Our submission to the 'Towards a new London Plan' consultation
This is my (Sem’s) submission to the Greater London Authority’s Towards a New London Plan consultation. The consultation period ran for 6 weeks from Friday 9 May 2025 to Sunday 22 June 2025.
You can read more about the Consultation document here.
Paragraph 1.1: What is the London Plan?
The London Plan is a document prepared by the Mayor of London. It is the strategic, spatial plan for Greater London, setting out the strategy and requirements for homes, jobs, transport, and other infrastructure, as well as policies to ensure quality development. It has two roles relating to the planning system:
Policies in the London Plan are used to help shape and determine development proposals for all planning applications across Greater London, and any conditions or legal obligations that may be applied. The London Plan is part of the ‘development plan’ together with the local plan for the area and any neighbourhood plans. Planning applications must be determined in accordance with the development plan unless material considerations indicate otherwise.
When local authorities write their own plans, they must be in ‘general conformity’ with the London Plan. This broadly means that the local policies can’t harm implementation of the London Plan.
OURI Labs response for P1.1
The Plan would benefit from explicitly acknowledging the Plan's role in addressing health inequities across London's diverse communities. Given that spatial planning decisions fundamentally shape the social determinants of health including access to quality housing, employment opportunities, transport connectivity, and social infrastructure. To effectively deliver on health equity, the Plan should recognise that achieving its stated objectives requires meaningful collaboration with cross-sector partners, including health and care systems, community organisations, voluntary sector partners, and local communities. This collaborative approach is essential because health equity cannot be created by planning decisions alone, nor can they be resolved through planning policies in isolation.
We recommend that this introductory section explicitly references the Plan's commitment to reducing health inequalities and signals the Mayor's intention to work with cross-sector partners including the NHS, local authorities, community groups, and residents to ensure that planning decisions actively contribute to creating healthier, more equitable communities across all London boroughs.
Paragraph 1.4: Viability and delivery
There are a significant number of development sites across London and a large pipeline of new housing schemes which have received planning permission. However, there are a range of challenges currently affecting housing delivery in London. These include the increase in construction costs seen in recent years, labour shortages in the construction sector, the impact of higher interest rates, a shortage of national government funding, recent regulatory changes, market absorption rates and general economic uncertainty. Together, all have impacted the pace of housing delivery. In some cases, new housing developments which were in the process of being built have stalled, leaving partly built developments on vacant construction sites.
There are indications that market conditions are improving, and London has a proven track record of being a very adaptable and resilient city. However, the new London Plan will be produced at a time when challenges will remain.
It is vital that we have an ambitious approach to quality, and we continue to deliver key objectives, like meeting our climate commitments and increasing inclusion, health, and wellbeing. In doing so, we must carefully consider the impact of policies, individually and cumulatively, on the costs and viability of development. Much is expected of what can be delivered through the planning system. At the same time, there are also constraints in terms of the cost of building homes, workplaces, and infrastructure.
The policies adopted in the plan will need to be considered in this context, as well as across the overall plan period. This will be informed by an assessment of the viability of development, and the delivery approaches that best support an increase in housing supply for London and the provision of sustainable development. The London Plan will need to identify the capacity to deliver 880,000 homes over 10 years and how we can achieve Good Growth. It will also need to show that the policies in it are viable in the context of our ambition to accelerate housing delivery. However, it is not a delivery plan: there are many other factors that will need to be in place alongside the plan. These include funding for affordable housing and transport, and the delivery of sufficient energy, water, education and healthcare and other infrastructure capacity needed.
The next London Plan will not increase the overall burden of planning policy requirements on development under the current circumstances. Opportunities will also be taken to streamline requirements and speed up consideration of planning applications. Some policy requirements may be phased so they start to apply at a later date or, for example, when economic conditions or technologies improve.
OURI Labs response for P1.4
There is an opportunity to strengthen the integration of social value considerations within viability assessments. Currently, viability assessments typically focus on financial returns and direct costs, but they should also account for the broader social and economic benefits that developments can generate for communities particularly in addressing health inequalities.
Social value should be embedded as a core component of development viability, not treated as an additional burden. This means recognising that investments in community infrastructure, health-promoting design, accessible housing, and local employment opportunities generate measurable social returns that contribute to long-term economic sustainability. For example, developments that prioritise affordable housing, provide accessible healthcare facilities, or create local training and employment opportunities deliver social value that reduces public sector costs and strengthens community resilience.
The paragraph correctly notes that delivery requires 'many other factors' beyond planning policy, including healthcare infrastructure capacity. This highlights the critical need for cross-sector collaboration in both viability assessment and delivery planning. Health and care partners, community organisations, and local anchor institutions should be engaged early in the development process to identify opportunities for shared investment and co-delivery of social infrastructure.
We suggest that viability assessments should include a social value framework that quantifies community benefits alongside financial considerations. This could include metrics such as health outcomes, local employment creation, community cohesion, and contributions to reducing health inequalities. Such an approach would ensure that developments contributing significantly to social value particularly health equity are appropriately supported through the planning process.
This integrated approach would help achieve the Plan's ambition for 'Good Growth' while ensuring that housing delivery actively contributes to reducing health inequalities across London's communities.
Paragraph 1.7: Integrated Impact Assessment (IIA)
The IIA will support the plan. There may be changes to how this is done in future due to changes to legislation in 2023, but these changes have not been brought in yet. It covers:
Sustainability Appraisal – considering social, economic, and environmental impacts. The Sustainability Appraisal also includes the Strategic Environmental Assessment which is required by law, and focuses on environmental impacts.
Equalities Impact Assessment – assessing impacts in relation to the Public Sector Equality Duty.
Health Impact Assessment – assessing impacts on health and health inequalities.
The IIA is a series of assessments prepared throughout the development of the plan. The first stage is the Scoping Report. This sets out baseline information so the impacts can be assessed and what objectives the plan will be measured against.
The IIA Scoping Report will be published later this year.
OURI Labs response for P1.7
We welcome the commitment to conducting comprehensive Integrated Impact Assessments (IIA) that include Health Impact Assessments within the process. However, to ensure these assessments are effective and avoid duplication of effort, we recommend that the IIA process is audited with experts that have delivered IIA and HIA within planning processes. Many local authorities have worked with consultants to deliver these assessments and have reported the potential for both assessments to overlap in scope and objectives when delivering on health. Consolidating this information so that there is no duplication will be a helpful consideration.
The IIA Scoping report would be the opportune time to deliver this comprehensive audit. It can aim to map where different assessment processes intersect and overlap, particularly between Health Impact Assessments (HIAs) and other components of the other assessments.
This audit should:
Map existing assessment requirements across different policy areas to identify where health considerations are already being assessed through other mechanisms (such as within Sustainability Appraisals or Equalities Impact Assessments)
Identify gaps and overlaps to ensure that health impacts, particularly on health inequalities, are comprehensively covered without unnecessary duplication
Establish clear boundaries between different assessment components, specifying when standalone Health Impact Assessments are required versus when health considerations are adequately addressed within the broader IIA framework
Define coordination mechanisms with cross-sector partners, including health and care systems, to ensure that assessment findings inform collaborative delivery approaches
The IIA should also establish how assessment findings will be shared with and inform cross-sector partners involved in delivery, particularly health and care systems, community organisations, and local authorities.
Paragraph 1.10: Good growth objectives
The current London Plan is based on Good Growth – growth that is socially and economically inclusive and environmentally sustainable. It is informed by six Good Growth objectives as set out in the current London Plan:
Building strong and inclusive communities
Making the best use of land
Creating a healthy city
Delivering the homes Londoners need
Growing a good economy
Increasing efficiency and resilience
Find out more about Good Growth objectives here.
As the Mayor has highlighted, delivering the homes Londoners need and growing a good economy are critical priorities for this next London Plan. At the same time, it remains vital to build strong and inclusive communities, help to tackle the climate crisis and ensure a healthy and resilient city. Overall, these remain sound principles to underpin the next London Plan, but nevertheless we welcome comments and views on these key plan objectives.
OURI Labs response for P1.10
We strongly support the continued commitment to Good Growth objectives, particularly the recognition that 'Building strong and inclusive communities' remains a vital principle alongside housing delivery and economic growth. However, we recommend that the London Plan adopts a broader framework for measuring and delivering on strong and inclusive communities that extends beyond traditional fiscal-based calculations.
While financial viability and economic indicators are important, truly strong and inclusive communities require investment in social infrastructure and community assets that may not generate immediate financial returns but deliver significant long-term social value, community wealth which has further implications for population health.
The Plan should recognise and systematically account for:
Social capital and community cohesion - measuring community connectedness, civic participation, and social networks that contribute to resilience and wellbeing which includes metrics such as agency and community voice.
Health and wellbeing outcomes - including mental health, social isolation reduction, and community access to health-promoting environments
Cultural and community assets - spaces and facilities that strengthen community identity, intergenerational connections, and local ownership
Social mobility and opportunity - access to education, skills development, and pathways to employment that may require upfront investment but generate long-term community benefits
Strong and inclusive communities are built through collaborative investment from multiple sectors. The Plan should encourage partnerships between developers, health systems, community organisations, and local anchor institutions to co-invest in community infrastructure. This might include shared community spaces, integrated health and wellbeing facilities, or local employment and training programmes that create social value alongside development.
We recommend that the Good Growth framework incorporates an assessment that incorporates community value alongside traditional financial appraisals, measuring how developments contribute to community strength, social inclusion, and long-term resilience. This would ensure that planning decisions actively support the creation of communities where all Londoners can thrive, and help to achieve health equity by assessing these metrics in a more holistic way.