Although the document has only been available for a short time, its expansion from 69 to more than 120 pages makes one thing clear. This is not a routine update. It is the most significant overhaul of national planning policy since the NPPF was introduced in 2012.
There are so many changes to the document and the implications range from far reaching to tweaking the text, that the biggest question is how do you absorb it all? Well, Bidwells has got you. We’re starting off with an article signposting the biggest changes, before a series of expert led sector and topic article. This first one engages in some signposting of some of the most relevant to developers and promoters, but with a focus on some of the changes that have received less coverage. We’ve looked at the changes that will provide new opportunities, change your strategy, or will have financial and evidence provision implications for your project.
For this article we have focussed on National Development management Policies only. This is because these will come in to force and over ride Local Plan policies (in theory) upon publication of the final version of the NPPF, which the Government has indicated may happen in late May.
A “Default Yes” Around Train Stations
One of the most striking additions to the draft NPPF is the new train station policy, set out in Policy S5(1)(h) and Policy GB7(1)(h). This introduces a presumption in favour of approval for housing and mixed-use development within a reasonable walking distance of a well-connected railway station.
The opportunity here is clear. This presumption applies even within the Green Belt, provided the Golden Rules are met. In practical terms, this could unlock significant areas of land without the need to demonstrate very special circumstances or wait for Local Plan allocation.
However, the policy is tightly defined. To qualify as well-connected, a station must be within a top 60 Travel to Work Area by GVA and have a minimum service frequency of four trains per hour, or two in one direction. This creates what we see as a potential frequency trap. Many otherwise sustainable locations may fall outside the policy unless service upgrades can be agreed with operators.
Density is also non-negotiable. Development must achieve at least 40 or 50 dwellings per hectare, depending on connectivity. Where this threshold is not met, the draft NPPF suggests that permission should be refused.
EV Charging Infrastructure Outside Settlements
The draft framework provides clear support for electric vehicle charging infrastructure beyond settlement boundaries. Policy S5(1)(a) includes roadside facilities, in accordance with Policy TR5, within a closed list of development types that should be approved outside settlements.
The implication is significant. EV charging stations, treated as essential infrastructure, are given a presumption in favour of permission in locations that would previously have faced considerable policy resistance. This is subject to compliance with design and landscape policies, but the direction of travel is unambiguous.
Protecting Emerging Allocations
A more subtle but strategically important change appears in Policy HO13(4). This states that development proposals affecting sites identified for large-scale residential development in emerging plans should not be inconsistent with the proposed scale, location and phasing of draft allocations.
While the wording is clumsy, the intent is clear. This policy is designed to prevent speculative applications from undermining emerging Local Plan strategies. For promoters, this reinforces the importance of aligning early applications with draft allocations rather than seeking to pre-empt them.
“Substantial Weight” as the New Planning Currency
The draft NPPF introduces a standardised approach to how benefits are weighed in decision-making. Vague and inconsistent terms such as significant or great weight are replaced with a single tier of substantial weight, now applied explicitly to 18 policy areas.
In theory, this should bring greater clarity and consistency to the planning balance. Decision-makers are directed to apply heavy positive weight to benefits such as housing delivery, economic growth and energy efficiency. For compliant schemes, this should strengthen the case for approval and reduce uncertainty.
Agricultural Land and a De Facto Sequential Test
Policy N2(1)(b) introduces a new development management test for Best and Most Versatile agricultural land. Where significant development of agricultural land is necessary, proposals must demonstrate that poorer quality land has been used in preference to higher quality land.
Some commentators have suggested that this effectively introduces a sequential test at the decision-making stage, something that was previously limited to plan-making. Developers promoting BMV land should expect increased scrutiny and will need robust evidence to demonstrate that suitable lower-quality alternatives are not available.
Viability: A Higher Bar to Clear
Policy DM5 represents a clear attempt to rein in site-specific viability negotiations. Proposals that comply with up-to-date plans are assumed to be viable, with site-specific assessments restricted to a small number of tightly defined circumstances, such as genuinely unforeseeable costs or material differences in site characteristics.
Crucially, the policy mandates the use of standardised inputs, proposed for Annex B. The intention is to prevent inflated land values being used to justify reductions in affordable housing or other policy requirements.
Grey Belt sites may still be subject to site-specific viability appraisal where development involves previously developed land, multi-phase strategic sites, or wholly different development models. The consultation document also signals further changes to viability inputs, which we explore in more detail in our dedicated viability article.
Development Outside Settlements and the “Unmet Need” Gateway
Policy S5 reshapes the approach to development outside settlement boundaries. While it includes a list of acceptable development types, this is deliberately broad and includes development that would address an evidenced unmet need.
For housing, this creates a potential gateway for development in circumstances where there is no five-year housing land supply or where the Housing Delivery Test has been failed. The wording may also allow for 100 percent affordable housing or self-build schemes to come forward where unmet need is demonstrated, even where supply tests are met. In all cases, development must be well related to the settlement boundary and supported by appropriate infrastructure.
For other uses, such as logistics, where a local need is evidenced, the locational requirement does not apply. This effectively codifies the tilted balance for certain forms of development in isolated locations.
Climate Change, Wildfires and Sustainability
The draft NPPF introduces new evidential requirements linked to climate resilience.
Policy CC3(1)(e) requires development at risk of wildfire to incorporate mitigation measures such as firebreaks and defendable spaces. At the same time, Policy CC2 gives substantial weight to improving energy efficiency and drawing energy from renewable sources.
Together, these policies reinforce sustainability as a decisive factor in the planning balance. Applicants will be expected to demonstrate how proposals address overheating risk, climate resilience and circular economy principles at a much earlier stage.
Medium-Sized Schemes and a Shift in Approach
To support SME builders, the Government is consulting on major changes for medium-sized development, defined as 10 to 49 homes on sites up to 2.5 hectares.
The proposals would allow affordable housing requirements to be met entirely through cash payments in lieu or off-site provision. This removes the complexity of on-site delivery and could unlock sites that have stalled due to viability or delivery constraints.
The consultation also proposes extending Permission in Principle to cover schemes of up to 49 homes. This could significantly reduce upfront cost and risk for medium-sized developments and represents a meaningful shift in how these schemes are brought forward.
Deliverability as a Material Consideration
Policy HO13 explicitly makes the delivery rate of a site a material consideration. Proposals for major residential development should be capable of bringing housing forward within a reasonable period.
This gives local planning authorities greater scope to interrogate absorption rates and phasing assumptions. It also increases the likelihood of tighter conditions, including shorter implementation timescales, to accelerate delivery.
Economic Development and Business Growth
Policy E2 directs decision-makers to give substantial weight to the economic benefits of commercial development that enables businesses to invest and expand.
This strengthens the case for commercial schemes, particularly where they align with the Industrial Strategy or support growth sectors such as logistics and data centres. In practice, this may allow economic benefits to outweigh local concerns relating to amenity or character.
Gentle Densification and Small Sites
Policy L2 provides explicit support for gentle densification, including upward extensions such as mansard roofs and infill development within residential curtilages.
By embedding this support within national policy and attaching substantial weight to it, the Government is signalling a more design-led alternative to permitted development rights for intensifying urban and suburban sites.
Value Engineering Under Greater Scrutiny
Policy DP4(2)(c) states that local planning authorities should not allow the quality of approved development to be materially diminished between permission and completion.
While this reflects established best practice, its elevation to national policy strengthens the hand of authorities seeking to resist cost-driven Section 73 amendments.
Sustainable Transport and Rural Pragmatism
Policy TR3 requires development to be located where a genuine choice of sustainable transport modes exists, unless the nature of the use makes this impractical.
Importantly, the policy recognises rural realities. In rural areas, opportunities to improve sustainable transport should be taken where they exist, but the absence of such options is not, in itself, a reason for refusal.
Green Space Standards
Finally, Policy HC3 states that where Local Plans do not define green space standards, applicants should apply national benchmarks, including those set by Natural England and Fields in Trust, to identify necessary provision and improvements.
