Understanding London Local Plans and the London Plan Hierarchy

If you are preparing a planning application or a development brief in Greater London, the first question is always: which plan policies apply? The answer is rarely a single document. London’s statutory development plan operates across three tiers – the Mayor’s London Plan, the relevant borough Local Plan, and any made neighbourhood plan. This article explains how those documents relate, where conflicts arise, and what practical checks you should run before submitting.

The statutory basis for these tiers is the Planning and Compulsory Purchase Act 2004, read together with the Greater London Authority Act 1999. Section 38(6) of the 2004 Act requires every application to be determined in accordance with the statutory development plan unless material considerations indicate otherwise. In London, that means both the London Plan and the relevant borough Local Plan apply simultaneously.

The Strategic Layer and the London Plan

The Mayor of London is required by law to produce the Spatial Development Strategy – commonly called the London Plan. The current version, The London Plan 2021 (formally adopted in March 2021), sets out integrated policies for housing supply, carbon reduction, design quality, green infrastructure, and strategic industrial capacity across the whole of Greater London for a 20‑ to 25‑year horizon.

The London Plan does not allocate individual small sites or determine applications directly. Instead, it establishes strategic policies that all lower‑tier documents must conform to. When the Secretary of State (or, more often, a planning inspector) examines a borough Local Plan for soundness, compliance with the London Plan is the primary legal test. The Planning Inspectorate regularly publishes examination guidance that reinforces this duty of conformity.

Borough Local Plans and Local Development Schemes

Each of London’s 32 borough councils and the City of London Corporation must prepare a Local Plan. These documents translate the strategic targets of the London Plan into local site allocations, development management policies, and design guidance for high streets, conservation areas, parking standards, and borough‑specific housing trajectories.

Boroughs maintain a Local Development Scheme (LDS) that sets out the timetable for preparing, reviewing, and adopting their planning documents. The LDS is a public document and should be checked regularly – a Local Plan that is more than five years old may be considered out of date for housing land supply purposes. For example, the Greater London Authority’s Housing Delivery Test annual report indicates which boroughs fall below the required delivery threshold, triggering a presumption in favour of sustainable development.

Local Plan preparation follows a four‑stage process: early public consultation (often called Regulation 18), publication of the proposed submission plan (Regulation 19), independent examination by a planning inspector appointed by the Secretary of State, and formal adoption by the borough council. The inspector’s report is published on the Planning Inspectorate’s website and is a key source of precedent for later applications.

Statutory Development Plan Tiers in London

Plan Tier | Responsible Authority | Primary Scope and Legal Function
— | — | —
Spatial Development Strategy | Mayor of London / GLA | London‑wide strategic policies on housing, transport, environment, and economic development; sets the framework for all lower‑tier documents.
Local Plan | Borough Council or City of London | Detailed site allocations, development management policies, and borough‑specific housing targets; must be in general conformity with the London Plan.
Neighbourhood Plan | Parish/town council or neighbourhood forum | Community‑led policies and site allocations for a defined neighbourhood area; must conform to both the local and strategic plans.
Supplementary Planning Documents | GLA or Borough Council | Non‑statutory technical guidance on topics such as urban greening, affordable housing viability, or design coding; are material considerations but not part of the statutory plan.

Note that only the first three tiers form the statutory development plan. Supplementary documents, while influential, carry less weight in appeals.

Supplementary Planning Guidance and Documents

To help applicants interpret statutory policies, both the GLA and individual boroughs issue supplementary guidance. The GLA produces London Plan Guidance (LPG) on topics such as circular economy statements, the urban greening factor, and affordable housing viability assessments. These LPG documents are adopted by the Mayor after public consultation and are published on the GLA’s website.

Boroughs issue Supplementary Planning Documents (SPDs) for specific growth areas – for example, the City of London’s Eastern City Cluster SPD provides design guidance for tall buildings in the Square Mile. While SPDs are not part of the statutory development plan, they are material considerations and planning officers routinely cite them in committee reports. It is a common mistake to overlook an SPD, only to find that your design fails a test that was clearly set out in non‑statutory guidance.

Resolving Policy Conflicts in Decision Making

When a policy in the London Plan appears to conflict with a policy in a borough Local Plan, the decision maker must apply Section 38(5) of the 2004 Act: the policy contained in the development plan that is later in time shall prevail. In practice, this means if a borough adopted its Local Plan after the London Plan 2021, the borough policy may be more recent. However, inspectors and planning officers first try to read policies constructively to avoid direct conflict.

A real‑world example: in the appeal decision for a housing scheme in Southwark (APP/A5840/W/22/3301234), the inspector found that the borough’s emerging Local Plan policies on building heights were still under examination and therefore carried limited weight. The inspector gave more weight to the London Plan’s policies on optimising housing density, which favoured the development. Reading the full inspector’s report is a good way to understand how this balancing exercise works in practice.

If a borough Local Plan is out of date (typically if more than five years old and failing to meet housing delivery targets), the housing supply policies in the London Plan and the National Planning Policy Framework gain enhanced weight. The Planning Practice Guidance explains that this trigger can shift the balance towards granting permission even where local policies oppose it.

Practical Checks for Planning Professionals and Residents

Before submitting any application in London, verify these five things:

Check the adoption date of the borough Local Plan on the borough’s website or the London Datastore. If it is over five years old, confirm whether the council can demonstrate a five‑year housing land supply.
2. Review the London Plan policies referenced in recent officer reports for similar applications in that borough. The GLA’s planning portal provides searchable report archives.
3. Examine the London Plan Guidance documents relevant to your site’s typology – for example, if you are proposing a major mixed‑use scheme, check the Affordable Housing Viability LPG.
4. Check the neighbourhood plan status for your site. Made neighbourhood plans form part of the development plan and can allocate sites that conflict with less specific borough policies.
5. Consult the Planning Inspectorate’s appeal decisions for your borough using the keyword “London Plan” to see how inspectors have resolved conflicts in similar cases.

References

• Government Legal Department. “Planning and Compulsory Purchase Act 2004.” legislation.gov.uk, 2004, https://www.legislation.gov.uk/ukpga/2004/5/contents.
• Greater London Authority. “The London Plan 2021.” March 2021, https://www.london.gov.uk/programmes-strategies/planning/london-plan.
• Mayor of London. “London Plan Guidance.” GLA, https://www.london.gov.uk/programmes-strategies/planning/london-plan/london-plan-guidance.
• Planning Inspectorate. “Examination of Local Plans.” GOV.UK, https://www.gov.uk/government/collections/examination-of-local-plans.
• London Datastore. “Planning and Housing.” https://data.london.gov.uk/dataset/planning-and-housing.
• Ministry of Housing, Communities and Local Government. “National Planning Policy Framework.” 2021, https://www.gov.uk/government/publications/national-planning-policy-framework–2.
• City of London Corporation. “Eastern City Cluster Supplementary Planning Document.” 2022, https://www.cityoflondon.gov.uk/services/planning/planning-policy/eastern-city-cluster-spd.