ADD2784 London-wide Small Site Design Code

1.1.    This project involves the development of a potential London-wide Small Site Design Code; this would provide greater clarity on acceptable design responses for a range of site contexts across London. A suitably qualified consultant will be procured to advise and lead on the development of a potential design code. Subject to this work, such a design code could be published within or alongside the next London Plan. 

1.2.    The next London Plan will have an annual housing need of 88,000 homes a year. Given the scale of this target which has been set by central Government, GLA officers are exploring a range of housing delivery models and types of sites – including the role of small sites (small sites are defined within the London Plan (2021) as being below 0.25 ha). This is a key workstream within the Making Best Use of Land Delivery Plan.

1.3.    The Mayor of London consulted on a Towards a New London Plan (TNLP) document between 9 May and 22 June 2025. This set out a direction of travel and a range of different options being considered for the preparation of the next London Plan (the spatial development strategy for London, used to guide and shape London’s development in the years ahead). It included an option to develop a London-wide Small Site Design Code which would aim to support small house builders and small and medium-sized enterprises (SMEs) in developing more small sites across London. 

1.4.    A London-wide Small Site Design Code would predominantly focus on the redevelopment of sites in London’s residential areas. This includes areas of inner London and also suburban London – with the need to support good quality densification of these areas if we are to deliver an increase in housing in London. A London-wide Small Site Design Code would be developed using a similar methodology to that set out in the Small Site Design Code London Plan Guidance (LPG) and could define specific design codes for different types of areas of London. 
 

2.1.    This work should be split into four phases, each comprising one or more stages. These are as follows:

3.1.    The public sector equality duty, under section 149 of the Equality Act 2010 (the Act), requires the identification and evaluation of the likely potential impacts, both positive and negative, of decisions on those with protected characteristics. The Mayor is to have due regard to the need to: eliminate unlawful discrimination, harassment and victimisation; and advance equality of opportunity, and foster good relations, between people who share a protected characteristic and those who do not. In particular, this may involve removing or minimising any disadvantage suffered by those who share a relevant protected characteristic; and taking steps to meet the needs of such people. In certain circumstances, compliance with the Act may involve treating people with a protected characteristic more favourably than those without one. 

3.2.    To assess the possible impacts of this project on those with protected characteristics, a scoping Equality Impact Assessment has been carried out. Its findings are shown in the table below:

3.3.    This assessment has concluded that the project is unlikely to have a significant impact on any persons with protected characteristics. The London Plan will be subject to an EqIA which will consider the impacts of the policies within it. 

Key risks and issues 
4.1.    The redevelopment of small sites can be divisive, and there are risks with potential options that could be explored which would be contentious with local residents e.g. the redevelopment of dwellings into flatted development. This was highlighted in 2022, when Croydon’s Suburban Design Guide (SPD) was revoked due to opposition to the SPD. 

4.2.    In communication with officers at Croydon, several other issues and challenges have been highlighted. These include the risk that if a design code is too flexible, it can be difficult to resist applications for poorly designed schemes / schemes that could have adverse impacts. This is reported to have happened in Croydon, where some schemes (such as those with lots of surface car parking) were refused by officers at the council only to be approved at appeal. 

4.3.    Another risk that will need further consideration is how a London-wide Small Site Design Code could be implemented at the borough level. This is an important consideration, given that almost all small site planning applications will be decided by the borough, rather than the GLA, as these applications will not meet the threshold set out within the Town and Country Planning (Mayor of London Order) 2008 to be referable to the Mayor. Therefore, the Mayor of London would not have control or oversight over the assessment of these applications.  

Links to other Mayoral strategies and priorities 
4.4.    This project primarily supports the Mayor’s mandates of building more homes and making best use of land. In addition, this project would also contribute to the boosting London’s growth sectors mandate if it made it easier for more small builders and SMEs to redevelop sites. The project could also support improvements to London’s housing stock through the use of planning conditions on extensions to existing dwellings. 
 

5.1.    Approval is sought to spend up to £55,000 to procure and appoint specialist consultancy services to develop a potential London-wide Small Site Design Code. The decision also requests approval to commence procurement for this project via the Architecture & Urbanism Framework Lot 7 (Small Sites); and award the subsequent contracts via a direct award. 

5.2.    The total funding for this project (up to £55,000) will be met from the London Plan 2025-26 budget. There is sufficient budget to cover this expenditure; all expenditure will take place in the 2025-26 financial year. 

5.3.    All appropriate budget adjustments will be made.
 

6.1.    The sections above indicate that the decision requested of the Mayor fall within his statutory power under section 30 of the Greater London Authority 1999 (as amended) (“the Act”), acting on behalf of the Authority, to do anything he considers will promote the improvement of the environment in Greater London; and in formulating the proposals in respect of which a decision is sought officers have complied with the Authority’s related statutory duties to:
(a)    pay due regard to the principle that there should be equality of opportunity for all people;
(b)    consider how the proposals will affect:
i.    the health of persons in Greater London,
ii.    the health inequalities between persons living in Greater London;
iii.    the achievement of sustainable development in the United Kingdom; and
iv.    climate change, and the consequences of climate change; and 
(c)    consult with appropriate bodies.

6.2    Section 334 of the Act requires the Mayor to prepare and publish a Spatial Development Strategy (known as the London Plan). Section 339 of the Act requires the Mayor to keep the London Plan under review, especially matters which may be expected to affect the development of Greater London or the planning of its development.

6.3    The Authority also has a subsidiary power pursuant to Section 34 of the Act. This gives the Mayor the authority to do anything which is calculated to facilitate or, is conductive or incidental to the exercise of any of the statutory functions of the Authority. In this case, the decision to procure a specialist consultant technical services to under this work may reasonably be regarded as facilitating, being conductive or incidental to, the exercise of the Mayor’s power detailed above.

Procurement

6.4    Officers must ensure that appropriate documentation is put in place and executed by the consultant and the GLA formalising the services before commencement of such services.
 

7.1.    The project will be delivered according to the following timetable

Appendix A: Procurement brief