The structure and tone of the Draft London Plan is clearly looking to shift the way in which growth is expected to be delivered across the capital. Policies (and new key diagrams in the plan) move increasingly away from guidance on how to manage growth and towards ways in which it can be encouraged through the optimisation of development.
In relation to development within the historic and contemporary townscape context of the city, this is evident in draft Policies MBUL1 (Spatial Strategy) and MBUL2 (Optimising the Use of Land and Site Capacity), and reinforced throughout Section 2, Making Best Use of Land and Achieving Good Growth.
Mid-rise development: the new model for intensification
There is a clear shift in policy direction towards mid-rise development (defined as 12-30 m in height) across the whole of London (where sustainable). This is a clear move towards a form of intensification that has the potential to be delivered across much of the capital, helping to optimise land use while responding to London's varied urban character.
A feature of this approach is stronger support for the development of small and medium-sized sites, reflecting the growing recognition that London's housing and economic needs will require a more intensive use of existing urban land.
Generally, this approach reflects the wider direction of national planning policy (including the draft NPPF), particularly the emphasis on intensification around public transport nodes as a means of delivering sustainable growth. The draft plan, therefore, reinforces a growing expectation that development potential should be maximised in accessible locations while maintaining a strong focus on design quality and responsiveness to the local context.
Tall buildings: a more strategic and prescriptive approach
Alongside the broader emphasis on mid-rise development, the draft plan adopts a more strategic and prescriptive approach to tall buildings. The adopted Local Plan allowed local authorities to set tall building thresholds above a minimum of 6-storeys or 18 m. Draft Policy MBUL3 (Tall buildings) establishes a two-tier framework, distinguishing between “standard” tall buildings of 30 m and above and “metropolitan” tall buildings exceeding 100 m.
Standard tall buildings are directed towards areas identified locally for significant growth or change, with excellent public transport accessibility. They should also be located in areas that are not unduly sensitive to the impacts of tall buildings, and where there is an existing or emerging townscape character capable of accommodating them (Policy MBUL3A 1, parts i—iv).
Metropolitan tall buildings are directed towards defined clusters, including, for example, the City of London, Canary Wharf, Croydon and Old Kent Road. More information on this is provided in the Metropolitan Scale Tall Building Study.
The expectation that tall buildings should improve the public realm at ground level, activate streets and contribute positively to the pedestrian experience is firmly embedded within policy and reflects established urban design practice. Draft policy further boosts the profile of the use of independent design review for major developments within Boroughs, in accordance with the expected future direction of national guidance. Again, in line with emerging national policy in the NPPF, the draft plan also places greater emphasis on design codes and Local Development Orders as mechanisms to facilitate delivery.
The plan strikes a note of caution in retaining specific policy requirements for the city beyond national guidance in terms of tall buildings and fire safety, including expectations to include fire evacuation lifts. Climate resilience is also more clearly embedded within policy on design in the new plan, again in accordance with the expected direction of future national guidance.
Proper consideration of the effect of taller buildings on local character and distinctiveness remains an important focus in renewed policies seeking to protect historic and high-quality townscapes and key views across the city. This in turn links to established expectations for new development and design approaches that have a wider influence on the townscape of the city to be of a high-quality (draft Policy MBUL6 (high-quality design for a growing, changing city)).
Strategic views: protection maintained (for now)
There is little to be read into the restructuring of the new plan that locates draft Policy PV8 (Strategic and local views) with later Section 6, entitled ‘Place visions and place-based approaches’. Essentially, the key principles of this views policy remain consistent with the current London Plan.
It will, however, be important to consider how any changes within the forthcoming revision of the existing London Views Management Framework (LVMF) could affect the assessment of development, and in particular taller buildings in relation to existing strategic city-wide views and landmarks. We will be providing further commentary on this following the release of the new LVMF.
Heritage policy: evolution not revolution
While the key principles of heritage policy remain consistent with the current London Plan in terms of balancing growth with conservation, the policy has become more concise; removing or delegating the detail of the previous plan and becoming more strategic in direction.
The draft plan also places greater emphasis on the adaptive reuse of heritage assets in support of the wider growth agenda in the plan (draft Policy MBUL7 (London’s Heritage)) and encouraging their contribution to de-carbonisation and climate resilience. Accordingly, greater support is given to retrofit measures and more flexible use of planning control for historic buildings, recognising the contribution that such underused assets can make to sustainability, regeneration, housing growth and the revitalisation of town centres.
There is further emphasis on the importance of good placemaking and contextual design, which policy identifies as a key tool in delivering development that can embrace and learn from heritage and local character.
There is new encouragement for Boroughs to prepare their own local heritage strategies to identify opportunities for positive change, with tangible actions and priorities. Such a strategic approach at Borough level could provide a more holistic understanding of local heritage and character, creating a stronger platform for proactively managing change to support growth ambitions.
A stronger evidence base
A renewed and comprehensive evidence base has been developed to inform the heritage and townscape policies of the Draft London Plan, which provide additional clarity on their origins and direction of travel.
The new London Context Map categorises the varied character of different parts of London into six broad “character settings” to establish a stronger baseline understanding. This document is also intended to assist Local Planning Authorities (LPAs) when carrying out more detailed Borough-wide or area-specific characterisation studies at the more granular level. The accompanying analysis suggests that many locations currently characterised by relatively modest building heights could support more intensive forms of development while remaining consistent with their wider urban context.
Exemplifying the more directional and prescriptive approach to policy making for the optimisation of land across the city is the Optimisation Framework, which sets a range of expected heights and minimum densities for certain developments and sites within certain contexts or “settings”. Those expectations would only apply to sites over 0.25 ha without existing specific designations / allocations, such as tall building locations.
Generally, this is a more sophisticated analysis of the diversity of the London context. The Optimisation Framework makes the case for how better-connected locations can support more homes and taller buildings, and where lower density areas with few heritage constraints can often have greater potential for redevelopment.
Alongside the policy these studies support, there is a shift away from past ideas of tall buildings being the primary answer to London's housing growth needs, to being one component of a broader intensification strategy focussed on widespread mid-rise development, suburban densification and the redevelopment of underutilised land.
But will it deliver?
The direction of the new London Plan is expanding opportunities for development to happen, both through the intensification of existing townscapes and through the release or flex in the use of other land within London. In return, these policies place a greater responsibility on landowners and developers to better evidence the suitability of their proposals for an area through detailed and early analysis.
Whether this recalibration of policy ultimately delivers the scale of required housing and economic growth remains to be seen. What is clear, however, is that the Draft London Plan speaks of a decisive shift from managing growth to proactively enabling it. The challenge now will be ensuring that the tools, evidence and policy ambitions are matched by delivery on the ground.
If you would like to discuss how the Draft London Plan may affect development opportunities, townscape considerations or heritage matters, please get in touch with Victoria Bellamy and Richard Brookes.
4 August 2026
