6. Place visions and place-based approaches

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

6.8    Helping to realise the capacity associated with BFOAs will typically require a plan-led approach that will help provide the necessary coordination. In the absence of this being achieved through Local Plans, OAPFs can provide it depending on the circumstances and development needs of each BFOA.

6.9    The Mayor may work with boroughs to identify new BFOAs linked to emerging strategic transport projects; this may include candidate brownfield BLGs identified on the 20-year key diagram.

This policy reflects a number of key considerations:

6.10    BFOAs are identified as locations with significant development capacity to accommodate new housing, commercial development and infrastructure (of all types), linked to existing (or potential improvements in) public transport connectivity and capacity. They are areas that face long-standing barriers to development where coordinated interventions are required to unlock delivery at scale. Where other designations may better suit circumstances of areas, the plan avoids duplication of multiple designations.

6.11    Annex E identifies the key strategic issues and opportunities that will need to be addressed in BFOAs, reflecting extensive collaborative work with boroughs and other stakeholder feedback. Given the intervention required, there may be particular opportunities for growth to be managed in an exemplar way, which should also help with place-making and creating value uplifts.  

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

6.12    The NIOD is geographically separate from the CAZ but it is treated as part of the CAZ in London Plan policy. The CAZ is an appropriate location for growth and is now distinguished between core CAZ and mixed CAZ areas. Core CAZ contains potential for growth in a diverse range of locations including the City of London and the West End, all the economic clusters and transformational gateways identified in Figure 6.2, areas around the majority of other public transport stations and interchanges, and core parts of the NIOD. 

6.13    Mixed CAZ comprises areas where new CAZ strategic functions are promoted alongside new residential development to create areas that are more mixed commercial and residential in character, complemented by social infrastructure. Core CAZ is the default designation in the CAZ and the NIOD unless an area is identified as a mixed CAZ area (having regard to the indicative mixed CAZ areas identified in figure 6.2 or as refined in local plans as appropriate) or a predominantly residential area or residential street. 

6.14    The CAZ contains clusters of night-time economic activity including the internationally significant West End (including Soho, Theatreland, Covent Garden, Piccadilly and Charing Cross Road), the South Bank, Waterloo and Bankside, South Kensington, the Barbican and Shoreditch (See Figure 6.2).

6.15    Plan-making authorities should take a positive approach to supporting growth in the night-time economy in these clusters and more generally across core CAZ (in particular) and mixed CAZ areas complemented by the national agent of change principle and promote an integrated approach to planning and licensing, transport, out-of-hours servicing and deliveries, safety and security, and environmental and cleansing services.

6.16    Al fresco hospitality is encouraged in the CAZ and town centres where appropriate, in line with Policy MBUL9 (Healthy Streets and Public Realm).

This policy reflects a number of key considerations: 

6.17 the CAZ is the vibrant heart and globally-iconic core of London. The density, scale and mix of business functions and activities in the CAZ and the NIOD are unique. The agglomerations of activity are nationally and internationally significant and are underpinned by the unparalleled connectivity provided by public transport, walking and cycling networks. This results in exceptional levels of productivity and economic output, providing London-wide and national benefits.

6.18 in core CAZ areas, CAZ strategic functions are prioritised relative to new residential development. This is to ensure that the agglomerations of CAZ strategic functions and their contributions to the London and UK economy are sustained and enhanced. Mixed CAZ areas are typically more mixed-use in character and CAZ policy recognises their potential to accommodate higher amounts of housing alongside CAZ strategic functions compared to Core CAZ areas. 
 

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

6.19 For the purposes of this policy, town centre uses include main town centre uses defined in the NPPF117 (except drive-through uses) and other complementary uses such as creative and light industrial workspace, research and development uses and social infrastructure. The national sequential test and impact assessments apply to main town centre uses only.

6.20 London’s town centres and high streets currently perform a range of different roles and functions in the wider town centre network (see Figure 6.3 and Annex B Town Centre Network Table B1). The network provides a framework for sustainable economic growth and access for London’s diverse communities to employment, goods, services, culture and leisure by public transport and active travel modes.          

6.21    Changes to the roles and functions of town centres at major and district centre level may occur organically through new development and/or through local plan-led approaches. Changes to town centre classifications at metropolitan and international level should be coordinated through the London Plan or through engagement with the Mayor.  Future potential town centres (see Annex B Table B2) include locations that are not currently functioning as a town centre but have the potential to evolve and become a genuine mixed-use town centre in the future supported by Local Plan policies.

6.22    London contains more than 600 high streets of which many are located outside of designated town centres. Some of these high streets are designated as local and neighbourhood centres in local plans. Plan-making authorities should review the high streets identified by the GLA and consider designating them in policies maps as high streets, local or neighbourhood centres and develop local planning policies for these areas. TfL’s SAM may serve as a useful tool for considering areas that are currently poorly served by local shops and services.

6.23    London’s strategic town centres play different roles in the night-time economy (see Annex B, and Tables B1 and B2) ranging from international to local significance. Plan-making authorities should take a positive approach to supporting growth in the night-time economy within town centres and high streets, complemented by the Agent of Change principle and promote an integrated approach to planning and licensing, out-of-hours servicing and deliveries, safety and security, and environmental and cleansing services.

6.24    To support the implementation of part E of this policy, the functional capacity of markets includes the number of stalls and/or units, usable floorspace and trading days. Operational capacity includes storage, utilities, waste and servicing. The footprint includes both functional and operational capacity.

6.25    Strategic and local partnership approaches should be supported and encouraged to develop strong, resilient and adaptable town centres and high streets, fulfilling their potential to accommodate economic, cultural and social infrastructure and housing development, and facilitating land assembly where appropriate. These approaches may be in the form of public/private partnerships, town centre management, business associations, neighbourhood forums, trader associations and Business Improvement Districts and should be inclusive and representative of the local community.

This policy reflects a number of key considerations:

6.26    Town centres and high streets are a central feature of London’s economic and civic life providing opportunities for employment and business start-up and promoting community and cultural exchange. High streets are one of London’s most characteristic urban features and many town centres contain important cultural and heritage assets. To continue to thrive they will need to evolve and diversify in response to current and future economic trends, technological advances, consumer behaviours, the imperative to deliver more housing and the development of the 24-hour city.

6.27    Markets play a valuable economic, social and cultural role providing choice and access to a range of food and goods for London’s diverse ethnic communities. They contribute to the vitality, character and heritage of town centres, high streets and the CAZ and provide opportunities for employment and for businesses to start-up. Several markets are of strategic importance, such as those at Portobello Road, Borough, Brick Lane, Columbia Road and Camden for example, and offer significant attractions for Londoners and visitors to the capital.

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

6.28    Plan-making authorities will play a key role in preparing local planning policies to support growth (informed by market evidence of demand) and ensure that strategic economic clusters complement nearby town centres and are well connected by public transport. Improvements to connectivity may be required for some strategic economic clusters that are currently not well served by public transport. 

6.29    Planning also has a role to play in supporting the growth of wider economic corridors – by  facilitating development in appropriate locations, the provision of infrastructure and cross-boundary coordination. Strategic economic corridors include:

• UK Innovation Corridor: anchored in the Knowledge Quarter, and extending north and east towards Cambridge, Harlow and Stevenage (outside London)
• West Tech Corridor: anchored in White City, and extending north and west through Old Oak and Park Royal, Ealing,  and towards Heathrow and Hillingdon
• Thames Estuary Production Corridor: anchored in the Queen Elizabeth Olympic Park and following the River Thames through east London, Essex and Kent.

This policy reflects a number of key considerations:

6.30    London contains numerous clusters (and corridors) of economic activity providing space for a range of specialist economic sectors including those identified in the London Growth Plan.

6.31    Most of these are either within the CAZ, NIOD, town centres or SILs, which are covered by other policies in this Plan (See PV2, PV3 or PV5). 

6.32    ‘Strategic economic clusters’ is a designation for locations for economic growth that are not in these other areas; and whose growth and evolution are also important to support in line with the London Growth Plan. Some are associated with relatively concentrated geographical areas (such as Earl’s Court and London Cancer Hub for example) whilst others, such as the Royal Docks or the Heathrow Economic Area, cover much wider areas.

Table 6.1: Strategic economic clusters  

Table 6.1: Strategic economic clusters  

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

6.33    The industrial release criteria in part A reflect GLA modelling, with more detail to support plan-making to be found in the Industrial Evidence Paper.118It is recommended that plan-making authorities engage with the Mayor and the plan-making authorities within their PMA when establishing the boundaries of their release areas, taking local detail into account. Plan-led release should be supported by site allocations to make best use of land. Resulting release parcels need to be of an appropriate and deliverable size and shape. Exclusion criterion A(1) only applies, if insufficient capacity has been identified to meet this need, (including in the Green Belt) based on Policy MBUL1 Spatial Strategy, and GLE2 Supply of industrial land.

6.34    Plan-making authorities have the opportunity to proactively define the exact boundaries of the specific release locations listed in Part B based on local circumstances and with relevant landowners to create release parcels of appropriate and deliverable size and shape.

6.35    Where land in industrial uses is not designated or allocated to help meet the plan-making authority’s strategic and local needs (see GLE2 Supply of industrial land Part D), brownfield residential (and mixed use) intensification in line with MBUL1 Spatial Strategy will be promoted.

6.36    The Agent of Change principle will apply where housing is introduced, but industrial uses remain. This should help to ensure that 24-hour operations and required operational vehicle access are not undermined. (See also Policy GLE4). 

This policy reflects a number of key considerations:

6.37 In the light of London’s housing need, industrial land has to make an appropriate contribution to meet that need in a coordinated, sustainable and viable manner and on the most accessible brownfield land. This must be done in a way that minimises and mitigates risks to continued industrial requirements and operations.

6.38 The specific release locations listed in Part B are two substantial release parcels in each PMA, at least partly within SAM 5 and also meeting the criteria set out in Part A.

6.39 The focus of release through development management is as far as possible on non-designated industrial land, but as this tends to be smaller in size and/or fragmented, the most accessible designated industrial sites are to be released through development proposals to speed up the delivery of housing and to address the time lag of plan-led release.

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

6.40    Although the size and function of MOL may vary, especially between inner and outer London, a consistent approach to designation remains important. The designation of too small or more locally significant areas, for example, risks devaluing the strength of the designation as a whole. For green space and open-air facility sites, which are more local in nature, alternative designations should be considered.

6.41    The criteria for designating new MOL in C(1) have been refined to emphasise and clarify the particular functions of MOL in line with Good Growth objectives. However, boroughs are not required to assess the performance of existing MOL. They are encouraged to consider whether isolated pockets of Green Belt or other land with MOL characteristics secured through the planning process, meet the C(1) criteria and may be appropriate for new MOL designation. This may be the case particularly where fragmentation within the urban area has or will occur. The distribution of current designated MOL can be seen in the Places sub key diagram.

6.42    Any proposed changes to existing MOL boundaries must be accompanied by thorough evidence which demonstrates that there are exceptional circumstances. Enabling development proposals should be plan-led, and opportunities to improve public access and quality without release should be prioritised. Where the criteria in C(2)(ii) are met and releasing part of a site is the only realistic way to enhance access and the strategic function of the remaining land and/or realise a strategic opportunity, those expected improvements should be set out clearly in any site allocations.

6.43    Not all development within MOL is inappropriate. Where it meets the definition of appropriate set out in part G, very special circumstances are not required. Given MOL has distinct function and purposes, as set out in parts A and C(1) of this policy, national Green Belt policies requiring the consideration of releases to meet development shortfalls or in relation to grey belt do not apply to MOL. However, established precedents when applying tests for exceptional and very special circumstances to MOL will continue to apply in the same manner, as historic decisions have always adapted such tests to MOL’s strategic role rather those of the Green Belt functions as is appropriate.

6.44    For the purposes of C(2), any releases of MOL hosting recreational facilities should still also be subject to an assessment against relevant policies within the NPPF (e.g. paragraph 98). Levels of public access to MOL vary depending on management arrangements but include all sites with free or de facto access (sites readily accessible and clearly used by the public). Determining whether the extent of charging or member only restrictions amounts to a lack of public access will vary case to case, but may include sites that are wholly inaccessible to the general public other than through paid access or membership, unless such fees are nominal.

6.45    MOL is a long-established London‑specific designation that protects the city’s most strategically significant green infrastructure for the benefit of Londoners and the environment. It safeguards open landscapes and improves Londoners’ quality of life by protecting areas which offer sporting and leisure use, heritage value, biodiversity, food growing, and health benefits through encouraging walking, running and other physical activity. MOL also plays a key role in linking London’s wider green infrastructure network and strengthening biodiversity across the city. Strong protection and positive management strategies for MOL are essential, even more so as growth and climate change places increasing demand for, and pressure on these spaces.

6.46    While MOL shares some characteristics with Green Belt, the two serve different purposes. Both are defined by their openness and aim to maintain clear breaks in the built environment. However, considering changes to Green Belt policies nationally as well as within the London Plan, these policies are now distinct. MOL purposes and functions are set out in parts A and C(1) of this policy, whereas national Green Belt purposes are set out within the NPPF. In addition to its openness, MOL purposes relate to its role as social and environmental infrastructure and do not relate to the national Green Belt purposes, for instance to restrict urban sprawl. 
 

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

6.47    The Mayor and TfL will support plan-making authorities responding to Broad Locations of Growth (BLGs) in their areas through Green Belt reviews and wider plan-making, drawing on the strategic evidence underpinning the London Plan to ensure alignment with the spatial growth strategy. As part of these reviews, locations that meet the sustainability criteria set out in Part D and Boxes PV7A–C will be prioritised over grey belt land that does not comply in order to enable the delivery and effectiveness of the Plan’s spatial strategy, including planned strategic mitigations.  

6.48    The only exception is in relation to data centres, where grey belt land outside of the BLGs may be preferred if the requirements of GLE3 are met as well as sites towards the edge of residential-led BLGs where they would provide an opportunity for low carbon heat (as noted in Box PV7A (3)(c)). This reflects the different operational impacts of this use, for instance lower trip generation compared to industrial uses such as storage and distribution. Other land should only be identified for release (or be brought forward in development proposals) where compatible with the criteria in Part E, and as such is likely to be limited. Land released following a review will remain subject to the full requirements of this policy. Boroughs are encouraged, and will be supported by the Mayor and TfL, to develop full masterplans to cover BLGs in addition to establishing master-planning objectives and principles within site allocations.

6.49    All boroughs containing Green Belt land are required to plan positively for its enhancement, and should draw on the approaches set out in policies GHR6 Trees, biodiversity and geodiversity, GHR7 Green Infrastructure and Urban Greening, and GHR8 Publicly accessible green space to improve its multi-functional value. Boroughs with a Green Belt BLG may leverage associated investment by clearly identifying priority locations and interventions—within or beyond the BLG—that development can help deliver.  Strategic level London Plan evidence relating to opportunities for Green Belt enhancement or areas with potential for meeting MOL criteria may provide a useful starting place for boroughs120.

6.50    Part D, boxes PV7A – PV7C and Table 6.3 of this policy provide an interim strategic framework for assessing proposals that reflect what will be expected to be incorporated in local plans via part A-C of the policy. The 1200m walking distance should be measured through the network where existing or planned rather than ‘as the crow flies’ and confirmed in discussion with TfL. Bus services are integral to sustainable urban extensions and must be optimised for frequency, speed and interchange quality, alongside complementary local services that meet day-to-day needs.  

6.51    For major industrial development, a benchmark distance of 2,500 metres, measured ‘as the crow flies’, should be used to identify locations with viable, short connections that minimise impacts on sensitive receptors. Where land may meet the sustainability criteria for both residential and industrial, under Box PV7A (3), residential should always be prioritised. Data centres should be assessed primarily against Policy GLE3 and other employment uses may be supported where they contribute positively to a coherent mixed-use vision for a BLG.

6.52    Development within BLGs is expected to contribute to cohesive urban extensions, with priority given to the most accessible sites, even where grey belt land is present elsewhere in the borough but falls outside the PV7A thresholds. This includes the expectation that densities and heights increase in areas with the highest connectivity, though the thresholds levels set in Table 6.3  allow for a range of unit typologies and sizes to response to local needs. Net density calculations should follow RICS definitions,121 excluding non-developable land such as large green spaces, with further guidance provided by emerging national Design and Placemaking Planning Practice Guidance.122

6.53    Table 6.3’s reference to AGS provision aligns with national standards set out in Natural England’s Green Infrastructure Framework, but local standards should be used where these are higher.123 This relates to the provision of green space only and does not negate the need to separately consider provision for play, sport and recreation in line with relevant national guidance, for instance Sports England’s Assessing Needs and Playing Pitch guidance.124  

6.54    It is recognised that in some cases development will be proposed outside the BLGs; Part E of the policy explains how this should be considered to ensure it does not undermine the overall plan-led approach.  

This policy reflects a number of key considerations:

6.55    This policy responds to changes to national Green Belt policy , which require the London Plan to establish a strategic justification for any broad locations where boundary changes are necessary to meet the development needs of the area. Alongside the spatial strategy set out in  MBUL 1, it provides a clear framework for the scale, location and form of Green Belt releases required during the Plan period, while securing robust protection and enhancement of retained areas to support and improve Londoners’ access to green spaces. This enhancement should in turn link with the Local Nature Recovery Strategy (LNRS) and other programmes and opportunities.  

6.56    The policy sets out a targeted approach to release, defining sustainable locations in the London context to ensure new development is well connected and viably serviced, in turn minimising the amount of land needed. This will come with improved access to good quality green spaces for Londoner and an increase in biodiversity. The BLGs identified have the greatest potential to meet London’s good growth needs due to existing infrastructure (or opportunity to enhance it) and the ability to accommodate growth of a critical mass at appropriate densities to sustain public transport, social infrastructure and local economic activity.

6.57    For residential this means proximity to stations that give good access to employment and services via sufficient service frequency and appropriate journey times to minimise car use and ownership (as is required to make the development sustainable). The role of quality bus services in extending the catchment of such stations is also acknowledged. For industrial, this is about connection to the wider strategic road network (and therefore economic clusters within and beyond London) in a way that minimises congestion and air quality impacts.  

6.58    Design specifications are oriented towards supporting this optimisation of land and opportunity, ensuring local benefit such as new or enhanced AGS. This approach recognises the value of the green spaces as well as the continued value of the Green Belt overall in defining the capital’s urban form, limiting sprawl, and protecting extensive areas of predominantly open countryside. The approach is predicated on the basis of building sustainable, liveable neighbourhoods at mid-rise density with access to public transport in order to make the best use of land - this is the only way that overall loss of Green Belt can be minimised.

6.59    The policy is designed to respond to the clear signal from the NPPF and reflect key objectives it sets out, but establishes the particular aspects necessary in the London context to make it workable. The key aspect of divergence is moving away from an ad-hoc approach using grey belt to ensure that Green Belt release can contribute in an optimal way and make the best use of expensive infrastructure and scarce land. This is vital to enable the effective planning of change in London. While the impacts of individual ad-hoc release and development may appear ‘reasonable’ it is the cumulative impacts that are of significant concern, including on congestion, the environment, and the extra land take required.  

6.60    The BLGs would make use of grey belt as far as possible, but this needs to be as an integrated component within the strategic approach. The disparate nature and location of much of that land would otherwise tend to result in proposals for low density development and/or development in unsustainable locations, which would ultimately constrain the overall level of housing delivery.  It therefore necessarily supersedes national provisions for ad-hoc release because it enables the otherwise unacceptable adverse impacts of development on infrastructure and the environment to be appropriately minimised, managed and mitigated. 

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

6.61    In managing strategic views, the LVMF provides Visual Management Guidance that draws attention to the general principles for managing development in the foreground, middle ground and background of the view. Each Strategic View is from a specific Viewing Place and within this, the LVMF identifies one or more Viewing Locations from which a viewer is able to experience particular aspects of the view.

6.62    For each Viewing Location, a View Type has been allocated to ensure that key aspects of the view that might be affected by development proposals are correctly analysed and that appropriate visual material is provided to allow positive and negative aspects of the proposals to be identified and assessed during the planning consultation process. Some views are static views where they are experienced from a specific point and others are experienced kinetically as a person moves through a viewing area. A third set of views provide panoramic views across London. Within some views, a Protected Vista has been defined and used to protect the viewer’s ability to recognise and appreciate the Strategically-Important Landmark.

6.63    Each element of the vista will require a level of management appropriate to its potential impact on the viewer’s ability to recognise and appreciate the Strategically-Important Landmark. These and other views are also subject to wider assessment beyond the Protected Vista. The LVMF provides guidance on how Accurate Visual Representations (AVR) should be undertaken, including requirements and considerations about atmospheric or seasonal conditions.  

6.64    Plan-making authorities and landowners should manage the viewing locations and where appropriate, mark the viewing location and provide information about landmarks that can be seen in the view. Vegetation in the foreground and middle ground of a view can risk obscuring a view if it is not regularly maintained.  

6.65    Clearly identifying local views in Local Plans and strategies enables the effective management of important local views. Alongside the strategic views of St Paul’s Cathedral, the St Paul’s Heights limitations are a key tool to maintaining the visibility of St. Paul’s Cathedral.  

Table 6.4: Designated strategic views 

Table 6.4: Designated strategic views 

This policy reflects a number of key considerations:

6.66    A number of views make a significant contribution to the image and character of London at the strategic level. These Strategic Views are highly valued and impact on people’s understanding and appreciation of London overall as a city. They also allow a viewer to see significant historic and cultural landmarks in their landscape or townscape setting and to understand the relationship between them.

6.67    Strategic views cross borough boundaries, and it is therefore essential that a consistent approach is taken to the protection and management of these views. The policy and the linked LVMF provide an important tool for cross boundary coordination in the development process between plan-making authorities, and a model that can be replicated for local views so that there is a consistent approach to defining and managing local views across London.