Climate change
The NPPF section on climate change has been updated to support the UK net zero transition, enhancing the weight given to climate change resilience and mitigating carbon emissions. The updates represent a step change in the weight applied to climate change in decision-making, and Policies CC1 – CC3 set out plan-making policy requirements and key decision-making policies.
CC1, Planning for climate change, states development plans should proactively address climate change mitigation and adaptation, support net zero and consider risks such as overheating, wildfires, drought, flood risk, coastal change, water supply, biodiversity and landscapes.
Whilst previous NPPFs have required planning for climate change impacts, wildfires are included for the first time, as is a requirement for setting local water efficiency standards. This feels particularly important given the climate change driven effects we have seen over the summer.
The policy also supports development which can contribute to radical reductions in greenhouse gas emissions, this could provide an opportunity for highly sustainable residential and non-residential sites. For example, this could favour sites centred around rail stations, or lines, which can cut transport emissions.
CC2, Mitigation of climate change, promotes development that helps reduce greenhouse gas emissions and supports the transition to net zero. It places particular emphasis on:
- sustainable patterns of movement to reduce transport emissions
- designing development to conserve energy
- reusing existing structures
- taking advantage of low carbon decentralised networks
- creating and restoring habitats which can act as carbon stores
Substantial weight is now given to the benefits of improving energy efficiency of existing buildings, and / or drawing energy from district heat networks, renewable and local carbon sources.
CC3, Adaptation to climate change, requires development proposals to consider the likely effects of climate change over their lifetime and incorporate appropriate adaptation measures. For example, locating development where the risk of flooding is minimised, designing to minimise risks from overheating, and incorporating measures to mitigate against wildfires where this poses a particular risk.
The Policy gives substantial weight to the benefits of improving the resilience of existing buildings and public spaces to anticipated climate change impacts where this would be achieved through proposals for development. For example, substantial weight could be given where a development improves flood resilience or green infrastructure for areas outside of a site boundary.
Setting standards
As part of the NPPF consultation in 2025 the Government proposed radical changes to national policy on setting standards which go beyond the requirements of the Building Regulations. This included revoking the Planning and Energy Act which enables Local Authorities to do this, providing a more consistent approach to building performance through amendments to the Building Regulations, i.e. through the Future Homes and Buildings Standards.
However, following consultation feedback, through Policy PM13, Setting Standards, local authorities will retain the ability to set standards above Building Regulations. This potentially paves the way for a continuation of policies that include a variety of targets relating to energy and carbon performance.
While Policy PM13 notes that energy performance standards should be expressed as a percentage improvement over the Target Emission Rate, the policy goes on to state that additional quantitative standards can be set provided there is a clear, evidence-based rationale and no adverse impact on development viability or deliverability. This suggests standards can also be set in relation to Embodied Carbon, Space Heating Demand, and Energy Use Intensity. We are seeing these types of policy increasingly in Local Plans, however, there is a lack of consistency in targets, evidence base and costs associated with them. If local authorities want to pursue these standards, they must have a strong evidence base and there are examples where this isn’t the case and the policies are challenged by Inspectors.
Concluding thoughts
The revised NPPF provides a good step forward in understanding climate risks and ensuring Plans and new development take account of climate change resilience and mitigation. Following the extremes of this summer, the inclusion of wildfires and provision for local water efficiency targets is particularly welcome. As is attaching substantial weight to development proposals which support climate change adaptation. This provides opportunities for development where improvements can be made to positively impact offsite buildings and public spaces.
Considering the impacts on greenhouse gas emissions as part of spatial strategies supports locating development in the right places and those developments which can help cut emissions.
Although the changes to how climate change is considered as a whole are positive, the amendments to Policy PM13 compared to the draft consultation version may cause issues. While we support the ambition to improve energy and carbon performance, the current picture of emerging Plans across the UK is of an inconsistent set of targets which make planning for developers, supply chains and delivery difficult. It is likely that this will impact on deliverability at a time where the Government is looking to accelerate housing delivery.
To discuss climate change policies in the NPPF, please contact Paul White.
9 September 2026
