This latest response follows representations made on the previous three NPPF consultations (January 2021, March 2023 and July 2024). The latest version of the NPPF is the eighth in 14 years. A recent podcast introducing some of the key themes of the draft NPPF can be listened to here. 

In June 2025, we assessed the challenges facing the government to stimulate Local Plan production and housing delivery in our annual Spotlight on Planning paper.

Up to date Local Plans remain a key issue (only standing at 26% across England) as does housing delivery (now at 202,000 dwellings year to date), below the peak in 2020 – and in addition new planning consents are falling, highlighted by Savills Research’s English Housing Supply update for Q4 2025.

Housing is an important component of national policy, though this should not overshadow the importance of other key issues, including mitigating climate change, achieving net zero carbon, planning positively for employment needs, enhancing green infrastructure / the environment, ensuring high quality design, planning for healthy communities and further embedding social value as part of the planning system.

Our overall view remains that the NPPF has provided a fundamentally more practical approach to conveying national planning policy since its inception in 2012. The streamlined approach to policy is to be commended, as is keeping it up to date. The revised approach is now a series of plan and decision making policies, which is intended to be clear and rules-based. Savills supports this approach, provided that it is made clear the appropriate weight to be provided to NPPF- and that it should be read as a whole.

As the National Development Management Policies have not been made statutory, it will be important for decision makers to make it clear the reasons why out of date Local Plans have been provided reduced weight.

We continue to support the government’s objectives of sustained economic growth, delivering more homes through sustainable development, building pride in place and a focus on stability, investment and reform.

While the focus of the NPPF Revision - and consultation questions - is on housing, we have made wider comments, for example on economic development and employment, retail, viability, renewable energy provision, urban design, heritage, flood risk, infrastructure social value and health.

Our response can be read in full here, but a summary of some of the points that have been made within include the following introductory comments:

• Savills is supportive of the format and structure of the NPPF, and emphasises the need for policy stability. A number of recommended alterations to the Annex Glossary are made including the approach to evidenced unmet need, density and veteran trees.
• We continue to advocate strategic planning at the relevant economic scale (the proposed Spatial Development Strategies – SDS) and, in respect of neighbourhood planning, continue to suggest reverting to earlier NPPF versions to enable targeted housing delivery and avoid the disproportionate protections provided.
• Up to date Local Plans - which realise the Standard Method local housing need (LHN) is urgently required, and hence the LHN should take precedence in the short term - ahead of emerging SDS. The sequencing is an important practical reality, as there may be delays with SDS production owing to ongoing local government reorganisation. More on the roll out of SDS can be read here.
• In respect of plan-making, the drafting on transitional arrangements risks allowing old, low housing requirements to persist – hence an “80% test” (existing or new Local Plan requirement versus up do date LHN) should be applied more broadly. In addition, the Planning Inspectorate should ensure plans currently at Examination reflect that they will operate under the new NPPF.
• Continued support for the five-year housing land supply and the Housing Delivery Tests. An emphasis is now also required on supporting SMEs, through positive allocation in Local Plans of smaller sites.
• In addition, to stimulate housing delivery care is required on the approach to viability, or rigid approaches to housing mix requirements, or floors in affordable housing provision.
• The approach taken to front load viability to the Local Plan stage risks being counter-productive. Market factors change more regularly than Local Plans. Savills warns that proposed changes may reduce applications rather than reduce negotiation. Recommendations are provided on factors such as fixed developer returns, land value premiums and the approach to standardised inputs. More on viability reform can be read here. 
• Caution is required on a requirement to deliver, which goes significantly beyond the existing policy. Instead, the NPPF is best placed to create the circumstances to encourage delivery.
• In respect of Green Belt, Savills supports a shift away from treating Green Belt review as “exceptional”: it should be part of routine plan making. The approach to undertaking reviews should not be held up by SDS production. The retention and strengthening of Grey Belt policy is also welcome, though caution is expressed on applying Golden Rules to Local Plans produced under pre-2024 versions of the NPPF.
• In respect of the Presumption in Favour, support is expressed on the structured approach, though the policies could be interpreted as adding complexity above the present “tilted balance”. The role and definition of the settlement boundary does gain additional importance.
• The focus on well connected stations is welcome. “Reasonable walking distance” should be qualitative, not a fixed national metric. Minimum densities (50 dwellings per hectare) should be removed from national policy as more appropriate for local policy. Additional development around stations is untapped potential, particularly in some Green Belt areas. This is explored in more detail here.
• Savills considers that the draft NPPF signals a step change in planning positively for employment. More can be read here.
• Savills strongly supports a pro growth approach including AI Growth Zones, logistics, manufacturing and data centres. Concern that the policy may over-emphasise office R&D over manufacturing. In addition, Savills requests explicit inclusion of manufacturing needs. Whilst market signals are now reflected in the decision making policies, these must also be required in plan making.
• On renewable energy and climate change, we are in support of the transition to a net zero carbon economy and calls for comprehensive national planning policy on carbon emissions and renewable energy projects.
• We have also highlighted the importance of embedding social value and health considerations in planning policy to address societal changes and health care challenges. In addition, we have highlighted the importance of credible approaches to heritage and urban design policies.

In summary, Savills largely supports the changes put forward in the consultation draft and the proposed policy / rules- based approach. This clearly builds momentum on the various policy updates provided in the December 2024 version.

The important next step will be a continuation of positive decision and plan making to provide the land and infrastructure to help sustain economic growth. To that end, Savills would encourage the government to promptly publish the final version of the NPPF, and for it to pertain for a reasonable period, to allow the changes to properly bed-in. The development industry needs stability, so an update on the rest of the reforms put forward under first the Levelling Up and Regeneration Act (2023) and the Planning & Infrastructure Act (2025) would be welcomed.