The Environment Committee met to discuss the draft London Plan, focusing on its environmental policies and their alignment with national planning frameworks. Key discussions revolved around changes to Green Belt policy, the Mayor's net-zero ambitions, energy efficiency standards, and the protection of natural spaces, with particular attention paid to the potential impact of development on biodiversity and the need for robust environmental enhancements.

Draft London Plan and Environmental Policies

The committee engaged in a detailed discussion regarding the draft London Plan, with particular focus on its environmental policies. Jules Pipe CBE, Deputy Mayor for Planning, Regeneration and the Fire Service, explained the pragmatic approach taken towards Green Belt policy, stating that development on well-located pockets of Green Belt, such as near tube stations, would be considered at a density of around six stories to minimise land take. This approach, he argued, is necessary due to the projected housing need of 830,000 homes, which cannot be met solely by brownfield sites.

Sophie Donaldson, London Plan Manager at the GLA, addressed the relationship between the draft London Plan's environmental policies and the National Planning Policy Framework (NPPF). She noted a timing issue, as the NPPF was published after the draft London Plan, and that the GLA would analyse the final NPPF's impact on the draft plan. Donaldson highlighted that while the GLA aims to add value and clarify what makes sense in a London context, some London-specific approaches may be required. For instance, regarding surface water flood risk, the GLA has set out an approach where developers can contribute to off-site provision, which may lead to more green infrastructure enhancements than on-site solutions.

Megan Life, Assistant Director for Environment and Energy at the GLA, confirmed that the draft London Plan still seeks to enable local authorities to set their own energy efficiency standards, a point conceded by the final NPPF. This, she stated, is a marker of the Mayor's ambition to tackle climate change. Life also discussed the shift from the previous Be Lean, Be Clean, Be Green approach to energy efficiency metrics, moving towards energy use intensity and space heating demand standards to provide a more accurate picture of actual energy use in buildings and close the performance gap.

Green Belt and Metropolitan Open Land (MOL)

Concerns were raised about the robustness of the Green Belt and MOL assessments, particularly as not all boroughs engaged with the London-wide Green Belt Review. However, it was clarified that the Green Belt assessment is only one source of evidence, and the spatial strategy and policy response rely on a broader range of evidence. The GLA is engaging with boroughs to explain its approach and welcome views during the consultation period.

The policy for MOL has been disaggregated from Green Belt policy due to the change in approach to Green Belt. MOL is considered distinct from Green Belt, being found across London rather than just on the outskirts. There are no planned changes to MOL policy now or in the future.

The draft London Plan acknowledges the potential for development in Broad Locations for Growth (BLGs) to result in the loss of Green Belt. However, it emphasizes that this should be accompanied by an increase in accessible green space and strategic opportunities for nature recovery. The plan also encourages boroughs to consider protecting land as MOL.

Biodiversity Net Gain and Urban Greening

The draft London Plan specifies that for off-site provision of biodiversity net gain (BNG), provision within London should be prioritised. Local planners are responsible for assessing how developments discharge their BNG requirements, with a preference for on-site provision. While the BNG metric itself is seen as an improvement, concerns were raised about developers potentially gaming the system to maximise figures without genuinely improving biodiversity. The GLA is working to integrate BNG with other policies, such as the Local Nature Recovery Strategy, to ensure a broader strategic impact.

A 30-year maintenance and management requirement is built into the BNG system to ensure habitats are sustained. The plan also includes policies on trees, emphasizing climate resilience and the selection of species suitable for future climates. The GLA is collaborating with institutions like Kew Gardens and supporting local authorities with knowledge for long-term tree maintenance.

Food Growing and Waterways

The draft London Plan has reorganised policies, with food growing expectations now being integrated into planning for large residential schemes and existing legal protections for allotments. While the policy intent remains, its consolidation into other areas aims for greater impact. The new NPPF also requires local plans to consider food growing opportunities within Green Belt enhancements. The GLA also supports food growing projects through the Green Roots Fund.

The draft London Plan identifies 10 Clean and Healthy Waterways Strategic Locations as a sub-category of environmental opportunity areas. These locations are intended to signal opportunities for development and other schemes to respond to, integrating their objectives into planning. While these 10 locations are prioritised, work in other waterways and locations outside these areas is not precluded. The policy incorporates an approach to consider water quality impacts of sustainable drainage systems and encourages benefits to the current baseline through enhancements to nearby waterways.

Water Use and Drought Preparedness

The draft London Plan sets a standard for water use of 105 litres per day for new developments. This is considered sufficient for now, as London's per capita consumption is still high at around 140 litres per day. The plan supports water efficiency through policies such as storing water for reuse on-site within the flood risk policy. The role of smart metering and pricing of high users is also acknowledged as important, alongside user behaviour and water company performance. The plan also considers the need for passive design measures, such as building orientation and shading, to maximise levels of shade and reduce heat gain, and encourages developers to consider future climate scenarios.

Data Centres and Energy

The draft London Plan policy on data centres acknowledges concerns about their resource intensity, particularly regarding water and electricity usage. The policy aims to harness the economic benefits of data centres while driving sustainability, including energy efficiency, water minimisation, and sustainable back-up power. The GLA sees its policy playing a market-shaping role by signalling expectations to developers. Discussions also touched upon the potential for data centres to connect to heat networks within designated zones.

Heat Networks

The draft London Plan softens the previous mandatory approach to heat network connections in priority areas, adopting a more technology-neutral approach outside of designated zones. The policy emphasizes that new developments should consider available heat networks, and if not the most desirable outcome, justification must be provided. The plan also aligns with new government zoning regulations for heat networks. Concerns were raised about the potential for residents to be trapped in expensive heating systems with heat networks, and the need for stronger protections from Ofgem.

Other Issues

The meeting also touched upon the importance of addressing cooling needs in buildings, the role of regulators like Ofgem in consumer protection for heat networks, and the need for robust data sharing between boroughs and agencies to tackle fly-tipping effectively. The draft London Plan's approach to food growing, the protection of allotments, and the potential for urban sprawl were also discussed.

The meeting concluded with the committee noting the report and discussion on the draft London Plan, and delegating authority to the Chair to agree any output arising from the discussion. The committee also noted its work programme and the date of its next meeting.