For those not in the know, NPPF might look like a dismissive onomatopoeic exclamation often found in a comic book hero's thought bubble, alongside blam and kapow!

For others, it's either the enabler of or the obstacle to good local planning. The NPPF, aka the National Planning Policy Framework, is the government's overarching land-use planning policy for England. Whether you see it as the former or the latter will very much depend on your view of the latest proposals to revise it.

Government is proposing significant changes to the Framework and Biodiversity Net Gain (BNG). And we recently brought our Countryside Climate Network together to assess the impacts and outline the best ways to engage with the proposals.

To summarise, we found that these changes risk undermining world class policies and centralising decisions in Westminster for decades, at the precise moment they’re trying to devolve powers. In the process, they will hinder local and strategic authorities’ ability to deliver their climate and nature ambitions, forcing them into national standards instead of place-based approaches that deliver for local needs. The result: Bad developments, disgruntled communities, degraded habitats, and costly fixes that only a superhero could tackle.

Here’s what you need to know.

Changes to the National Planning Policy Framework

The NPPF is the backbone of England’s planning system, but draft changes proposed in the current consultation would establish national planning policy as a ceiling rather than a floor, limiting the ability of local and strategic authorities to go beyond national minimum standards in a number of areas.

Specific proposed changes of concern are:

• Weakening local requirements on home energy efficiency and decarbonised construction, preventing councils from setting higher building standards that reflect local climate objectives and needs.
• Constraining local ambition on Biodiversity Net Gain, including authorities’ ability to require BNG above the statutory 10% minimum through planning policy.
• Weakening evidence requirements and the ability for planning authorities to seek evidence on climate risks, coastal vulnerability, carbon emissions and more. 
• Removing flood risk considerations including requirements to apply sequential tests to sites at risk of surface water flooding, and weakened oversight from local flood authorities.

Changes to Biodiversity Net Gain

Biodiversity Net Gain ensures developers leave habitats and biodiversity in a ‘measurably better state’ than they were prior to development. When introduced in February 2024, the policy was a world first, requiring developers to deliver a 10% improvement to nature. For local government, it offered much needed finance for the protection and restoration of new and existing habitats and green spaces. 

However, the following recent changes and upcoming proposals are putting the policy at risk:

• BNG has a loophole which is undermining its impact. The ‘de minimis’ offered an exemption for certain smaller sites, yet no evidence is required to prove the exemption. This has resulted in 86% of small-site applications claiming exemptions and providing no evidence to prove it.
• The Government has now committed to a new 0.2ha threshold for BNG, instead of the existing ‘de minimis’, which according to analysis from Wildlife and Countryside Link could exempt up to 80% of all planning applications. 
• Government is also proposing to exempt brownfield sites and custom builds from the policy entirely.

If the ‘de minimis’ loophole remains alongside the new threshold and exemptions, BNG as we know it will be little more than a tickbox exercise for developers, delivering nothing for local government, the communities they serve, or the nature it had intended to support. Yet the fix is easy, make it easier to deliver BNG than to claim exemption: change the evidence requirements and close the loophole once and for all.

It would be easy to cast the government as the comic book villain and the revised NPPF as its dastardly plan for world domination. But we're grown-up enough to acknowledge there's more nuance to it than that. As it stands, however, the revised framework and the BNG loophole both risk doing significant damage — curtailing local ambition at precisely the moment it should be unleashed.

That’s why we're pretty nppft about the changes. But all is not lost.

Here is what you can do:

There is still time to have your say on these changes and here’s how.

1. Respond to the government’s NPPF consultation (NPPF) by 10th March‍

It’s a big document, so if you’re lacking time to get into the finer details, read this joint letter we signed with TCPA to Rt Hon Steve Reed which highlights specific concerns or their more detailed blog on the climate implications, use CPRE’s consultation guidance, or check out Community Planning Alliance’s suite of tools.

2. Share your concerns with your MPs

On both the NPPF and the BNG changes. Our friends at Wildlife and Countryside Link have put together this handy briefing on BNG challenges which you can share.

3. Prepare to respond to the future BNG consultation

Though the BNG threshold consultation is now closed, we are expecting another consultation on the brownfield exemption which we recommend you respond to, using it as a tool to encourage a closure of the evidence loophole.

Contact membership@uk100.org for any questions