Draft National Planning Policy Framework for England – LCNR response

The Centre submitted a response to consultation by the Department for Environment, Food and Rural Affairs (Defra) in March 2026.  The purpose of the consultation was to gather feedback on a revision to the National Planning Policy Framework (NPPF) for England.  A summary is below. For a copy of the Centre’s response in full, please contact kay.jenkinson@ouce.ox.ac.uk

• Nature protection and nature recovery obligations are not adequately addressed. The current draft National Planning Policy Framework (NPPF) does not deliver the level of protection needed to deliver the UK’s statutory nature recovery requirements under the Environment Act 2021 and our commitments under the Global Biodiversity Framework. Requirements on nature protection are weak, isolated, not given the same ‘substantial weight’ as policies on economic growth and development, and not adequately integrated into wider policies. For example, Policy N6 has weakened protection for Sites of Special Scientific Interest (SSSIs) and still does not offer any protection for National Nature Reserves or Priority habitats and species (of principal importance). Also, the list of standard information required does not include Environmental Impact Assessments or Strategic Environmental Assessments. 
• Presumption in favour of so-called ‘sustainable’ development is likely to drive habitat loss. Much of the language in the document has moved away from a focus on necessary balance and weighting of evidence, towards a presumption in favour of development. In many cases, this funnels power, land and permissions towards developers, at the expense of local people and the environment. The IPBES report on Transformative Change emphasizes the need to tackle the underlying drivers of biodiversity loss, which includes land use planning. 
• Lack of safeguards: the new document is overly vague in its definition of ‘unacceptable impact’, and risks creating the conditions for biodiversity loss via development. Given that we know that this is likely to lead to a decline in economic growth, as well as increased problems with national security, the policy is internally inconsistent. Producing economic growth in one sector, at the expense of a greater cost to economic growth in another is irrational and illogical – and these inconsistencies strongly suggest that the Ministry of Housing, Communities and Local Government (MHCLG) has not grasped the extent or urgency of biodiversity loss as a social problem. 
• There is a lack of appreciation of the benefits of green spaces to communities: the draft does not explicitly refer to the benefits of green spaces for health and well-being. Reference to Natural England’s Green Infrastructure Standards is welcome but there is no requirement to meet minimum standards for the area of green space provided per person, the accessibility (within a 15 minute walk) and the quality and nature-richness of green space, in line with these standards. 
• This risks undermining local democracy. While there is a need for local decisions to be in line with national and international obligations, sound decisions can only be made with a full appreciation of local needs, priorities and constraints. The current draft NPPF undermines this local democracy by allowing Spatial Development Strategies or the Secretary of State to take over local planning powers or overrule local decisions. Centralisation of policy and authority is also inconsistent with stated government ambitions elsewhere towards devolution. 
• The draft curtails the ability of local planning authorities (LPAs) to set ambitious targets: limiting proposals to a 10% statutory minimum for biodiversity net gain (BNG) will constrain the ability to apply higher thresholds where required. It also flies in the face of the intention with BNG, which was to set a minimum standard for nature recovery, not a maximum. Similarly, PM13 explicitly attempts to stop LPAs from applying net zero policies that go beyond the national minimum standard. More widely, the planning system works on site-by-site discretion for good reasons, and the imposition of constraints on LPAs risks locking in policies that cannot respond to local conditions.