By Claire Gayle, Heritage Director at Pegasus Group
The draft London Plan largely conforms to the current Plan on heritage considerations for developments across the capital. As opposed to other topics within the Plan, such as housing, it opts for more subtle changes, which includes tidying up and clarifying existing policies. However, some of the specific language shifts emphasis in ways that could favour developers.
The London Plan consolidates heritage policies into a singular framework
While there is no substantial shift in heritage strategy, the draft London Plan does consolidate various heritage policies from the 2021 London Plan into a singular policy.
More specifically, the draft has merged general heritage protection and targeted measures for London’s four World Heritage Sites into Draft Policy MBUL7: London’s Heritage. The aim here is clearly to avoid duplication, while maintaining protection for London’s key heritage assets.
The draft also puts more onus on Local Planning Authorities to provide policies relating to development on or near World Heritage Sites, and to maintain or update their own heritage evidence bases. That means maintaining and updating evidence pertaining to Greater London Historic Environment Record (GLHER) and Archaeological Priority Areas (APAs). This also extends to “non-designated heritage assets of archaeological interest of national importance to which the policies for designated heritage assets would apply,” which is in line with Footnote 64 of the National Planning Policy Framework (NPPF) (2026).
The expected outcome here is that boroughs must be more proactive in identifying potential assets that previously sat in a less clearly-defined category. Developers, in turn, should expect borough-level heritage scrutiny to reflect that in due course.
Energy efficiency receives more favourable wording in the context of heritage assets
One of the language changes with potentially big implications for Listed Buildings, for example, concerns energy efficiency. The draft London Plan now explicitly says that improvements to energy efficiency “should be supported” — which is language that did not exist in previous policy. This is significant given that one of the recurring tensions in heritage planning is the careful balancing act of retrofitting buildings for energy performance while preserving their architectural and historic interest.
Under the draft London Plan’s framing, decision-makers should certainly feel more empowered to support interventions that improve energy efficiency, rather than assume refusal where there is any impact on historic fabric. This does not necessarily mean energy efficiency supersedes the statutory requirement of the Planning (Listed Building and Conservation Areas) Act 1990, but the ‘level of harm’ and planning balance still applies. This approach is also in line with the guidance set out in Historic England’s Advice Note 18: Adapting Historic Buildings for Energy and Carbon Efficiency (2026).
However, there is more explicit policy backing now for any well-designed scheme proposals that improve a building’s performance without harming the overall special interest. This should prove useful for proposals that relate to retrofit schemes or mixed-used developments involving Listed Buildings or buildings in Conservation Areas. Developers may wish to reference this shift in tone explicitly in planning applications.
Standalone ‘loss of public houses’ policy is scrapped
While not strictly a heritage matter, the standalone policy relating to protecting public houses has been scrapped and incorporated into a new standalone night-time economy policy instead.
The wording around the loss of public houses could be interpreted as more positive now or more likely to favour new development or expansion, stating: “(6) accept the loss of a public house where there is no realistic prospect of the building being used as a public house in the foreseeable future supported by compelling marketing evidence.”
This is relevant to any developers working on town centres, high streets, or mixed-use schemes. The protection of public houses has historically been treated as a distinct policy area in the London Plan, reflecting the perceived community and cultural value of buildings like historic pubs. Many of these are identified as heritage assets, whether they are non-designated or simply fall within the boundaries of a Conservation Area.
The NPPF (2026) has emphasised that development proposals “should not result in the loss of key community facilities and public service infrastructure” unless there are exceptional circumstances, which could include marketing evidence that there is “no reasonable prospect of the use being retained.” It will be worth waiting to see how the Campaign for Real Ale (CAMRA) responds to the London Plan’s new combined strategy with the night-time economy generally, or if the Draft London Plan is amended to more closely match the new NPPF’s wording.
Do you have questions about heritage considerations for your London project?
While London’s heritage policy will not drastically change under the new London Plan, developers will still need clear and commercially-focused advice to navigate policy requirements. Early advice and engagement is more likely to secure planning permission but will also unlock opportunities for better placemaking in historic environments.
Our heritage team in London works closely with developers and landowners to provide pragmatic heritage advice at every stage of the planning process. This covers everything from site feasibility and due diligence to planning applications and appeals. Whether you are retrofitting a Listed Building, bringing development forward in a Conservation Area, or dealing with a non-designated heritage asset, we can advise on a variety of heritage constraints, as well as contribute to a robust planning strategy that leads to a positive outcome.
If you would like to discuss any heritage considerations for your London project, please get in touch with our team today.
