An Iceni Briefing Note
National Planning Policy Framework Ministry of Housing,Communities & Local Government
August 2026
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An Iceni Briefing Note National Planning Policy Framework
Introduction
The August 2026 NPPF is a much more substantial change than a routine policy update. It is longer, more structured and, in places, noticeably more prescriptive than the December 2024 version. More importantly, it changes the way national planning policy is intended to work. For the first time, the Framework clearly separates plan-making policies from a new suite of national decision-making policies. The intention is to create a more consistent, rules-based system, with less scope for duplication locally and a clearer steer on how applications should be determined. There is plenty in the detail too. The new NPPF strengthens support for growth around well-connected stations, gives greater recognition to strategic and medium-sized housing sites, recasts the relationship between under-delivery and the presumption, and introduces more explicit policy on Green Belt, transport, economic growth, infrastructure, climate and energy. Some of this was well trailed in the December 2025 consultation draft, but not all of it survived unchanged.
Key Contacts For further information, please contact:
James Bompas Director, Planning / Business Development E: jbompas@iceniprojects.com T: 07736 314 143
That means the interesting question is not simply “what is in the new NPPF?” It is “what has actually changed, and what difference does that make?” This briefing is our attempt to answer that question. We have focused on the changes that matter most in practice, rather than working through the document line by line. The result is intended to be useful on a train, between meetings, or wherever else planners now seem to do most of their reading.
An Iceni Briefing Note National Planning Policy Framework
The New NPPF: Rules-based Policy and National Decision-making Policies
The 2026 National Planning Policy Framework (NPPF) looks to fundamentally change what the NPPF has previously stood for. This is shown where the most recent 2024 Framework (December 2024) operated as a single integrated document, whereas the 2026 Framework explicitly looks to separate plan-making policies from national-decision making policies. The revised version states that the plan-making policies must be taken into account during the preparation of development plans, while the national decisionmaking policies are now a material consideration in determining planning applications. The new Framework highlights a clear path that the planmaking policies should not be used when making decisions on development proposals. The 2026 Framework operates more like a nationally prescribed policy code, with separate policies for plan-making and decisionmaking. The Government has made this change to make development management more certain and streamlined, standardising policies that apply across England and look to reduce unjustified Local Plans.
Key Contacts For further information, please contact:
Archie Noden Senior Planner, Planning E: anoden@iceniprojects.com T: 07909 532 161
An example of this is the differences between the presumption in favour of sustainable development. In the 2024 NPPF edition, paragraph 11 included the phrase ‘tilted balance’, which was engaged when there were no relevant development plan policies or the most important policies were out of date. However, the 2026 Framework replaces this structure and introduces a permanent presumption in favour of sustainable development and has parameters for development proposed within settlements (Policy S4) or outside settlements (Policy S5). The focus here is no longer on whether local plan policies are out of date, but
on applying the national decision-making policies against the relevant settlement-based criteria. As outlined above, the 2026 NPPF takes a different approach to what has come before. Whilst the development plan remains the starting point for decision-making in the NPPF 2026 version, greater weight is now given to the new national decisionmaking policies. Instead of asking whether a Local Plan policy is old, decision-makers must consider whether that policy is consistent with the national decision-making framework. Where a development plan policy materially conflicts with a national decision-making policy, it should be given very limited weight unless it has been examined and adopted under the 2026 NPPF. This represents a move towards a more nationally consistent and rules-based planning system, where the substance of policies is more important than their age.
An Iceni Briefing Note National Planning Policy Framework
A Plan-led Policy Approach
The Government’s objective is to create a system that is genuinely plan-led which is reflected in policies of the new Framework. It sets out with useful clarity that the development plan is required to include a Spatial Development Strategy, Local Plan, Minerals and Waste Plan and a policies map, but can also include supplementary plans and neighbourhood plans. Sitting at the top of that hierarchy, Spatial Development Strategies (SDS) are sub-regional in scale and provide a clear spatial framework, identifying broad locations for growth and regeneration and strategic infrastructure requirements. Notably, they should also identify broad locations where changes to the Green Belt boundaries may need to be considered to meet development needs (but cannot alter the boundaries in themselves). In terms of timeframes, SDSs will extend over a period of 25 years, with a requirement for review to take place 7 years from adoption. Government has also confirmed that only housing requirement figures from SDSs that are under 5 years old can be used in Housing Delivery Test or 5-year housing land supply calculations, which in theory would not be engaged if up to date Local Plans are maintained.
to 10 years, which could inhibit strategic planning and ambition at the local level, although there is scope for plans to cover a longer time period to help support delivery of longer-term infrastructure or strategic development. Local Plans should be reviewed every five years, and prepared and adopted in 30 months. In terms of identifying and assessing land for development, a notable change sits within Policy PM9.2d, which states that assessments should include “the identification of appropriate sites for development”, rather than the “most appropriate” as per the draft. The shift in wording is subtle, but it moves the emphasis away from the need from a potentially onerous sequential assessment of sites. Turning to examining plans, much of the content is familiar and the soundness tests remain broadly as presented in the draft, with the exception of the “realistic” test, which has been renamed “effective”, with an emphasis being on site allocations being delivered at the point when they are envisaged.
For further information, please contact:
In order to ensure that the plan-led system is a success, the Secretary of State has the power to intervene if there is a lack of progress with plan making.
Finally, and whilst not contained within the plan-making policies set out in Section 2, Policy HO4 does outline that the development plan should identify suitable locations for strategic sites for housing-led development and identify specific sites for this form of development. Strategic sites are defined as having capacity for at least 1,500 dwellings. This categorisation is a welcome addition and will provide the framework for increased housing delivery and infrastructure-led development.
Lorna O’Carroll Director, Planning E: locarroll@iceniprojects.com T: 07875 681 532
Local Plans, in turn, should set out a strategy that supports the delivery of the SDS and include policies for the minimum amount of development, allocations and broad locations for growth. Perhaps surprisingly, the minimum plan period has been reduced
In summary, the direction of travel is clear: a tighter, more directive plan-making framework, with the real test now being whether authorities can prepare and adopt plans at the pace the system expects to support the delivery of growth.
Key Contacts
An Iceni Briefing Note National Planning Policy Framework
Homes Around Well-connected Stations and Higher Densities
This is one of the Government’s signature growth policies and should unlock plenty of high-quality development opportunities for logical sites that make the most of the country’s existing underutilised infrastructure. Correlating infrastructure, homes and sustainable connectivity to employment locations is a central premise of sustainable land use planning and is embedded in this policy.
The consultation draft applied a minimum density of 50 net dwellings per hectare, but this has sensibly been dropped. The final Framework instead requires a minimum of 35 net dwellings per hectare, rising to 45 net dwellings per hectare at stations with at least eight trains per hour during the daytime. This is a level that housebuilders should be more comfortable delivering in current market conditions and suggests that Government has listened to the industry on this important element of the policy.
Railway station growth proposals, including those on greenfield and Green Belt land, do not require a plan allocation or a demonstration of unmet housing need. Moreover, there is a clear presumption that residential and mixed-use development which is physically well-related to the station should be approved “unless the benefits of doing so would be substantially outweighed by any adverse effects”.
Iceni considers this to be a very positive piece of national planning policy which should help boost housebuilding and support the delivery of more high-quality development. However, some potentially suitable stations are excluded because qualification is linked to average daytime service frequencies rather than peak-hour service levels, which we consider to be a missed opportunity. The 800-metre walking-distance criterion may also inhibit opportunities to maximise high-quality growth at qualifying locations. Planning casework and decisions should provide useful evidence to feed back to policymakers, and Iceni will continue to highlight areas where best practice and further policy evolution could improve outcomes.
Iceni has identified qualifying stations and geographic areas on the accompanying plan and schedule (plan on the next page). The final policy expands coverage beyond the top 60 Travel-toWork Areas proposed in the December 2025 consultation draft to the top 80. While this extension creates additional opportunities, the most significant development potential remains concentrated around stations within the highest-ranking Travel-to-Work Areas. The August 2026 NPPF anticipates development being located within a reasonable walking distance of a qualifying station, defined as “around 800 metres”. Iceni considers the word “around” to provide some flexibility in interpretation. However, proposals located materially beyond this distance, or larger schemes where significant proportions of development fall outside this range, are likely to face closer policy scrutiny. This is already emerging as a key consideration in the assessment of potential development opportunities.
An Iceni Briefing Note National Planning Policy Framework
Unconstrained & undeveloped land near well-connected stations (ha) Green Belt Not Green Belt
Key Contacts
200 ha
For further information, please contact:
75 ha 25 ha 5 ha
James Waterhouse Director, Planning E: jwaterhouse@iceniprojects.com T: 07734 464 067
Travel to work areas by GVA Top 80 Outside of top 80
An Iceni Briefing Note National Planning Policy Framework
Green Belt and Grey Belt
Green Belt Assessments
Grey Belt
Paragraph 1(a)(ii) of Annex E requires LPAs’ Green Belt Assessments to be broadly consistent with any Strategic Green Belt Assessment in an adopted Spatial Development Strategy. We will therefore need to pay close attention to consultations on SDSs, as there may be less scope to diverge from Green Belt findings once an SDS is adopted. One example is the recently published London Plan and its Green Belt Assessment. If a site was not considered Grey Belt within that Assessment, it may become more difficult to argue that it is Grey Belt when Local Plans are subsequently prepared. Equal attention will need to be paid to the methodology used for SDS Assessments, as future LPA.
As anticipated in the December 2025 consultation draft, the reference to footnote 7 has been removed from the definition of Grey Belt. Under the December 2024 NPPF, Grey Belt excluded land where the application of policies relating to the areas or assets in footnote 7 would provide a strong reason for refusing or restricting development. This meant that, alongside considering whether land made a strong contribution to Green Belt purposes (a), (b) or (d), a separate assessment was required of the potential effect on assets listed in footnote 7, including National Landscapes, National Parks and designated heritage assets.
Altering Green Belt boundaries As part of the changes to the Duty to Cooperate, LPAs will no longer need to consider whether neighbouring authorities could accommodate some of their growth requirements before concluding that there are exceptional circumstances for altering Green Belt boundaries and releasing land.
Key Contacts For further information, please contact:
Silke Gruner Director, Landscape E: sgruner@iceniprojects.com T: 07840 178 777
The prioritisation of previously developed land, then Grey Belt land, and then other Green Belt land for allocation and release remains unchanged. Policy GB4(d)(i) confirms that this prioritisation should be applied where it promotes a sustainable pattern of development overall. Given that the emerging London Plan does not appear to follow this hierarchy, we can expect the GLA to argue that doing so would not promote a sustainable pattern of development in London. The ability of allocations to meet the Golden Rules will also need to be considered.
This had led to a run of Judicial Reviews through 2025 and 2026 testing the limits of this policy safeguard. Its removal should streamline the Grey Belt assessment process. These assets remain important and may still carry significant weight in the planning balance, but they no longer have the effect of automatically disqualifying land from being considered Grey Belt.
The Golden Rules The Golden Rules remain broadly unchanged. The principal change is one of weight: rather than “significant weight”, Policy GB8(2) now states that “substantial weight should be given to the importance of complying with the Golden Rules”.
An Iceni Briefing Note National Planning Policy Framework
Housing Delivery, Housing Mix and Small/Medium Sites
While the core component of assessing housing need, the standard method, has not changed, these figures now initially apply through Spatial Development Strategies where one is in place, with Local Plans then required to conform to the SDS. Where an SDS redistributes housing need across its area, Local Plans will need to respond accordingly. SDSs will also look beyond the reduced 10-year minimum period required for Local Plans, covering at least 25 years. As the emerging London Plan shows, this may mean housing need is not met evenly across the strategy period where infrastructure has to be delivered first. The August 2026 NPPF is, however, clear that housing requirements should reflect the extent to which identified needs can be accommodated over the plan period as a minimum. The NPPF also requires housing need figures to be informed by an understanding of unmet needs in neighbouring areas. This appears to be a relatively weak mechanism in practice, as the requirement to understand unmet need does not of itself require that need to be accommodated. Chapter 6, and Policy HO1 in particular, retains the list of specific groups whose housing needs must be addressed. Service families no longer appear as a standalone group, but they have not disappeared from the policy framework. They are included within the definition of essential local workers, while the definition of affordable housing has been expanded to include Military Affordable Housing. This new tenure provides sub-market rented accommodation, as defined by the MOD, for veteran households and their families.
Proposals will need to respond to a demonstrable unmet need identified by the MOD. They are also exempt from the relevant affordable housing mix policy, although the overall affordable housing requirement continues to apply. Policy HO5 introduces a clear national accessibility floor, requiring no less than 40% of homes on major developments to be delivered to M4(2) standards. Local authorities can set higher requirements where justified by evidence, and many already have adopted policies seeking significantly higher levels. The NPPF also requires SDSs or Local Plans to address the needs of older people, students, self and custom builders, Gypsies and Travellers and other groups identified in Policy HO1. Policy HO7 provides further support for development that contributes towards meeting these evidenced needs. In particular, substantial weight should be given to the benefits of providing homes which contribute towards meeting evidenced accommodation needs identified through local needs assessments and other relevant evidence. Policy HO9 then sets out further requirements for specialist accommodation, with additional Government guidance expected on how these needs should be assessed. While the standard method itself has not changed, the NPPF does alter how under-delivery interacts with the new rulesbased decision-making system and places greater emphasis on delivering housing through a more diverse range of sites. Where Housing Delivery Test performance falls below 75%, this no longer simply triggers the former presumption. Instead, an
An Iceni Briefing Note National Planning Policy Framework
evidenced unmet need for housing is deemed to exist for the purposes of Policy S5, feeding directly into the new rules-based approach to sustainable locations.
Key Contacts For further information, please contact:
James Bompas Director, Planning / Business Development E: jbompas@iceniprojects.com T: 07736 314 143
Paul McColgan Director, Economics E: pmccolgan@iceniprojects.com T: 07827 944 637
Nick Ireland Director, Economics E: nireland@iceniprojects.com T: 07917 417 834
The August 2026 NPPF also strengthens the policy framework for a more diverse housing pipeline. Policy HO4 introduces a distinct category of strategic housing-led sites, with greater emphasis on infrastructure, realistic delivery rates, land assembly, masterplanning and an appropriate tenure mix. Government has separately highlighted strategic sites as a key feature of the final Framework, describing them as a distinct category of around 1,500 homes or more. For smaller schemes, the existing expectation that at least 10% of the housing requirement should be accommodated on sites of no more than one hectare is now supplemented by a further 10% on sites between one and 2.5 hectares, unless there are strong reasons why this cannot be achieved. This creates a clearer national expectation for a pipeline of medium-sized sites, with obvious implications for SME builders and land promoters. There are also more targeted changes to housing mix. The December 2025 consultation proposal to require tenure-mix policies on sites of 150 homes or more has been dropped in favour of a more flexible requirement for allocated sites where this is appropriate and deliverable.
An Iceni Briefing Note National Planning Policy Framework
Affordable Housing, the Golden Rules and Viability
The August 2026 NPPF does not make substantive changes to affordable housing policy compared with the December 2025 consultation draft, although it does tighten some of the wording and links more clearly to other parts of the Framework. The main policies are contained in Chapter 6. Development Plans are expected to set out affordable housing needs, applying the definition in Annex B, while development proposals should meet or exceed up-to-date Development Plan requirements. Exceptions remain where off-site delivery would optimise the quality or quantity of affordable housing, or where a cash payment in lieu of on-site provision can be robustly justified. Policy HO8 also includes a new provision on vacant buildings. Affordable housing contributions should be reduced proportionately to reflect the gross floorspace of existing buildings, helping to support viability. This does not apply where buildings have been abandoned, or to major development on land within or released from the Green Belt, where the Golden Rules apply.
Key Contacts For further information, please contact:
Lucy Howes Associate Director, Planning E: lhowes@iceniprojects.com T: 07921 172 616
Policy GB8 strengthens the wording around the Golden Rules, with “substantial weight” now to be given to the importance of complying with them. The Framework also provides greater clarity on the circumstances in which a viability assessment may justify a departure from the Golden Rules. This includes previously developed land that is demonstrably burdened by costs associated with that previous development which were not taken into account in the viability assessment informing the Development Plan.
This is an important point of flexibility. Development proposals are still expected to make the maximum possible contribution, but where this falls significantly below the Golden Rule requirements, that position should only be accepted in exceptional circumstances and where it is fully evidenced and justified. The Framework does not define those exceptional circumstances, so this is likely to remain an area for detailed discussion with local planning authorities.
An Iceni Briefing Note National Planning Policy Framework
Economic Growth, Logistics and Data Centres
Key Contacts For further information, please contact:
Stuart Mills Associate Director, Planning E: smills@iceniprojects.com T: 07771 394 497
The August 2026 NPPF strengthens national policy support for economic development and more clearly links planning decisions to the Government’s wider growth agenda, including Industrial Strategy Zones, AI Growth Zones and other strategic initiatives. In plan-making terms, Policy E1 is more explicit than the December 2024 NPPF in requiring plans to allocate sites to meet identified needs. There is also greater emphasis on flexible premises and the supporting network infrastructure needed by a modern economy. The terminology has also shifted from “storage and distribution” to “freight and logistics”, reflecting a broader range of activities including freight terminals, HGV parking, ports and last-mile facilities. The national decision-making policies are also notable. Policy E2 requires substantial weight to be given to the economic benefits of commercial development, particularly where proposals support the Industrial Strategy, improve freight and logistics networks or align with Industrial Strategy Zones and AI Growth Zones. It also provides a more detailed basis for demonstrating unmet need, including market signals, changing sector requirements, infrastructure availability and specific locational requirements. Policy E3 introduces a dedicated national policy for freight and logistics development. Much of the detail reflects established planning principles, but giving the sector its own policy is significant and should support a more consistent approach to decision-making across different local authority areas. The Framework also gives greater prominence to digital infrastructure. Data centres are expressly recognised as part
of the modern economy, alongside the power generation, electricity network upgrades and grid connections needed to support them. Overall, the direction is clear: stronger support for logistics, industrial and data centre development, clearer decision-making criteria and a more direct relationship between planning policy and the Government’s wider ambitions for growth, productivity and technological investment.
An Iceni Briefing Note National Planning Policy Framework
Town Centres and the Sequential Approach
Key Contacts For further information, please contact:
Craig Stewart Senior Planner, Planning E: cstewart@iceniprojects.com T: 07345 749 061
Harriet Todd Senior Planner, Planning E: htodd@iceniprojects.com T: 07785 485 953
The August 2026 NPPF retains the established town centre first approach, with only limited substantive changes from the December 2024 NPPF and the December 2025 consultation draft. Despite suggestions during consultation that the sequential test might be diluted or replaced by a broader accessibility-based approach, the Government has retained both the sequential and impact tests as core safeguards for town centres. The main change from the consultation draft relates to how the sequential test operates. Policy TC3 continues to require applicants to demonstrate that suitable in-centre and edgeof-centre opportunities have been properly explored before out-of-centre proposals are considered, and it retains the need for flexibility in format and scale. However, the final Framework removes the consultation wording which suggested considering whether the proposed development could be accommodated across multiple sites. In practice, this avoids a return to disaggregation as part of the sequential test. Policy TC4 leaves the national approach to impact assessments unchanged, including the default 2,500 sqm gross floorspace threshold where no locally-set threshold applies. More broadly, the Framework places greater emphasis on adapting and diversifying centres. Policy TC1 supports a wider mix of uses, including residential development, markets, public realm improvements and the re-use of vacant premises. Policy TR3 also reinforces the importance of accessibility and connectivity, with preference given to sites that are well connected to town centres by sustainable transport modes.
Overall, the direction of policy is familiar. Town centres remain the preferred location for retail, leisure and other main town centre uses, with the most notable change being the removal of the consultation draft wording that could have reopened the door to disaggregation.
An Iceni Briefing Note National Planning Policy Framework
Vision-led Transport and Connectivity
The August 2026 NPPF formalises the Government’s shift towards a more vision-led approach to transport planning, with greater emphasis on people and movement rather than simply highway capacity. For developers, strategic site promoters and local planning authorities, this changes how the sustainability of locations and transport impacts are likely to be assessed. Transport considerations should continue to influence site selection and masterplanning from the outset, but the Framework places greater weight on demonstrating how development can support sustainable patterns of movement. The 800-metre walking-distance test is one example of this, although it does not automatically exclude development beyond that distance. The broader direction is towards supporting locations that are sustainable now, or can become so through planned interventions.
Key Contacts
There is also a more forward-looking approach to site promotion, with greater consideration of planned transport infrastructure and future connectivity improvements. The DfT Connectivity Tool is likely to play an important role, but the NPPF is clear that it should be used alongside other quantitative and qualitative evidence. In our view, that wider evidence will remain important in demonstrating the true sustainability of a site.
For further information, please contact:
Matt Bolshaw Principal, Transport E: mbolshaw@iceniprojects.com T: 07990 380 284
For strategic sites, transport evidence will increasingly need to set out a clear vision supported by specific interventions and tangible benefits. The emphasis moves beyond identifying worst-case highway impacts and mitigating capacity constraints towards showing how active travel, public transport, accessibility and placemaking can reduce travel demand and support sustainable travel patterns.
The specific emphasis on inclusive design, including the needs of women, girls and other potentially vulnerable groups, is also a welcome addition and should be reflected in proposed interventions. Transport Assessments are therefore likely to need a stronger narrative around accessibility, connectivity, future investment and scenario testing, rather than relying primarily on highway modelling. The definition of “severe impact” has also been widened to include both construction and operational phases. Ultimately, transport evidence will need to explain not just the impacts of development, but why the location is sustainable, or how it can become sustainable through planned intervention.
An Iceni Briefing Note National Planning Policy Framework
Design, Density and Placemaking
Compared with the December 2024 NPPF, the August 2026 NPPF strengthens the relationship between good design, density optimisation and growth delivery. While the previous Framework promoted well-designed places and the efficient use of land, the revised wording places greater emphasis on making the best use of sustainable and well-connected locations. This is most evident in the stronger policy support for higher-density development around transport hubs and other accessible locations. In practice, the debate is increasingly likely to move from whether higher densities are appropriate to how they can be delivered successfully through good design. The Framework also places greater emphasis on comprehensive masterplanning for major and strategic developments. The August 2026 NPPF more clearly links housing delivery, infrastructure, connectivity and placemaking, reinforcing a broader shift towards strategic, infrastructureled growth. Applicants promoting large-scale development will therefore need to demonstrate from an early stage how development can be coordinated and supported by transport, green infrastructure and community facilities.
Key Contacts For further information, please contact:
Aghiad Baranbo Associate Director, Design E: abaranbo@iceniprojects.com T: 07345 772 931
Design codes and design review remain important tools, but their role is increasingly tied to delivery as well as design quality. In practice, design review is likely to consider not only architectural quality and local character, but also whether proposals optimise density, integrate infrastructure, support sustainable movement and provide a coherent long-term vision. Design codes should similarly provide greater certainty for the delivery of larger and more complex sites.
These changes sit alongside the new distinction between planmaking policies and national decision-making policies. Taken together, the direction is clear: design quality remains fundamental, but it is increasingly expected to sit alongside efficient land use, infrastructure integration and the delivery of growth.
An Iceni Briefing Note National Planning Policy Framework
Climate Change, Clean Energy and Water
The August 2026 NPPF maintains that the purpose of the planning system is to contribute to the achievement of sustainable development. The three interdependent overarching objectives, pertaining to economic, social and environmental sustainability, and which are to be pursued in mutually supportive ways, have been retained. Whilst the economic and social objectives are unchanged from the December 2024 NPPF, the environmental objective has been restructured to bring the need to mitigate and adapt to climate change, including moving to a low carbon economy, to the forefront.
Climate Change Much of the guidance and information contained within Chapter 14 (Meeting the challenge of climate change, flooding and coastal change) of the December 2024 NPPF has been restructured into specific plan-making (CC1) and decisionmaking (CC2 and CC3) policies. Under Policy CC1, additional emphasis is placed on the need for development plans to take a proactive approach to mitigating climate change and supporting the transition to net zero, particularly with respect to the implications of extreme weather and long climate trends, including overheating, wildfires, drought, flood risk, coastal change, water supply, biodiversity and landscapes. This policy pushes the requirements of the December 2024 NPPF, requiring development plans to propose development patterns that can help contribute to radical reductions in greenhouse gas emissions. This is supported by Policies CC2 and CC3, which set out specific requirements for development proposals with respect to
the mitigation of and adaptation to climate change, respectively. To mitigate climate change, emphasis is placed on the role of sustainable transport options, access to facilities and services, the conservation of energy and resources, centralised low carbon energy sources, and the creation or restoration of habitats that act as carbon stores. Accounting for flood risk continues to be a focus in the context of climate change adaptation, with consideration of overheating and wildfire risks also to be accounted for. The need to embed climate change mitigation and adaptation measures within the design of development proposals it further emphasised within Policy DP3. Part 2b of this policy requires development proposals to support the transition to net zero by using layouts and materials to conserve energy and resources, whilst also minimising the risks associated with climate change, such as overheating. Similarly, part 2c of this policy requires that nature be incorporated within development proposals to, in part, improve climate resilience.
Securing Clean Energy and Water Where guidance relating to the delivery of renewable and low carbon energy and water infrastructure was previously covered under Chapter 14 of the December 2024 NPPF, the August 2026 NPPF contains a dedicated chapter on securing clean energy and water. As for climate change-related policy, much of the guidance pertaining to energy and water infrastructure contained within the December 2024 NPPF has been restructured into specific plan-making (W1 and W2) and decision-making (W3 and W4) policies. Policy W1 requires a clear understanding of energy supply and network capacity, water supply, drainage and wastewater
An Iceni Briefing Note National Planning Policy Framework
capacity and the associated requirements for additional provision, to enable consideration of the impacts of planned growth, changes in consumption patterns, climate change and relevant strategic infrastructure plans. This information should then be used to inform the location and phasing of planned growth, as well as to contribute to the planning of new or enhanced renewable and low carbon energy development, electricity and water infrastructure. Under Policy W3, applicants continue to not be required to demonstrate the need for renewable or low carbon energy development and electricity network infrastructure. The drive to deliver infrastructure of this type has been strengthened, with decision makers required to give substantial weight to the benefits of improving energy security, supporting economic development and/or the transition to a net zero future. Policy W4 provides prescriptive guidance on the consideration of proposals for water supply, drainage and wastewater development, affording significant weight to the provision of capacity needed to serve new development and the improvement of water quality.
Key Contacts For further information, please contact:
Grace Wileman Associate Director, Futures E: gwileman@iceniprojects.com T: 07807 350 354
Energy and Water Efficiency Under Policy PM13, it is stated that development plans should not include for policies relating to qualitative standards that are addressed by the Building Regulations. Exceptions to this, however, include water and energy efficiency. In terms of water efficiency, it is highlighted that there may be cases where the requirement for a level of water efficiency that aligns with the tighter Building Regulations optional requirement may be appropriate, with increasingly stringent requirements
potentially being appropriate in exceptional circumstances within areas of serious water stress. With respect to energy efficiency, it is noted that a clear and robustly costed rationale should be provided where standards that go beyond the current or proposed Building Regulations are set out. Such standards will be acceptable only where it is demonstrated that there would be no adverse impact on the viability and deliverability of development. Should standards that go beyond the requirements of the Building Regulations be included for within development plans, these should be expressed as a percentage uplift of a dwelling’s Target Emissions Rate (TER), based on calculations undertaken using a specified version of an approved calculation method.
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Nature, Landscape and Flood Risk
Increased Importance of Green Infrastructure Policy N1 requires development plans to set out standards for green infrastructure provision, in a way which complements and/or incorporates those for recreational land, which should draw upon Natural England’s Green Infrastructure Standards for England. Where land is being promoted for allocation, the potential to accommodate suitable green infrastructure should therefore be clearly highlighted within Vision Documents, to show how proposed development would include and make best use of these multi-functional areas. Policy N2 also includes a much more detailed checklist of principles development proposals should achieve, in order to contribute positively to the natural environment, and support nature’s recovery. Whilst the reference to ‘valued landscapes’ has been removed, the new NPPF focuses more on considering the qualities and character of an area, including point (1)(d), which sets out to “conserve and enhance existing natural features of visual, historic or nature conservation value (such as established trees and hedgerows) where possible; and use appropriate landscaping to help create a well-designed place and integrate the development into its surroundings”. It also noted in relation to Plan-making policies, that development plans should set out a hierarchy of international, national, and locally designated sites and areas for, amongst others, landscape importance, signalling the return of locally designated landscapes.
Trees Policy Policy N3 includes the requirements for street trees. Considering the density requirements in other policies, some clever design will be required to accommodate the verges, active travel routes, required areas of recreation space and green infrastructure,
alongside sufficient dwellings to meet the density requirements. From experience, our Masterplanning and Urban Design team knows that the only way this can be achieved is by reducing the parking provision, and this is not necessarily what house builders outside of cities, nor many house buyers, want.
Protected Landscapes A new definition, incorporating National Parks, National Landscapes, and the Norfolk and Suffolk Broads. These will also benefit from stronger protection, with the new NPPF noting that “substantial weight”, as opposed to great weight, should be placed on the importance of conserving and enhancing the natural beauty of these areas.
Biodiversity Net Gain Policy N1(2) sets out that local standards above the statutory requirement should only be set where: They relate to specific site allocations They are fully justified and deliverable They do not extend to exempt categories of development It also says decision-makers should not give weight to development plan policies requiring biodiversity gains beyond the statutory framework unless properly justified.
Swift Bricks Pretty specific, but development proposals should incorporate integrated nest boxes into their construction unless there are compelling technical reasons not to.
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Flood Risk and Sustainable Drainage
Key Contacts For further information, please contact:
Hollie Cannell Sustainability Consultant, Futures E: hcannell@iceniprojects.com T: 07471 805 300
Silke Gruner Director, Landscape E: sgruner@iceniprojects.com T: 07840 178 777
Grace Wileman Associate Director, Futures E: gwileman@iceniprojects.com T: 07807 350 354
The majority of the information pertaining to flood risk and sustainable drainage, previously set out within Chapter 14 of the December 2024 NPPF, has been restructured into Policies F1 to F9. As per the December 2024 NPPF, development plans and development proposals are required to minimise the risks to people and properties arising from all sources of flooding and climate change. Site-specific Flood Risk Assessments continue to be required for all development proposals located within Flood Zones 2, 3a and 3b, as well those located within Flood Zone 1 where a site is greater than one hectare, the land has been identified as having critical drainage problems, and/or the land is at risk of flooding from any source, either in the present or the future. Similarly, it is required that sustainable drainage systems be incorporated within proposals that have the potential to affect drainage on or around a development site. Policies F5 and F6 set out the requirements of the Sequential Test and the Exceptions Test, respectively, with much of the guidance remaining as per the December 2024 NPPF. Annex F, which comprises an update to Annex 3 of the December 2024 NPPF, sets out the flood risk vulnerability classification. Of note, the following development types are now also considered Essential Infrastructure: Hydrogen production facilities; Carbon Capture, distribution and storage facilities; Heat networks; Data Centres; and Electric vehicle charging stations. This reflects the increased weight given to low carbon, renewable and electric infrastructure, as well as Data Centres.
An Iceni Briefing Note National Planning Policy Framework
Heritage
Chapter 20 remains largely unchanged from the 2025 Consultation Draft. It continues to refine policy tests in line with key case law — notably confirming that positive effects on heritage assets carry the same weight as harm — and the ‘less than substantial harm’ terminology has been removed as anticipated, leaving simply ‘harm’ to describe these effects. However, there are a few noteworthy changes for the discerning heritage consultant and/or decision-maker: Policy HE6 retains the use of ‘substantial weight’ for designated assets, aligning with weighting used elsewhere (e.g. housing, economic benefits, net zero). However, it now also references “considerable importance and weight” for designated assets, alluding to the fact that statutory protections apply. This does not appear to override the need for ‘substantial weight’, but raises questions over how ‘considerable importance’ applies to designated assets currently lacking statutory provisions (e.g. settings of conservation areas or registered parks and gardens).
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‘Substantial harm’ is now introduced for non-designated heritage assets that should be outweighed by benefits relative to significance. Importantly, though, this is not equivalent to the test for designated assets, despite similar wording. Overall, this chapter has only been refined, but arguably slightly diluting the clarity that the consultation draft sought.
Georgia Foy Director, Built Heritage & Townscape E: gfoy@iceniprojects.com T: 07799 089 425
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