NPPF 2026 - It was almost the end for Net Zero Homes

When the Government launched the consultation on the 2025/26 reforms to the National Planning Policy Framework (NPPF), one particular proposal sent a collective shiver through the sustainability community.

Not the housing targets.

Not the green belt reforms.

Not even the changes to plan-making.

For many, the headline concern was PM13 - a proposal that would have fundamentally changed the role of local planning authorities in driving energy performance standards beyond Building Regulations. If adopted in its original form, it would have effectively ended what many local authorities have been doing for years: using Local Plans to push new homes towards genuine net zero performance.

As 54% or consultation respondents strongly disagreed with the draft PM13, that isn't what happened.

The final version of PM13 is very different from the consultation draft, and while there are still questions to answer, the result is considerably different.

Why PM13 Matters

For those who don't spend their evenings sifting through energy policy and planning consultations (I appreciate that's not everyone's idea of fun), PM13 deals with what local planning authorities can require through their development plans.

Historically, many councils have adopted policies requiring enhanced fabric performance, reduced carbon emissions, renewable energy generation, operational energy targets, embodied carbon assessments and various forms of net zero planning policy.

Often these local policies have been justified because national standards have evolved at a slower pace – with building regulation for net zero homes over 10 years in the making.

Standards such as the London Plan energy hierarchy, Passivhaus requirements, LETI-inspired energy targets and local net zero policies have all emerged because authorities were able to respond to local climate commitments and local political priorities.

The concern with the consultation draft of PM13 was that this flexibility looked set to disappear.

The Consultation Proposal

The consultation wording proposed a much tighter approach to energy standards within Local Plans.

The principle was simple enough: reduce complexity, avoid a patchwork of local requirements, and provide greater certainty for developers operating across multiple authority areas.

On paper, that sounds reasonable.

In practice, however, it risked setting Part L as both the ceiling and the floor for energy efficiency standards.

Many sustainability practitioners, local authorities and industry bodies raised concerns that councils would lose the ability to require standards beyond the national baseline, even where they had robust climate objectives and evidence to justify higher performance.

Consultation respondents highlighted the potential impact on local climate action.

The Great PM13 U-Turn

Fast forward to the publication of NPPF 2026 and the final wording tells a different story.

Crucially, local planning authorities retain the ability to set energy efficiency standards that go beyond national Building Regulations, but there are conditions attached.

Authorities must demonstrate a clear rationale, ensure policies are evidence-based, and consider viability and deliverability. None of those tests are particularly surprising. In truth, most authorities developing robust sustainability policies are already undertaking this work as part of the examination process.

The important point is that the opportunity for Local ambition survives, and the government will not commence s.43 of the Deregulation Act 2015 to amend local authority planning powers.

That matters because some of the most progressive energy policies currently operating around the country depend upon local authorities being able to set standards that exceed the national minimum.

Without that flexibility, achieving many local climate emergency commitments would have become considerably more difficult.

The Catch: Operational Energy Targets

While PM13 emerged with local planning authorities having more freedom than expected, it wasn't a complete recall.

The final wording indicates that development plan policies relating to energy efficiency should be expressed as a reduction in carbon emissions calculated through the recognised Part L regulatory methodology.

In housing, that currently means SAP.

This raises an interesting challenge for operational energy policies.

Over recent years many authorities have moved towards LETI-style operational energy targets, often expressed as Energy Use Intensity (EUI) measured in kWh/m²/year.

The attraction is obvious, EUI measures energy use directly and so speak the same language as net zero carbon frameworks. It is easier to compare against actual building performance.

Most importantly, it helps address the performance gap between modelled and real-world energy consumption.

PM13's focus on carbon emissions methodologies appears to make these operational energy targets harder to justify within planning policy.

Not necessarily impossible, but certainly more challenging.

And that feels slightly odd given where national policy is heading.

The SAP Problem

The timing is perhaps the most curious aspect of all.

PM13 appears to reinforce alignment with SAP-based carbon metrics, yet SAP itself is approaching the end of its journey.

The Future Homes Standard and the forthcoming Part L 2026 changes are expected to transition the industry towards the Home Energy Model (HEM), replacing SAP as the primary assessment methodology.

The Home Energy Model promises a more sophisticated approach to modelling building performance, accounting for evolving technologies, smart systems and more detailed occupancy assumptions.

In other words, the industry is preparing to move on from SAP at the very moment planning policy appears to be doubling down on it.

Perhaps the wording is intended simply to ensure alignment with whatever the recognised national methodology happens to be at the time. If so, the practical implications may be limited.

However, it inevitably creates uncertainty for authorities that have invested heavily in operational energy policy and EUI-based approaches.

What Happens Next?

Viewed overall, PM13 represents a considerably more flexible outcome than many expected when the consultation was first published.

The ability for local authorities to pursue enhanced energy standards remains in place.

The complete rollback of local net zero planning policy has been avoided.

At the same time, questions remain around operational energy targets, Energy Use Intensity metrics, and how local planning policy should evolve alongside the transition from SAP to the Home Energy Model.

Those discussions are unlikely to disappear any time soon.

If anything, PM13 may simply have shifted the debate from "can authorities set higher standards?" to "how should those standards be measured?"

And perhaps that's where the industry should be focusing its energy.

Because while Net Zero Homes narrowly avoided a very difficult few years, the challenge of delivering buildings that actually perform as intended remains every bit as important as the policy framework that supports them.

A bridge still to cross.