Planning matters

Since its first publication in 2012, the National Planning Policy Framework (NPPF) has encouraged local authorities to establish the need, size, type and tenure of housing for different groups, including older people. As set out in Martin Taylor’s blog, the 2025 NPPF consultation (16 December 2025[1]) does not waver from this core principle, which seeks to secure a diverse mix of homes to meet the needs of different groups through the planning system.

Despite this longstanding approach, Lichfields’ Solutions to Age Old Problem Insight identified both in 2019 and the 2024 update that whilst many local plan policies refer in general terms to the needs of older people, few set out a specific requirement for the level of older person’s housing that could be provided or contain allocations for the development of such accommodation. Similarly, only a few local authorities have tended to monitor the delivery of specialist housing for older people. As of 2019, just 14% of development plans in England had policies that identified a requirement for housing for older people and just 8% of English development plans included allocations for housing for older people. The 2024 update showed an improvement in identified specialist housing requirements within development plans to 48% but the number of plans with allocations for specialist housing remained largely static at 9%. 

The ageing population has been a longstanding and significant contributor to household growth. The 2022-based Household Projections shows that the number of over-65 households in England is anticipated to grow by over 3 million between 2022 and 2047, equivalent to 57% of all household growth over this period.

Importantly, older people generally live in smaller households (single or couples) so the housing implications of the population increase will be disproportionately significant. The provision of specialist accommodation for older people can provide social and economic benefits by increasing social interaction, providing safety and security, and helping to meet care needs, whilst also helping to free up general needs housing. It therefore represents an important part of the puzzle to solving the housing crisis.   

This blog considers whether the suite of new Plan-making and Decision-Making Policies within Section 6 of the draft NPPF will require local authorities to properly plan for older person’s housing and, in turn, deliver the step-change in delivery that is required to meet needs. 

There are four key policies within the draft NPPF which consider housing for older people; three of these are plan-making policies which seek to provide greater clarity to local planning authorities over what is expected at the plan-making stage. The fourth is a National Decision-Making Policy (NDMP) which should be used by local planning authorities in the determination of planning applications. 

The draft policies are not substantially different to the current approach within the NPPF, but the restructuring helps provide greater clarity for plan-making and decision-taking. 

 

Draft Plan-making policy HO1 “Assessing the Need for Homes” largely reflects the approach set out in paragraph 63 of the current NPPF (2024), which requires development plans to assess the size, type and tenure of housing or other accommodation to meet the needs of different groups, including older people. 

Whilst the overall number of homes needed is to be addressed through Spatial Development Strategies (SDSs) (part 1 of HO1), part 2 of Policy HO1 states that size, type and tenure requirements should be determined “at the most appropriate level”. This will allow plan-making authorities to adjust their policies to encourage a particular housing mix to respond to local needs. Taking the West of England SDS authorities as an example, it would seem inappropriate for the same approach to be taken to older person’s housing delivery in Bristol, where less than 13% of people are aged over 65, and North Somerset, where almost a quarter of residents (23.9%) are aged 65 or over.

This element of flexibility within Policy HO1 is welcomed but care must be taken to ensure that planning for specialist forms of accommodation does not ‘fall through the cracks’ with the SDS deferring to the local plan and then for local authorities to fail to pick up the mantle.

As recommended in Lichfields’ Insight, clear guidance will need to be published on how housing for older people is calculated when assessing local housing need, with the current 2019 guidance pre-dating the standard method. 

It is important to note that the standard method identifies a minimum housing annual need figure for residential in Use Class C3 and therefore an assessment of need for any older person’s housing falling within Use Class C2, such as care homes, should be in addition to the standard method figure.

It will be important for site promoters and developers to evidence the need for development at both SDS and local plan preparation and examination and make the case for care, retirement and sheltered housing. Lichfields’ Carepacity product can provide up-to-date evidence to assess the need for housing for older people. This will ensure that local authorities prepare development plan policies and identify suitable allocations that are robust in accordance with draft policy HO1. 

 

The draft NPPF’s Plan-making policies HO4 “Land for large scale residential and mixed-use development” and HO5 “Meeting the needs of different groups” both set out specific requirements to identify sites or parts of sites capable of supporting delivery of housing for specific groups, such as older people. 

This is a positive step as it arguably provides the greatest certainty of delivery, ensuring that there are clear expectations for the land use on a given site. The delivery of older person’s housing should be embedded into the allocation policies for large-scale residential sites and this will ensure that development is located in the most sustainable and suitable locations for older person’s housing. Given the low proportion of local plans that currently contain such allocations, this policy could present a step-change in the identification of sites appropriate for older person’s housing.

Policies HO4 and HO5 both set out that policies for a mix of tenures, and therefore consideration of specialist forms of housing, need to be provided on sites for 150 homes or more. Reflecting the housing needs for older people within strategic allocations is important for a number of reasons, including that strategic allocations offer the economies of scale which can often support a mix of different housing types (which might not be viable elsewhere) and thereby contribute to more diverse and sustainable local communities.

However, given the prevalence of viability issues within the residential sector and potential complexities of delivering specialist forms of accommodation alongside general market and affordable housing, the 150-home threshold is unlikely to be appropriate as a national benchmark. Instead, it should be set at a local level to reflect local circumstances and the outcomes of plan-making authorities’ viability assessments to inform local plan preparation. 

 

Policy HO9 is a new NDMP which would provide greater clarity on requirements for different specialist forms of accommodation, including older person’s housing. The draft Policy HO9 part 1a) sets out two key aspects for housing for older people:

• Part i requires a sustainable location with access to frequently used services via sustainable transport; and,
• Part ii requires delivery of housing to M4(2) or M4(3) accessibility standards. 

It should be noted that within the supporting text to the consultation, the government proposes a national minimum target of 40% of new housing over the course of the Plan period to be delivered to M4(2) standards (Policy HO5). It should be confirmed whether this minimum applies to the local authority need or at site level. Once confirmed, this should be explicit within wording of Policy HO9 or deferred to plan-making authorities to determine an appropriate level based on local requirements. 

Policy HO9 part 1b) also provides helpful guidance which will be of relevance to developers of older person’s housing. It suggests that “specialist community-based accommodation”, which could include Integrated Retirement Communities, should be supported by a management plan which will provide a “safe and secure environment for residents”. Whilst there is merit in securing the safety of residents, there is a lack of clarity on how this is would be assessed at application stage and what criteria might need to be met. Specialist community-based accommodation is not defined within the draft NPPF and some clarity on this would be helpful.

As a non-statutory NDMP, Policy HO9 would act as guidance and must be read alongside any policies of the adopted development plan, which would be the basis for decision-making[2] . The consultation asks whether NDMPs could be introduced as statutory in “the most effective manner”, so it will be important to monitor this and other NDMPs going forward.

 

The NPPF consultation takes positive steps to address the lack of clear policy direction at a national and local level for older person’s housing, however this does not feel like the significant change needed to considerably boost the supply of specialist accommodation for old people. 

It is vital that a positive policy landscape is shaped to address the significant needs of the older population and to help free up family housing. In the light of the new policy context, Carepacity will play an even greater role in supporting developers by providing evidence for a robust needs case when assessing housing need in accordance with draft policies HO1 and HO5.

Policies HO4 and HO5 encourage plan-making authorities to allocate sites for specialist forms of accommodation. Lichfields’ evidence shows this is severely lacking in adopted local plans and so that change in approach is welcomed. These policies will help to provide greater certainty of delivery and clearer expectations for the land use, type, mix and tenure on a given site.

The Government should implement Lichfields’ three recommendations to help boost the supply of older person's housing:

1. Planning Practice Guidance (PPG) “Housing for older and disabled people” was last updated in 2019. It is vital that this is revised alongside the publication the NPPF to provide clear guidance on how housing for older people should be considered when assessing housing need, making clear where it forms part of, and where needs are in addition to, the standard method.
    
2. Greater certainty of delivery should be provided by requiring plan-making authorities to allocate sites for specialist accommodation where there is an identified need. This should include updating PPG which currently states “It is up to the plan-making body to decide whether to allocate sites for specialist housing for older people”. 
    
3. The PPG should be updated to clarify how older people’s housing should be considered within CIL Charging Schedules and whether other obligations such as affordable housing should be sought.

Please get in touch if you would like to understand more about the draft NPPF and how the proposed changes could affect your residential developments, or if you would like assistance in preparing representations to the consultation.

The consultation closes to representations on 10 March 2026.

 

The Government has begun a consultation on the usability of the proposed consolidation of the Design and Placemaking Planning Practice Guidance (DPPPG). The draft DPPPG is intended to support the application of policies in the draft National Planning Policy Framework (NPPF) 2025, which is currently being consulted upon – see Lichfields blogs on this here.

 

It is not standard practice for MHCLG to consult on planning guidance updates; however, on this occasion the Government wants to “seek views on whether this consolidated approach improves usability and supports preparation of effective design and placemaking policies, tools and processes”. The consultation will last for 7 weeks from 21 January 2026 to 11:45pm on 10 March 2026.

 

Edward Clarke, Dominic Bowers and Matthew Spry’s blog here analyses how proposed NPPF policy L3 could unlock development potential equivalent to 632,600 homes on land at rail stations outside settlement boundaries. The blog also reminds us that whilst 632,600 homes might seem a lot, not all land will turn out to be available for development and there may be site-specific reasons that make development unfeasible in particular places.

 

In relation to density, 50 dwellings per hectare (dph) on the net developable area is the minimum density set in the proposed NPPF policy L3 for most scenarios[1]. The aim of building at increased densities to make better use of constrained land supply is not new and is promoted by the NPPF. However, this specific requirement raises questions about how sites coming forward would successfully achieve 50 dph, especially outside of urban areas and when site constraints come into play such as local context and character, Green Belt and landscape sensitivity. This blog therefore comments on how the draft DPPPG would support draft NPPF policy L3 in relation to achieving 50 dph.

 

 

Firstly, the draft DPPPG uses and amends a paragraph in the National Design Guide (2021) – see Table 1 Below showing new additions and amendments in bold to paragraph 59 of the National Design Guide in the draft DPPPG. The tone of this draft paragraph is perhaps more optimistic and supportive than the National Design Guide’s paragraph by emphasising that there can be benefits to reap when new development is “very different” to an existing place. The new references to “innovative” and “exceptional” development could show support for proposals that would respond to modern construction methods, changing 21st Century lifestyles and more sustainable ways of living; indeed, page 11 states that “new development can introduce elements that reflect how we live today, to include innovation or change such as increased densities and incorporate new sustainable features or systems”.

 

 

Secondly, reference to the appropriateness of scaling up the character of an existing place is removed presumably so as not restrict or hinder the manifestation of difference. The emergence of courtyard housing typologies is an example what departure from existing character might look like. Courtyard housing typologies create outward facing homes to animate streets and more private individual and communal gardens and courtyards to the rear. These typologies are popular amongst individuals, couples and families, especially because outdoor spaces and play spaces are conveniently nearby. There is a growing catalogue of exemplary medium density developments with innovative housing models that we should be looking at that feature modern townhouse typologies and reimagined mews house typologies – if you edit the filter to search for exemplary schemes at 50 dph on the Housing Design Award’s online catalogue[2] numerous entries appear…

 

Of course, difference is not always inappropriate or wrong and new development can draw influences on local character in numerous complementary ways such as through materiality, landscaping and local forms of architecture. Reference is also made to garden ‘towns’ instead of garden ‘villages’ in the draft DPPPG which appears to be a subtle shift towards supporting larger developments containing distinctive neighbourhoods with varying characters and densities to meet an average of 50 dph – Alkerden Gateway, part of Ebbsfleet Garden City, features as an example of this in the draft DPPPG.

 

Some view building at higher densities as a problem rather than an opportunity. Ultimately, higher densities can create popular, liveable and sustainable neighbourhoods that are well connected, walkable and contribute positively to wellbeing and placemaking. Indeed, Ebenezer Howard’s garden city movement in 1898 aimed to create communities at around 45 dph[3]. Successfully proposing higher densities requires a carefully coordinated and thought-out masterplan that has a strong vision and embeds placemaking principles – which is possible and should be the aim. A great example of this in the draft DPPPG is The Chocolate Quarter in Somerdale, Keynsham which includes up to 430 dwellings, a 60 bed care home, primary school, a local centre, community facilities and open space. Located approximately 50m from the Bath-Bristol railway line and Keynsham station, the scheme successfully shows how density is an output of good placemaking and responding to the site’s context to create a high quality garden neighbourhood. The site features six distinct character areas that vary in density to feature different housing typologies and there are a large number of terraced units with 36% of dwellings being flats. The lowest density areas are along the edges of the development to create a suitable transition with the open countryside – but overall – the scheme achieves a net density of 82 dph.

 

 

It is evident that optimising housing densities will remain central to meeting future housing and sustainability challenges. Turning to innovative and reimagined housing typologies should be promoted when considering density as we are seeing growing examples of how such an approach does not compromise the ability to successfully deliver community-oriented, sustainable, green, characterful and high-quality places that meet diverse housing needs. 

 

 

 

The next step towards the Government’s stated ambition for strategic planning - universal coverage of spatial development strategies (SDS) across the country - was announced for consultation on 12^th February 2026.  If the system works as intended (and given both past history and current political vicissitudes, it is inescapably an ‘if’), then SDSs could eventually become the key development plans for longer term strategic decision-making across much of the country.

In this initial analysis we consider the make-up of the new geographies, and explore some metrics related to two of their key priorities: meeting housing needs, and growing the economy, all set out within our interactive SDS Data Dashboard, to which we will be adding metrics over time.

The announcement provided (for consultation) the Government’s preferred geographies for SDSs. For some time, more than half of England’s population has lived in areas led by Mayors; these settled geographies are – mostly[1] – continuing in the same form, and across at least seven of the major cities, the preparation of SDSs is already underway (as we observed in December).

For much of the rest of the country, those in purple and yellow in Figure 1, last week’s formal announcement begins to shed light on these areas. However, with significant proportions ‘yet to be confirmed’ (shown in white) there is still a way to go.

  

For each of the proposed SDS geographies we have assembled a small number of the key indicators to explore each area, initially focused on the twin challenges of housing and economic growth. We provide commentary below alongside a mapping of each indicator.

SDSs are intended to ensure that sub-regional areas can effectively plan to meet their housing needs over twenty years.[2] Figure 2 shows how this maps out using the current standard method for housing need. To meet these needs across the SDS area, Strategic planning boards will therefore need to: “re-distribute housing need and other development needs between local planning authorities and may include specific policies for development or to be taken into account by local planning authorities when preparing or updating their local plans".[3] In total, over 20 years, the SDS system will need to make provision for some 7.4m homes, of which 5.7m are outside London.

SDSs in areas with existing devolution deals such as Manchester, the West Midlands and the East Midlands will need to apportion 17,000, 12,400 and 11,000 homes each year, respectively. New SDS geographies such as ‘Thames Valley’[4] Kent and Medway and Wessex will need to apportion 17,000 and 14,000 per annum respectively under their emerging geographies. For context, all of these are larger than the equivalent for West Midlands or West Yorkshire.

Analysis of recent housing delivery rates shows that for many SDS areas, housing delivery over the last three years is less than 60% of the local housing need (Figure 3) indicating that new strategies will need to demonstrate a real step change in provision, most likely pursuing spatial approaches to land release that the local plans of the last 15 years did not consider.  

Across the South East those preparing SDSs will face some of the greatest challenges in meeting housing need. London, Hertfordshire, and Surrey will require building at between 120-150% of the current rates (over the last three years). A similarly big task faces much of the South West of England including Cornwall and Plymouth, Devon and Torbay, where the Government says it awaits to “hear proposals for appropriate SDS geographies”.

Meanwhile, a small number of SDS areas – those shown in blue on Figure 3 – have been successfully delivering homes at a level consistent with what their new SDS will need to secure for the next 20 years.

 

In increasing housing delivery (and indeed, providing for other land-hungry uses), it will be necessary to consider the presence of relevant environmental and other designations that restrict development (See Figure 4), and how that relates to functional economic and market geographies that might extend beyond SDS areas. This is in the context that the consultation draft NPPF proposes (Policy PM14) that the SDS test of soundness should be based, inter alia, on the plan being ‘positive’, with a “strategy that seeks to meet objectively assessed needs, and is based on effective joint working on cross-boundary strategic matters. A strategy which does not provide for objectively assessed needs should be considered an exception, and only where it is evidenced that stringent efforts have been taken to meet those needs through cooperation with other strategic planning authorities.”

A particular challenge will arise in the more tightly defined SDS areas such as the West Midlands Combined Authority where the SDS has an acute challenge (one with which the wider West Midlands RSS tried and failed to grapple)[5] accommodating its own development needs within its current administrative boundary. Across the WMCA SDS area, recent delivery is around 65% of the aggregate housing need, but three quarters of the land area is either already built-up or subject to national planning restrictions or the green belt.

In this, and many other SDS areas, reviewing green belts will be critical to achieve sustainable patterns of development. But the big questions remain as to how effective will be the SDS process in engaging with overlapping housing market or functional economic areas without falling into (a larger-scale version of) the local duty to cooperate trap.  

 

 

Each SDS will be expected to plan for economic growth at the strategic level within its area (see draft NPPF Policy PM1). There is no employment land equivalent to the standard method for housing need, but projecting workforce growth, using Experian forecasts over the next twenty years, shows varied challenge for SDS (See Figure 5),. Employment growth is projected for around 4.9m jobs by 2045, an increase of 15.4% in compound growth over the period to be addressed. 

The geography of workforce growth shows a continued ‘North-South divide’ with hotspots including Central Bedfordshire[6]. Within this overall scale of employment, there will also be structural economic changes that all SDS will need to address and ensure the right land and infrastructure is provided to attract the indigenous and exogenous investment necessary for improved productivity and global competitiveness.

Without a prescriptive direction on how to measure ‘need’ (as reflected in the draft NPPF PM1 2 (c)) each SDS will be looking at building on the existing strengths of their economies and supporting growth in key industries identified nationally.[7] While SDSs will need to plan strategically for growth across the whole economy, the eight sectors identified in the industrial strategy are clearly earmarked for consideration, namely: Advanced Manufacturing, Clean Energy Industries, Creative Industries, Defence, Digital and Technologies, Financial Services, Life Sciences. There are clear geographical strengths and, in some locations, clusters of growth that will need to be supported in emerging development plans (see Figure 6).

 

With the task ahead – planning for 7.4m homes, unlocking investment for a changing economy and 4.9m extra jobs, infrastructure provision and nature recovery – so significant, the return to strategic planning has been largely welcomed across the sector. And why not? Who doesn’t want nice big plans that provide answers to the big questions? But of course the process to get there comes with challenges that extend well beyond the logical (and largely straight forward) nuts and bolts of what is to be laid down in regulations, policy and guidance. Many of these are familiar to observers and participants in previous iterations of strategic planning: a lack of political consensus; strategies that duck the big issues; bold ambitions that are eviscerated or revoked; delays and misalignment of timescales across tiers of plans and between areas.[8]

The extent to which these risks manifest themselves will determine whether ‘strategic planning’ becomes more than an industry in itself (and a conversation piece for planners) and provides what it could and should – a mechanism for genuinely addressing strategic cross-boundary requirements and ensuring the national growth, infrastructure and nature recovery imperatives are met. 

The Government is aiming for full SDS coverage by the end of the parliament. This appears ambitious, but the consultation on geographies, progress of the English Devolution and Community Empowerment Bill, the direction of travel in the draft NPPF and the Planning and Infrastructure Act 2025 shows the Government’s intent.

However, there remain tensions inherent in the structure. Unlike in the Capital where the London Plan is subject to scrutiny by an elected Assembly, elsewhere, the equivalent is provided by a cabinet of council leaders, who - with a simple majority - can veto submission. In many of the strategic planning authorities there are four or five councils alongside a mayor, so the potential for local elections (themselves in flux)[9] to tip the balance against an emerging SDS which might have previously enjoyed support is a live prospect even for those existing Combined Authority areas with momentum. The prospect of change – with local government reorganisation, devolution processes – including Mayoral elections delayed to 2028[10] – adds to the uncertainty.

The Government’s consultation recognises the potential for SDS to falter with a change in leadership:

It is early days and a mixed picture. The strategic planning landscape in some areas continues to look auspicious, notably the Combined Authorities with mayors who are keen to win the race to be first to adopt an SDS.[11] But one cannot help but think that the system created by the Government was best suited to an administration with an almost inevitable prospect of at least two full terms of parliamentary majority and the strength of writ to impose its national planning will (over local planning 'won't') throughout most of that period. But with its electoral prospects now much less clear, and the political map of England likely to evolve in the May of each of the next three years, the spectre of a modern-day version of the notorious “Caroline Spelman letter”  looms large.[12] 

 

Not since the first publication of the National Planning Policy Framework in 2012 has there been meaningful change for the high street and town centre uses, during which time the way we use, experience and value our town centres has changed fundamentally. Against this backdrop of economic, technological and structural transformation, the current consultation on the NPPF presents a timely opportunity to reassess how planning policy can better respond to evolving retail patterns, support mixed-use centres, and encourage new forms of development that can help underpin healthier high streets.

While the draft NPPF introduces a number of changes to retail policy that may appear unremarkable at face value – with the key retails tests that we are already familiar with remaining in place – there are subtle but significant shifts proposed that will impact on planning within town centres and the uses found within them.

 

At a high level, the draft NPPF recognises the evolution of town centres and retail uses and the changing societal ways that we engage, shop and work. There is a clear acceptance that centres are no longer defined solely by their traditional role as destinations to shop and that their long-term vitality depends on a broader mix of uses. Encouragingly, the framework continues to support the repurposing of existing buildings, reflecting the vital role this often has in sustaining town centres. 

This flexibility is welcome, particularly in the context of long-term vacancies, surplus retail floorspace and the ongoing shift towards experiential, leisure, community and residential uses within central locations. All of this is manifested in draft Policy TC2 which proposes that ‘substantial weight’ is given to proposals which support the overall vitality and viability of a centre; a big win for those seeking to reoccupy or repurpose vacant spaces.

 

Despite this recognition of change, the draft NPPF makes clear that traditional retail remains important. The policy framework continues to support the protection of town centres as the focus for main town centre uses and retains the core mechanisms that have underpinned retail planning for decades: the sequential test and retail impact assessment.

However, the accompanying consultation document explicitly questions whether the sequential approach should continue to be applied in its current form, particularly following the introduction of Use Class E in 2020. The document acknowledges that this more flexible use class has made it significantly easier for retail uses to be delivered in out-of-centre locations without the need for planning permission, potentially undermining the effectiveness of the sequential test.

  

One of the more substantive policy changes for retail proposals is the proposed removal of the concept of “primary shopping areas”, which is proposed be replaced with a broader definition of “town centres”. Alongside this, the glossary definition of edge of centre (for retail proposals) within the NPPF has been extended to 300 metres from the town centre boundary.

The implications of this shift are significant. By broadening what is considered to be “in centre”, the pool of sites that must be considered as part of a sequential assessment for a retail proposal is likely to increase. For applicants, this could mean a more extensive and potentially more complex site search exercise. It will also strengthen policy protection for existing retail assets that may previously have fallen outside the primary shopping area but within the wider town centre. It also provides more explicit policy support for expansion on town centre sites that were previously located outside of the primary shopping area.

  

Another notable change is the potential reintroduction of disaggregation within the sequential assessment process. In line with previous legal judgements, the current NPPF does not expressly mention disaggregation and simply requires applicants to demonstrate flexibility in terms of scale and format, which has generally been considered a reasonable and logical approach. However, proposed new Policy TC3 suggests that, moving forward, applicants will be required to consider whether a proposal could be accommodated across multiple smaller sites within a town centre, rather than on a single, consolidated site:

TC3 “….it is not necessary to demonstrate that a potential town or edge of centre site can accommodate precisely the sale and form of development proposed, and it should be considered whether the type of development proposed could be accommodated across multiple sites”

Assuming Policy TC3 makes it through to the final document, it is likely to open up new debate around the viability and practicality of multi-occupier schemes and, indirectly, act as a brake on investment; directly contrary to the wider aspirations of Government to promote economic growth, wherever possible.

 

The current NPPF seeks, at paragraph 97, to restrict the location of new hot food takeaways and fast-food outlets within walking distances of schools – and other places where young people congregate – unless they are in the town centre. This was a new policy approach introduced in December 2024 without any consultation on either the thrust of the policy or the specific policy wording.

Paragraph 97 is carried forward into the new NPPF under draft Policy HC5 with only a very minor change which seeks to provide ‘clarity’ in inserting that any walking distances should be ‘reasonable’ – without providing any guidance as to how a reasonable walking distance might be defined. It also provides no further clarification as to whether the restrictions apply to both primary as well as secondary schools – or how ‘other places where children and young people congregate’ should be defined. These are issues which applicants and local planning authorities alike have been grappling with since the first introduction of the policy in 2024.

While the consultation document invites views on whether further clarity is required to improve the application of this policy, the opportunity has been missed to consult on a more clearly defined policy approach.

 

Outside of town centres, roadside facilities finally receive some long-overdue attention. Draft Policy S5 explicitly recognises such facilities as acceptable in principle outside settlement boundaries, subject to meeting the requirements of draft Policy TR5.

Draft Policy TR5 provides positive support for new and expanded roadside services where they would meet an unmet need or improve access to electric vehicle charging and alternative fuels. This is a welcome acknowledgment of changing travel patterns and the role these facilities play in supporting the transition to low-carbon transport.

However, the draft policies are notably silent on the retail and food and drink elements that typically form an integral part of roadside facilities. While it might be assumed that such uses fall to be tested against the relevant policy tests, this would seem to be a missed opportunity to clarify, for example, that small scale retail uses proposed as part of new roadside services / infrastructure (e.g. EV charging provision) should be treated as acceptable in principle and this omission risks creating uncertainty for schemes that rely on a mix of uses to be commercially viable.

  

While the consultation draft NPPF carries forward a broadly similar policy approach - requiring local authorities to remain focused on the long term vitality and viability of town centres and applicants to satisfy the impact and sequential test - it does, on closer analysis, propose subtle but potentially significant changes which are likely to have a major bearing on the approach taken in relation to applications for retail and other town centre uses. In other respects, it represents a missed opportunity to provide greater policy clarity – particularly in relation to hot food take away uses and ancillary retail uses which form part of new roadside infrastructure. 

If you would like to understand more about the draft NPPF and how the proposed changes could affect your retail or town centre developments, or if you would like assistance in preparing representations to the consultation, please do get in touch.

The consultation closes to representations on 10 March 2026.