Our response to the Mayor of London’s consultation on the draft London Plan strongly supports his ambition to deliver good growth across London and strengthen the capital’s position as the UK’s economic powerhouse. We welcome positive changes in the draft Plan, including recognition of the need for net additional prime office space in the Central Activities Zone (CAZ), greater flexibility on affordable workspace policy via off-site provision and payment in lieu and proposed reductions to cycle parking standards.
However, we have identified a number of areas where our members believe the draft Plan should go further to support growth, investment and delivery across central London.
Central to our response is the need for the London Plan to plan positively and aspirationally for office growth over the next 25 years. To support this, we are calling for a dedicated office policy that puts offices on a par with data centres in the Plan and sets out a clear vision for office growth, alongside overarching employment and floorspace targets linked directly to the Mayor’s London Growth Plan.
This is particularly important at a time when London’s success is increasingly at risk from a shortage of modern workspace, rising development costs and growing constraints on development. Ensuring a sufficient supply of modern, high-quality office space is therefore fundamental to supporting business expansion, attracting investment and delivering the Mayor’s ambitions for good growth. Offices should be explicitly recognised as critical economic infrastructure, supporting jobs, investment, productivity and London’s competitiveness.
Our key points are:
- A standalone offices policy: The Plan should include a standalone office policy that sets out a clear vision for office growth, consistent with previous London Plans, alongside strategic employment and floorspace targets aligned with the London Growth Plan. This will help ensure London can accommodate the businesses, jobs and investment that drive economic growth. Offices should also be recognised as critical economic infrastructure, reflecting their central role in delivering the objectives of the Government’s Modern Industrial Strategy. We are particularly concerned that the evidence base underestimates future demand for office space in Westminster and the City of London. The Plan should therefore strengthen its approach to monitoring, requiring boroughs to track and report on the loss of office floorspace to ensure sufficient capacity is maintained to support future growth.
- Recognising the benefits of high-quality office space: We welcome the Plan’s recognition of the need for net additional prime office space within the CAZ. However, the Plan should go further by giving significant weight to the economic benefits of delivering high-quality office accommodation, particularly HQ-quality workspace with large floorplates capable of accommodating major occupiers and supporting business growth. Such provision is critical to attracting and retaining investment, boosting productivity and sustaining London’s global competitiveness. Local Plans within the CAZ should therefore plan positively for ambitious office growth, providing greater certainty for investors and developers and supporting the delivery of the next generation of commercial development.
- Unlocking growth potential: The Plan should take a positive approach to growth by supporting the optimisation of sites, enabling tall buildings in appropriate locations and providing a stronger framework for Transformational Gateways, including Liverpool Street and Victoria. This will help to maximise development potential in the CAZ, avoiding unnecessary constraints on height, density and sustainable intensification. The Plan should support a flexible approach to tall buildings and allowing for new metropolitan-scale clusters, such as Fleet Valley, where justified. Transformational Gateways should be backed by clear growth ambitions, infrastructure priorities and delivery frameworks.
- Affordable workspace: While we welcome greater flexibility around off-site provision and payment in lieu, affordable workspace policies should not apply within the CAZ, where rising development costs, increasing policy requirements and viability pressures are already constraining office delivery. This is reflected in a 54% decline in major commercial planning applications in central London between 2013 and 2023. The market already provides a diverse range of lower-cost, flexible and managed workspace products that cater to different business needs. Where affordable workspace policies are pursued in the CAZ, they should be supported by robust local evidence of need and subject to thorough viability testing to ensure they do not further undermine investment and development.
- Carbon benchmarks: We broadly support the proposed embodied carbon benchmarks, which are largely consistent with the findings of Arup’s London Property Alliance Embodied Carbon in Central London (2026) analysis. However, that evidence suggests tall office buildings are less likely to meet the proposed targets. We therefore welcome the recognition in the supporting text that offices in the CAZ, tall buildings and developments on constrained sites may face particular challenges in achieving the benchmarks. This flexibility should be reflected more explicitly in the policy wording itself, making clear that where applicants have demonstrably minimised embodied carbon and provided justification, failure to meet a benchmark will not in itself constitute non-compliance with the policy. This is important to ensure carbon policy supports both decarbonisation and the delivery of the commercial development needed to drive jobs, investment and growth.
- Cycle parking: We strongly support the proposed reduction in cycle parking standards, reflecting our Cycling & the City (2024) and The Cycle Storage Gap (2026) research and positive engagement with TfL and the City of London. Where a development provides cycle-hire facilities or additional provision for dockless bikes, this should be reflected in corresponding reductions in cycle-space requirements and, where appropriate, public-realm obligations.
