Max Fordham urges Retrofit First test and tighter housing standards in draft London Plan response

Max Fordham has published its response to the Draft London Plan 2026, opposing proposals to relax ceiling height, kitchen daylight and single-aspect home rules and calling for a Retrofit First test where substantial demolition is planned.

The practice published the response on 30 October 2026 with five named contributors: David Montgomery, Principal Engineer and Partner; Kiru Balson, Principal Sustainability Consultant and Partner; Chris Price, Senior Sustainability Consultant; Anna Bardos, Principal Sustainability Consultant and Partner; and Conor Haselden, Senior Passivhaus Consultant and Partner.

Max Fordham describes the draft as the Mayor of London's proposed replacement for the London Plan 2021. The practice said the draft was published in July 2026 with consultation running up to October.

Housing design

On the housing design section, Max Fordham said it opposes proposals to reduce requirements for ceiling heights, natural light and passive ventilation for kitchens, and to relax restrictions on single-aspect homes. The practice said these changes "could increase overheating and energy use while reducing residents' comfort and wellbeing".

It does not support cutting the minimum floor-to-ceiling height to 2.4m. The practice pointed to the Good Homes Alliance early-stage overheating risk tool checklist, which it said is referenced in the draft's heat risk policy GHR4 and requires a minimum of 2.8m so that ceiling fans can be installed later.

Max Fordham also objects to excluding kitchens from the definition of residential habitable rooms that must receive natural light and have openable windows. It said kitchens without natural light and ventilation to the working area would need more lighting and ventilation and may be more prone to overheating.

On single-aspect homes, the practice said the London Plan 2021 states they should be avoided, whereas the draft only asks developments to seek to minimise them. It does not support that softening of language.

Circular economy and demolition

On circular economy policy GLE11, Max Fordham said the Circular Economy Statement should influence a development rather than be mainly a reporting exercise, and it recommended a clear hierarchy similar to a retrofit first policy.

Where substantial demolition is proposed, the practice said London should introduce a proportionate Retrofit First sequential test. It cited Westminster as an established model in which applicants must justify substantial demolition with sequential evidence rather than simply showing that retention was considered.

Westminster City Council formally adopted its new City Plan, including the Retrofit First policy, at Full Council on Wednesday 21 January 2026. The council said the policy requires developers to fully explore reasonable options for retrofitting and extending existing buildings before demolition.

Cllr Geoff Barraclough, Cabinet Member for Planning and Economic Development at Westminster City Council, said at the time: "Our Retrofit First policy will reduce carbon emissions from development".

Max Fordham also wants direct reuse measured separately from recycled content, saying grouping the two in a single percentage does not recognise their different resource and circularity outcomes. It supports the strategic waste stream targets but wants a circularity metric considered as well.

Energy and whole life carbon

The practice said it broadly supports the draft's approach to energy efficiency and low-carbon heat, including the move to energy use intensity (EUI) and space heating demand (SHD) standards, renewable energy provision and post-construction monitoring. It proposed allowing Passivhaus certification as an alternative route to compliance.

However, Max Fordham said it does not consider the residential EUI targets currently deliverable, and that they are particularly unrealistic for high-density apartment blocks. It called for a consistent methodology, realistic baselines and more clarity on regulated and unregulated energy, whole-building assessment and occupancy.

On whole life carbon, the practice welcomed the shift from reporting embodied carbon to requiring reductions. It said the policy should apply to all major developments, not only referable applications, and that the proposed upfront carbon limits need a more robust evidence base. It added that the targets rely on GGBS as the only mainstream cement replacement, used in higher proportions than are typically available.

On heat risk policy GHR4, Max Fordham said it does not believe the policy will be effective. It wants guidance to require dynamic modelling against current and future climate scenarios, with developments meeting the relevant CIBSE compliance criteria for all weather files.

The practice

Max Fordham was founded in 1966 and now numbers more than 250 people. It describes itself as a partnership in which around half of its people are partners, and says all five of its offices are verified as net zero carbon.