Given the timing of last year’s update to the National Planning Policy Framework and this year’s consultation on further revisions to the Framework, it seems that the Government is trying to establish a new Christmas tradition for those working within the built environment sector. In the spirit of the season, we have asked the keen elves who lead our key sectors to check the draft twice and provide their initial views on what’s naughty and nice.
Is planning policy keeping pace with the challenges of climate change, sustainable transport and biodiversity? The Government’s latest consultation on the National Planning Policy Framework (NPPF) suggests it’s trying to do just that. Here’s what our clients and fellow professionals need to know at a glance:
- Planning: Clearer separation between plan-making and decision-making policies, though it remains to be seen how much weight plan-making policies will carry in decisions.
- Housing Delivery: New measures aim to accelerate development, with SMEs playing a bigger role, higher-density housing near rail stations encouraged and greater opportunities for land within the Green Belt and Grey Belt to be brought forward for development.
- Transport & Connectivity: Vision-led planning is reinforced, with the DfT Connectivity tool now central to assessing sustainable travel options.
- Climate & Nature: Stronger emphasis on green infrastructure, water efficiency, effective reuse of materials, and nature-based solutions to tackle flood risk, urban heat, biodiversity loss and support the transition to net zero.
If you want to know more, keep reading for a more detailed analysis.
Supporting development
The draft NPPF introduces measures aimed at accelerating delivery across different scales of development. For medium-sized sites (1ha–2.5ha), new policy seeks to boost delivery by small and medium-sized enterprises (SMEs), recognising their role in diversifying housing supply and unlocking stalled land. For larger residential and mixed-use sites, conditions may be applied to require timely submission of reserved matters applications, helping to maintain momentum and avoid delays in bringing forward homes and the necessary supporting infrastructure.
The consultation also signals a more flexible approach to land supply, with Green Belt and Grey Belt sites expected to play a greater role in meeting housing numbers, including challenges around connectivity and biodiversity net gain. In addition, there is a clear push for higher-density development near well-connected railway stations outside existing settlements, subject to minimum service levels. This reflects a broader ambition to align growth with sustainable transport options, reducing car dependency and supporting vibrant, accessible communities.
Movement
The draft reinforces vision-led approaches to transport planning, with greater emphasis on strategies that minimise the need to travel and reduce distances through land use planning. These principles are core elements of the vision-led approach and are very much in line with the triple axis approach to movement planning.
The DfT Connectivity tool is now referenced as a key resource, and transport professionals and planners will need to get to grips with connectivity scores and how these might be influenced by land use planning and investment in sustainable travel measures.
The serve impact test is retained and is extended in scope to consider transport rather than road networks. Overall, this change is positive as it will require better consideration of the generation of trips by all modes rather than just vehicle movements. There is proposed to be greater flexibility in the policy tests around transport choices which may be beneficial to sites in rural areas or land uses where sustainable travel options are less practical.
The draft includes the widely advertised policies encouraging development in locations near rail stations, but only where the rail network provides sufficient levels of service and where development can be delivered at sufficient density.
Parking standards must be set as part of a local plan, and these should align with a plan’s transport vision. There is a notable shift here towards maximum standards as a tool to support sustainable travel choices and higher-density development.
Active travel features prominently throughout the draft, with positive references to continuous footway crossings, segregated cycleways and inclusive design for disabled people, older people and children. However, the absence of a reference to specific consideration for women and girls is a missed opportunity.
Place
Placemaking principles are largely retained from the existing framework, but greater emphasis is placed on the need for local plans to identify where design guides, codes and masterplans are required for development including those coming forward in key regeneration areas and town centres.
The key features of well-designed places within the draft are noted to be Liveability, Climate, Nature, Movement, Built Form and Public Space, all of which need to be informed by context.
Notably, the reference to Building for a Healthy Life is absent from the draft, although it is suggested that this guidance will be referenced within the forthcoming Design and Placemaking Planning Practice Guidance.
Climate Change
Climate change policies are brought forward in the framework, this shift clearly signals their importance and emphasises that climate impacts extend far beyond water management. Local authorities would be given greater flexibility to set tighter water efficiency standards, and there’s a strong push for green infrastructure and nature-based solutions to tackle urban heat, reduce biodiversity loss, provide resilience against extreme weather and to support the transition to net zero.
Infrastructure and Water Management
A proposed new section on clean energy and water infrastructure encourages early engagement with providers to ensure that there is sufficient capacity for water supply, drainage and wastewater treatment, with the aim of enabling engineers and master planners to accommodate suitable provision from the earliest stages of planning, including considerations around water quality and the management of pollution.
It is notable that the draft suggests that applicants will no longer need to justify water infrastructure projects, helping water companies to deliver strategic resource options more efficiently.
Flood Risk and Drainage
While the changes to flood risk and drainage policy are not radical, they aim to provide greater clarity and incorporate key elements of the Planning Practice Guidance directly into the NPPF. We are pleased to see that the Vulnerability Classifications of Data Centres and green energy solutions such as Carbon Capture (Essential Infrastructure) have been confirmed.
Policy updates clarify when sequential tests and Flood Risk Assessments are required, with a shift in language from ‘should not be permitted’ to ‘should be refused’ for high-risk sites. While there is a greater emphasis placed on the impacts of climate change, this does not have any impact on flood zone definitions.
Redrafted policies around safety from flooding require that proposals “should not present a risk from flooding”, however the term ‘risk’ needs to be clarified or defined, to ensure that this does not blight areas with extensive flood risk (unmanaged) such as London, East Anglia or Somerset,. Related to this there is a greater emphasis placed on emergency planning to manage residual flood risk.
Additionally, the draft encourages developers to consider opportunities to de-culvert watercourses, stating that culverting should only occur where there are compelling reasons.
On surface water drainage the draft proposes referencing the, recently published, National Standards for Sustainable Drainage Systems, aiming to bring consistency in its application across the country. It also clarifies that only major developments need to take account of advice from Lead Local Flood Authorities (LLFAs), which should ease pressure on LLFAs and smaller development projects.
Coastal Change
Coastal policy now includes tidal rivers and estuaries, reinforcing the role of Shoreline Management Plans in strategic risk management.
Biodiversity Net Gain
The draft proposes capping biodiversity net gain requirements at the mandatory 10% and seeks views on offsetting shortfalls through over-delivery elsewhere. Clarifications on veteran trees and alignment with industry standards are also suggested.
Effective Use of Land and Materials
The draft repeatedly highlights the need for the regeneration of previously developed land, thereby bringing sites back into beneficial use and providing a mechanism for addressing residual land contamination issues.
A strong emphasis is also placed on the need for sustainable reuse of chemically suitable excavated soils and other materials within a development. This is welcomed, however the current regulation of excavated materials and what constitutes ‘waste’ is not straightforward and can be prohibitive to material reuse within brownfield development projects. This complexity in the regulatory framework will therefore need to be addressed if the sustainable reuse of soils and other materials is to be maximised.
Why It Matters
Changes to the NPPF are clearly intended to boost housing delivery and promote economic growth, and we think that the changes will certainly have a mild but positive effect in this regard. However, the draft also proposes significant changes to plan-making and decision-taking along with a clear mandate for the planning system to better integrate climate resilience, infrastructure capacity and biodiversity from the outset, while delivering well-designed, well-connected and inclusive places at pace. This is going to be a challenge for the industry, but the team at PJA, with our integrated offer of services across movement, place, engineering and environment, are well placed to help our clients and the wider industry to navigate these emerging requirements.
The consultation runs until 10 March 2026, offering an opportunity for professionals to shape policies that are practical, ambitious and future-focused.
What do you think? Will these changes help deliver better places and more sustainable transport? Or do they fall short of what’s needed? Share your thoughts below – and if you want to read the full draft, you can find it here: https://assets.publishing.service.gov.uk/media/6941965758a21370f58f304e/Draft_NPPF_December_2025.pdf
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