10 March 2026 Just Space has submitted strong objection to the government’s proposed draft NPPF

“… by appearing to destroy the core mechanisms at the heart of planning since 1947, it is an intensely disturbing document that seems contemptuous of planning itself. It certainly goes far further even than the previous Tory government in its utter determination to wreck the cornerstone of the planning system, local decision-making.”

Download the full Just Space response.

Thanks to Southwark Law Centre for their work in the following briefing, circulated earlier:
https://justspace.org.uk/wp-content/uploads/2026/03/NPPF-Consultation-2026-JS-Briefing.

Government proposals:

National Planning Policy Framework: proposed reforms and other changes to the planning system – GOV.UK

Other organisations’ responses: (thanks for sharing them, especially to Duncan Bowie.)
Highbury Group on Housing Delivery
Housing Forum NPPF-consultation-response-from-The-Housing-Forum.pdf
RTPI response to the proposed reforms to the National Planning Policy Framework and other changes to the planning system | Championing the power of planning
CIH responds to the National Planning Policy Framework consultation (December 2025)
LGA submission to MHCLG NPPF reforms consultation March 2026.pdf
British Property Federation
London Forum
London Councils
HBF
NPPF Changes | London Assembly
Stephen Hill
Community Land Trusts Network
Community Planning Alliance

The GLA’s plans for the impact appraisal of the next London Plan are strongly criticised by Just Space and many of its member organisations.

If the GLA were serious about impact they would have started their analysis right at the beginning of making the plan. Then the assessments could alert them to bad policies with likely poor outcomes and could test improvements. In fact this Impact Assessment has yet to start and plan making is well under way.

The GLA has been consulting on the scope and design of the Integrated Impact Assessment (IIA) and we find it to be weak in many respects and biased in ways which would make it blind to the downsides of many controversial policies. Policies will gain plus points for growth and plus points for almost all extra density. How can density policy and tall building policy be evaluated if increases in density are the measuring rod for success?

Another weakness of the approach is the lack of analysis of why earlier plans have failed – especially failed over 25 years to produce anything like enough low-rent social housing. The need for it is unchallenged but the backlog of unmet need mounts. Without much better monitoring, evaluation and explanation it will be next to impossible for the Assessment to point towards better policies.

Many of the criticisms of the London development process come down to the effects of prioritising developer and land owner profits in the assessment of projects, captured in the phrase ‘subject to viability’ and its application to everything in the plan.

Is there no alternative? The regulations require a strategic assessment of the plan against reasonable alternatives which have been explicitly or implicitly rejected. Just Space is working on an Alternative Plan for London which differs radically from the Mayor’s and the GLA has no excuse for not exploring some of the main alternatives that Londoners call for: less pressure for growth, a more polycentric metropolitan region with less need to travel, more care and support for existing enterprise.

Read our consultation response in detail. Download here.It has been prepared by a group of JustSpace members and others have been consulted on drafts. Particularly valuable inputs have come from the Southwark Law Centre.

CPRE London has submitted a strong critique aimed at evaluation professionals. Reading it is educational. Download here.

For the previous London Plan City Hall planners got the IIA seriously wrong and were required to go back and do a lot of extra work. Earlier posts have the details.

On 5 February 2026 Zoë Garbett, Green Party member of the London Assembly hosted a gathering at City Hall under the banner  Fighting London’s profit-driven estate demolition and gentrification.

Speakers from a number of threatened estates testified to the injustices and miseries increasingly imposed on tenants and residents as the increasingly profit-driven ‘regeneration’ machine operates across the city. Tenants from the Lesnes Estate at Thamsmead, Brick Lane, Aylesbury, West Kentish Town and many others spoke, as did Joseph Jones from the London tenants Federation and Richard Lee from Just Space – the 2 organisations which set up and manage the EstateWatch.London web site.

A detailed write-up including the many round-table discussions among the 100 or so participants will be posted here when it is available. Here is an account from Focus E15 including the speech of Joseph Jones of LTF.

Richard Lee of Just Space said “The question for our tables to discuss is about the resources and practical measures that are needed to protect tenants whose estates are under threat.  

Knowledge about housing and planning is central to this, as we have heard, but other types of knowledge are very important too.  Tenants need to know their rights and have access to legal advice.  They also need to know about tools they can use to make the case for an alternative to demolition, such as retrofit surveys and trauma informed practice as part of a community health impact assessment.  

Most of us here need more support to be able to do the above, but what about tenants on estates who are not here!   We very much need resources for an outreach programme.  How can the London Assembly support this?  Where else do we go for resources and how do we coordinate this?  Coordination of our activities is a big issue.  Zoe has brought us together today, but we need a space that brings us together more often.  We are asked today to give our ideas for policy change but without resourcing communities on the ground, good policies will never be put into practice.” 

A group of students at the Bartlett School of Planning at UCL have been working with EstateWatch.London to update the web site and have prepared a leaflet suitable for use in door-to-door canvassing on estates. A copy can be downloaded from here for you to print:
https://justspace.org.uk/wp-content/uploads/2026/02/FinalJustSpaceGuideLeaflet.pdf

Also available is the full report by EstateWatch, Alternative Good Practice Guide to Estate Regeneration.

The GLA is required to do a whole series of impact studies as they prepare the draft London Plan – to alert them to bad impacts and highlight scope for improvements. They are also required to consult the public about the scope of the studies they plan to do. The consultation about this draft Scoping Report could have been done months or a year ago but finally it is happening now.

The consultation was badly announced just before christmas and with very short notice for responses. We protested strongly and the GLA has extended the consultation until 13 February.

All responses must be made in writing to londonplan@london.gov.uk and Just Space will be compiling a collective response. Individuals and groups are also encouraged to respond.

The Just Space response will be coordinated by Michael Edwards, Jed Holloway and others. Please get in touch if you want to contribute. A first reaction by Jed Holloway is here to download. A later composite draft response is added here 9 February. Do use any or all of it in your own.

The Draft Scoping Study for the Integrated Impact Assessment can be found at https://www.london.gov.uk/programmes-strategies/planning/london-plan/towards-new-london-plan-consultation

The Integrated Impact Assessment (IIA) covers requirements relating to Sustainability Appraisal (SA)/Strategic Environmental Assessment (SEA), Equality Impact Assessment (EqIA), Health Impact Assessment (HIA), and Community Safety Assessment (CSA). It proceeds by defining the objectives against which the plan should be judged, then sub-objectives and detailed questions. It should deal with alternatives.

Our previous experience in 2019 was shocking. The Panel of Inspectors at the Examination in Public were persuaded by us that the draft IIA was of such inadequacy that the London Plan team were required to produce additional appraisals of the impact each and every policy in the draft plan would have on each of the groups protected in the Equality Act. Links to back story in our post of 5 January.

(Page amended 26 January to add the download link to Jed Holloway’s text)

Friday 23 January. This consultation is now closed. Our Just Space responses to the Mayor and to MHCLG are here. It is a devastating expose of wrong-headed proposals. Some other responses are at the foot of the page.
Just Space response to Mayor
Just Space response to MHCLG

Despite 90,000 homeless children and 300,000 people on housing waiting lists across London, Mayor Sadiq Khan is consulting on proposals to reduce the amount of affordable and social rent housing developers are required to provide!  The government is consulting on related proposals to let some developers make less contributions to local infrastructure.

The consultation on a package of measures to help developers ends this Thurs 22nd Jan – and we’re urging everyone to submit a strong objection. 

 Attached are two briefings:
A simple briefing explaining the GLA City Hall proposals and how to object
A briefing on the MHCLG consulttaion on reducing CIL and increasing the Mayor’s powers.

Later (22 January): the deadline is tonight. Here are more submissions which you may find stimulating as you prepare your own comments:
Michael Edwards
Robin Brown
Highbury Group to GLA
Highbury Group to MHCLG
HBF to GLA
HBF to MHCLG
London Forum to MHCLG
London Forum to GLA
Zoẽ Garbett AM

Next day comes a brilliant article in the Financial Times by Britain’s best housing journaliist Pete Apps. It’s not about the London proposals but a broad welcome to the slowdown in housebuilding and falling prices. This could be the beginning of the end of house prices escalation. If you are able to read this article, do.

Our protest to the Mayor on 7 January (text below) must have shamed them into a re-think. The consultation was yesterday extended to 13 February. Thank you.

Dear Sadiq (copied to Assembly Members in the Planning Committee) 7/1/26

We wish to register our outrage at the unacceptable consultation timetable on the Integrated Impact Assessment Scoping Report, and request it be extended for 3 weeks.

As you know, you are legally required to consult on a draft of how to evaluate the impact of a new London Plan. The London Plan team began consultations on a new London Plan in 2023, at which point we requested consultation on the IIA scoping. We have repeated this request several times in the intervening two years, and submitted extensive evidence on this matter in response to ‘Towards a new London Plan’ last June, when we asked “is inclusion an illusion?”

We were reassured that there would be consultation on the IIA scoping “later this year”. We learnt only yesterday that just such a consultation purportedly began on 19th Dec 2025, running for 6 weeks, with a closing date for comments 30th January 2026.

None of us or our extensive network of community groups were notified of this consultation – indeed I spoke to CPRE London this morning who were completely unaware. It would appear from their website that the London Forum of Civic & Amenity Societies remain similarly uninformed.

To slip out under cover of the Christmas break such an important consultation does not demonstrate a commitment to equalities. To slip it out without even notifying many of London’s longstanding networks and organisations runs counter to your claim on the landing page for this consultation: “I want to forge a new consensus on planning that’s fit for 21st century London”.

This is particularly inauspicious given our previous experience in 2019, when the Panel of Inspectors at the Examination in Public were persuaded by us that the draft IIA was of such inadequacy that the London Plan team were required to produce additional appraisals of the impact each and every policy in the draft plan.

We share your aspiration to forge a new consensus, and urgently request that you extend this consultation by 3 weeks in order to cover the time wasted by failing to inform London’s communities of this important consultation and thereby reaffirm your commitment to equality, transparency and consensus.

Yours sincerely. Michael Ball, Just Space Co-ordinator

Links to back story in our post of 5 January

5 January 2026 The Mayor is legally required to consult on a draft of how they plan to evaluate the next London Plan. They have been postponing the consultation for a year or more and now they have slipped it out under cover of Christmas. Consultation closes at the end of January so nearly half of the period has expired already. We interrupt our work on the alternative plan to alert Londoners to the need for urgent action.

The Draft Scoping Study for the Integrated Impact Assessment can be found at https://www.london.gov.uk/programmes-strategies/planning/london-plan/towards-new-london-plan-consultation

We have no trace of receiving any notification about this, despite us being on the Mayor’s email lists for updates. We discovered today 5 January from a friend who had received an email on 23rd December, telling them that the consultation had started on 19th December. This is very bad practice indeed.

Those who weren’t around in 2016 may be interested to know that the London Plan team initially worked well with Just Space and community groups on the Integrated Impact Analysis for the current (2021) London Plan. [ link ] We failed to agree, however and they went ahead with a process which we considered seriously inadequate. In the event their analysis of impact on inequality was so weak that we persuaded the Panel of Inspectors to insist on more work; then the further work was found still quite inadequate and the London Plan team were sent away by the Inspectors to attempt an appraisal of how each policy in the plan would likely affect each of the sections of the population. The resulting report confirmed our worst fears about the inability of the plan policies to arrest the growth of inequality or reverse it. But it was by then too late to influence the content of the plan. Catch up with that story here: https://justspace.org.uk/2019/04/28/actual-equalities-study-at-last/

‘The IIA includes Sustainability Appraisal/Strategic Environmental Assessment (SA/SEA), Health Impact Assessment (HIA), Community Safety Impact Assessment (CSA), and Equalities Impact Assessment (EqIA). In addition, information from the parallel workstream of the Habitats Regulation Assessment (HRA) will inform this IIA but be reported separately.’

Individuals and groups concerned about the equality and/or environmental impacts of the Plan are urged to read the scoping report (link above) and comment to us so we can prepare a collective response to City Hall before the end of January. If we can, we’ll organise a briefing between now and then.

Consultation has closed on the Mayor of London’s Towards a New London Plan. Our response, along with other material, is at http://justspace.org.uk/towards

At the same location are links to earlier publications and policy statements by Just Space and others and information about our conference on 14 June when our member groups put together our submission in response to the Mayor. Consultation closed on 22 June.

This post revised 23 June 2025.

6 May 2025: For more than a year the GLA (Mayor of London) has been refusing to start the public processes which would lead to the next London Plan. We protested to no avail.

Now, however, the Mayor of London begins a 6-week consultation on ‘Towards a new London Plan’ from Friday 9th May.

This follows hard on the heels of the Mayor’s depressing ‘build, build, build’ policy sketched out in his London Growth Plan (published in February with minimal consultation) and his appearance at MIPIM in March, the developer’s trade fair in Cannes – where he was seeking ‘investment partners’ for £22bn of projects on public land and estates.

Just Space is hosting a network meeting shortly to prepare our response to the proposals. If you are a member or active supporter you should have an invitation. If one does not arrive, please get in touch.

We also hope to hold a conference in June to develop our response – an alternative vision for a Caring City.

More details to follow, but in the meantime, you can access the London Growth Plan  – and our critical guide to what it contains.