The proposed NPPF contains tangible regression on climate policy
The greatest test of the draft NPPF is its ability to provide a positive pathway through the climate crisis. To do so, it must deliver against legally binding net zero carbon targets and secure the long term safety and resilience of communities in the face of the growing climate crisis.
Putting aside the frustrating lack of priority this policy area has been awarded in recent years,[1] we must carefully consider whether the proposals will meet this urgent test. However, trying to answer that question is not easy. This is in part because the draft NPPF represents a radically different planning system, and piecing together the cumulative effect of changes across a diverse range of policy topics that have a bearing on local planning’s ability to address climate change is a complex task.
But it is also because the framework, when read as a whole, creates a much more permissive planning regime, subject only to a very limited number of policy safeguards, which do not include climate mitigation or adaptation.[2] As drafted, the expanded presumption in favour of development would undermine strategic approaches to locating development in the most climate resilient locations, weaken the application of local policy requirements on climate, and provide no avenue for refusing development on the grounds of creating unacceptably high levels of carbon emissions.
The framework, when read as a whole, creates a much more permissive planning regime, subject only to a very limited number of policy safeguards, which do not include climate mitigation or adaptation.
The need for evidence
Also of concern is the waning value placed on evidence. In our guidance on planning for climate change,[3] we are clear that robust carbon assessment and climate risk evidence is fundamental to developing a spatial strategy and development standards that respond to the climate challenge effectively.
Whilst the opportunity for planning authorities to produce carbon assessments is acknowledged in draft policy CC1, it frustratingly limits the scope of assessments to the spatial strategy and allocations, ignoring key sources of territorial emissions and energy demand, and the significant carbon impact of the qualitative and design aspects of development. The powerful policy hook of achieving ‘radical reductions’ in greenhouse gas emissions has been similarly constrained.
In addition, the draft framework will limit the information that planning authorities can ask for to help determine planning applications. Omitted from the prescribed list at Annex C are climate risk assessments, coastal vulnerability assessments, sequential and exception test evidence, and evidence on carbon emissions.
Barriers to delivering net zero (carbon) homes
Turning to specific climate policy areas within the NPPF, we find many areas of regression and confusion, which will prevent local planning authorities taking serious climate action.
Most harmful of these is the new prohibition on for net zero (carbon) homes. Ten years since the previous Labour government’s Code for Sustainable Homes should have come into force, this iteration of Labour is seeking to ban local authorities from setting aspirational standards for new development that go beyond building regulations. This will close an essential avenue for accelerating the delivery of highly energy efficient new homes, and withdraw from local authorities a vital lever for ensuring compliance with the carbon budgets.
The government is seeking to ban local authorities from setting aspirational standards for new development that go beyond building regulations.
The justification for this is the claim that local authorities are setting ‘varying standards’ in local plans,[4] but variation has in fact been limited to the use of a specific set of energy-based metrics which are backed by industry. There is therefore no evidential basis for this regressive move. The policy also seemingly prevents local policy from seeking high environmental standards for commercial development, using industry recognised certification schemes such as those developed by BREEAM.
Regression on flood risk policy
Also of huge concern is the regression on flood risk policy, which brings into the NPPF recent updates to the planning guidance, removing the requirement to apply the sequential test to sites at risk of surface water flooding.[5] Alongside weakened consultee oversight from Lead Local Flood Authorities and the Environment Agency, this incremental policy regression undermines vital safeguards.
The draft NPPF is a missed opportunity to introduce a more precautionary policy approach that would direct vulnerable development away from flood risk areas.
This is an extraordinary position for any government to adopt in the middle of a climate crisis where the challenge of flooding from all sources is becoming more extreme. The sequential test no longer fit for purpose, and the draft NPPF is a missed opportunity to introduce a more precautionary policy approach that would direct vulnerable development away from flood risk areas.
A complex picture
Other policy areas that are crucial for addressing climate change are both complex and contradictory. In sustainable transport we see progressive moves to further embed vision led transport in plan making, but development management policies that appear to offer a weak basis for refusing planning applications on the grounds of the carbon emissions from transport. The design principles include reducing carbon emissions through building layout, materials and resources, indicating embodied carbon as a concern for planning, which is seemingly at odds with policy directions to limit standards relating to construction.
There are other changes which we welcome, not least the long overdue restrictions on further fossil fuel expansion.
There are other changes which we welcome, not least the long overdue restrictions on further fossil fuel expansion. Further amendments on clean energy policy appear more supportive of community energy and encourages local plans to plan positively for renewable energy infrastructure. Changes to transport policy have the potential to properly prioritise sustainable transport strategies in plan making.
A confused and conflicted framework
But these gains do not temper the overriding direction of travel which ultimately will constrain and limit the scope of local plan climate policy, in many cases by pushing considerations to design at the site and building scale. This is undoubtedly important, but there are missed opportunities.
Importantly, there is no articulation of how the new strategic tier of plan making can comply with legal requirements on climate change and there is no requirement to take a strategic approach to climate resilience by placing adaptation and mitigation as a fundamental driver for spatial planning. This would require focusing not just on new development but recognising the need to radically reshape existing places.
The confused and conflicting framework we are presented with is symptomatic of an increasingly narrow view of what the planning system is should achieve.
The confused and conflicting framework we are presented with is symptomatic of an increasingly narrow view of what the planning system is should achieve. The blinkered prioritisation of granting housing permissions, with scant regard for their quality and long term sustainability leaves us stripped of the aspirational ability to places that support thriving, climate resilient and healthy communities. This further stripping out of an already underperforming system will leave us wholly incapable of tackling the urgent challenges we face.
The table below provides an overview of the TCPA’s initial assessment of how the draft NPPF would impact policy areas that are promoted in our guidance for local authorities on planning for the climate crisis.
[1] A comprehensive review of climate policy in the NPPF has been promised by government since at least 2021.
[2] For more detail see our blog on how the NPPF could affect local decision making: https://www.tcpa.org.uk/how-the-draft-nppf-could-affect-local-planning-decisions/
[3] See our updated resources here: https://www.tcpa.org.uk/collection/planning-for-the-climate-crisis/
[4] National Planning Policy Framework: proposed reforms and other changes to the planning system. MHCLG, December 2025. https://www.gov.uk/government/consultations/national-planning-policy-framework-proposed-reforms-and-other-changes-to-the-planning-system
[5] See our detailed policy briefing on this issue, available here: https://www.tcpa.org.uk/resources/a-dangerous-precedent-for-flood-risk-policy/
