With ministers indicating that no further national planning policy changes are anticipated [2], the focus now shifts from policy-making to delivery. The Planning Inspectorate will play a vital role in embedding the new framework into day-to-day development management.
For the industrial and logistics sector, forthcoming appeal decisions are likely to provide the first indication of how policies E2 and E3 will be interpreted and applied in practice. These decisions over the coming weeks and months will set the tone for delivering the Government's ambition for “growth in every postcode” [3], including through new industrial and logistics development, particularly where proposals are located outside of settlements.
Ten changes we expect to emerge through forthcoming appeal decisions are:
- An early indication of the scope, quantum and quality of economic benefits which attract “substantial” weight, and clarification on whether it is the top weight to be applied or whether we see “very substantial” being applied in exceptional cases.
- Greater and tighter cross reference to economic visions and strategies (e.g. Economic Development Strategies) for the “area”, although this could extend to the local and sub-regional level as well as better alignment of decision-making in the context of the Government’s Industrial Strategy, for example.
- A stronger recognition of market signals influencing the under-supply of industrial and logistics land or premises, including rental values and availability. There is a strong possibility that the “suppressed demand” methodology will attain more credence.
- Greater clarification on what constitutes an “anticipated catchment area”, particularly for strategic logistics proposals which address a larger than local need. Therefore, expect decision-making to rely on pre-defined functional economic market areas unless in very specific circumstances.
- An appreciation of the changing needs of the industrial and logistics sector noting what was once a need yesterday is no longer a need for tomorrow, so an acknowledgement that land and premises to be brought forward will support a flexible, dynamic and responsive economy. This is especially true for locational requirements which are ever evolving.
- Whilst not a specific information requirement in Annex C, there could possibly be a deeper analysis of alternative site assessments to ensure the specific locational requirements of an industrial and logistics proposal cannot be met elsewhere in a catchment area by way of existing allocations in a development plan(s). This is especially true for occupier-led propositions. And, if there is a lack of alternative sites, sufficient weight (i.e. substantial) should follow.
- And whilst silent in national policy (i.e. E2(2)), “substantial” weight will be applied in the planning balance to the demonstration of a proposal addressing an unmet need for business land and premises. Again, in exceptional cases, could “very substantial” be applied where a considerable proportion of the unmet need is met on a single site (rather than several smaller sites in less sustainable locations)?
- Increased emphasis on comprehensive sustainable transport proposals that are multi-faceted - incorporating active travel, public transport and measures that reduce reliance on private car use. This will be very relevant to those industrial and logistics proposals outside of settlements, near motorway junctions though relying on labour supply in proximity.
- The impact on local residents or other neighbouring uses from industrial and logistics proposals is limited in scope to matters of noise, vibration, air quality, lighting and odour with cross reference to policy P3 when considering policy E3.
- Where exception policies for additional employment land in adopted Local Plans are materially inconsistent with policy E3, they are likely to attract very limited weight. This should reduce the influence of restrictive, ambiguous or vague local planning policies for freight and logistics.
Whilst these expectations relate specifically to policies E2 and E3 (and in turn S5, GB6 and GB7), we also anticipate that innovative, integrated and social value driven proposals for industrial and logistics floorspace will benefit from “substantial” weight being attached to wider policy objectives, including climate change (CC2), well-designed places (DP3) and public health (HC4). These baskets of benefits should be carefully considered in any place-making for industrial and logistics proposals.
The new NPPF provides a clearer and more favourable policy framework for industrial and logistics development. The key question is how the Planning Inspectorate and Secretary of State apply these policies in practice. As appeal decisions emerge, they will provide greater certainty on interpretation and in turn help unlock economic growth.
We are currently advising on a range of industrial and logistics planning applications and appeals across England and are closely monitoring how the new NPPF is being interpreted through decision-making in the sector.
To discuss what these changes could mean for your proposals, please get in touch with Sam Lake.
20 October 2026
[1] https://www.gov.uk/government/publications/the-new-national-planning-policy-framework-letter-to-the-chief-executive-of-the-planning-inspectorate
[2] https://www.planningresource.co.uk/article/1971125/no-nppf-updates-says-pennycook
[3] https://www.gov.uk/government/news/prime-minister-pledges-growth-in-every-postcode-across-whole-of-uk-as-he-visits-scotland
