I described MHCLG’s and the Mayor of London’s proposed emergency measures for London as “underwhelming” in my 13 December 2025 blog post.
By contrast, maybe the only word for this week’s draft revised NPPF, accompanying consultation paper (225 questions to respond to by 10 March 2026) and the Planning and Infrastructure Act 2025 is “overwhelming”.
However, in suitably positive and festive mode, the theme of this blog post is as follows:
🎵 It’s beginning to feel a lot like we are moving towards a coherent, understandable, English planning system 🎵 and for that the relevant ministers and civil servants deserve a couple of weeks’ rest and reflection before the hard work begins again (because it certainly isn’t all finished yet…).
After all, doesn’t the following summary start to make sense to someone fresh to all this? In a way that the system hasn’t since the abolition of the regional strategies in 2010, or indeed long before that in much simpler times?
At a national level:
- a comprehensive set of numbered policies setting out the approach to development plan-making to be taken by plan-making authorities at three levels: strategic (via procedures the framework of which is set out in the 2025 Act); local (via procedures the framework for which is set out in LURA 2023), and neighbourhood;
- a comprehensive set of numbered policies to be followed when planning applications and appeals are determined, written in a rules-based style so as to minimise ambiguity – policies which (from the date the draft NPPF is finalised) override any inconsistent policies in any development plan (unless those policies have been examined and adopted against the finalised NPPF).
Planning practice guidance will still have an important “but supporting” role to national planning policy “and its status should be regarded in that light”.
At a strategic level (the boundaries of which in many cases will be determined in due course via the devolution process happening meanwhile in another part of the forest):
- a comprehensive set of spatial development strategies focused on providing a clear spatial framework for investment and growth, including new housing, looking forward at least 20 years (to be altered at least every five years to reflect any changes to housing requirements for the local planning authorities in the strategy area and to be replaced at least every ten years). This will include apportioning to local planning authorities in the strategy area the objectively assessed needs for housing and other uses which those authorities should plan for in their local plans and identifying “broad locations for strategic development including new settlements, major urban extensions, major cross-boundary development and key locations with the potential for new homes and jobs” as well as strategic infrastructure requirements. There should be no duplication, substantive restatement or modification of the content of the NPPF, unless any policy in the NPPF so directs.
At a local level (the boundaries of which in many cases will be determined in due course via the local government reorganisation process happening meanwhile in yet another part of the forest):
- slimmed-down local plans, to be prepared and adopted within 30 months, setting out a vision with a limited number of measurable outcomes, policies for minimum amounts of development to be provided for, land allocations (with a specified amount of detail), broad locations for growth, infrastructure requirements to support delivery of the plan and other policies “only where these support the delivery of specific allocated sites”. There should be no duplication, substantive restatement or modification of the content of the NPPF, unless any policy in the NPPF so directs. There must be “general conformity” with the relevant spatial development strategy. Supplementary plans may be used to address specific issues, subject to constraints set out in the NPPF.
At a neighbourhood level (optional):
- allocating land to meet the development needs of the neighbourhood (with a prohibition on promoting less development than provided for in other parts of the development plan for the area) and policies to address particular local issues. Neighbourhood plans should accord with the plan-making policies in the NPPF and again there should be no duplication, substantive restatement or modification of the content of the NPPF.
At each level (strategic; local; neighbourhood) a specific set of tests is set out against which draft plans will be examined. There are specific requirements for plan-making authorities at each level to engage with infrastructure providers, other relevant plan-making bodies and other relevant bodies and to demonstrate this by way of statements of common ground. Expectations as to developer contributions should be set at the relevant level. Qualitative standards for development should not cover matters already addressed by Building Regulations with limited specific exceptions and should not cover matters relating to the construction or layout of buildings unless they are to implement the nationally described space standard. Plans are to be published in a searchable digital format – no more PDFs!
Aside from there being a more cohesive, tiered, policy basis for decision making, the decision-making process will be made simpler and more predictable by way of simplified procedural requirements for schemes of less than 50 dwellings, by way of increasing the standardisation of section 106 agreements and viability inputs and by way of greater delegation of decision-making to officers.
I’m focusing here more upon the structural framework of the system – the hardware as it were – rather than the substantive direction of the policies – the software as it were. But the software also now works more smoothly. Rather than the previous tilted balance, with its various caveats over time and footnotes, we have, front and centre, policy S4 setting out the principles to be applied to development within settlements and policy S5 setting out the principles of development outside settlements (including the new criteria for housing and mixed-use development within reasonable walking distance of railway stations which meet a specifically defined level of connectivity to jobs and services (with those criteria also now providing a new category of not inappropriate development in the green belt)) and the drive towards densification, a more diverse mix of homes, focus on particular areas and sectors (e.g. those names in the government’s growth strategy, AI growth zones, logistics, town centres and agricultural and rural development), minerals, a vision-led approach to transport, addressing climate change, a tidying up of heritage policies and finally a more strategic approach to the natural environment (with the read-across to local nature recovery strategies as well as the environmental delivery plans provided for within the 2025 Act).
Complicated? Inevitably. But refreshingly it does all hang together. In fact, the new system is probably more intimidating for all of us who have to get to grips with this quite different approach and unlearn a whole host of previous policy tests and workarounds than for someone coming at this afresh. Any attempt at a straightforward mark-up of changes from the current December 2024 NPPF is doomed to failure but this side-by-side comparison of the paragraphs of the draft revised NPPF as against the relevant paragraphs of the existing 2024 NPPF may help (for which I thank my colleagues Archie Hunter and Adam Choudhury).
What are the challenges ahead?
- How to get there from here, i.e. transition. The NPPF’s decision-making policies will have full effect from the day that the final version of the document is published. We are of course going to have to wait longer for spatial development strategies (individual timescales dependent on dependent on individual devolution processes but against the government’s ambition of a full suite of adopted SDSs by 2029) and indeed the next generation of local plans (27 November 2025 written ministerial statement: “Local planning authorities covered by the NPPF transitional arrangements will have to commence formal plan making (Gateway 1) by 31 October 2026, while those that have a plan that is already over five years old must commence by 30 April 2027”).
- Politics and administrative processes. The planning system is under major reconstruction but of course so is the whole architecture of sub-national government. The worst that could happen would be for any of these reconstruction jobs to be left half-done. Continuity is important and if this is going to work, for the long-term improvement of the whole system, those elected to prepare plans need to proceed in a way which is consistent with the timescales and objectives that have been set out – and to avoid every understandable temptation in a period of transition to wait first for the next jigsaw piece to fall into place.
Have a good Christmas everyone and don’t worry: I shall switch back to Grinch-mode in the new year I feel sure.
Simon Ricketts, 19 December 2025
Personal views, et cetera
SIMONICITY 