Our team have been busy reviewing the NPPF consultation since its release before Christmas, and digesting what this means for our clients. This, our first article, focuses on what the draft NPPF could mean for energy, carbon & net zero buildings.
In collaboration with Bioregional, we’ve been supporting numerous councils formulate net zero policies into local plans and develop robust evidence bases for ambitious policies. We are committed to ensuring these changes are fully understood and debated, and will continue to work collaboratively with Bioregional and wider industry partners to support local authorities in local plan formation.
The Government’s consultation on the revised National Planning Policy Framework (NPPF) represents a potentially significant shift in how planning policy addresses energy and carbon and for local authorities striving to deliver net zero development, these proposals could reshape the landscape.
To be clear, this is a consultation, not a final decision. Things can change (and have done in the past) and based on strong feeling across the planning and sustainability sectors, we hope they do. The consultation runs until 10 March 2026, and now is the time for local authorities, industry partners, and stakeholders to reflect, review evidence, and share knowledge. We’re actively working with LPAs and industry groups to bring people together to share insights and shape responses that safeguard climate ambition.
What’s Proposed? PM13 and Local Powers
One of the most striking proposals is Policy PM13, which seeks to limit the scope of quantitative standards in local plans. Under PM13, local authorities would no longer be able to set energy efficiency standards beyond Building Regulations, except in very narrow circumstances.
The consultation also signals the Government’s intention to amend the Planning & Energy Act 2008 to remove the explicit power for LPAs to set higher energy efficiency standards for dwellings. If enacted, this also seeks to change how local plans can drive climate action.
Why does this matter?
Building Regulations alone will not deliver the reductions needed to meet carbon budgets. The Climate Change Committee has been clear: without ambitious local action, the UK will fall short of its net zero target. Restricting local powers now risks locking in emissions for decades and creating costly retrofit challenges later.
Local planning authorities also have a statutory duty under Section 19(1A) of the Planning & Compulsory Purchase Act 2004 to include policies that mitigate and adapt to climate change. This duty remains, regardless of changes to the Planning & Energy Act. Courts have confirmed that national policy is guidance, not law, and local circumstances can justify departures where robust evidence exists.
Our advice (cautionary, not prescriptive)
While these proposals are not yet in effect, LPAs should prepare for potential changes:
- Plans submitted before 31 December 2026: Continue as planned but monitor developments. Ensure policies are backed by strong local evidence—feasibility studies, viability assessments, and carbon budget analysis.
- Plans submitted after 31 December 2026: Focus on renewable energy and low-carbon development and pursue ambitious energy efficiency targets where possible. Justification will be key—linking policies to statutory climate duties and demonstrating alignment with net zero.
Opportunities still exist
Despite the proposed restrictions, there are areas where LPAs could and maybe should continue to lead:
- Renewable and Low-Carbon Energy: Strongly supported in the draft NPPF, with no proposed changes to the Planning & Energy Act in this respect.
- Embodied Carbon: Not mentioned in the consultation and outside Building Regulations, leaving scope for local targets if proportionate and evidence-based.
- Overheating and Design Standards: PM13 allows quantitative standards for design where justified, meaning policies referencing TM52 and TM59 could still progress.
Working Together: Responding to the Consultation
Edgars and Bioregional are working with many local authorities and industry partners to ensure these proposals are fully understood and debated. We’re helping stakeholders come together to reflect, review evidence, and share knowledge because collaboration is key to shaping a planning system that supports net zero.
The consultation is open until 10 March 2026. If you care about the future of sustainable development, now is the time to make your voice heard. You can respond via the official Government portal: https://www.gov.uk/government/consultations/national-planning-policy-framework-proposed-reforms-and-other-changes-to-the-planning-system.
Or get in touch with us to join our collective action and response.
Watch this space
We’ll be publishing more insights over the coming weeks as the industry responds and the debate evolves.
Authors
- Amy Powell, Associate, Edgars
- Paul Slater, Associate Director, Edgars
Published in collaboration with Bioregional
- Lewis Knight, Director of Sustainable Places, Bioregional