The new NPPF is a missed opportunity to genuinely empower plan-makers and decision-makers to be ambitious about the outcomes that planning could achieve on the ground, to make peoples lives better in the context of the changing climate.

I can’t help feeling rather anti-climactic, following yesterday’s publication of the new National Planning Policy Framework (NPPF). Perhaps this is partly as, like most of us in the planning world, we’ve been living with the December 2025 draft in our minds for all those months and, what with a new Prime Minister, the return of Angela Rayner to MHCLG, a summer of heat, drought and fires and a solar eclipse, the planning drama has been somewhat, erm, eclipsed.

But I thought it would be good to look back at what I thought needed to change when I prepared my own response to the draft, way back in the depths of winter. I narrowed the whole thing down to six specific changes I hoped to see, so now I can see to what extent they are reflected in the final version.

1. The purpose of planning

I said that para 14 should read: The purpose of planning is to provide a framework within which every development decision makes the place it is located in better over the long-term, for the health and prosperity of people and for nature, in the changing climate.

Result: no change (now para 15). The adopted wording is:

The purpose of the planning system is to contribute to the achievement of sustainable development, by managing the use and development of land in the long-term public interest.

The problem with the existing statement of purpose is that ‘sustainable development’ within planning has a circular definition: NPPF states that planning’s purpose is sustainable development, but the key test of sustainability of a plan or development proposal is essentially its consistency with NPPF. If NPPF says it’s sustainable then it is. Whereas my proposed purpose for planning tests development dynamically against outcomes observed in the outside world. It’s high time that we stopped judging proposals only by their stated intent, not their actual outcomes, and I don’t see that the new NPPF rises to that challenge.

2. Spatial Development Strategies (SDS)

I said that Policy PM1(1) should read:

Spatial development strategies should set out a clear vision and spatial framework for investment, that is geared to employment, housing and infrastructure needed to deliver thriving economies, reduce spatial inequalities, improve public health and respond positively to the challenges of climate change and nature recovery.

Result: no change. The adopted wording is:

Spatial development strategies should set a positive vision for future growth and change at a sub-regional scale and provide a clear spatial framework for investment and growth, including for new housing. Their content should be genuinely strategic in nature and allow for more detailed issues to be considered and addressed through other parts of the development plan.

Again, my proposed wording would have stated the actual outcomes that SDSs need to deliver. Growth, investment and – indeed – housebuilding are means to deliver societal outcomes; they are not the ends in themselves. Imagine a strategy for walking to visit a friend in the next town, that included putting on shoes and packing a snack but didn’t involve looking up their address or plotting a suitable route. You’d have the means to travel but no sense of where you were going.

This is a key problem for planning, and to do SDSs well we urgently need to start determining spatially-specific outcomes. Recent excellent work by Catriona Riddell, Bev Hindle, Paul Frainer and Richard Wood to identify what the SDS ‘Core Product’ needs to fulfil includes the point that “There should be a clear articulation of how this spatial strategy continues, or is different to, the existing spatial strategies within Local Plans…It will set out clear and measurable outcome-focused objectives…”  The message is that the SDS needs to express how it will effect change compared to the existing trajectory, not just restate some targets.

3. Design Standards and the Climate

I said that Policy PM13 should be completely reworded as follows:

Development plan policies should set such quantitative standards – for affordable housing, parking, accessible and adaptable dwellings, design and placemaking, water efficiency, building space standards and carbon and energy efficiency – as are justified to meet the strategic objectives of that plan and to encourage innovation. All nationally-set quantitative targets are taken to be the baseline minimum, so whichever is the more ambitious out of the national and local target will take precedence.

Result: There is a marked improvement to PM13 in that the very damaging limitation the draft proposed on setting local energy efficiency standards has been removed. Howls of protest can work, it seems: over half of respondents objected to the proposed restriction.

Nevertheless, we’re still lacking a clear mandate for local ambition and innovation. I have never seen the point of allowing national standards to become lowest common denominators: in what world is it OK not to actively encourage improvement wherever there is the appetite for it, wherever there is good practice?

4. The new Presumption in Favour of Sustainable Development

I said that Policy S5 – The Principle of Development Outside Settlements – should not be national decision-making policy. Instead, policy S2 (Producing a spatial strategy) should include identifying ‘land outside existing settlement boundaries that is well-related to a railway station and within reasonable walking distance of it, the development of which would not prejudice other aspects of the spatial strategy.‘

Result: No material change.

The reasoning for my suggestion was that, whilst it may often make sense to locate development near to railway stations, when you look at the area covered by an SDS there may well be some stations where development is more appropriate, some stations where it’s less appropriate, and some locations that don’t currently have a station but where the spatial strategy is geared towards opening up new stations. So having a blanket national policy could scupper the rationale behind an SDS. Retaining the preference for proximity to stations, but devolving to SDSs the decision as to which stations to focus on, therefore makes much more sense.

There is a further element to the new presumption that undermines Development Plans. Policy S3 states: In all locations, development proposals that accord with both an up-to-date development plan and the decision-making policies in this Framework should be approved without delay.

But S3 then separates all development – in a binary sense – according to whether it falls within settlements (S4) or outside them (S5). And S4 and S5 only weighing adverse effects against NPPF, not against the Development Plan. No doubt those drafting the policy expected that S3 would keep the Development Plan in play but, in the adopted wording, if a proposal comes forward that does not accord with the Development Plan, its adverse effects need only be assessed against NPPF, not against the Development Plan that it is contradicting. I expect we’ll soon see a flurry of appeals nibbling at the edges of this wording.

5. Healthy Communities

I suggested Policy HC1 should be prefaced with a much more ambitious statement along the lines that “Every plan policy and development decision must be regarded as an opportunity to improve public health and reduce health inequalities, and assessed accordingly.”

Result: no change.

To be fair, I’m not confident that HC1 is exactly the right place for my suggested text, but the point is a wider one about engendering a Health in All Policies approach to NPPF. There is a tricky balance between having a distinct chapter on healthy communities, and integrating health outcomes into all other areas of policy. The new NPPF probably gets this balance about right, but there is a need to be more outcome-focused. Planning policy tends to pigeon-hole ‘healthy communities’ as being about the provision of facilities that support health – that is, both healthcare-related developments, and wellbeing-related amenities such as green space. These are, of course, hugely important and need to be planned for; but we know that crucial determinants of health such as levels of physical activity and access to healthy food are not yet improving, and are subject stark spatial inequalities. Hence, healthy communities need to be a core outcome of the planning system that must be considered from SDS spatial options all the way down to development decisions.

It’s more worrying that new NPPF appears to make no explicit requirements for Health Impact Assessments (HIA). The TCPA Planning for Healthy Places guide states: “Local Plans should include soundly evidenced, strong and clearly defined health and wellbeing requirements, specifying what is required from developers when they make a planning application or submit a development proposal for assessment by a local planning authority. Weaknesses in Local Plan policy mean developers can be unclear about their responsibilities in addressing local health priorities and they then fail to adequately incorporate healthy development principles and features in their proposals.” An HIA requirement is conspicuously absent.

6. Nature Recovery

I said Policy N1(2) should read: “In localities where the nationally-set exemption thresholds for statutory biodiversity net gain would unacceptably constrain nature recovery objectives – i.e. where there are small sites rich in biodiversity – development plans may set a reduced exemption threshold as justified by local evidence.”

Result: no material change.

My logic here was that, on the one hand, there was not only a case in favour of extending small site exemptions but also a government initiative already in train to do so, and therefore little value in objecting to them outright. But on the other hand, some places and some local authorities have many small sites, and the exemptions risked knocking out a large chunk of their overall BNG opportunity. Therefore local flexibility was key. With so many ecological experts poring over the new NPPF I must defer to their analysis, but the flexibility that was widely called for has not materialised, and that is deeply disappointing.

All in all:

• It’s a great relief to see that the worst offence of the new NPPF – restricting local ambition on energy and emissions standards in development – has been reversed.
• The new presumption in favour marks a significant centralisation of planning powers compared to its predecessor that doesn’t sit comfortably with the devolution agenda, and doesn’t sufficiently empower Spatial Development Strategies to be spatially specific to their area.
• There is little sign of planning getting to grips with its latent potential to really help people live healthy, thriving lives in the changing climate.
• Now I shall go back to making sacrifices to the rain gods.