Celia Davis is a Senior Projects and Policy Manager at the Town & Country Planning Association (TCPA)
The Town and Country Planning Association (TCPA) has for decades championed the vital role of planning in addressing the climate crisis. This is because planning has a regulatory influence over a number of high emitting sectors such as surface transport, the construction and design of new development, and energy, and also because as the impacts of climate change become more prevalent, we must radically adapt places to unprecedented climate impacts. As global action on emissions reductions has failed to accelerate, and we face the ominous reality of living on a 1.5⁰C warmer planet, the need to pivot the planning system towards a primary focus of climate mitigation and adaptation has become urgent.
But in England, the planning system has faltered in the face of this challenge, and since 2010 has been characterised by continual reforms, none of which have succeeded in driving meaningful progress on the climate agenda.
Planning legislation in England contains a provision for local plans to ‘contribute to the mitigation of, and adaptation to, climate change’, [1] and a similar requirement in the Planning and Infrastructure Act 2025 applies to the development of Spatial Development Strategies. The National Planning Policy Framework also makes clear that ‘mitigating and adapting to climate change’ is a core planning objective, [2] and that the ‘planning system should support the transition to net zero by 2050 and take full account of all climate impacts.’ [3]
Yet despite these stated ambitions, evidence shows that climate considerations are rarely prioritised in practice. In a recent study for the Climate Change Committee, the Centre for Sustainable Energy and the TCPA found that only 12.5% of planning authorities could quantify the carbon emissions arising from the local plan, and there are low levels of coverage in plan policies on adaptation issues including overheating and water supply.
This lack of prioritisation is rooted in a number of systemic and procedural issues, not least the crisis in planning skills and capacity in the public sector. But the primary factor is that despite legislative and policy hooks for climate action through planning, these are not given primacy or clear direction in national policy, and climate considerations are often outweighed when balanced against other policy objectives, such as housing. The result is a system that pitches housing delivery against other policy requirements, rather than providing clear guidance on how they can be achieved in tandem.
Successive governments have been promising a comprehensive review of climate policy in the NPPF since 2021, and with the publication of a radically different framework for consultation in December 2025, a key test of this document is whether it provides a positive pathway through the climate crisis. To do so, it must deliver against legally binding net zero carbon targets and secure the long term safety and resilience of communities in the face of the growing climate crisis.
While there are some areas of positive progression, such as long overdue restrictions on fossil fuel expansion, as a whole the new framework represents tangible regression on key climate issues and a frustrating limitation on the scope of local development plans to prioritise climate action.
Most harmful of these is the new prohibition on local policies setting standards for net zero (carbon) homes, which will withdraw from local authorities a vital lever for ensuring development is compliant with the carbon budgets. Also of huge concern is the regression on flood risk policy, which brings into the NPPF recent updates to the planning guidance, removing the requirement to apply the sequential test to sites at risk of surface water flooding. [4] Alongside weakened consultee oversight from Lead Local Flood Authorities (LLFAs) and the Environment Agency (EA), this incremental policy regression undermines vital safeguards.
These specific policy regressions sit within an overarching framework which will create a much more permissive planning regime, where an expanded presumption in favour of development would undermine strategic approaches to locating development in the most climate resilient locations, weaken the application of local policy requirements on climate, and provide no avenue for refusing development on the grounds of creating unacceptably high levels of carbon emissions.
This is symptomatic of planning reform that has been driven by a narrow view of what the planning system is should achieve. The blinkered prioritisation of granting housing permissions, with scant regard for their quality and long term sustainability leaves us stripped of the aspirational ability to places that support thriving, climate resilient and healthy communities. Until we redirect the planning system to achieve these outcomes, we find ourselves ill equipped to respond to the mounting climate emergency.
[1] Schedule 7 (15C) of the Levelling Up and Regeneration Act 2023 (which amends the Planning and Compulsory Purchase Act 2004
[2] National Planning Policy Framework. Ministry of Housing, Communities and Local Government, December 2024. (Paragraph 8)
[3] Ibid. (Paragraph 161)
[4] See our detailed policy briefing on this issue, available here: https://www.tcpa.org.uk/resources/a-dangerous-precedent-for-flood-risk-policy/
