The Engineers Reuse Collective has provided a response to the draft London Plan consultation 2026 regarding the following policies:

• GLE11: Circular economy
• GLE12: Waste
• GHR3: Whole life-cycle carbon
• MBUL7: London’s heritage
• HN2: Protecting and reshaping housing

A copy of our full response can be downloaded below, but in summary:

We welcome the Mayor’s decision to retain and strengthen circular economy policy in the draft London Plan, and recognise that this draft goes further than the 2021 Plan in requiring Circular Economy Statements, setting waste diversion targets, and linking retention of existing buildings to embodied carbon reduction. This represents genuine progress.

However, we do not believe the draft Plan is ambitious enough to deliver the scale and pace of change needed to shift London’s built environment from a linear to a circular model within the timeframe the climate emergency demands. Our central observation is one of internal coherence rather than of disagreement with the Mayor’s direction. The Plan’s reasoned justification already states the right principle. Paragraph 5.30 says that retaining existing built structures for reuse and retrofit ‘should be prioritised before considering substantial demolition, as this is typically the lowest-carbon option’, and paragraph 4.95 says that ‘strategies which prioritise retention of existing structures should be robustly considered’. What the policies then do is narrower than what the justification promises. The requirements that matter most apply to a small subset of referable schemes, retention is framed as an assessment rather than a sequence with an outcome, the most ambitious carbon figures are aspirational rather than mandatory, the reuse hubs on which construction product reuse depends are supported if proposed but never planned for, and the Plan’s monitoring framework does not track circular economy delivery at all.

Critically, this gap is not a matter of what is achievable. Westminster City Council has already adopted and is operating a materially stronger set of requirements under its Policy 43 (Retrofit First), found sound at independent examination, with published evidence of delivery. Nor is this a single-borough outlier: the City of London Corporation is moving in the same direction, with its own retrofit-first approach already shaping outcomes and a statutory retrofit-first design policy currently in examination. Our position is therefore that the Plan should as a minimum adopt requirements equivalent to those already in force in Westminster, and should ideally go further and faster, given the Plan’s London-wide reach and the pace the Mayor’s own stated climate position demands.

The publication of a new National Planning Policy Framework on 17 August 2026 changes the context in two ways that both point in the same direction. National decision-making policy now expects all development proposals, at every scale, to take opportunities to reuse existing structures and materials, and directs substantial weight to the benefits of improving existing buildings. At the same time, plan-making policy PM13(2)(b) allows development plans to set quantitative standards on other matters not addressed by Building Regulations, which opens the way for a local embodied carbon standard, where these have a clear and robustly costed rationale, are proportionate and will not harm viability or deliverability. This matters particularly because the Plan states at paragraph 1.1 that it was prepared having taken into account the draft NPPF published in December 2025, and explains at paragraphs 5.10, 5.19 and 5.20 that it moderated its own ambition in deference to that draft’s standardising intent. The final Framework departed from the draft on that point: it no longer restricts local standards on matters such as embodied carbon. The Mayor therefore has both a national policy expectation to meet and an express national policy route to meet it, and the stated reason for the Plan’s restraint has been removed.

The Plan’s own Integrated Impact Assessment (IIA) reinforces the case. It records that London is not currently meeting the Mayor’s target of net zero by 2030, and assesses the Plan as a whole as having only mixed minor positive and minor negative effects on climate change. It identifies no reasonable alternatives for GLE11, GHR3, MBUL7 or HN2, although it appraised alternatives for sixteen other policies, including a more ambitious alternative for GHR1. It attributes significant positive effects to GLE11 and GHR3 without accounting for their confinement to referable schemes or for paragraph 5.31, and it proposes no indicator to monitor those effects. It identifies embodied carbon effects from tall buildings and from redevelopment in the Central Activities Zone, but recommends no mitigation for either.

We ask the Mayor to use this consultation to close that gap between ambition and mechanism, in line with our specific policy comments made above.

We support the direction of the draft Plan, which goes further than the current Plan. But we do not think it shows the ambition or the leadership London needs on existing buildings and embodied carbon.

The Plan’s own words, in paragraphs 5.30 and 4.95, already say that keeping existing buildings should come first. The policies do not make that happen. Where Government has left a gap, the construction industry, Westminster and the City of London have each stepped forward. The London Plan should be leading them, not following.

National planning policy now expects this and allows it. The GLA’s own assessment shows why it is needed: London is not on track for its 2030 target, and the Plan as drafted is not expected to change that much. We ask the Mayor to use this Plan to lead.