Decision details

To confirm Brent’s response to the Greater London Authority consultation on the Draft London Plan.

That the Corporate Director Neighbourhoods and Regeneration:

i)               Approves the submission of Brent’s response and answers and associated preamble to the draft London Plan to the Greater London Authority by 15 October 2026.

The draft London Plan is a key strategy that will shape Brent’s future, which the Borough Local Plan will have to confirm with once adopted. The response strikes a balance between supporting the general direction of travel of the Plan with regards to supporting sustainable growth (including addressing housing needs of residents) and highlighting technical ambiguities, such as the evidence underpinning housing targets.

The main points raised in the response relate to:

Ø  Strategic vision and delivery: The Plan should articulate a clearer vision for London’s future form, character, and identify, supported by better spatial mapping. It should be accompanied by a practical London-wide delivery strategy covering infrastructure coordination, land assembly, compulsory purchase support and cross-boundary planning.

Ø  Housing requirement and evidence: Brent is positive about optimising its potential capacity for additional housing requirements because increasing housing supply is necessary to meet the needs of Londoners. The GLA should publish clearer evidence on the sites and modelling inputs used, small-site assumptions, viability treatment and anticipated delivery uplift.

Ø  Affordable housing and local flexibility: The strategic 50 per cent affordable housing ambition is supported, but the proposed 25 per cent fast-track threshold should not become Brent’s permanent level of ambition. Borough should retain the ability to set higher or more locally responsive requirements where supported by evidence.

Ø  Design-led optimisation: Strategic guidance on density is welcomed, but density, height, accessibility and parking bands should not be applied rigidly across whole boroughs. Quality, character, infrastructure capacity, viability and local evidence must remain central.

Ø  Industrial land and economic growth: Brent supports protecting and intensifying industrial capacity, but the Plan should more clearly reconcile competing demands from housing, logistics, data centres and other uses, especially in the Park Royal / A40 / Heathrow property market area and at Staples Corner. Stronger GLA coordination is requested.

Ø  Town centres and place priorities: The response welcomes Wembley’s proposed Metropolitan town centre status, Church End’s recognition as a District Centre, and the strategic focus on Wembley and Staples Corner. It seeks a more nuanced approach to town-centre intensification and stronger links between growth, infrastructure, public realm and local economic inclusion.

Ø  Housing mix and specialist accommodation: Brent seeks discretion to determine market housing size mix using local evidence, including the borough’s need for family-sized and multigenerational homes. It also requests greater transparency in the distribution of student and supported housing requirements.

Ø  Climate and energy: The stronger performance-based approach is welcomed, but removing the carbon-offset mechanism could reduce investment in existing buildings and wider decarbonisation. Brent proposes a hybrid approach combining mandatory on-site standards, monitoring, corrective action and a limited contribution for unavoidable residual emissions or verified underperformance.

Ø  Green infrastructure and environmental quality: The response supports stronger protection of Metropolitan Open Land, biodiversity, canopy cover, accessible green space and urban greening. It seeks a more ambitious and locally responsive approach to tree replacement and industrial Urban Green Factor targets, together with clearer definitions and delivery mechanisms.

Ø  Transport and accessibility: sustainable transport and greater flexibility in cycle-parking provision are supported. The Plan should nevertheless allow site-specific evidence where borough-wide accessibility bands would lead to under or over provision.

The alternative option to not submit a response was not recommended because the Council would lose the opportunity to influence policies and strategic requirements that will have significant implications for Brent’s new Local Plan, development management and infrastructure planning.

The consultation response has been prepared alongside the pre-plan making stages of Brent’s new Local Plan and makes clear that the Council will test the Draft London Plan’s proposed housing requirement and other strategic assumptions through its own land availability, housing need, economic needs and viability evidence.