NCLOG Response: National Planning Policy Framework 2026 revisions

At the end of 2025, the Government published proposed reforms to the National Planning Policy Framework (NPPF) and other changes to the planning system.

These proposals were subject to consultation in early 2026. The National Contaminated Land Officers' Group (NCLOG) submitted a response to the consultation, based on the views of its members working as Contaminated Land Officers.

We also supported an IES response which covered the views and insights of members working across specialisms. The IES response highlights and quotes key sections of the NCLOG response.

These proposals are important and come in the context of a range of linked changes in the policy world, including:

• A revised Environmental Improvement Plan for England (EIP)
• The Planning & Infrastructure Act
• The Devolution Bill and reforms to local authorities
• England's Water White Paper and the Welsh Green Paper for Water
• Previous reforms to the NPPF in recent years, as well as changes through the Levelling-Up and Regeneration Act that include the prospect of a shift from Environmental Impact Assessment to Environmental Outcomes Reports

Find out more about the latest policy developments by reading Essential Environment.

Executive summary

Throughout our response, we make specific recommendations and suggested amendments to the proposed NPPF text. Read the full response for more information.

• We strongly support the policy DM2 on information requirements for planning applications, and policy DM7 on the relationship between planning decisions and other regulatory regimes.
• We strongly support the clarification in policy P3 that planning decisions should not assume other regulatory regimes will completely control emissions.
• We have requested clarification of terms across the new NPPF, including explicit reference to 'brownfield first' in PM9 and P1, and definitions of 'site assessment’ and 'competent person' that explicitly reference the Environment Agency’s Land Contamination Risk Management (LCRM) definitions.
• We are highly concerned that policy DM3 may result in statutory consultees, including the Environment Agency, and non-statutory consultees, including Contaminated Land Officers within local authorities, not being consulted when their input is essential. The IES response also sets out wider concerns that the removal of several smaller discretionary levers adds up to a significant reduction in the flexibility of local authorities to take innovative and ambitious approaches that might make more sense locally, have the ability to promote growth, and may be essential to meeting national targets.
• We recommend that additional tools and guidance are essential to support consistent, proportionate, and effective decision-making on contaminated land; see our response to Q166 for more details.
• We recommend greater recognition of sustainable soils management throughout the proposed NPPF; see our response to Q43 and Q165 for more details.

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