Draft London Plan: The New Rulebook

The London Plan describes planning as the “rulebook” which governs where London’s homes, workplaces, schools, shops, transport infrastructure and public spaces can be built. That is a useful description because, for developers, the Plan is not just a statement of mayoral ambition. Once adopted, it becomes a key document against which planning applications across the capital are assessed.

The new draft Plan looks ahead over two decades. Its ambitious and is intended to provide a framework for housing, employment, and infrastructure while managing transport and environmental impacts and securing good-quality development. That’s bloody hard to do in half the pages of the previous version, but arguably that is what is needed to streamline planning and meet the central aim which is to accommodate significantly more homes and economic activity.

From a transport perspective, this growth must be supported by more efficient use of land and more sustainable patterns of movement, however, for those of us advising private developers, the important question is whether transport policy will genuinely help unlock development.

Transport at the heart of the growth strategy

Policy MBUL1: Spatial Strategy sets the overall direction. It looks to focus new homes and jobs in well-connected locations, make better use of brownfield land and align growth with public transport and other infrastructure.

The scale is significant. The draft Plan expects boroughs collectively to plan for at least 558,000 new homes, alongside employment space and the facilities needed to support growing communities. Affordable housing and public transport are identified as priorities in delivering that growth.

For developers, this creates a clear opportunity. Sites with good public transport, strong walking connections and access to local services should have a stronger case for more intensive development. Transport accessibility is therefore not only something to report in a Transport Assessment; it can help justify the principle and scale of development.

The new Sustainable Access Measure, or SAM, is likely to become important here.

SAM is intended to provide a broader measure of sustainable accessibility than the familiar PTAL system. Rather than looking mainly at access to public transport services, it considers how easily people can reach jobs, services and facilities by public transport and walking.

In principle, that should be helpful. A site can have a reasonable PTAL but still be poorly connected to the places people need to reach. SAM should provide a more rounded picture and support better decisions about density, parking and land use.

Transport infrastructure as a way of unlocking housing

Policy MBUL5: Sustainable Transport to Enable London’s Growth is probably the most directly relevant transport policy for developers.

Its key message is straightforward: London cannot accommodate substantial housing and employment growth through increased car travel. Development must support more travel by public transport, walking and cycling, while freight and servicing must be managed more efficiently.

The policy expects transport interventions to be identified alongside growth locations and site allocations. It also expects development to help fund and deliver transport improvements where necessary.

There is a lot to welcome in that approach, however, assessments and contribution requests should be proportionate, reasonable and directly applicable to development. Developers need to know early whether a site depends on a new station entrance, bus capacity, a junction redesign, a cycle route or major public realm works. It also should prevent schemes being held up through planning. That certainty helps with land values, viability, design and programme.

However, the risk with this approach is that developer contributions become a substitute for a properly funded transport strategy. A development can reasonably mitigate its own impacts and contribute towards infrastructure from which it benefits. It cannot be expected to resolve every existing transport problem in the surrounding area.

This matters because major developments are already expected to provide affordable housing, public realm, environmental improvements and community infrastructure. If transport asks are not clearly linked to the scale and impact of the scheme, otherwise deliverable sites can quickly become unviable.

There also needs to be greater confidence that infrastructure will actually be delivered. A financial contribution towards a long-term transport project is of limited value if the scheme remains unfunded and uncertain for years.

The best outcome would be a clearer partnership: public authorities identify and commit to strategic infrastructure, while development provides proportionate funding and delivers the site-specific elements needed to support it.

Healthy Streets, safety and the public realm

Policy MBUL9: Healthy Streets and Public Realm continues the Healthy Streets approach but places a stronger emphasis on safety, inclusion and how public spaces feel to the people using them.

The policy wants streets and public spaces that are welcoming, accessible, greener and designed around health and wellbeing. It specifically refers to creating places that feel safe throughout the day and night, including for women and girls. This is essential. We all want better streets.

Major developments are expected to create or improve public spaces and involve local communities in their design. A developer can also provide good lighting, active frontages, clear routes and secure cycle access within the site. But the success of those measures often depends on the wider journey to stations, bus stops and local facilities.

Developers should address the impacts of their scheme and contribute fairly to necessary improvements, but they should not be expected to fix every existing highway problem in the area. Well-targeted off-site works can strengthen a planning case and support car-free development, but contributions should be proportionate, with Healthy Streets remaining a shared responsibility between developers, boroughs and TfL.

If boroughs want car-free and low-car development, they will also need to take stronger action on the existing highway. It is difficult to reduce driving and improve routes while large areas of public streets remain dedicated to relatively cheap or unrestricted parking. Councils must therefore create the conditions that make walking, cycling and public transport the obvious choices, without solely relying on developer’s contributions.

New cycle and car-parking standards

Policy GHR11: Cycle and Car Parking combine cycle and car parking within a single policy.

The overall direction is familiar: restrain car parking, protect disabled access and provide enough cycle parking to support sustainable travel. However, the detail appears more flexible than the current approach, which is very much welcomed.

New cycle standards vary according to location and development type. The draft also recognises that conventional on-site cycle stores may not always be the best answer. Shared cycle hubs, public-hire cycles, managed cycle fleets and other alternative arrangements may be acceptable in some circumstances.

That is great news, especially given all the cycle parking studies Velocity has recently undertaken which demonstrates shared bike usage is very high and cycle store occupancy levels are very low. 

Too often, developments provide very large cycle stores simply to meet a numerical standard, despite evidence that they are likely to be lightly used. A more flexible approach should allow developers to focus on quality, accessibility and likely demand.

On car parking, the starting point remains car-free or car-lite development, particularly in accessible locations. That makes sense. Parking takes up valuable space, reduces development capacity and can add significant construction cost.

But parking restraint cannot be considered in isolation. A car-free development surrounded by unrestricted or lightly controlled on-street parking may simply displace demand. This is particularly important in outer London, where public transport access and travel patterns vary considerably. If boroughs want genuinely car-free development, parking controls in the surrounding area may need to change as well.

In regard to disabled parking there is a clearer recognition that car-free development must still work for people who rely on a car because of mobility needs. The policy allows for disabled parking to be provided either on site or, where appropriate, through nearby on-street bays. This gives developers more flexibility to balance inclusive access with wider car-free objectives, provided the approach is agreed early and there is confidence that suitable spaces can actually be delivered.

What this means for transport and developers

The draft Plan creates a positive framework for development.

It gives transport a clearer role in unlocking growth, rather than treating it only as an impact to be mitigated. Better use of accessibility evidence through SAM could help support higher densities in the right locations, while the more flexible approach to cycle parking should allow solutions to respond better to actual demand and site constraints.

The stronger focus on Healthy Streets, inclusion and disabled access should also help create developments that are easier and safer to use. For developers, this provides an opportunity to strengthen the planning case by showing how transport, public realm and accessibility have shaped the scheme from the outset.

The main benefit will be greater certainty. Where transport requirements are identified early, proportionate to the development and linked to a clear infrastructure strategy, they can support viability, reduce planning risk and help bring forward more ambitious schemes.

The draft Plan therefore gives developers a stronger basis to argue that well-connected, car-free and inclusive development should be supported—particularly where it makes efficient use of land and contributes to wider transport improvements. In return, boroughs and transport authorities need to provide the infrastructure, controls and certainty that allow those places to work.

That is how transport can genuinely unlock housing, rather than becoming another barrier to delivering it. Roll on the next 20 years.