The draft National Planning Policy Framework (NPPF) released in December 2025 is being sold as a simplification. However, in practice it is a major re-set of how strategic and local planning policies are written and how planning decisions will be made, including a centralising shift towards nationally defined decision-making ‘rules’, away from local discretion.
That matters for many reasons, as other TCPA blogs highlight, but one change is especially worrying in relation to the nation’s health: the draft NPPF quietly weakens the policy basis for tackling health inequalities. Oddly, this is happening at the very moment that planning legislation, devolution reforms and health strategy and policy are all pulling in the opposite direction.
What’s changed: an explicit commitment has disappeared
In the current NPPF (Dec 2024), national policy is clear that planning policy and decisions should ‘enable and support healthy lives’, especially where this would ‘reduce health inequalities between the most and least deprived communities’ (Paragraph 96c).
In the draft NPPF, references to health are present (indeed a basic word search finds 44 mentions), but a clear, specific purpose for planning to promote good health and reduce health inequalities is no longer clearly stated.
The NPPF will be out of step with new planning legislation and devolution reforms
The draft NPPF provides guidance on making strategic development strategies (SDSs), (policy PM1), as well as Local Plans (PM2).
Current law and governance reforms are aiming to tackle health inequalities as a core purpose, making the timing of this change to the NPPF baffling.
Current law and governance reforms are aiming to tackle health inequalities as a core purpose, but this revised NPPF removes that very same purpose from national planning guidance, making the timing of this change by MHCLG baffling.
In the Planning and Infrastructure Act (2025), new strategic authorities are explicitly instructed to consider the effect of any new SDS on ‘the health of persons in the strategy area’ and ‘health inequalities between persons living in the strategy area’.
Meanwhile, the English Devolution and Community Empowerment Bill, currently in the House of Lords, includes a health improvement and health inequalities duty for strategic authorities. This duty is framed around the wider determinants of health: housing quality; what streets enable (or prevent) people doing in terms of walking, wheeling, cycling and play; access to green space; exposure to air, and other, environmental pollutants; access to services and good work; and the community and social infrastructure that supports connection and resilience.
If Local Plans are to support the delivery of SDSs, why introduce the possibility of confusion and conflict over tackling health inequalities? Especially at a time when the evidence of the scale of poor health and health inequalities in England is so stark and persistent. ONS data for England shows that in 2020–2022 healthy life expectancy at birth was around 51 years in the most deprived areas, compared with around 70 years in the least deprived areas. This is roughly a 20-year difference.i
Health inequalities are systemic, place-based and shaped by factors beyond the NHS and the healthcare system.
Health inequalities are systemic, place-based and shaped by factors beyond the NHS and the healthcare system. They are defined and measurable, and planning is one of the few statutory levers that can shape multiple determinants of health at once in a comprehensive way. The new NPPF needs to grasp that opportunity with drive and clarity.
Promoting health communities: in policy but not decisions?
The draft NPPF’s new structure separates plan-making policies from national decision-making policies and is explicit that plan-making policies should not be used when determining planning applications. This split matters because the strongest health language in the draft sits in plan-making policies, not in the national development management policies that will carry weight in decision-making.
Proposed Chapter 16 ‘Promoting healthy communities’ sets an aim of creating healthy and inclusive places and minimising inequalities. It stops short of an explicit commitment to reducing health inequalities which are defined, and which the government already measure. Plan-making policy HC1 states that plans should take ‘opportunities to reduce inequalities through the availability of facilities’, rather than naming the reduction of health inequalities through actions on the wider determinants of health as a core purpose of Local Plans.
Proposed Chapter 16 offers no definition of what a ‘healthy and inclusive place’ is or the outcomes planning should secure to achieve one..
The chapter makes no reference to housing as a key determinant of health and offers no definition of what a ‘healthy and inclusive place’ is, or the outcomes planning should secure to achieve one.
The national decision-making policies focus largely on providing and protecting community facilities and social infrastructure. Such services are vital, but not enough. A healthy place is directly shaped by the well evidenced everyday conditions that can drive or reduce unequal health outcomes.
Because many English authorities do not have up-to-date Local Plans, national decision-making policies such as HC3 through to HC8 will carry very significant weight in decision-making and appeals until places can get development plans in place. In planning, clarity creates leverage. This change to the NPPF is the difference between health being a material consideration that can shape decisions and negotiations and health being a worthy aspiration that loses out to narrower (and often louder) priorities.
Evidence and Health Impact Assessment (HIA)
Finally, these changes are compounded by the omission of health evidence — including Health and Wellbeing Strategies, Health Impact Assessment (HIA) and Health Equity Impact Assessment— from the evidence that can be used for plan-making and decision-taking.
For plan-making (policy PM8), there is no overt reference to health evidence for shaping Local Plans, despite clear statements in the Healthy and safe communities Planning Practice Guidance that Health and Wellbeing Strategies and Joint Strategic Needs Assessments (JSNAs) are key strategies for local planning authorities to take into account when plan-making to improve health and wellbeing. For decisions policy DM2 (supported by Annex C on evidence and information requirements) does not list that any form of health evidence or health impact assessment be considered when determining development proposals.
HIA is an established approach for identifying how plans and developments affect health and health inequalities, and for shaping mitigations early enough to matter. Public Health England produced national guidance for local authority public health and planning teams on this in 2020 and over the last decade many Local Planning Authorities have embedded HIA approaches in their plan making processes and decision-making policies.
In the draft NPPF there is no mention of health evidence.
Yet in the draft NPPF there is no mention of health evidence or any clear expectation for proportionate HIA for plan-making, strategic allocations or developments likely to have significant impacts on health and wellbeing, including major planning applications.
The fact national policy does not explicitly require health evidence will lead to contested positions on the benefits and harms of proposals creating avoidable delays in decision-making.
What should change in the draft NPPF
If government is serious about healthy communities and reducing health inequalities, the fix is not complicated. Three changes would materially strengthen the draft and allow Local Planning Authorities to play their part in shaping local health outcomes:
- Restore ‘reducing health inequalities’ as a purpose of policy and decisions— bringing the NPPF into line with the Planning and Infrastructure Act (2025) and the English Devolution and Community Empowerment Bill, as well as supporting the government’s own stated health objectives.
- Strengthen the expectation that health evidence should be used to inform both plan-making and decisions in PM8 and DM2 and add health evidence to Annex C.
- Make proportionate HIA the norm for Local Plan making, locally appropriate development proposals and strategic allocations, and include it in the draft’s information requirements so applicants understand expectations upfront.
Why this matters now
This is a key moment. Planning reform is being framed around speed, certainty and delivery, but if we remove the explicit policy commitment to reducing health inequalities and weaken how health evidence is used in decisions, we risk building faster while entrenching the very inequalities that government says it wants to reduce.
The question isn’t whether planning should be about health. It already is. The question is whether national policy will be clear enough to result in healthier places.
