Greater London Authority referable thresholds explained

If your scheme crosses a GLA referable application threshold, the borough is no longer the only decision maker. The Town and Country Planning (Mayor of London) Order 2008 defines the categories of application that a London borough must refer to the Mayor, and for those applications the borough cannot grant permission until the Mayor has been consulted twice and has decided not to intervene. Plan for the extra weeks and the extra documents from the outset, because a referable scheme discovered late is a programme problem rather than a policy one.

Referral is a procedural power over the borough's decision, not a separate application. You submit to the borough as normal. The borough runs consultation and forms a view, and the Mayor gets two bites.

Which applications must be referred

The 2008 Order sets out three broad categories. The first captures development of a size or height that makes it strategically important, measured by residential units, floorspace or building height. The second captures development in locations where London-wide policy applies with particular force, including the Green Belt and Metropolitan Open Land, along with waste and minerals development. The third is the catch-all: applications the borough proposes to approve that conflict with the development plan in a way the Order specifies.

That third category catches schemes the applicant never expected to be referable. A modest proposal on Metropolitan Open Land, or one the borough intends to approve against its own designation, can be referred while a larger scheme elsewhere is not.

Check the Order itself rather than the borough's summary. Boroughs occasionally miss a trigger, and a permission granted without referral is vulnerable.

The unit, floorspace and height triggers

The residential trigger most people know is 150 or more houses or flats. Below that, a scheme can still be referable on floorspace or height, and both of those thresholds vary geographically: the floorspace figure differs between central London, the City of London and the rest of the capital, and the height figure is lower for buildings beside the River Thames than elsewhere. The numbers sit in Schedule 1 of the Order and have been amended, so read the current version rather than a secondary summary.

A few practical points follow from how the triggers are written:

1. Floorspace is measured as the development proposes it, so a mixed use scheme can cross the threshold on the total even where no single use is large.
2. Height triggers bite on the building, which means a tall element on an otherwise modest scheme makes the whole application referable.
3. Site area triggers for Green Belt and Metropolitan Open Land are small, and a single building in the wrong designation is enough.

Our note on mayoral referral thresholds for London residential schemes goes through the residential category in more detail. What matters at scoping stage is a yes or no answer, because the answer changes the evidence base.

Stage one: the Mayor's initial view

The borough refers the application after validation and consultation, and GLA officers prepare a Stage 1 report setting out whether the scheme complies with the London Plan. The report is published, goes to the Mayor or a delegated officer, and comes back to the borough as a formal response.

Stage 1 responses are long, specific and useful. They tell you exactly which London Plan policies the GLA thinks the scheme fails and what would fix it. Affordable housing tenure and the threshold approach, energy and carbon, whole life carbon, circular economy, urban greening, fire safety and transport all get their own paragraphs.

Treat Stage 1 as a negotiation document. The borough will expect you to respond to it, and a scheme that arrives at Stage 2 with the Stage 1 points unresolved invites a recommendation to direct refusal. Affordable housing is where most of the argument happens, which is why the Affordable Housing Statement on a referable scheme needs to engage with the threshold approach and the viability route rather than simply stating a percentage.

Stage two: allow, direct refusal or take over

Once the borough has resolved to grant permission, it refers the application again. The Mayor then has 14 days to do one of three things: allow the borough to determine the application as it proposes, direct the borough to refuse it, or direct that the application be determined by the Mayor instead.

The third option is the takeover. Where the Mayor becomes the local planning authority for that application, the Greater London Authority takes over the decision, holds a public representation hearing and issues the decision. That route has been used on schemes the borough resolved to refuse as well as ones it resolved to approve.

The Mayor cannot direct a borough to grant permission. So a borough resolution to refuse does not automatically trigger Stage 2 in the same way, and the Mayor's route in that situation is to take the application over.

Illustrative example: a 210 unit mixed tenure scheme on a former industrial site, referred at Stage 1 with objections on affordable housing tenure split and a shortfall against the urban greening factor. The applicant revised the tenure mix, added a green roof and a podium planting scheme, and the Stage 2 response allowed the borough to grant. Around seven weeks were added to the determination period across the two stages. The figures are illustrative and used to show the sequence.

What referral adds to the programme

Budget for the referral in the programme rather than assuming the statutory 13 or 16 week period absorbs it. Stage 1 needs the borough to have consulted and formed a view, and the GLA needs time to report. Stage 2 has its own 14 day window after the committee resolution. In practice a referable application is very unlikely to be decided inside the statutory period, and a planning performance agreement with an agreed timetable is normal.

There is a second programme effect that catches people out. Because the GLA scrutinises energy, carbon and fire, the technical work has to be finished to a higher standard at submission than a borough alone would demand, and that work sits on the critical path months earlier.

Pre-application engagement with the GLA

The GLA offers pre-application meetings for referable schemes and charges for them. Use them. A pre-application note from GLA officers gives you the Stage 1 issues before you have committed to a design, and the cost is small against redesigning after a Stage 1 report lands.

Bring the same material the Stage 1 report will test: the affordable housing offer and how it was arrived at, the energy strategy against the London Plan hierarchy, the transport strategy and the fire statement approach. Where the scheme is large enough to need screening, the Environmental Impact Assessment position should be settled before the meeting, because an unresolved screening question makes every other discussion provisional. An Environmental Statement must be prepared by competent experts under the Environmental Impact Assessment Regulations 2017, and an AI-assisted draft is a starting point for those experts rather than a substitute for them.

Preparing a referable submission

The document list for a referable application is longer than for a borough-only major, and the additions are mostly London Plan requirements: a whole life carbon assessment, a circular economy statement, an energy assessment following the Be Lean, Be Clean, Be Green, Be Seen hierarchy, urban greening factor calculations, play space provision and a fire statement. The list of statutory and non-statutory consultees also grows, as set out in our note on the statutory consultees that appear as a scheme grows.

Three habits make the process smoother. Write the planning statement so that London Plan policies are addressed by number and in order, because that is how the Stage 1 report is structured. Keep a single tracked schedule of GLA comments and responses. And do not leave the affordable housing position to be settled between Stage 1 and Stage 2, because that is the point at which the Mayor's bargaining position is strongest and yours is weakest.

This is general guidance, not legal advice, and the referral categories have been amended since 2008, so check the current Order and the position with the borough and the GLA before relying on it. PlanScope drafts the supporting documents a London major needs, structured to UK planning policy, with the site facts it cannot know flagged for you. Browse all 66 PlanScope report types and start a draft.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.