames
• areas and buildings that have an historic, archaeological or cultural association with the Thames

5.101    The Simple Index Approach should be used to inform the design of the SuDS strategy for the site, (required as part of compliance with GHR5 Flood risk and drainage and national policy) ensuring that this component meets the pollutant hazard levels of the site.

5.102    Where possible, development proposals should seek to improve and expand the Thames Path and towpaths; improve connections to slipways and historic steps; and develop better linkages to the transport network and water sports centres. With improved access however, impact on habitats and wildlife may need more deliberate management and mitigation.

5.103    To protect the openness of waterways, they should not be used as an extension of developable land in London, nor should parts be a continuous line of moored craft.  Infrastructure that supports moorings and related active use of the water may include boatyards for the maintenance of houseboats and other vessels.

This policy reflects a number of key considerations:

5.104    London’s waterways are multi-functional assets that provide a range of environmental, economic and health and wellbeing benefits for Londoners, as well as contributing to London’s character and identity. However, London’s waterways have been neglected and damaged by pollution, with access and enjoyment of them constrained by multiple factors.

5.105    As London’s waterways cross borough boundaries, the policy seeks to ensure that they are managed strategically, taking into account relevant Plans and Strategies. In particular, the policy embeds the planning levers of the Mayor’s Clean and Healthy Waterways plan and the Joint Thames Strategies, which address the issues in a holistic way, also seeking to make waterways climate resilient.

5.106    London’s waterways are also home to some Londoners. The policy sets the parameters in which residential development on waterways should be considered.

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

5.107    The Mayor has an adopted Environment Strategy which includes objectives for air quality in London. In line with that Strategy, where this policy refers to poor air quality this is defined in relation to the fourth interim WHO guideline for PM2.5 (10ug/m3 ) to be achieved by 2030 and national air quality objectives for PM10 and NO298. In light of WHO Guidelines 2024, London’s Mayoral ambition is to continue to reduce harmful emissions and exposure to them beyond current statutory air quality objectives so as to reduce the risk of harm to human health and protected habitats.

5.108    Where the policy refers to “areas of concern”, these include Air Quality Management Areas (AQMAs), which are defined in relation to national legal limits (and by agreement may also reflect the higher (Mayoral) WHO air quality guidelines where national limits are now met); and the CAZ. Additional areas of concern may be identified by Local Plans. These may relate to habitat vulnerabilities to air pollutant deposition at particular levels (for example in Epping Forest SAC) and may also include areas where current pollution levels are within 5 per cent of national limits of WHO air quality guidelines.

5.109    The evidence to review in plan-making includes (but is not limited to) the latest London Atmospheric Emissions Inventory, Habitats Regulations Assessments, and information on health inequalities relating to air quality. Cumulative and in-combination effects of proposed and recent development should also be considered, as should opportunities relating to the scale of development in a particular area.  Vulnerability and exposure can also be affected by particular pollution pathways, street canyon effects and habitat sensitivities as well as sensitivities of particular populations or communities including those with protected characteristics.

5.110    As part of the work to identify prioritised interventions in response to these areas of concern, TfL and the GLA will work with boroughs on mitigation strategies to ensure that new housing and employment development planned does not result in adverse air quality impacts on Epping Forest SAC alone or in combination with other plans and projects.

5.111    In areas of concern, a preliminary AQA should draw on similar, up-to-date evidence. It should identify the most significant sources of air pollution in the area, and likelihood of it being worsened by the development individually or in combination with others. Assessment of the likely air-quality impacts of a scheme should reflect fixed plant such as boilers and emergency generators, as well as expected construction and transport-related sources, and all relevant pollutants emitted. Industrial, waste and other working sites may additionally need to include assessments of on-site vehicles and mobile machinery.

5.112    Further assessments should then be carried out as the design evolves, iteratively in response to this evidence, to ensure that impacts from emissions are prevented or minimised as far as possible. The expected effect of any proposed mitigation measures and any remaining emissions should be fully quantified in order to assess their significance in relation to policy aims. The minimum expectation is that development must not cause new exceedances of national limits and , in locations where national limits are currently exceeded, must not delay the date on which those limits will be attained. Mitigation measures should be secured as part of the consent, and be in place prior to occupation.

5.113    Responses to poor air quality sought by policies and/or incorporated in proposals should be informed by plan-making, evidence-based assessment and good practice guidance99. They may relate to design transport and access, suitable uses/use mix, landscaping and management/operational practices. In some cases, they may involve retrofit of existing buildings such as schools and hospitals to address exposure, (e.g. through the installation of air filters), which may be funded by developer contributions, or otherwise secured by the consent process. Development proposals’ responses should reflect all approaches and prioritised interventions established in the Local Plan.

5.114    Operational emissions impacts can be expected to arise from the introduction of new motor vehicle parking, combustion plant (e.g. gas-fired boilers) or where the proposal is likely to generate increases in motor vehicle movements. It will be for the LPA to determine where no operational emissions impacts are expected and to confirm whether an AQN assessment is needed, and its scope.

5.115    An AQN development is one that, at least, meets the most up-to-date AQN benchmarks100. AQN Assessments should be prepared in accordance with latest guidance and may form part of wider AQAs where those are needed. Achieving AQN in most cases will serve to demonstrate that the development is minimising emissions in line with policy aims. However, where relevant other emissions impacts will need to be addressed as part of an AQA (where required) such as those from HGV movements and construction.

5.116    Emissions from backup generators should be included as part of AQN assessments, where these are not used exclusively to provide power during emergencies and for life-safety purposes. An ‘emergency’ is any situation in which a generator is required to maintain the continuous operation of essential systems due to the failure or interruption of the primary electricity supply or to ensure life-safety. In relation to emissions standards for generators, retrofitting with emissions abatement technologies is permitted, provided the technologies are either recognised by the Energy Saving Trust101 for NRMM engines or demonstrably achieve equivalent reductions for stationary plant. Alternative but related requirements for data centre back-up generators are set out in GLE3 Data Centres.

5.117    Where a development does not as originally proposed achieve AQN, additional mitigation measures will be required in line with the AQN guidance. Further measures necessary to demonstrate additionality where stipulated, (criterion E) are suggested in the Air Quality Positive guidance and should be documented102. Reference to strategic interventions means policies and plans implemented by the Mayor, TfL, or the government that have beneficial air-quality impacts by managing vehicular use, mode choice and energy use.

5.118    Offsetting payments should only be considered acceptable in situations where on-site mitigation measures have been explored, exhausted and otherwise found to be insufficient or unachievable. Calculations should follow the formula set out in guidance, with funds raised expected to be ring-fenced to be used for priority air quality improvements identified in local plans and related schemes.

This policy reflects a number of key considerations:

5.119    The policy sets out a strategic approach to air quality improvement across London, in light of considerable health impacts and inequalities that arise from poor air quality and the Mayor’s ambitions to tackle this robustly as originally established by the London Environment Strategy. These ambitions and approach are underpinned by the WHO air quality guidelines which are an evidence-based assessment which identify harm to human health at levels below existing national air quality objective levels. However the approach is also necessary because of expected significant effects associated with growth on habitats of international significance (notably Epping Forest SAC), which may be harmed by nitrate and ammonia deposition primarily from increased transport movements. These must be reliably mitigated to ensure compliance with the Habitats Regulations.

5.120    The approach identifies areas of concern and development types that present most risk to emissions reduction. The AQN approach seeks to address expected emissions to minimise that risk to a level compatible with air quality objectives, while area-based approaches and the additional ask of larger (EIA-able) schemes (which is what is known as the ‘Air Quality Positive’ approach) seeks to work with both the opportunity and risk of larger developments to further minimise emissions and reduce cumulative negative impacts. The broader AQA requirement additionally addresses impacts from sources such as HGVs and construction.

5.121    As a London-wide approach it supports certainty over expectations for developers and magnifies overall impact, coordinating management across different AQMAs while reflecting their consistent objectives. The overall approach is now well-established, with 75 per cent of required developments presenting as AQN at submission, helping to secure, with the ULEZ and overall technological change, national air quality objectives being achieved in most places. Given this, and the evidence from WHO Air Quality Guidelines that adverse health impacts occur at levels below existing national air-quality objectives, together with the Mayor’s duty to address health inequalities through the London Plan, it is considered  that a policy seeking to reduce emissions is justified. Additional policy requirements which are already partially required as part of the NRMM LEZ are cost-effectively incorporated when considered at an early design stage, as the policy requires; and addresses harmful pollution spikes associated with construction sites and back-up generator testing.

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

Cycle parking

5.122    For calculating the cycle parking non-residential requirement where the number of staff is not known at the time of application, reference could be made to the density matrix of the ‘Employment Density Guide’112 or other evidence. For offices, however, one member of staff per 15 sqm of net internal area should be assumed, which is consistent with the London Employment Sites Database 2024113 assumption of one member of staff per 10 square metres at a 66 per cent mid-week peak utilisation rate. Where the mix of E class uses is not known, the most likely mix of office, retail and light industrial uses could be used for the calculation.

5.123    Whether it would be acceptable to provide less than the required minimum parking should be considered in the balance of site constraints and impacts on design, such as the following:

• Avoiding the need for a basement (or additional basement level) or other design requirements that materially improve viability
• A small building footprint relative to overall floorspace
• The density or scale of development generates a very large requirement, and this has a disproportionate effect on requiring what could otherwise be lettable or saleable floorspace.

Car parking

5.124    Provision for car clubs at SAM 4 and below should be considered with reference to SAM scores, Public Transport Access Levels (PTAL) and any other appropriate local evidence of connectivity. The level and design of provision should not add to the vehicle dominance of street environments or undermine the effectiveness of car ‘lite’ development.

5.125    The Department for Transport’s ‘Inclusive Mobility’ guidance114, guidance on building regulations115 and ‘BS 8300-1’116 set out guidance on the design of disabled persons’ parking.

Cycle parking

5.126    Quality cycle parking enables cycle ownership, which is a key factor in enabling and encouraging more Londoners to cycle, alongside other models e.g. cycle hire. This contributes to the increased use of sustainable modes of transport, and the core objective of the Mayor’s Transport Strategy to support mode shift. It also contributes to Healthy Streets indicators, the health of Londoners and a range of other objectives. The minimum standards provide for current ownership and use, while also allowing for room for growth in cycling.

Car parking

5.127    As London continues to grow, restrictions on car parking are required to limit car use so that congestion on London’s roads can be managed. It is also a fundamental requirement for making the best use of land and accommodating more homes and growth than would otherwise be possible.