To	London Plan Team, Greater London Authority
From	Barnet Green Spaces Network
Date	2 September 2026
Subject	Draft London Plan 2026 – proposed strengthening of green-space policies

1. Overall response

Barnet Green Spaces Network (BGSN) brings together around 40 Friends groups representing parks and green spaces across the London Borough of Barnet. We welcome the Draft London Plan’s recognition that green and blue infrastructure is essential infrastructure, particularly as London grows and becomes denser.

We strongly support the plan’s use of the London Green Infrastructure Framework and Local Nature Recovery Strategy; the Urban Greening Factor; accessible green-space standards and Areas of Deficiency; protection of Sites of Importance for Nature Conservation; sustainable drainage; and the objective of cleaner, healthier waterways.

However, measured against the principles in BGSN’s Parks and Green Space Manifesto, the draft does not yet give adequate protection to the full range of green spaces or ensure that promised environmental gains will be delivered, maintained and monitored. Several important provisions are qualified, limited to designated land or major development, or left to local discretion. That is a particular concern in boroughs facing substantial housing growth, including Barnet, where the draft identifies a ten-year housing target of 32,730 homes.

We therefore support the environmental direction of the draft, subject to the changes below. Our requests are intended to make the plan clearer and more effective, while allowing sustainable housing growth to proceed alongside – rather than at the expense of – the green infrastructure on which existing and new communities depend.

2. Priority amendments sought

Protect all existing green space, not only designated publicly accessible green space. Amend Policy GHR8 so that the starting point is no net loss in area, function, quality or accessibility of all existing green and open space, including undesignated land, small green frontages, incidental green space, community gardens and ecologically valuable brownfield land. Ownership or an incomplete policies map should not determine whether a space is valued.

Make avoidance the clear first step. Require applicants to demonstrate that loss or harm has first been avoided through alternative layouts and design. Replacement or off-site compensation should be a last resort and should not make the loss of an established space, mature habitat or tree acceptable by default.

Strengthen tree protection and set measurable canopy objectives. In Policy GHR6, replace qualified wording such as ‘wherever possible’ with a clear avoid-minimise-compensate test. Require no net loss of canopy cover at maturity, borough canopy targets, protection of rooting environments and replacement that reflects time-lag, ecosystem services and survival.

Go beyond the statutory minimum for biodiversity gain. Set a London-wide expectation demonstrably above 10 per cent Biodiversity Net Gain – BGSN suggests 20 per cent – while permitting boroughs to adopt higher evidence-based targets. Require on-site delivery first, connectivity with the LNRS, and long-term monitoring.

Add pollinators, hedgerows and ecological connectivity explicitly. Require development and local plans to protect and reconnect habitat corridors, including hedgerows, railway edges, road verges, gardens and waterways, and to provide season-long, pesticide-free habitat for pollinators.

Introduce a London-wide dark-skies and ecological-lighting requirement. Extend control of light pollution beyond tall buildings and general public-realm amenity. All relevant development should demonstrate that artificial light is necessary, minimal, directed, time-limited and designed to avoid harm to wildlife corridors, trees, waterways and SINCs.

Secure nature-friendly management and permanent stewardship. Management plans should cover establishment, funding, replacement, pesticide reduction, ecologically sensitive mowing and habitat care for the lifetime of the development. They should be secured and publicly available, with a named responsible body and enforceable review arrangements.

Put communities and Friends groups into the policy process. Require early consultation with established Friends groups and relevant community organisations on proposals affecting green space, and their involvement in management plans where appropriate. Voluntary groups should inform decisions, but must not be treated as a substitute for properly resourced public management.

Strengthen waterway restoration. Apply community engagement principles to all waterways, not only the Thames. Policy GHR9 should explicitly support naturalisation, removal of culverts where feasible, buffer habitats, action on misconnections and measurable improvement in ecological condition.

Tie growth to green-infrastructure capacity, funding and monitoring. Green infrastructure needs should be assessed alongside housing and other infrastructure. Local plans and major schemes should identify capital and revenue funding, including ring-fenced planning obligations where justified, and report publicly on loss, gain, condition and access.

3. Detailed comparison and requested changes

3.1 Policy GHR8 – Accessible green space

GHR8 contains valuable provisions: local plans are to map accessible green space and Areas of Deficiency; major development should contribute to additional provision; and designated publicly accessible green space should not be lost. The weakness is the narrow protection in part B. Many locally important spaces are undesignated, privately owned but publicly valuable, too small to meet a category neatly, or omitted from an out-of-date policies map.

The manifesto rejects the idea that a green space is expendable because it has been labelled low value or low quality. Condition can be improved; it should not become a reason for development. The plan should also distinguish genuine green-space provision from features such as a green roof or street planting: these are valuable, but do not necessarily replace accessible ground-level space.

Requested change: amend GHR8(B) to prevent net loss in the area, function, quality, biodiversity value and accessibility of existing green or open space, whether designated or not. Any loss should require a robust needs and value assessment, proof that avoidance is not feasible, and equivalent or better replacement in advance, within the same walkable catchment. Add a presumption that poor condition is a case for restoration, not loss.

3.2 Policy GHR6 – Trees, biodiversity and geodiversity

We welcome protection for ancient woodland, veteran trees and SINCs; use of the LNRS; support for habitat connections; arboricultural assessments; and replacement based on the benefits of removed trees. However, parts B and C rely on ‘where possible’ and ‘wherever possible’. Those qualifications invite tree retention to be balanced away too early, especially where a higher-density layout is preferred.

Requested change: require design around trees of value and their future rooting and canopy space unless an applicant proves, through tested alternatives, that retention is genuinely unavoidable. Replacement must be additional to ordinary UGF and BNG obligations, reflect the long time needed to replace mature canopy and ecosystem services, and include funded establishment, monitoring and replacement of failures. Local plans should set and monitor canopy-cover targets, prioritising heat-vulnerable and canopy-deficient neighbourhoods.

3.3 Biodiversity Net Gain and ecologically valuable brownfield land

GHR6(E) requires gains only ‘in accordance with national BNG requirements’. This misses the opportunity for London to set a higher strategic expectation and does not fully address brownfield sites which have acquired significant habitat value.

Requested change: set a London-wide minimum of 20 per cent BNG, subject to the evidence supporting the final plan, with explicit support for higher local targets. Require the mitigation hierarchy, on-site delivery first, LNRS connectivity, and transparent long-term monitoring. Add explicit protection for Open Mosaic Habitats on Previously Developed Land and other priority habitat, so that ‘brownfield first’ is not treated as ‘biodiversity last’.

3.4 Policy GHR7 – Green infrastructure and Urban Greening Factor

The UGF targets and recognition of retained green cover are welcomed. Nevertheless, a numerical score can allow small or technically convenient features to be combined in place of mature, connected and publicly useful green infrastructure. The policy applies the UGF only to major development, leaving cumulative impacts from smaller schemes insufficiently addressed.

Requested change: state that the UGF does not override requirements to retain existing green space, trees and habitats, meet BNG, provide accessible green space or follow the mitigation hierarchy. Require qualitative tests for ecological connectivity, public benefit, climate resilience and maintainability. Boroughs should be supported to apply a proportionate greening requirement to smaller development and cumulative intensification.

3.5 Dark skies, pollinators and pesticide-free habitat

The plan refers to lighting impacts near SINCs and controls light pollution in tall-building and public-realm policies, but it contains no coherent London-wide ecological-lighting policy. It is also largely silent on pesticides and does not give pollinator networks explicit recognition.

Requested change: add a cross-cutting requirement for ecological lighting assessments where development may affect habitats or corridors. Lighting should follow an avoid-first hierarchy, protect dark corridors and use controls such as appropriate siting, shielding, intensity, spectrum and operating hours. Landscape and habitat plans should provide season-long forage and nesting opportunities, avoid routine pesticide use and employ ecologically sensitive management.

3.6 Policy GHR9 – Clean and healthy waterways

The attention to water quality, misconnections, natural corridors, access and SuDS is strongly supported. Community engagement is, however, expressed principally through the Thames riverside principles, while many of Barnet’s smaller rivers and streams also need restoration and public stewardship.

Requested change: extend early community engagement to all waterways and explicitly require local plans and relevant development to identify opportunities for naturalisation and de-culverting, restore vegetated buffers, remove barriers where appropriate, tackle misconnections and improve ecological status. Access improvements must be designed so that sensitive habitat is protected.

3.7 Long-term management, funding and participation

GHR7 says conditions or obligations may secure management; GHR8 requires management and maintenance plans for additional or re-provided green space. These provisions should be firmer and should apply to retained and enhanced assets as well as new ones.

Requested change: require costed management plans for the lifetime of the development, covering capital works, revenue funding, ecological objectives, inspection, replacement and reporting. Plans should identify a responsible body and be publicly available. Local Friends groups and community organisations should be consulted early and, where they wish, involved in stewardship arrangements. Their participation must complement, not replace, trained and adequately funded staff.

3.8 Greener streets, structures and health

The manifesto seeks conversion of under-used grey space into planted street parks, restoration of park structures, support for green social prescribing and recognition of the many health benefits of green space. Elements appear across MBUL9, GHR4, GHR7 and GHR8 but are not brought together as delivery expectations.

Requested change: strengthen MBUL9 and GHR7 to require area strategies to identify opportunities for pocket parks, rain gardens, street trees and conversion of surplus hardstanding, particularly in areas deficient in green space and exposed to heat or pollution. Supporting text should encourage the conservation and active community use of suitable park buildings, and recognise green social prescribing when planning accessible green infrastructure.

4. Suggested policy wording

The following wording is offered as a practical route to implementing the changes above. It is not intended to preclude equivalent drafting by the London Plan team.

GHR8(B) – replacement wording

Development proposals should avoid the loss or degradation of existing green or open space. They should not result in a net loss of its area, function, quality, biodiversity value or accessibility, whether or not the land is designated or publicly owned. Where harm is claimed to be unavoidable, the applicant must demonstrate that reasonable alternative designs have been tested and must secure equivalent or better replacement in advance within the same walkable catchment. Poor condition or under-investment shall not, by itself, justify loss.

GHR6(C) – strengthened tree test

Development proposals must retain trees of value and protect the soil, rooting environment and future canopy space needed for their long-term health, unless robust evidence demonstrates that removal is unavoidable after reasonable alternative layouts and construction methods have been tested. Any unavoidable loss must be compensated in addition to ordinary UGF and BNG requirements, with replacement reflecting canopy, amenity, ecological and climate-regulation value and the time required for those benefits to mature.

GHR6(E) – biodiversity gain

Development should deliver at least 20 per cent Biodiversity Net Gain, unless a higher target is set by an adopted local plan, and must first avoid and minimise harm. On-site delivery and contributions to priorities and connections identified by the LNRS should be prioritised. Delivery, condition and management must be secured and reported for the required period.

New ecological-lighting clause

Development must avoid unnecessary artificial light and prevent adverse effects on habitats, species, trees, waterways and ecological corridors. Where lighting is necessary, it must be the minimum needed for its purpose and be appropriately located, directed, shielded, spectrally designed and time-controlled, informed by ecological evidence.

New community-stewardship clause

Local plans, area strategies and development proposals affecting green or blue infrastructure should involve established Friends groups and relevant community organisations at an early stage. Costed, enforceable and publicly available management plans must identify long-term ecological objectives, funding, monitoring and the body responsible for delivery. Community participation must not substitute for adequate professional resources.

5. Monitoring and delivery

The final plan and Annex A should include indicators capable of showing whether growth is producing a genuinely greener London. At minimum, the monitoring framework should report:

• total area and condition of green space, distinguishing losses and gains and identifying whether land is designated and publicly accessible;
• households and daytime populations within the accessible green-space standards, including inequalities between neighbourhoods;
• tree canopy cover, mature-tree loss, replacement survival and canopy projected at 15 and 30 years;
• BNG promised, delivered and maintained, including the proportion delivered on site and within London;
• condition and connectivity of priority habitats and progress against LNRS priorities;
• waterway ecological condition, misconnections remedied, and lengths naturalised or de-culverted;
• amounts of developer funding secured and spent on green infrastructure, including long-term maintenance; and
• evidence of early community and Friends-group participation in relevant strategies and management plans.

6. Conclusion

The Draft London Plan contains a valuable framework for green infrastructure, but its stated ambitions will be undermined if existing local spaces can be lost because they are undesignated, if mature trees can be removed before alternatives are fully tested, or if new greening is delivered without durable management and community involvement. Green space is not residual land: it is essential social, health, climate and ecological infrastructure.

We ask the Mayor and London Plan team to strengthen Policies GHR6-GHR9 and related policies in the ways set out above, and to carry the changes through into implementation guidance, viability assumptions and the monitoring framework. This would give boroughs, applicants and communities a clear and consistent basis for accommodating growth while protecting and improving London’s green inheritance.

Source documents reviewed

• Mayor of London, Draft London Plan 2026: especially MBUL9; HN8; GHR4-GHR9; PV6-PV7; Annex A; and the housing target in Table 3.1.
• Barnet Green Spaces Network, A Parks and Green Space Manifesto for the Local Elections in May 2022 (final, 21 February 2022).