UK100 has submitted a comprehensive response to the Government’s consultation on changes to the National Planning Policy Framework. The submission assesses how the proposed reforms would affect plan-making, decision-making, and the ability of local authorities to deliver net zero, nature recovery and sustainable development.

It outlines key priorities for the revised Framework:

Maintaining a genuinely plan-led system: While separating plan-making and decision-making policies may improve clarity, stronger guidance is needed to ensure these functions operate together in practice. The Framework should reinforce a holistic approach to decision-making that balances economic, social and environmental objectives.

Protecting local authority ambition and flexibility: Proposals that restrict Local Plans from going beyond national policy, including limits on locally set standards and duplication of national policies, risk undermining local leadership and innovation. Local authorities must retain the ability to respond to local circumstances and pursue higher environmental and energy performance standards where justified.

Strengthening climate and nature integration: Climate mitigation, adaptation and nature recovery should be embedded throughout the Framework rather than confined to specific chapters. Policies should require measurable carbon reductions, support whole-life carbon assessment, and ensure development contributes to national climate targets and biodiversity recovery goals.

Supporting effective and proportionate decision-making: Simplifying policy wording should not create ambiguity or undermine established approaches to weighting considerations. The proposed expansion of “substantial weight” risks increasing complexity, subjectivity and reliance on specialist input, particularly in already resource-constrained local authorities.

Resourcing local authorities to deliver change: Many proposals increase expectations on local authorities without addressing capacity constraints. Effective plan-making, cross-boundary cooperation, infrastructure planning and climate delivery will require additional funding, technical support and clear national guidance.

UK100 highlighted several important considerations:

• Restrictions on local policy-making, including limits on energy efficiency standards and biodiversity net gain, could slow progress towards net zero and weaken nature recovery outcomes.
• Stronger requirements are needed for carbon assessment, climate adaptation, and integration of health, transport and environmental considerations into both plan-making and decision-making.
• The Framework should ensure biodiversity net gain is treated as a minimum rather than a ceiling, allowing local authorities to set higher requirements where supported by evidence. 
• Spatial strategies must better align housing delivery with infrastructure capacity, environmental constraints and sustainable transport to avoid car-dependent and high-carbon development patterns.
• Policies on renewable energy are broadly positive, but require clearer coordination with grid infrastructure planning, stronger support for community energy, and safeguards for landscape, heritage and biodiversity.
• The Framework should place greater emphasis on meaningful public participation, ensuring communities are actively involved in shaping Local Plans and development outcomes.
• Environmental protections, particularly for protected landscapes, Green Belt land and biodiversity, risk being weakened through changes to policy wording and expanded development presumptions.

Overall, UK100 called for the revised NPPF to be aligned with statutory climate and environmental targets, and supportive of local authority leadership. Strengthening policy clarity, protecting local flexibility, and embedding climate and nature throughout the Framework will be essential to ensuring that planning supports thriving, low-carbon and resilient communities across the UK.

‍