Simon Ricketts

To maximise the prospect of securing planning approval, scheme promoters need to ensure that their schemes press as many of the relevant buttons in the new NPPF as possible.

I have counted 21 of them, which I set out below. Most have detailed qualifying criteria to meet, but hopefully this will allow you to see the wood for the trees in applying the new policy framework. Not triggering the particular policy may in some cases count against you in the planning balance, so this is not quite just the Scrabble approach of always looking to maximise use of those triple word scores.

S3: Presumption in favour of sustainable development

1. Decisions on development proposals should apply a presumption in favour of sustainable development. This means:

1.  Policy S4 in this Framework should be applied when considering development proposals within settlements;
2. Outside settlements, policy S5 should be applied; and
3. In all locations, development proposals that accord with both an up-to-date development plan and the decision-making policies in this Framework should be approved without delay.

S4: Principle of development within settlements

1. Development proposals within settlements should be approved unless the benefits of doing so would be substantially outweighed by any adverse effects, when assessed against the national decision-making policies in this Framework.

S5: Principle of development outside settlements

1. Only certain forms of development should be approved outside settlements, as set out in the following list. These should be approved, unless the benefits of doing so would be substantially outweighed by any adverse effects, when assessed against the national decision-making policies in this Framework.

For developments outside settlements, falling within the a to j list is vital. If your land is green belt the development proposed must not be “inappropriate development” and must therefore fall within one of the a to h criteria in policy GB7 1 – so grey belt development, for instance, also qualifies for this strong pro-development presumption.

CC2: Mitigation of climate change

2. Substantial weight should be given to the benefits of improving the energy efficiency of existing buildings and/or drawing energy from district heat networks, renewable and low carbon sources (including through the installation of heat pumps and solar panels where these do not already benefit from permitted development rights) where this would be achieved through proposals for development.

CC3: Adaptation to climate change

2. Substantial weight should be given to the benefits of improving the resilience of existing buildings and public spaces to anticipated climate change impacts where this would be achieved through proposals for development.

HO7: Meeting the need for homes

1. In applying the policies in this Framework, substantial weight should be given to the benefits of providing homes which will contribute towards meeting the evidenced accommodation needs of the community, as identified through needs assessments prepared for the area of the local planning authority and other relevant evidence. This includes, but is not limited to, homes needed for different groups assessed under policy HO1.

E2: Meeting the need for business land and premises

1. To support business growth, substantial weight should be given to:

1. The economic benefits of proposals for commercial development which allow businesses to invest, expand and/or adapt; especially where this would support the economic vision and strategy for the area, the implementation of the Industrial Strategy, support improvements in freight and logistics and/or reflect proposals for Industrial Strategy Zones and AI Growth Zones; and
2. Benefits for domestic food production, animal welfare and/or the environment which can be demonstrated through proposals for development for farm and agricultural modernisation.

TC2: Development in town centres

1. In considering proposals for development in town centres, substantial weight should be given to the benefits of:

1.  Supporting the overall vitality and viability of the centre, including where this can be achieved through the diversification of uses, intensification and provision of residential accommodation (provided this would not conflict with policies in the development plan for specific locations); and
2. Improving or retaining access to local shops and other facilities which provide day-to day services for the local community.

CO1: Proposals for telecommunications infrastructure

1. In considering proposals for the expansion or upgrading of electronic telecommunications networks, substantial weight should be given to the benefits of maintaining or improving network coverage, capacity, reliability and resilience, including where significant improvements are required such as along rail corridors. This includes, but is not limited to, providing for next generation wireless technologies (such as standalone 5G), gigabit capable broadband connections and supporting infrastructure such as fibre exchanges.

W3: Renewable and low carbon energy development and electricity network infrastructure

1. In considering proposals for renewable and low-carbon energy development and electricity network infrastructure, substantial weight should be given to:

1. The benefits for improving energy security, supporting economic development and/or the transition to a net zero future;
2. In the case of applications for the re-powering and life-extension of existing sites, the additional benefit of utilising an established site for this purpose; and
3. The contribution that small-scale and community-led renewable and low carbon energy projects can make to reducing greenhouse gas emissions, along with their associated economic and social benefits.

W4: Water infrastructure

1. In considering proposals for water supply, drainage and wastewater development, substantial weight should be given to the benefits of: a. Providing the capacity needed to serve proposed development and/or improving the security of supply and capacity for existing users (both residential and commercial, including agricultural users); and

b. Improving water quality and reducing water-borne pollution.

M3: Assessing the benefits of mineral development

1. In assessing proposals for minerals development, substantial weight should be given to the benefits of mineral extraction and processing, including to the economy.

L2: Making effective use of land

1. Substantial weight should be given to the benefits where a development proposal would achieve one or more of the following:

1. Remediating despoiled, degraded, derelict, contaminated or unstable land;
2. Making better use of vacant and underutilised land and buildings (such as: by bringing back into residential use empty homes and other suitable buildings; converting space above shops; redeveloping underutilised retail and business sites; and building on or above service yards, lock-ups, car parks and other transport infrastructure which are no longer required);
3. Making effective use of previously developed land and buildings through temporary uses, in situations where alternative development is anticipated within a reasonable period (including as a result of the land being allocated for an alternative purpose in the development plan); or
4. Creating additional homes or floorspace within settlements by using the airspace above existing residential and commercial premises, or through sensitive redevelopment or additional development within existing plots (including, but not limited to, the addition of mansard roofs, proposals to fill gaps in the existing roof line, the introduction of higher buildings at street corners and additional units within residential curtilages).

GB8: The Golden Rules

2. In considering applications for major development involving the provision of housing on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, substantial weight should be given to the importance of complying with the Golden Rules.

DP3: Key principles for well-designed places

5. Substantial weight should also be given to outstanding or innovative designs which promote high levels of sustainability, or which help raise the standard of design more generally in an area, so long as they are consistent with the overall form and layout of their surroundings.

HC4: Proposals for new and improved community facilities, public service infrastructure and development providing public health benefits

1. Substantial weight should be given to the benefits where:

1. New or improved public service infrastructure or community facilities would be provided; and
2. Development proposals would make a demonstrable contribution towards promoting good health, preventing ill-health, reducing health inequalities or supporting social interaction in the local community (such as, but not limited to, the provision of new recreation facilities, meeting places and opportunities to grow or purchase healthier food).

P6: Land and operations for defence and public safety

1. Substantial weight should be attached to the importance of sites, activities, facilities and infrastructure required to maintain and enhance defence capability, or whose primary purpose is public safety (including uses such as coastal protection works, coastguard and lifeboat facilities and emergency services telecommunications infrastructure), when considering:

1. Proposals for such development (whether through modernisation, intensification, redevelopment or expansion for operational and related purposes); and
2. Proposals which could affect their operational activity and capability, including situations where other development should only proceed where it can make alternative or replacement provision for defence or public safety operations which would otherwise be affected, or where noise from operational activities could affect the proposed development (in which case policy P4 should also be applied).

HE6: Proposals affecting designated heritage assets

2. Development proposals which would have a positive effect on a designated heritage asset should be supported.

HE7: Decisions on non-designated heritage assets

1. Development proposals which would have a positive effect on a non-designated heritage asset should be supported.

HE8: World Heritage Sites

2. Proposals that conserve those elements of a World Heritage Site or its setting, including any buffer zone, that make a positive contribution to it or which better reveal its significance, should be supported.

HE9: Conservation areas

3. Proposals which conserve those elements of a conservation area that make a positive contribution to the area (or which better reveal its significance) should be supported.

Simon Ricketts, 31 August 2026

On 17 August 2026, the government published its response to the public consultation on a new National Planning Policy Framework (NPPF) and announced wider measures to create a faster, more certain planning system.

The government has also published the recent Housing Delivery Test (HDT) results.

Relevant Planning Practice Guidance will be updated.

This is an important subject covering proposals for housing development in London for the next 20 years.

We invited the London Plan team to talk about:

• The amount of housing required to meet London needs and the tenure and size mix required;
• Where and how the new housing will be accommodated by location and the types of places that would be created; and
• The types of housing in terms of density and building types – low-rise, mid-rise and high-rise.

This covered a number of London Plan policies, the speakers painting a picture of the direction of travel, followed by a Q & A session, plus discussion.

Meeting record

Click on the image above for the slide presentation.

The draft London Plan is also available.

Contents:

• Housing, devolution & new towns — Burnham’s growth agenda, National Housing Bank.
• London’s office squeeze — shortage of prime workspace & economic impact.
• Olympia unveiled — Spparc & Heatherwick’s £1.3bn regeneration in Hammersmith.
• £9bn in unspent developer contributions — why S106 & CIL funds are stuck in council accounts.
• Planning policy & appeals — City Plan 2040 stalled, station-led development & rising appeal rates.
• High streets & city culture — placemaking, healthcare anchors & call for a City of London cultural strategy.
• RIBA National Awards 2026 — London takes 17 of 32.
• Tourism & demographics — Middle East visitor impact & updated GLA population projections.

Our AI-generated summary is here.

The full journal is not available on our website, but selected excerpts are available on the PiL website. Below, London Forum has a subscription arrangement for members.

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This article provides an account of how the legislation relating to telecoms masts has evolved over the past four decades. It also presents a case study from East Sheen in the borough of Richmond upon Thames, which highlights some of the issues we currently face. It would be useful if our member societies could provide information about their experiences in their respective boroughs, so that we can get a view of how applications are handled across London.

The 1990s and the introduction of Permitted Development Rights

When masts first started to appear, they required a full planning application under the Town and Country Planning Act 1990, allowing local planning authorities (LPAs) to prevent the erection of masts in inappropriate locations or where they had an adverse visual impact. But in 1995, the General Permitted Development Order (GPDO) brought a huge increase in what were termed ‘Permitted Development Rights’(PDRs). It created a dual-track system under which instead of full applications, telecoms operators could use a “prior approval” process for masts of under 15 metres tall, and LPAs could comment only on their siting and appearance. But full planning permission was required for masts over 15 metres tall or those in sensitive areas such as National Parks, Areas of Outstanding Natural Beauty (AONBs), and Conservation Areas.

This regime remained relatively stable for over 15 years, with the rapid development of the 2G and 3G networks. The only significant change came as a result of concerns about the health effects of radiation from the masts. In 2000, the Stewart Report recommended a precautionary principle for the development of the mobile phone network. It included, even before the introduction of smart phones and widespread use of social media, a recommendation that children should not use mobile phones for anything other than essential purposes. It also recommended that all telecoms masts be subject to planning control regardless of size. The Government did not accept that recommendation, but it introduced a Code of Best Practice that required operators to consult with schools and local communities before erecting masts.

The NPPF and the latest rule changes

In 2012 the National Planning Policy Framework (NPPF) introduced by the Coalition Government brought a profound shift in policy, with an explicit statement that LPAs should support the expansion of electronic communications networks. The NPPF also restricted councils’ ability to reject masts on health grounds provided that the equipment met international guidelines. Permitted development rights were expanded in 2016 to allow for masts up to 25 metres tall, or 20 metres in conservation areas and other protected areas. Prior approval was still needed for new masts, but not for changes to existing ones.

The most recent changes came in 2022, under the Johnson Government. They were designed to facilitate the rapid rollout of 5G, which requires a higher density of “small cell” antennae. Permitted development rights were expanded once more to cover masts up to 30 metres tall, or 25 metres in conservation and other protected areas; and the permitted width was increased from one metre to two, in order to allow for the size of 5G equipment; and further flexibility was allowed for masts on rooftops. Prior approval is still required for most masts.

Anecdotal evidence suggests that councils have adopted a range of usually unstated policies relating to full and prior-approval applications for telecoms masts. Success in restricting the erection of masts on sensitive sites and conservation areas seems to be patchy, as recent experience in East Sheen shows.

The most conspicuous eyesore in East Sheen, namely the aerial mast atop Parkway House, which looms above the South Circular Road (the photo here was taken from a residential backstreet), is about to be dismantled and the telecom providers are proposing to erect a replacement mast with similar paraphernalia of antennae atop another building nearby which is wedged between two Conservation Areas. The local community is alarmed because the proposal constitutes ‘permitted development’. The alternative is for the providers to find a site nearby for a ground- based monopole on the South Circular Road. Interestingly the Richmond Council has recently refused several applications for monopoles rising to 20m on the grounds of their dominance and visual intrusiveness but the GPDO was updated in 2022 to allow an increase in the height of permitted development from 15m (excluding antennae) to 25m within Conservation Areas and 30m outside. Alas, the Council has no time to impose any Article 4 direction which would enable it to control the location and design. We have to bite the bullet and accept a major change is about to hit our townscape not just here but London-wide. Or perhaps the Borough of Richmond is unique in this instance? We have no tall buildings on which to mount aerial masts offering a wide area of coverage. Our tallest buildings are still our church steeples.

A final thought. In the busiest parts of London, including parts of the City and Oxford Street, you don’t see any masts at all. 5G coverage is now provided by small boxes hidden in lampposts and bus shelters, or, less satisfactorily, by the ‘Inlink’ digital kiosks that disfigure so many high streets. Is there perhaps the chance that further technological advance will diminish the need for the masts that we see almost everywhere today?

Michael Jubb
Chair, London Forum
With many thanks to Tim Catchpole, Chair Mortlake and East Sheen Society

Our AI-generated summary can be downloaded.

Table of contents:

• The housing delivery crisis from multiple angles (Berkeley halting land buys, the 84% collapse in starts, viability evaporating across most of London)
• The new NPPF and what it means in practice (minimum densities, simplified local plans, stronger presumption for development)
• The LP&DF Annual Planning Update conference in full
• Specialist opinion pieces on BtR SFH, Gateway 3, resilience, new towns funding, density barriers, viability guidance, and planning appeals reform
• Features on heritage retrofit (Grosvenor’s Retrofit or Ruin), health impact assessments, and international lessons for new towns
• Both book reviews and the Thames Estuary infrastructure investment piece

The full journal is not available on our website. Selected excerpts are available on the PiL website. 

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The report by Verian on that research is here. There is strong support for clearer national guidance, standardised carbon assessment methods, fiscal measures such as VAT harmonisation to incentivise retrofit, and mandating consideration of retrofit in planning applications.

Stakeholders highlighted challenges including Local Authority resource constraints and skills gaps in retrofit delivery.

The Government has not indicated yet the next steps.