Below is our submission to the Towards a New London Plan Consultation.

The London Plan is a blueprint for development and growth in London. It includes policies on key issues such as new homes, workplaces, public transport and open spaces.

The consultation, open till 22nd June, provides the opportunity for Londoners to have their say on the plan. Our submission is on behalf of our over 400 members across London and was drawn up following an online meeting.

You can make a an individual submission too at https://consult.london.gov.uk/towards-a-new-london-plan-consultation

Our Submission in Full

Who We Are

SERA (Socialist Environment and Resources Association) is Labour’s Environment Campaign and the party’s affiliated environmental network. For over 50 years, SERA has championed climate and environmental leadership in the Labour Party. Our members include Labour councillors, MPs, and activists committed to building a just, climate-resilient, nature-rich society.

With over 400 members in London, SERA welcomes the opportunity to respond to the Towards a New London Plan consultation. A new London Plan is a critical opportunity to embed environmental justice, public health, and climate action into the future of the capital. Our response draws on recent work with our members.

Section 2: Increasing London’s Housing Supply

General Comments on Section 2
London needs more homes — but it also needs healthy, sustainable, and inclusive neighbourhoods. The London Plan must ensure that housing growth delivers:
• Equitable access to nature and green infrastructure
• Resilience to heat, water stress, and air pollution
• High-quality energy-efficient homes that are affordable to run
• Respect for London’s diverse communities and natural assets
The planning system must not replicate the social and environmental inequities of the past. It must deliver environmental benefits where people live, not at remove, far from those most affected by development.

Paragraph 2.1 – A Brownfield First Approach
SERA supports a brownfield-first approach — provided this does not excuse poor-quality, low-nature developments. Too often, brownfield sites are treated as ecological voids, but they may support important biodiversity or sit within habitat corridors.
Ask: Apply Urban Greening Factor and Biodiversity Net Gain requirements equally to brownfield sites, and require ecological assessment for all.

Paragraphs 2.10–2.11 – Green Belt & Metropolitan Open Land
We support the Mayor’s cautious exploration of low-value Green Belt land for housing. However:
• Nature-rich Green Belt sites must be protected and restored
• Where development is permitted, it must deliver exemplary green infrastructure, meet BNG and UGF thresholds, and leave nature better off than before
Ask: Re-designate ecologically valuable Green Belt land for nature restoration and require nature-positive outcomes on all Green Belt developments.

Paragraphs 2.12–2.14 – Affordable Housing and Estate Regeneration
Affordable housing should not come at the cost of environmental quality. Green space access must be a right, not a privilege.
SERA echoes the 15-minute neighbourhood principle: everyone should live within a 15-minute walk of a high-quality green space. This is especially urgent in deprived areas, where public health and climate resilience are weakest.
Ask: Require all affordable and estate-regeneration schemes to:
• Deliver new or enhanced green space
• Meet heat risk and nature-based cooling standards
• Include planting for shade, habitat, and water management

Paragraphs 2.16–2.17 – Specialist, Supported and Older Housing
Rising heat risk and poor insulation pose growing risks especially to vulnerable residents.
Ask: Reinstate or match former Code for Sustainable Homes Level 5–6, including:
• Passive cooling and ventilation
• Water efficiency and greywater systems
• Integrated green infrastructure (green roofs, trees, bunds, swales)

Section 5: Infrastructure, Climate Change and Resilience

General Comments on Section 5
London’s infrastructure strategy must be shaped by the principle of environmental justice: the communities most exposed to climate risks must be first in line for green infrastructure, resilience funding, and nature restoration.
The London Plan must help achieve a joined-up planning system — one that aligns housing need, environmental protection, and climate resilience across boroughs and sectors.

Paragraph 5.1 – Energy Efficiency Standards
The energy crisis has shown the failure of inefficient buildings. SERA strongly supports ambitious energy efficiency standards in new homes.
Ask: Make energy efficiency the foundation of London’s growth by requiring:
• Passive House standard or equivalent
• Building fabric-first approaches
• Integrated low-carbon heating and cooling
• Mandatory heat risk mitigation strategies

Paragraphs 5.5–5.7 – Green and Open Spaces, Biodiversity
SERA urges the GLA to retain and strengthen:
• Urban Greening Factor (Policy G5)
• Biodiversity Net Gain (Policy G6)
This must apply to all developments, including small sites, estate infill, and housing in the Green Belt.
Ask:
• Define and embed a Nature-Positive principle in the Plan: halt biodiversity decline by 2030, achieve recovery by 2050.
• Require that offsite BNG contributions be spent within London.
• Invest in borough skills and capacity to implement and monitor BNG.

Paragraphs 5.8–5.11 – Water, Rivers, Flooding
Climate pressures on water will intensify. SERA supports:
• Daylighting London’s buried rivers
• Rain gardens
• Greywater reuse and sustainable drainage
• Encouragement to depave front gardens to reduce runoff and urban heat
Ask:
• Include explicit targets and funding models for river daylighting and front-garden depaving
• Collaborate with boroughs and utilities on joined-up water strategies

Paragraphs 5.13–5.15 – Sustainable Transport and Corridors
London’s transport corridors offer underused space for nature and flood mitigation. SERA supports integration of green infrastructure into TFL works, roads, and cycling upgrades.
Ask: Set requirements for biodiversity enhancements on all major transport infrastructure, including:
• Planting for pollinators
• Shaded walking and cycling routes
• On-road stormwater management features

Paragraphs 5.17–5.19 – Air Quality, Heat Risk, Healthy Communities
Climate change will hit Londoners unequally — and dangerously. SERA urges:
• Mandatory overheating risk assessments for all developments
• Use of nature-based cooling solutions (trees, water, green space)
• Stronger protections for mature trees, especially in small sites and gardens
Ask: Require measurable heat risk mitigation as a planning condition. Invest in green space creation in deprived areas — London’s “natural health service.”

Cross-Cutting Recommendations
• Retain and strengthen environmental protections from the 2021 Plan
• Ensure all policies contribute to fair access to green space, with explicit targets for deprived communities
• Support cross-borough collaboration on nature recovery
• Register the GLA as a Responsible Body for BNG offsetting
• Fund training for borough planning officers in ecology and nature assessment
• Raise the profile and protection of Sites of Importance for Nature Conservation (SINCs) across London
• Use the planning system to help meet Labour’s 30x30 commitment and nature recovery targets