By Ella Moseley, Pegasus Group
Summary: The Mayor’s draft London Plan gives biodiversity the much-needed strategic role it deserves in shaping developments that add value to communities and improve climate resilience. Some elements of the Plan, however, could stand to receive clearer guidance.
Key changes:
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- Biodiversity, trees, habitats and geodiversity are bundled into the Green, Healthy and Resilient City framework (Policy GHR6).
- Stronger alignment with Biodiversity Net Gain and the Local Nature Recovery Strategy, pushing for habitat creation and connectivity, not just protection.
- Urban Greening Factor stays, but is now framed as complementary to BNG, not a substitute.
- Green infrastructure is treated as essential, multifunctional infrastructure for climate, health and placemaking.
- Areas that still need more clarity: clearer UGF–BNG rules, how LNRS priorities apply to BNG, and long-term management/enforcement over 30 years.
Sadiq Khan’s London Plan marks a notable shift in the role of biodiversity within the capital. No longer is the focus simply on mitigating harm or meeting basic policy tests, but rather on granting biodiversity a more strategic role that links nature recovery closely with economic growth, climate resilience, and placemaking.
No policy is perfect, but the Mayor’s proposed changes show a welcome direction of travel. Biodiversity is not relegated to the edge of development as an afterthought; instead, the Plan identifies it as an intrinsic part of how London grows, functions and builds climate resilience over time.
For applicants and project teams bringing forward major development across London, below are some key considerations to be aware of.
A more integrated policy framework
One of the most significant changes introduced by the draft London Plan is the consolidation of biodiversity, trees, habitat, and geodiversity within the Green, Healthy and Resilient City policy framework, including Policy GHR6 and supporting text.
Effectively, this should result in a much more integrated approach to protecting designated sites, trees, habitat, and geological features, while embedding nature recovery alongside climate resilience. This also reflects a more pragmatic understanding of how environmental planning works in the real world. Things like biodiversity, green infrastructure, flood management, urban cooling, and public health are all increasingly interrelated today, and the Plan rightly acknowledges that these outcomes should not be planned in isolation.
Nature recovery becomes more strategic
The draft attempts to more closely align developments in London with Biodiversity Net Gain mandates and the Local Nature Recovery Strategy framework.
On closer inspection, there’s now greater emphasis on using strategic nature recovery evidence not just protect existing biodiversity but to deliver ecological enhancements that expand and connect habitats.
Greater weight has also been given to strategic ecological networks alongside site-level mitigation. In practice, boroughs are expected to use relevant evidence to:
- Identify opportunities for habitat creation, expansion, and connectivity
- Support the review of Sites of Importance for Nature Conservation
- Encourage the increases of tree canopy cover where appropriate
To support this approach, the London Local Nature Recovery Strategy is intended to provide the spatial habitat evidence base and strategic biodiversity priorities. Our team at Pegasus Group welcomes this consideration of how the wider planning system can support nature recovery at scale; in the long run, we believe this will help development across London deliver stronger ecological and community outcomes.
What does the draft London Plan mean for Biodiversity Net Gain (BNG) and Urban Greening Factor (UGN)?
UGN remains an important criterion but the Plan now positions it as a complementary tool to BNG instead of a substitute. That’s an important distinction: UGN can no doubt help secure urban greening outcomes but should not replace measurable biodiversity enhancements.
The draft seeks to align the two tools so that both can contribute to nature recovery without unnecessary overlap. The challenge for applicants and boroughs will be to ensure that both tools are used coherently, with clear expectations on evidence and reporting.
Is green infrastructure now essential infrastructure?
The draft London Plan elevates the importance of green infrastructure within London’s wider development needs. It treats green infrastructure as essential infrastructure and reinforces the role of multifunctional green infrastructure in delivering biodiversity enhancement, climate adaptation, flood management, urban cooling, improved public health, and access to green space.
The ‘multifunctional’ wording is important framing for greenery in a city like London that has lots of constrained land and development pressures. Green infrastructure can do more than one job, which the draft recognises by drawing a link between more liveable places and well-designed networks of open space, habitat, and planting.
Nature recovery is also more explicitly embedded within growth and placemaking. More specifically, the Plan treats ecological enhancement as a vital part of place-based planning, including through strategic habitat connectivity, Green Belt enhancement, and nature-positive development. This avoids treating ecology as an environmental constraint to be mitigated in a vacuum.
What still needs clarity in the draft London Plan?
While the overall pivot towards making ecology a strategic part of placemaking is categorically positive, there is still some room for clearer guidance in some places.
- The relationship between UGF and BNG would benefit from clearer guidance to avoid duplication of evidence, assessment, and reporting requirements.
- Greater clarity is needed on how boroughs should apply Local Nature Recovery Strategy priorities when delivering BNG. This is particularly true where on-site gains and strategic off-site opportunities may not align.
- The Plan would benefit from greater emphasis on the long-term management and enforcement of BNG. Successful nature recovery hinges on habitat creation, as well as effective delivery and maintenance throughout the required 30-year management period.
- We would recommend amendments to the draft that make expectations around ecological connectivity across borough boundaries clearer, particularly in relation to river corridors, woodland networks, species movement corridors, and other strategic green infrastructure. These ecological networks do not stop at administrative boundaries, so the planning framework should more explicitly reflect that reality.
Despite the room for further clarification, the draft London Plan moves the needle in the right direction for biodiversity. It recognises the strategic role that biodiversity can and should have in the grander scheme of developments across London. Nature recovery – and the green infrastructure that supports it – is not only central to climate resilience but also to adding value to placemaking projects.
With some further policy clarification, the London Plan has real potential for to help move development across the capital away from a mitigation mindset towards a meaningfully nature-positive development.
If you have questions about how the London Plan might affect your development, please get in touch with Ella Moseley.
