The new NPPF: Energy Efficiency and tackling the Climate Crisis

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The new NPPF: Energy Efficiency and tackling the Climate Crisis

The new NPPF: Energy Efficiency and tackling the Climate Crisis

Neil Purvis 11 Jan 2024
The amendments to the NPPF introduce some important changes in relation to the environment. A new paragraph 164 in the amended NPPF states that when determining planning applications, local planning authorities should give significant weight to the need to support energy efficiency and low carbon heating improvements to existing buildings, both domestic and non-domestic[1]:
“164. In determining planning applications, local planning authorities should give significant weight to the need to support energy efficiency and low carbon heating improvements to existing buildings, both domestic and non-domestic (including through installation of heat pumps and solar panels where these do not already benefit from permitted development rights). Where the proposals would affect conservation areas, listed buildings or other relevant designated heritage assets, local planning authorities should also apply the policies set out in chapter 16 of this Framework.”
Existing buildings are one of the largest sources of greenhouse gas (GHG) emissions in the UK, indeed the heating sector in the UK accounts for roughly a third of the UK’s annual carbon footprint[2]. We all therefore need to be considering ways of reducing the carbon footprint of our buildings and retrofitting can play a key role in this. The amendment to the NPPF in relation to the environment is welcome but can it make a difference in achieving the UK’s Net Zero targets and addressing climate change?


Energy Efficiency and PD Rights

When it comes to retrofitting existing buildings, including through the installation of heat pumps and solar panels, there is a lot which can already be installed under Permitted Development Rights.
The permitted development right of Class G allows you to install, alter or replace an air source heat pump on a residential property without planning permission (with certain limitations applying). This can be a house, bungalow or a block of flats and you are permitted to install it either on the property itself or within the curtilage of the property.
Changes to permitted development rights rules announced by the Department for Levelling Up, Housing and Communities in November of last year will also mean more homeowners and businesses will be able to install solar panels on their roofs without going through the planning system.
The Government has confirmed that homes with flat roofs can now install solar photovoltaic (PV) panels without planning permission, which brings rules in line with those for businesses. As part of the confirmation, the Government also removed the 1MW capacity restriction, which required businesses to apply for planning permission if its solar panels were to generate over 1MW of electricity[3].
The intention is that the changes to permitted development rights rules will slash the wait-time for rooftop solar installations caused by the planning system, which can include waiting over eight weeks and accruing extra costs and encourage more people to install solar panels on their homes.


Energy Efficiency and Climate Change targets – what’s the story?

Retrofitting of existing buildings is a fundamentally important decarbonisation solution and can play an important role in the UK’s drive to net zero. The use of heat pumps for example can offer carbon emission savings of around 30% when compared to conventional natural gas boilers. The Government has set some ambitious targets around energy efficiency and low carbon heating improvements to existing buildings including the commitment for 600,000 heat pumps to be installed per year by 2028[4]. The National Infrastructure Commission (NIC) has also stated that around eight million buildings will need to switch from gas boilers to cleaner alternatives by 2035 to meet the UK’s 2050 net zero target[5].
However, the big problem in the UK to date when it comes to heat pumps is the level of uptake. While most of the world's heat pump uptake has risen, the UK is lagging behind drastically, with only 72,000 heat pumps being sold in the UK in 2022[6]. In terms of heat pumps per capita, the European Heat Pump Association notes that the UK ranks 20th out of 21 European nations. The European average is 4,016 heat pumps per 100,000 people, compared to 564 heat pumps per 100,000 people in the UK[7]. This means the UK would need approximately seven times more units to meet this standard, a total of 2.7 million heat pumps! The huge numbers of heat pumps required to help achieve the UK’s net zero targets therefore seem a long way off.
Reasons for the lack of uptake so far in the UK range from limitations in heat pump performance and skills shortages to high cost (typically it costs £10,000 to buy and install an air source heat pump). This is despite the Government offering subsidies to reduce costs through for instance the Boiler Upgrade Scheme in England and Wales, which provides grants of £7,500 for air-source heat pumps, and £7,500 for ground-source heat pumps.
Despite the low numbers of uptake to date, things may be about to change as the technology improves and a wider range of heat pumps become available on the market – whereas older heat pumps might have struggled to heat some homes adequately heat pumps are now able to supply much higher temperatures without incurring efficiency losses. This could therefore entice more homeowners away from fossil fuel-based boilers.
The increase in solar panel installations offers a more promising picture. Solar is the most common domestic renewable energy source in the UK and latest data suggests there are over a million UK homes with solar panel installations. Solar panel installations almost doubled in 2022, compared to 2021 and should continue to increase as technology improves and solar panels get more affordable in the coming years[8].
The Government has set a clear target to achieve a fivefold increase in solar power by 2035, from an existing capacity of 15GW to 70GW[9]. There is a long way to go to achieve this target but a continued and sustained increase in solar panel installations on existing buildings will make an important contribution to increasing capacity.


Planning for Climate Change

Decarbonisation of the UK economy is essential if we are to stand any hope of achieving Net Zero by 2050 and keep temperature rises below 1.5°C to avoid the very worst impacts of climate change. Retrofitting existing buildings and switching to renewable fuel powered systems from fossil fuels can make a difference.
Eliminating stumbling blocks on the way to reducing GHG emissions and climatic impacts is essential and strong in-principle policy support for energy efficiency is therefore encouraging.
What is clear however is that if the UK is to reach net-zero carbon emissions by 2050, a rapid acceleration in the use of renewable fuelled power systems such as heat pumps is required. The scale of the challenge is enormous and we must embrace it.


[1] The National Planning Policy Framework (NPPF), 20 December 2023.

[2] House of Commons. Business, Energy and Industrial Strategy Committee. Decarbonising heat in homes. January 2022.

[3] The Town and Country Planning (General Permitted Development) (England) (Amendment) (No.2) Order 2023.

[4] HM Government. Heat Pump Investment Roadmap. Leading the way to net zero. April 2023.

[5] National Infrastructure Commission. The Second National Infrastructure Assessment. October 2023

[6] Accessed January 2024

[7] Accessed January 2024

[8] Accessed January 2024

[9] Access January