Published in collaboration with Edgars Planning Consultancy

Authors:

• Lewis Knight, Director of Sustainable Places, Bioregional
• Amy Powell, Associate, Edgars
• Paul Slater, Associate Director, Edgars

What could the draft NPPF consultation mean for energy, carbon and net zero?

The Government’s consultation on the revised National Planning Policy Framework (NPPF), launched in December 2025, is more than a technical update. It 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.

At Bioregional, we’ve been leading work on sustainable planning for many years, helping councils embed net-zero into local plans and develop robust evidence bases for ambitious policies. Working in collaboration with Edgars and wider industry partners, we are committed to ensuring these potential changes are fully debated and understood.

To be clear, the new NPPF is a consultation, not a final decision. Things can change (and have done in the past), and based on strong feelings 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 – so if this piece strikes a chord with you, get in touch.

What’s proposed in the new NPPF? 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 fail to meet its net-zero target. Restricting local powers now risks locking in emissions for decades and creating costly retrofit challenges.

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 analyses.
• 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: this is 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

Bioregional and Edgars 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 - 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. Respond through the Government portal here, or get in touch with us to join our collective response.

Watch this space

We’ll be publishing more insights over the coming weeks as the industry responds and the debate evolves. Follow us on LinkedIn and sign up for our Built Environment newsletter for updates and practical guidance on how to navigate these changes.

About the authors:

Lewis Knight, Director of Sustainable Places, Bioregional

Lewis has over 15 years’ experience in built environment sustainability. He is Bioregional’s lead on all place-based projects across the UK. This includes leading Bioregional’s sustainability support on the UK’s first eco-town, NW Bicester, a wide range of large new-build masterplans, complex regeneration projects and estate-wide carbon footprints and zero-carbon pathways.

Lewis is experienced in working alongside Local Planning Authorities, having supported numerous authorities with their development of zero-carbon policies in the past four years. Lewis has provided detailed sustainability and planning advice to the public sector for almost a decade. 

Amy Powell, Associate, Edgars

Amy joined Edgars in the autumn of 2019 having managed an independent lettings office in Oxford for eight years. Having graduated from the University of Southampton with a degree in Geography she went on to complete the RTPI’s apprenticeship and gained a distinction in her Master’s degree in Chartered Town Planning at London South Bank University. In 2022, she became a Chartered Member of the Royal Town Planning Institute and was awarded the RTPI’s Southeast Young Planner of the Year award.

Paul Slater, Associate Director, Edgars

Paul is an associate planner at Edgars; he works on a range of projects, including the strategic promotion of housing sites, county waste matters and infrastructure projects. He has particular expertise in Local Plan work, submitting timely representations for clients as well as scrutinising Councils’ housing land supply.