Planning matters blog

Best-laid plans? The Starmer stocktake

Matthew Spry 17 Jul 2026

Published on 5^th July 2024, as Sir Keir Starmer took office, my Lichfields blog - A new dawn has broken, has it not? – provided a stock take of the new Government’s planning inheritance on housing and identified five policy elements that were “likely to be necessary if the Government is serious about aiming for its 1.5m target” over the five years of the parliament.

As it turned out, the Prime Minister’s term will last a little over two years, shorter than the typical period for securing an outline planning permission for a residential scheme.[1] If the average time it takes to get consent for building new homes is a day longer than the term of any Prime Minister except George Canning or Liz Truss (and perhaps Viscount Goderich), you know you have big problems with your planning system.[2]

The five policy necessities identified by the blog were:

Reform and strengthen the presumption
Update local housing need
Unlock poor quality Green Belt
Remove technical blockages
Lay the ground

With Starmer about to be replaced by Andy Burnham and a new NPPF prepared but not now to be released until after the summer recess, it is worth measuring progress against those asks and the baseline to see if the new dawn is likely to fulfil its promise.

1. Reform and strengthen the presumption

My blog asked for the circumstances in which the presumption in favour of sustainable development applies to be broadened and the tilted balance sharpened through ‘extra tilt’ and some prescription on weights to be applied in the balance of benefits and harms to improve consistency.

The Government did the first part of this quickly. The December 2024 NPPF reinstated the five year housing land supply requirement for every authority irrespective of local plan progress, reversing the December 2023 concessions. Our own estimate is that 65-80% of the country is now operating under the presumption.

However, the Government waited until the December 2025 Consultation NPPF to put forward its response to the second and third parts of the ask (which we unpacked further in this October 2024 blog), with suggested changes that included amending the tilt in the balance from the 2012 formulation of “significantly and demonstrably” to a new “substantially”, and the attribution of “substantial weight to certain benefits, and the limited circumstances in which it is expected that permission would be refused”.[3] Of course, none of this will be in place until the new NPPF is published.

On the debit side, the Government has fallen behind on publishing the Housing Delivery Test which is an important mechanism for triggering access to the presumption.[4] The Government was elected promising to reinstate so-called “mandatory” targets, but has not published one of its measures for enforcing them.

2. Update Local Housing Need

I suggested a simple, stock-based standard method with an affordability adjustment, distributing need more evenly, addressing obvious flaws in relying on circular demographic projections, and opening up more authorities to land release.

This ask was delivered almost to specification, first in draft within weeks of taking office and with tweaks for its final form in December 2024. The method is stock-based, affordability-multiplied, strips out the arbitrary caps and the 35% urban uplift, and is ‘mandatory’ as the basis for need (but not the planned requirement). It raised the assessed need from 305,000 to 370,000, a 21% increase, and redistributed towards the least affordable places. London’s figure landed at 88,000, posing a challenge for the Mayor’s next plan which has just been launched for consultation.[5]

3. Unlock poor quality Green Belt

My blog suggested the automatic ‘substantial’ weight to Green Belt harm to be qualified for previously-developed and low-performing land, and for plan making to require Green Belt reviews with a brown-grey-green sequential approach to meeting needs.

This was delivered, and then some. Grey belt, the Golden Rules, and a route by which development in the Green Belt is not inappropriate where four tests are met, went considerably further than many anticipated. Contrary to the findings of the House of Lords Built Environment Committee,[6] it also seems to be working, albeit the viability burdens it imposes may put a cap on its potential in a suppressed market.[7] The policy requirement for Local Plans to review Green Belt reversed the December 2023 NPPF and makes clear for the first time that Green Belt should be reviewed with the objective of meeting needs.[8]

4. Remove technical blockages

I noted the need for nutrients, the flood risk sequential test, statutory undertaker responsibilities and the section 106 affordable housing cliff edge to be addressed.

The Government has made strides, but it is a difficult area at the intersection of a fractured infrastructure ecosystem, longstanding investment backlogs, and statutory obligations, notably on habitats. The challenge has resembled ‘Wack-a-mole’. Just as the Government addressed one set of blockages (e.g. its deal on water neutrality in North Sussex)[9], new ones appeared (e.g. Anglian Water’s promise to block schemes).[10]

The Building Safety Regulator shifted its performance: a previous maximum of 1,206 starts in a quarter – associated with a growing backlog - shifted after the June 2025 reforms to a reported 7,089 in 2025 Q4 and 6,276 in 2026 Q1.[11]

The Government and Mayor’s London emergency package was produced with measures - a time-limited route at 20% affordable housing without viability assessment, CIL relief, and changes to some London Plan Guidance as it relates to density - that were largely seen as positive, tempered by concerns that they do not go far enough to address the viability crisis.

The Planning and Infrastructure Act 2025 introduced the idea of Environmental Delivery Plans and a Nature Restoration Fund and the first use is likely directed at nutrient neutrality catchments.[12] But it will take time and secondary legislation was laid just last month.[13]

Many of the solutions involve on-site mitigation, paying a levy or buying a credit, all adding to the cost of building a home. Taking into account other economic pressures, this has increased by an estimated £76,000 since 2020.[14]

Making the dysfunctional planning consent process work more effectively and removing the general grit in the system remains work in progress.[15] Delaying release of the NPPF until after summer recess is unhelpful in this regard.

5. Laying the ground

Recognising the long-term nature of any sustainable solution for tackling the housing crisis, my 2024 blog pointed to the need for a platform: strategic plans, local plans, New Towns.

The government has begun to deliver on this, but with added complications. The new plan-making system came into force on 25th March 2026, twenty months into the parliament, with its 30-month preparation timetable, three Gateways and no Duty to Cooperate. In response to the strategic planning question, Spatial Development Strategies are coming, at least in some locations. The New Towns Taskforce began work almost immediately and reported in September 2025, twelve locations became seven in March 2026, and final decisions are expected in late summer 2026, with no dedicated grant programme announced.[16]

Weakening the strategic platform has been:

the fracturing of the Government’s political writ through poor local election results and the national opinion poll performance that ultimately cost Sir Keir his job. In some locations, those running local administrations are at best ambivalent about high levels of housing growth and may believe the Government can be toppled at the next election; this dilutes their motivation to make hard decisions through the formation of local and strategic plans.
The decision to run major policy change in planning – including the SDS and Local Plan making – at the same time as local government reorganisation and devolution changes has also had an impact on the focus of officers and elected members. Was it wise to twin track in this way? Views differ, but the genie is out the bottle and – as a generality - it may now be preferable to resolve the institutional uncertainty and crack on.

Meanwhile the second new NPPF is on its way, although seemingly unlikely to see light under Sir Keir. The December 2025 draft laid out 133 coded policies, national decision-making policies and a restructure that the Government itself describes as the biggest change since 2012.

But that change is not as big as it might have been. The Government decided not to implement s.93 of the Levelling Up and Regeneration Act 2023 and put these policies on a statutory footing. Whether the desired simplification can in fact be achieved without doing so remains to be seen. Many people at the coal face of decision making on applications have their doubts.[17]

What has this produced on the ground?

Just 18 local plans were submitted for examination in 2023/24 (see Figure 1). In 2024/25, the ‘threat’ of the new Standard Method and emerging policy requirement to release Green Belt provided motivation for some of the slowest cohort of plan making LPAs to suddenly realise how quickly they could formulate a local plan working to the December 2023 NPPF under transition arrangements. Submissions fell back to 25 in 2025/26 but now PINS projects 115 submissions in 2026/27.

Figure 1: Local plan submissions

Source: PINS / Lichfields analysis

The implication is that the housing targets in adopted Local Plans are still hovering around the 230,000 mark, as they were in 2024; local plans are still being adopted based on the old Standard Method’s targets; twelve alone in Q1 of 2026. The gap between what’s forward planned and what’s needed has almost doubled.

Of course, an authority commencing preparation of a plan adopts it in 2028/29 earliest, and its allocations (assuming they are deliverable) deliver first completions in the early 2030s. New Local Plans were never likely to contribute meaningfully in this decade.

Housing Delivery

So where are the homes? Figure 2 shows that the rate of housing delivery (as measured by EPC registrations) is lower in 2025/26 than it was in 2023/24, albeit with a small uptick year-on-year from the low of 2024/25. Measuring net additional dwellings 9^th July 2024 to 14^th June 2026 the figure is an estimated 392,400 homes, leaving 1.1m to achieve over the remaining three years of this parliament, broadly similar – as if by magic - to the Standard Method’s circa 370,000 a year.[18]

The OBR does not think this will happen. Its March 2026 forecast has UK net additions falling to a low of 220,000 in 2026-27 before rising to just over 305,000 in 2030-31, a year after the parliament ends.[19] Its verdict on the reforms is that the impact “has yet to meaningfully materialise in outturn”.[20] Full Fact rates the pledge as off track.[21] At the current run rate, England reaches 1.5 million in about 2032.

Figure 2: Housing Delivery (EPC Registrations) (000s)

Source: MHCLG (Housing Supply Indicators of new 2026 Q1 19^th June 2026)

Completions are the rear-view mirror, reflecting the housing market but also the planning system operating in preceding years. In the year to Q1 2024, before Labour took office, only 236,000 homes were granted permission, implying a delivery rate of 190,000 per annum. The forward flow of consents was expected to decline further because the number of applications for major development was down 12%, almost half the level they had been in 2016/17.

Unsurprisingly, therefore, the position on homes granted permission is not (yet) positive – See Figure 3. MHCLG decided to stop publishing its Glenigan-based data on homes granted planning permissions pending data validation, so no official data is available after Q3 2025.[22] However, it has been suggested the number for the 12 months to Q1 2026 is just 186,000.[23] Not auspicious.

Figure 3: Residential Units Granted Permission to Q3 each year (000s)

Source: MHCLG (Glenigan) / Lichfields analysis

However, given these numbers relate to detailed permissions, and it takes two years on average even to get to an outline, this fall is not surprising; it is the echo of the policy trough created in 2022 by the draft NPPF and its December 2023 denouement, and matches the trend anticipated by our assessment of that policy

More promisingly, MHCLG data shows the pipeline is looking up, with the number of homes within planning applications submitted having increased by a third between 2024 and 2025 – see Figure 4, even as the absolute number of applications is down 3%.[24]

Figure 4: Planning applications received – residential units in outline and detailed applications to Q4 2025 (000s)

Source: MHCLG / Lichfields analysis

This is the December 2024 NPPF starting to do its work. Bigger sites, brought forward by promoters responding to higher housing targets and with more opportunity in local authorities previously off-limits due to Green Belt.

How many of these applications expect to be approved is a different question, and given the majority were submitted in 2025 won’t be determined until late 2026 or 2027, this will be significantly influenced by how (and when) the new NPPF lands.

But this surge of applications should convert into more consented homes and boost the supply of homes in 2029/30. That’s the nature of the pipeline, and one the Government now recognises in its focus on tackling the grit.

Conclusions and turning to the demand side

The Government undertook or at least began most of the five suggested ‘supply-side’ planning measures we identified in July 2024 as a pre-requisite for its 1.5m homes ambition, and it executed its reforms much faster than previous Governments did for their equivalents.[25] Housing targets are up and ‘mandatory’, the presumption is engaged across most of the country, the Green Belt is reopened, there is an Act on the statute book, and the plan-making system has been replaced. Yet, housing output fell every year and the 1.5m homes is conclusively beyond reach. A reasonable estimate in the current climate is that the Government might achieve the same “one million homes in a parliament” commitment made by the Sunak Government.[26]

Does that mean supply-side reforms needed to go further? Perhaps – there is always more that could be done, notably the transition arrangements in the December 2024 NPPF that baked in low local plan housing targets, suppressing potential supply by 70,000 homes.

But those polices have an inescapable payback period measured over two electoral cycles.[27]

In July 2024 we concluded our analysis of the five policy measures by saying: “none of this is a silver bullet that diminishes the need for complementary measures to overcome other barriers to housing delivery”.

Early delivery was about releasing the potential of schemes already with permission. Much of this relates to the demand side and the viability crisis arising from wider economic challenges.

Here, to use the parlance of the school report, the Government has been “working towards expectations”.

It created a £39bn funding settlement for affordable housing, but the FT and IFS showed much of this was backloaded, with the increase beyond current rates of investment not rising until after 2029.[28]

The Government recognised the challenges of affordability and has launched various measures to boost home ownership.[29] But it didn’t grasp the nettle of how to find a replacement for Help to Buy. At UKREiiF 2026, the Housing Secretary said he needed “to have conversations” with the Treasury about a stimulus to demand.[30] A report in the Times on 11^th July suggests the Chancellor has been resisting it.[31]

The ongoing approach to viability reform from the Government is seemingly based on the idea (popular in many circles) that there is more land value uplift to be extracted from the planning and development process, by standardising developer profit and suppressing benchmark land values.[32] And yet it is increasingly apparent (from here and overseas) that there are fundamental difficulties in pushing this too far, and Jules Pipe - London Deputy Mayor – has suggested the current cross subsidy model for affordable housing is “surely dead”.[33]

In our July 2024 blog, we identified the risk that the Government’s new dawn for housing delivery would find itself “perceived as a false one”.

In planning terms, it wasn’t, although there is still more to do (e.g. on grit). The reforms are real and set to have a positive effect ahead of 2029, at least for the flow of permissions and – probably – plan coverage and - perhaps - tangible progress with some new towns.

The difficulty for Starmer’s record is that the system his Government reformed runs to a clock that extends beyond what turned out to be his period of office. Burnham may reap some of the benefit if he quickly embraces the demand side ask that is reported to be before him.[34] It will also help if he acts promptly to issue the final NPPF. But the real dividend of a significant increase in the supply of new homes will only sit on his ledger if he wins the next election.

Footnotes

[1] As demonstrated by the 2025 Lichfields research How Long is a Piece of String for LPDF and Richborough.
[2] Per this Wikipedia list
[3] Consultation Draft NPPF Paragraph 7
[4] Nothing has been published since December 2024, and it is now promising to combine data collections for 2024 and 2025 HDTs and publish both results together – see here
[5] The Next London Plan is here. Analysis of this document can be found elsewhere in the Lichfields firmament, but I find the GLA’s decision to continue with ten year housing targets (rather than 20 years more befitting a strategic plan) utterly perplexing.
[6] A rather curious set of findings from its report published on 5th February 2025
[7] Box 3.B of the Budget 2025 reported on research by Marrons which found that 80% of major residential appeals located on grey belt land had been approved, homes that wouldn’t have been built under previous policy.
[8] See December 2024 NPPF para 146
[9] See its 8th October announcement: Thousands of new homes get the go ahead in North Sussex
[10] See this BBC news item. Subsequently addressed – at least in part - via the announcement on 2nd July 2026
[11] As reported in Housing Supply : indicators of new supply, England: January to March 2026
[12] See Notification from Natural England to Secretary of State
[13] A summary is provided in this DEFRA blog
[14] See this HBF report The viability Crunch: Analysing the impact of policy, tax, and regulatory pressures on home building May 2026
[15] As captured in the Minister of State’s speech to UKREiiF. Work by Lichfields on this for the LPDF will be launched on 23rd July 2026
[16] Lichfields contributed to the New Towns Taskforce report to Government (September 2025)
[17] A review of different perspectives is provided by Planning Resource here (£)
[18] MHCLG, Housing supply: indicators of new supply, England: January to March 2026
[19] Not all of these 305,000 are in England, obviously.
[20] OBR, Economic and Fiscal Outlook, March 2026.
[21] Full Fact Government Tracker on 1.5 million homes
[22] In its 19th June 2026 publication MHCLG states: “The latest figures on the number of residential units permitted provided by Glenigan have been removed from this publication while MHCLG and Glenigan undertake further quality assurance.”
[23] See Savills - English Housing supply Q1 2026
[24] MHCLG Planning applications in England: January to March 2026 - statistical release Published 19 June 2026
[25] Compare for example the timelines of the Blair Government with PPG3
[26] DLUHC, Measuring Progress towards one million homes, 24th May 2024
[27] Supply-side policies that aim to remove an existing pathway to permission and delivery act far more quickly: A yet to be determined application prepared pursuant to a positive planning policy can be refused the day after a new policy is introduced.
[28] Reported in the Financial Times England’s social housing funds ‘less generous’ than £39bn settlement suggests 12 June 2025 (£)
[29] For example, a mortgage guarantee scheme, changes to financial regulations to allow more loans at over 4.5 times a buyer’s income and the recent consultation on First Time Buyer ISA
[30] Reported by BD, 21 May 2026.
[31] The report in the Times (£) states: “Andy Burnham will be presented with plans to revive the Help to Buy scheme when he enters office on July 20. A review commissioned in the final throes of Starmer’s government by Matthew Pennycook, the housing minister, will explore a new iteration of the scheme following a long tussle with Rachel Reeves. Pennycook’s review, conducted in recent weeks, is understood to have followed an internal report, commissioned by members of the housing department and Treasury, which concluded that rolling out a new version of Help to Buy would not force up house prices. Critics argued that the Help to Buy scheme artificially inflated new-build prices. Whitehall sources said the chancellor blocked attempts to consider a new version since Labour came to power in 2024, citing concerns about inflation.”
[32] Per the December 2025 consultation
[33] In June, Deputy Mayor Jules Pipe told the London Planning Conference that the cross-subsidy model for affordable housing - in which private developers provide or fund low-cost homes using profits from private sales - “is now surely dead". See this Planning Resource report (£)
[34] Per the Times report

End of term report: what three years of LSIPs have taught us, and why the next phase matters more than ever for the future of skills

Luke Bonnici 17 Jul 2026

The latest wave of Local Skills Improvement Plans (LSIPs) for 2026-29 has now been published by the Secretary of State for Education, marking a significant moment for England’s skills landscape. For the uninitiated, LSIPs are employer-led plans designed to strengthen the relationship between businesses and post-16 training providers (i.e., further and higher education), ensuring that the supply of skills genuinely reflects the needs of local economies.

Since 2023, Lichfields has worked closely with the Hampshire Chamber of Commerce – initially the Employer Representative Body (ERB) for the Solent, and now with a wider remit covering Hampshire and the Solent – to develop the original Solent LSIP [1], review progress in 2024 [2] and 2025 [3], and (this year) refresh the LSIP to reflect the newly-formed Hampshire and the Solent Combined County Authority area [4].

Three years in, LSIPs have reshaped how regions think about skills and employer participation, and the role these play in driving economic growth. In a period defined by shifting priorities, changing local government boundaries and growing socio-economic pressures, LSIPs have become the one stable, employer-centred thread running through local skills delivery. Led by independent ERBs – often local Chambers of Commerce – they are positioned arm’s length of political cycles and provide continuity in a system that desperately needs it.

In this blog we reflect on what has been achieved so far, what we have learned through our work, and why we think the next phase of LSIPs matters more than ever.

The biggest gap isn’t a skill

Across Hampshire and the Solent, one insight that surfaced repeatedly was not a shortage of specific skills, but employers’ and people’s ability to navigate the skills system itself. Time and again, employers show willingness to engage; yet many simply do not know where to start, who to speak to, or what support is available to them. Business time pressures, squeezed margins and competing priorities make it difficult to invest in skills planning, even when the appetite is there.

Progress is being made locally, but the lesson is clear; navigation is the foundational challenge. Without addressing this, even the best provision will struggle to reach the businesses and people it is designed to support.

A second, persistent challenge is lack of awareness. Historically, young people gained early exposure to work through entry-level roles, or by following familiar pathways. However, as the economy has diversified, these traditional routes into employment have become few and far between.

Low levels of awareness and deep-rooted perceptions continue to hold many young people back. The disconnect between the classroom and the world of work means that parents and teachers often lack visibility of modern career opportunities, making awareness not a communications issue but a structural one. Without it, aspiration stalls and so does progression.

One of the most striking shifts seen over the past three years (at least within Hampshire and the Solent) has been the move from employer engagement to genuine employer participation. This is more than semantics; it has seen employers move from being “buyers” of skills to active “investors” in the ecosystem, signalling a significant cultural shift.

By becoming active participants, employers are now co-designing curricula, embedding training into day-to-day operations and committing to long-term collaboration. Where this shift has taken hold, it has been transformational. It builds trust, strengthens value exchange and creates provision that genuinely reflects industry needs.

Why this matters?

The most important lesson from our work with the Hampshire Chamber of Commerce is that the skills ecosystem must serve people, not just sectors of the economy. This is especially urgent given rising economic inactivity and the sharp increase in young people not in education, employment or training (NEETs). Recent figures show NEET levels have now surpassed one million, the highest since the financial crisis in the 2000s.

Running to 217 pages, the Milburn Review diagnostic report [5] sets out the scale of the challenge, and highlights how limitations across health, education and welfare have interacted with labour market changes to drive up NEET levels. Access to housing is also important, as we discuss elsewhere [6]. The report concludes that Britain faces “a deeply entrenched problem that is getting worse and a system that has been trying but failing to deal with it”.

The Review does not yet set out what government should do; that will come later this year. But LSIPs already play a critical role in raising awareness, identifying sector-specific and economy-wide skills gaps, and generally shaping the direction of travel. Youth engagement is essential, but so is the wider re-engagement advocated by the Get Britain Working White Paper [7].

Within Hampshire and the Solent region, the 2026-29 LSIP sets out a roadmap built around the following four priorities:

Priority 1: Improve awareness, navigation and access to the skills ecosystem;
Priority 2: Strengthen employer participation;
Priority 3: Build a responsive and inclusive ecosystem; and
Priority 4: Support pathways, progression and workforce transition.

These priorities reflect the lessons learned so far, and the need for a system that works for all residents, not just those closest to opportunity.

The big lesson

After three years of delivery, the conclusion is simple. Meaningful skills transformation isn’t about fixing individual courses or qualifications; it’s about building a strong ecosystem that is flexible enough to work for everyone.

Devolution (i.e., as outlined by the English Devolution White Paper [8], and the wider ambitions that have been trailed by the new Prime Minister, Andy Burnham) has the potential to be genuinely game changing. However, this can only be achieved if skills remain central and people are at the heart of the wider ecosystem. LSIPs are now the bridge between employers and devolved authorities (existing and forthcoming), and provide the stability needed to shape long-term delivery.

As LSIPs enter their next chapter, all areas will need clear evidence and coherent delivery structures to turn ambition into meaningful change. This next phase will demand even deeper collaboration, sharper insights and a skills ecosystem capable of responding to both economic priorities and human realities. LSIPs are now central to this mission.

Footnotes

[1] Hampshire Chamber of Commerce (2023), Solent Local Skills Improvement Plan (Solent LSIP) [Link]

[2] Hampshire Chamber of Commerce (2024), Solent LSIP, 2024 Progress Report [Link]

[3] Hampshire Chamber of Commerce (2025), Solent LSIP, 2025 Progress Report [Link]

[4] Hampshire Chamber of Commerce (2026), Hampshire and the Solent LSIP 2026-2029, A unified skills plan for an integrated region [Link]

[5] Department for Work & Pensions (2026), Young people and work: Diagnostic report [Link]

[6] See Lichfields blog: Milburn, NEETs and housing: the connection that counts [Link]

[7] HM Government (2024), Get Britain Working White Paper [Link]

[8] Ministry of Housing, Communities & Local Government (2024), English Devolution White Paper: Power and partnership, foundations for growth [Link]

Further fee uplifts by year end, with more to come

Jennie Baker & Sean Farrissey 16 Jul 2026

The Government has responded to its April 2026 consultation on ‘Fees for planning applications’[1].

That consultation sought views on a new national default fee schedule to act as a baseline from which a new local fee setting model might operate and on the key principles behind local fee setting. It also presented proposals to introduce new fees and restructure existing fee categories, implement a surcharge on planning fees for statutory consultees, and review the future role of discretionary services such as Planning Performance Agreements and pre-application advice.

We discussed these proposals in detail in Counting the cost: proposed default national application fees.

Legislation to increase fees to the national default level has been laid before Parliament in draft. The Government intends that it will be made during the summer with the intention of the fee uplifts being in force “by the end of the year”. There is no indication that the annual inflation-based uplift would not apply, therefore fees seem likely to increase at least twice in the next year.

There will be further consultations on planning related fees to follow, including on more complex potential approaches to calculating fees. In essence, where there were concerns that there was more to consider within a fee model, and that introducing it might prevent a fee uplift this year, the current model is retained.

The revised fees will be within a ‘National Default Fee Schedule’, which will be the only published fee schedule until such time as localised fees are introduced, but reflects the Government’s intention that they will come forward.

There will be a consultation later in the year on the design and implementation of any planning fee surcharge payable to statutory consultees. The working proposal is that the surcharge should be in the region of 10% of the national default fee. The consultation will seek views on “how it could be targeted, administered and support statutory consultee performance”.

The December 2025 national policy consultation, in relation to fees, proposed extending permission in principle to applications for development of 10-49 dwellings. The fees consultation response says “the government will set out its response on this issue as part of its wider response to the PIP proposals in the NPPF consultation response”. This gives some indication that a response to the national policy consultation, including on the National Planning Policy Framework (NPPF) is not imminent.

Changes to fees to be introduced Summer 2026

During summer 2026, the government will prepare legislation to increase national planning fees “up to an estimated 90% cost recovery”. The draft National Default Fee Schedule consulted on in April was designed to reflect 90% of the estimated costs of determining applications. Accordingly, most of the draft forthcoming fees to reflect those set out in Annex A of that consultation[2] and the examples in the Lichfields table (below) showing the proposed fees for the main types of planning application, compared with the equivalent fee currently applicable (also set out in this Lichfields blog).

Notable exceptions to achieving 90% cost recovery are the fees for s73 planning applications and the fees for discharge of conditions. This summer, fees are to be increased for major applications only, presumably to the £3,150 consulted on (currently £2,076). This is in response to consultation responses observed “that the proposed fee for non-major s73 applications (£825) could exceed the equivalent full application fee in some cases”. Accordingly, the non-major s73 application fee will remain at £608 but will also be part of the further review of planning application fees – as is the case for several fee types.

The fees for relating to prior approvals for creation of new dwellings via upward extension or demolition and rebuild permitted development rights have also changed slightly.

Key imminent changes to planning related fees are as follows:

simplifying the fee structure for outline, full and reserved matters applications for residential and non-residential development. This includes removing baseline fees to support clearer and more straightforward fee calculation and adjusting residential thresholds from 50 to 49 dwellings (explained in our Counting the cost: proposed default national application fees blog).
all prior approvals that currently have no fee will have the same flat fee of £310 as for other prior approval applications
increased and rationalised fees for agricultural development
changes to Permission in Principle fees, which will be further determined by whether or not the national policy consultation outcomes says that PiP on application will be extended to development for up to 49 dwellings.

Fees to be reviewed within a wider programme

The consultation response refers to a wider programme of structural fee reform. This will cover the introduction of localised fees and will also consider new approaches to fees including:

monitoring the fee structure for outline, full and reserved matters applications and considering whether fees adequately reflect the complexity of outline and reserved matters applications, particularly for phased developments;
potential ‘additional or more granular’ s73 fees (and s73B fees, see below);
looking at how fees reflect complexity, EIA development and large or multi‑phase schemes;
considering the alternative views on the removal of fee caps and whether they provide cost recovery or certainty;
a national fee for applications under s106A to modify a s106 agreement (it is noted that fees are sometimes charged locally);
fees for the approval of details required by a condition/condition discharge to be charged per condition, and whether banded fees or other mechanisms could better support cost recovery and improve performance;
separate fee for the approval of biodiversity gain plans;
fees for agricultural development;
for prior approval fees;
the restructuring of fees generally (in response to comments received, see below).

The consultation had asked if there were other existing fee categories not mentioned that would benefit from restructuring. Respondents suggested:

support for charging for specialist and technical processes, including EIA screening and scoping, and the review of mineral permissions;
retrospective applications should attract a higher fee;
reintroducing a ‘free-go’ for resubmissions, or alternatively a reduced fee (e.g. 50% of the original fee);
align fees for solar and onshore wind schemes more closely with Planning Practice Guidance and base them on the footprint of operational equipment rather than the whole site, which is disproportionately high and not reflective of development complexity;
higher fees for applications for advertisement consent for digital displays to reflect their greater impacts (e.g. light and visual pollution) (this sounds like those suggesting it intend it to be a deterrent rather than based on cost of assessment);
greater clarity on definitions of plant and machinery;
new category for minor works on non-residential sites (e.g. schools), as current site area–based fees can be disproportionate for small-scale development.

Section 73B application fees

The Government has committed to bringing forward Section 73B (S73B) applications, which are “Applications for permission not substantially different from existing permission”. These were designed to provide a procedural route that allows amendments to schemes that are more than non-material, including changing the description of development (not possible via s73).

When s73B is introduced, the same fee structure will apply to it as applies for section 73. The Government considers this appropriate based on the available evidence, but “will keep section 73B fees under review as evidence emerges, including to ensure that fees remain proportionate and provide an appropriate level of cost recovery”.

Trees and listed buildings

The Government is sticking with its intention not to introduce national fees for applications for listed building consent or works to protected trees, despite consultation responses noting the resourcing implications for local planning authorities (LPAs). The Government says “this reflects the strong public interest in conserving the historic environment and natural assets, and the need to avoid creating financial barriers that could deter appropriate management or increase the risk of unauthorised works. We will, however, keep this position under review”.

Localised fees

The consultation sought to gauge the level of support for local fee setting and how such a model would operate. There was broad support amongst LPAs for being able to set their own fees as a mechanism for addressing acute resourcing challenges. A common theme across all stakeholders was the need for clear national guidance on establishing cost bases, evidencing and justifying fees, and ensuring consistency across regions given the high divergence of costs around the country.

The Government has recognised the need for clear national guidance. They are working with the Planning Advisory Service to develop guidance and toolkits to help LPAs understand and apply their own planning fees. The Government intends to introduce the regulations setting out the framework for local fee setting and associated guidance before the end of the year.

LPAs will be able to set planning fees up to a maximum of 30% above the national default fee, when justified by evidence. If LPAs cannot cover their costs within this threshold, they will be able to consult the Secretary of State and provide ‘robust’ evidence to justify any further fee increases. A Written Ministerial Statement (WMS) by the Housing and Planning Minister says that this is expected to apply to only a small number of LPAs that face exceptional cost pressures. The WMS also says that operation of the 30% cap, including the use of the approval mechanism and intervention powers will be among the matters addressed when formulating localised fee policy.

The future of Planning Performance Agreements

The Government has reiterated their support for discretionary planning services including Planning Performance Agreements (PPAs). Indeed, the consultation response notes that there was broad support for the continued role of discretionary planning services that support the delivery of more complex developments.

The consultation response noted the role of the Greater London Authority in delivering large and complex schemes, therefore relying on the use of PPAs more than other strategic authorities. Other strategic authorities will be able to use similar powers in the future due to ongoing devolution reforms.

Fees for PPAs and other discretionary planning services such as pre-application advice should not exceed the cost of providing them. In similar fashion to other fee increases, there is a broad expectation from Government and the development industry that higher fees will translate to a better service. The Government expects LPAs to be transparent on the basis for their charges. Further guidance is going to be published covering transparency of costs and good practice in delivery.

Effectively there is no change to the fee arrangements and opportunities to provide PPAs which, in early consultations on localised fees, looked to be in question.

Next steps and conclusion

As noted above, the Government is to bring forward the necessary legislation to increase planning related fees and establish a National Default Fee Schedule, during the summer with the increases to take effect before the end of the year. Observations in our last blog regarding localised fees continue to apply:

Setting localised fees is clearly a significant piece of work. It will be costly to carry out. Therefore, a significant uplift against the national default fee would likely need to be anticipated before such work is undertaken. It is likely that local authorities would group together to carry out such analysis. Furthermore, are salaries or external advice where frequently required due to a specific local issue the only cost matters likely to have a significant local variation, such that looking into setting localised fees is justified? And would an authority go through this process in order to charge lower fees?

In addition, the Government intends to introduce the statutory framework and associated guidance for local fees by the end of the year. Given that significant work will be required in order to set up localised fees, it seems very unlikely, but not impossible, that any localised fees up to a maximum of 30% above the national default fee would be introduced this year also.

The continued support for PPAs and the acknowledgement of their role is good news.

The conclusion to blogs on fees will always be the same: increased fees must be accompanied by a high quality development management service. In this regard in particular, ongoing reviews of fees are to be welcomed.

Table of example fees proposed in the consultation, which we believe will apply by the end of the year:

Application / fee type	Current fee	Proposed fee	£ Uplift	% Uplift
Residential
Outline planning application for erection of dwellinghouses on 2.5 ha site	£16,291	£22,400	£6,109	37%
Full planning application for 50 dwellinghouses	£32,578	£40,318	£7,740	24%
Non-residential
Outline planning application for erection of non-residential building(s) on 2.5ha site	£16,291	£22,400	£6,109	37%
Full planning application for 3,750 sqm (gross) non-residential building(s)	£32,578	£37,950	£5,372	16%
Scheme amendments
Section 73 application relating to major development	£2,076	£3,150	£1,074	52%
Non-material amendments other than for householder development	£309	£360	£51	17%
Other
Change of use other than to residential	£610	£732	£122	20%
Discharge of condition other than for householder development	£309	£435	£126	41%
Advertisements displayed externally on business premises / other land within curtilage / for wayfinding purposes	£174	£192	£18	10%
Fee caps
Fee cap on outline planning application for erection of dwellinghouses/non-residential building(s)	£213,769	£290,625	£76,856	36%
Fee cap for full planning application for residential/other buildings including non-residential/change of use to residential	£427,537	£513,512	£85,975	20%

Footnotes

[1] Fees for planning applications: government response - GOV.UK

[2] Annex A: Proposed national default fee schedule

Decarbonising the NHS Estate: Planning, Funding and Delivery through the Public Sector Decarbonisation Scheme

Nuala Wheatley, Emma Hepplewhite & Caitlin Attrill 01 Jul 2026

The Government’s commitment to reach net-zero greenhouse gas emissions by 2050 has become a defining objective across the built environment sector since it was enshrined in legislation in 2019 under the Climate Change Act 2008 (2050 Target Amendment) Order 2019. Net-zero is achieved where total greenhouse gas emissions are balanced by emissions removed from the atmosphere. Within this context, planning and decarbonisation are intrinsically linked; the planning system provides a mechanism to enable upgrades to existing estates, whilst also securing net-zero and low emission new development.

In the UK, and linked to the Climate Change Act, the NHS is working towards becoming the world’s first net-zero health service (for emissions it directly controls) by 2040. This target requires a substantial reduction in energy-related emissions across the NHS estate, reflecting the NHS’ position as one of the UK’s largest public landowners and largest single public energy user. These objectives apply equally to capital investment in existing estates and to the construction of new healthcare facilities.

Retrofitting the NHS estate

With energy use in existing buildings representing one of the most significant contributors to NHS emissions, and heating remaining one of the largest sources of emissions across the NHS estate[1], decarbonisation is both an environmental imperative and an opportunity to enhance the long-term resilience and efficiency of healthcare infrastructure. The Health and Care Act 2022 requires all NHS Trusts and Integrated Care Boards to implement approved ‘Green Plans’ to set out how each Trust will reduce emissions and mitigate the impacts of climate change across their estate and operations.

Lichfields Image: Wharfedale Hospital, Otley, Leeds Teaching Hospitals NHS Trust

As set out in previous Lichfields blogs[2], this often involves transitioning away from fossil-fuel heating systems through interventions such as air-source and ground-source heat pumps, alongside on (or near) site solar generation. For major refurbishment projects and new development, the approach to net-zero approach is guided by the NHS Net Zero Building Standard, which seeks to ensure consistency in the delivery of low-carbon healthcare environments while allowing flexibility to respond to site-specific constraints. This should be a consideration from project inception and can be achieved through:

Increasing on site renewable generation;
Phasing direct fossil fuel usage out of all primary heating and cooling systems;
Optimising self-supply from renewables with energy storage and demand response technologies;
Installing EV charging points;
Considering embodied and whole life carbon.

Early consideration of these measures is critical to successful project delivery.

The role of planning in decarbonisation

Engagement with the planning system is essential to decarbonising the sector and it is a key stage of ensuring the NHS’ and health care providers ambitious net zero targets are met. Planning permission is often required for the installation of heat pumps and solar panels across existing estates making proactive engagement with Local Planning Authorities (LPAs) a fundamental component of sustainable retrofit programmes.

Funding constraints remain a significant challenge in relation to retrofitting. The NHS maintenance backlog is estimated at c. £14 billion, with capital budgets frequently absorbed by urgent maintenance rather than longer-term sustainable upgrades. This restricts the financial flexibility available to invest in deep retrofit measures necessary to meet net-zero targets. Against this backdrop, the Government’s Public Sector Decarbonisation Scheme (PSDS), introduced in September 2022, has become a key funding mechanism supporting emissions reduction across public sector buildings, including the NHS estate.

Public Sector Decarbonisation Scheme – national funding patters

Phase 4 of the PSDS is currently in operation, supporting projects across the 2025/26 and 2027/28 financial years. A total of £816,619,753 has been allocated across the country, with around half of this funding awarded to NHS bodies.

As illustrated in the infographic below, funding distribution varies across regions. London received the largest allocation at approximately £167 million, followed by the North West at £132 million. Yorkshire and the Humber (£112 million) and the East Midlands (£81 million) also secured substantial investment. Importantly, smaller regions such as the North East received awards in the order of £79 million, demonstrating that significant funding opportunities have been available beyond the largest metropolitan areas.

The regional distribution of PSDS funding reveals clear variation in both scale and uptake. While London and the North West secured the largest allocations - likely reflecting the size and density of their public sector estates - smaller regions have also attracted funding at levels capable of delivering transformative outcomes. For example, the North East, with the smallest population of the regions referenced (2.65 million according to ONS mid‑2024 estimates, published July–November 2025), nonetheless received a substantial share of funding. This equates to £29.80 per person and 9.7% of the total funding awarded.

This relatively high level of funding may indicate that certain Trusts possess stronger awareness of available funding streams, greater expertise in navigating application processes, or a more established commitment to delivering net-zero ambitions across their estates.

Within the North East, approximately £20 million was awarded to Northumbria Healthcare NHS Foundation Trust. The Trust has a strong track record in delivering net-zero initiatives, having previously secured £22 million in Phase 1 of the PSDS. This earlier funding supported a major carbon reduction scheme at North Tyneside Hospital, delivered in collaboration with Lichfields (see case study below). The Trust’s approach is guided by its Green Plan Strategy and supported by a dedicated team of sustainability officers focused on reducing emissions and identifying cost-effective energy solutions.

By developing established partnerships with key stakeholders such as Lichfields, the Trust has been able to streamline project delivery and position itself effectively to secure subsequent funding. This highlights the critical role of cross-disciplinary collaboration - including planning - in successfully accessing and implementing decarbonisation funding. We discuss this further below.

Delivering decarbonisation in practice: Northumbria Healthcare NHS Foundation Trust

Funding through Phase 4 of the PSDS is supporting a wide range of technologies, including air‑source heat pumps at 135 sites and solar PV installations at 38 sites nationally. Within the North East, a significant beneficiary of funding through the latest award, over £20 million – around 25% of the region’s allocation – was awarded to Northumbria Healthcare NHS Foundation Trust to support the decarbonisation of three hospital sites at Wansbeck, Cramlington and Hexham.

Across all three sites, existing heating systems are being replaced with a combination of ground‑source, air‑source and water‑source heat pumps. Lichfields is advising the appointed contractor, Dalkia, on the planning implications of these upgrades, drawing on a detailed understanding of each site’s planning history and local context. Notably, Lichfields previously secured planning permission for the Northumbria Specialist Emergency Care Hospital at Cramlington itself in 2013.

Lichfields Image: Northumbria Specialist Emergency Care Hospital

The project demonstrates how a combination of planning tools can be used to streamline delivery, including minor applications, prior approvals, permitted development rights and lawful development certificates. This approach enables timely implementation while ensuring that potential amenity impacts, such as noise or visual effects associated with new technologies, are appropriately assessed and mitigated. Critical to its success is early and proactive engagement with local planning authorities, in order to provide meaningful information regarding the detail and nature of the proposals at pre-application stage and agree the scope and type of application required. Amid the current pressure upon local government resource, it is fair to say that both local planning authorities and health trusts can unlock efficiencies through pursuing any more streamlined planning process is available, such as prior approvals or lawful development certificates.

This experience builds on Lichfields’ earlier work at North Tyneside Hospital, where a £22 million carbon reduction scheme was delivered in 2021. Working alongside Breathe Energy Ltd, Lichfields supported the introduction of large‑scale heat pumps, boiler upgrades and a solar PV installation with an output of approximately 975 kW. The project is estimated to deliver a 75% reduction in CO₂ emissions, saving around 3,470 tonnes of CO₂ per year and approximately £500,000 annually in energy costs, demonstrating the tangible benefits of well‑planned decarbonisation projects.

At Wansbeck General Hospital, Ashington, Lichfields are currently seeking consent for an innovative decarbonisation scheme utilising ground source heat pumps to tap into warm water from historic coal workings under the Hospital, associated with the nearby former Woodhorn Colliery. Capitalising on resources left over from Northumberland’s coal-based energy past, there is a neat symmetry and inherent sustainability in using the same infrastructure to heat and power a modern healthcare facility. With planning policy at national and local levels fundamentally supportive of both improved healthcare infrastructure, and decarbonisation, we continue to lead local community engagement and work closely with Northumberland County Council as the local planning authority in order to provide comfort that all other technical considerations arising from the scheme, for example in relation to noise, have been robustly addressed through the planning process.

Looking ahead

Alongside the Public Sector Decarbonisation Scheme PSDS, the Low Carbon Skills Fund previously played an important role in supporting feasibility studies and heat carbonisation plans, although it was not renewed for 2025-2026. The absence of this preparatory funding further reinforces the need to embed decarbonisation considerations at project inception and to take a strategic, plan‑led approach.

Decarbonising the NHS estate is a complex but essential task, requiring alignment between national policy, funding mechanisms, technical solutions and the planning system. While the PSDS has provided a critical funding catalyst, successful delivery increasingly depends on early planning engagement, a clear understanding of consent pathways and the ability to integrate low‑carbon technologies into operational healthcare environments.

Lichfields has extensive experience supporting NHS Trusts and their delivery partners to navigate these challenges, combining technical planning expertise with a deep understanding of healthcare estates. As public sector decarbonisation continues to evolve, proactive planning will remain central to turning ambition into deliverable, low‑carbon outcomes.

Footnotes

[1] Five years of a greener NHS: progress and forward look report, published 30 September 2025: NHS England » Five years of a greener NHS: progress and forward look

[2] Planning for Net Zero Healthcare, Robert Dibden

Planning matters

Best-laid plans? The Starmer stocktake

Footnotes

End of term report: what three years of LSIPs have taught us, and why the next phase matters more than ever for the future of skills

Further fee uplifts by year end, with more to come

Changes to fees to be introduced Summer 2026