Back in August, we discussed the proposed reforms to the NPPF. Now that the December 2024 update has been published, here’s our take on some significant changes that firmly embed climate adaptation and mitigation into planning policy.

Net-zero targets acknowledged

Crucially, for the first time, Paragraph 161 explicitly references the UK’s legally binding target of achieving net zero by 2050. This move signals the government’s recognition of the planning system’s critical role in our net-zero transition. While challenges clearly remain, these updates represent a telling step toward aligning planning policy with the realities of the climate crisis and the opportunities of a net-zero future.

Climate change impacts addressed (but no explicit mention of embodied carbon)

One of the most notable additions in the updated NPPF is Paragraph 163, which requires planning applications to address a “full range of potential climate change impacts.” While this is a significant step forward, there is a notable omission: embodied carbon is not explicitly mentioned. As Estelle Dehon KC suggests in her blog, this paragraph seems to align with the broader concept of "mitigation," which could be interpreted as encompassing embodied carbon. However, the absence of a direct reference leaves room for interpretation, and this ambiguity means that embodied carbon may not be automatically incorporated into planning decisions.

This lack of clarity presents both a challenge and an opportunity. On the one hand, local authorities can use the language of Paragraph 163 to advocate for assessments such as Whole Life Carbon Assessments (WLCA) to address embodied carbon at the local level. This provides a potential "hook" for promoting its consideration in planning applications. On the other hand, unless further clarification is provided through planning appeals or case law, it is likely that embodied carbon could remain a local or voluntary priority rather than a universally mandated requirement.

In its current form, the NPPF does not go far enough to mandate WLCA or to ensure embodied carbon is consistently assessed in all planning applications. Stronger language and more explicit guidance would be needed to make this a national requirement. For now, the updates present a clear opportunity for advocates of sustainable design to push for more comprehensive carbon assessments, but it remains to be seen how this will evolve in practice.

Progress on renewables

A particularly encouraging development is the renewed emphasis on renewable and low-carbon energy projects. Paragraph 168 introduces a requirement for local planning authorities to give “significant weight” to the benefits of such renewable projects, underlining their role in achieving a net-zero future.

While there is room for further clarity and ambition, this shift in policy sends a clear signal to developers and local authorities: renewable energy is a key priority, and even small-scale or community-led projects can make a valuable contribution to reducing national emissions.

The removal of the controversial footnote 57, often cited as a barrier to onshore wind development, demonstrates the government’s willingness to address long-standing challenges in planning policy. This change, alongside the recognition of the giving greater support to for applications that highlight the benefits of repowering existing renewable energy sites in Paragraph 168(c), positions the NPPF as a key enabler of the UK’s clean energy transition.

Climate resilience emphasised

The update also places a welcome emphasis on climate resilience. Paragraph 182 expands the requirement for sustainable drainage systems (SuDS) to all applications affecting site drainage, not just major developments, while Paragraph 136 reiterates the importance of tree-lined streets and green infrastructure, importantly ensuring maintenance is considered for new trees, and existing trees should be retained wherever possible.

These measures reflect a growing understanding within the industry of the role that nature-based solutions play in adapting to climate change and improving the quality of our urban environments, and importantly the health and wellbeing of residents and visitors. While there will always be room for improvement, to me, these updates are a step in the right direction, particularly in light of the increasing risks posed by extreme weather events that we’ve been seeing, such as the recent Storm Bert Flooding and 2022’s record-breaking heatwave.

Health considerations

Similarly, the inclusion of health considerations in Paragraph 162 now demonstrates a more holistic approach to climate adaptation. By requiring policies to support measures that enhance the future health and resilience of communities, the NPPF acknowledges the weighty connection between the built environment, public health, and climate change. This approach is essential for ensuring that our towns and cities are not only sustainable but also equitable and liveable for future generations.

Missed opportunities

The December 2024 NPPF update is not without weaknesses or omissions. Beyond the embodied carbon issue covered above, retrofitting existing buildings - an essential strategy for reducing embodied carbon overall - receives understated encouragement. Clearer policy direction could have driven greater action in this area.

The same could be said for fossil fuel-powered developments. While the Climate Change Committee and international reports have emphasised the urgent need to phase out fossil fuels, the NPPF remains largely - and surprisingly - silent on this issue. Incorporating a presumption against new fossil fuel developments, as suggested by consultation responses, would have further aligned planning policy with the UK’s net-zero ambitions. Without this, the planning system risks enabling developments that could be fundamentally incompatible with the UK’s legally binding climate targets, undermining progress in other areas of the framework.

Despite these gaps, the updated NPPF does seem to provide a solid foundation for driving change in the planning system. By specifically referencing national net-zero targets, emphasising the importance of renewable energy regardless of scale, and promoting resilience, the NPPF creates key opportunities for local authorities to drive and pursue developments and local plans that allow alignment with our nationally mandated carbon targets.

As Anna Hollyman of the UK Green Building Council (UKGBC) observes, the planning system has enormous potential to create greener, healthier, and more resilient communities. These updates, while incremental, represent a positive step toward realising that vision. Hollyman continues to make a vital call for stronger links between the Planning Act, the Climate Change Act, and the Environment Act – which we echo – but the progress made in this NPPF update should not be underestimated.

To conclude

The December 2024 updates to the NPPF should mark an important milestone in the UK’s journey toward net zero. While there is still much to do, the strengthened emphasis on climate adaptation, renewable energy, and resilience creates the foundations for meaningful action.

^{Image credits: House fire from heatwave, Benjamin Elliott via Unsplash, Green planting in Sheffield, Alastair Johnstone / Climate Visuals}