1.Background
The National Planning Policy Framework (NPPF) is the Government’s national planning policy for England. It is a material consideration for Local Plan-making by local authorities and most decisions around planning applications in England. It covers a wide range of topics, including housing, transport, and environmental considerations, aiming to promote sustainable development and involve local communities in planning decisions.
First introduced in 2012, it is regularly revised. The current version was introduced in August 2026, after public consultation earlier in the year, and replaces the 2024 NPPF.
1.1Why NPPF is important to Epping Forest
The NPPF has a big part to play when considering how to protect Epping Forest. The Forest itself is protected from development by the 1878 Epping Forest Act, which maintains that the Forest be kept unenclosed and unbuilt on. A large part of Epping Forest is also a Special Area of Conservation (SAC), and The Conservation of Habitats and Species Regulations 2017, which requires assessments for determining whether negative ecological from developments close to the Forest can be either avoided or mitigated. Nevertheless, the NPPF is important for Epping Forest because its policies signpost whether development would or would not be inappropriate around the Forest and the kind of development which ought to take place.
Accordingly, EFHT have always paid close attention to the NPPF, drawing on it regularly for our planning responses. Given that a large part of Epping Forest falls within Epping Forest District and around 92% of the district is Green Belt, EFHT’s concerns about the NPPF have mainly centred around its Green Belt policies. We maintain that the Green Belt around Epping Forest should remain undeveloped, to mitigate impacts of air pollution, increased footfall and other effects of urban settlement. Currently, we are currently monitoring eight applications for development on Green Belt land, ranging from five to 400 dwellings. The extent to which the new NPPF’s Green Belt policies enable or inhibit future applications for these kinds of developments is therefore of key concern.
Alongside these, the NPPF includes policies around standards of best practice for strategizing development and safeguarding/improving biodiversity. These also have the potential to impact the Forest
2. What remains the same?
2.1 The impacts of a low Housing Delivery Test Score on EFDC’s Green Belt.
A crucial continuity between the 2024 and 2026 NPPFs is that the availability of the Green Belt for development is still linked to housing targets and made easier if those housing targets are not met by local authorities.
One of these targets is calculated by a Housing Delivery Test (HDT). HDT measures how many homes have been delivered in a local planning authority’s area against the number that should have been delivered. EFD’s score is 66% and the District is therefore one of the 93 local authorities with sub-75% HDT results. This increases the risk of development within Forest-surrounding Green Belt. The 2026 NPPF identifies a HDT performance of under 75%, as examples of “evidenced unmet need” (NPPF 2026 GB7(1)(g)(ii)). Where the relevant requirements of GB7 are satisfied, this can provide a route for development in the Green Belt to be treated as “not inappropriate.” Concerningly, this means that “very special circumstances” for development on the Green Belt do not need to be demonstrated.
3. What are the positive notes in the new NPPF?
3.1 Spatial Development Strategies signal a positive future for conscientious infrastructure development in Epping Forest District.
Spatial Development Strategies (SDS) are high-level strategic plans for counties and similarly sized regions. The 2026 NPPF clarifies the significance SDSs will play in influencing how Local Plans are designed, setting out general strategic priorities which will then be made area-specific in individual Local Plans (NPPF 2026 PM1). In Epping Forest District, the relevant SDS would be that of Greater Essex.
This signals a shift to a more strategic way of thinking about infrastructure development around Epping Forest, including solar farms. Among the concerns of a SDS is setting out utilities provision, including low-carbon energy. Generally, we are concerned about the impact of solar farms around Epping Forest, and the risks, embodied by the current application for a solar farm at Upland Road in Thornwood, that the Green Belt surrounding the Forest will be diminished by these developments. Nevertheless, albeit there is currently no formal timeline for a Greater Essex SDS, once published we hope that this will provide guidance on a more strategic approach to the development of solar farms in the district which ensures that the impact on the Forest is properly considered. Up until now, the approach has been too ad hoc, too compromising of the Green Belt and risking too much impact on the Forest.
3.2 Stronger protection for Biodiversity
Policy N2 of the new NPPF emphasises the importance of development improving the natural environment. This includes referencing the need for new developments to strengthen ecological networks that extend beyond the site being developed (NPPF 2026 N2(1)(c)).
EFHT strongly supports strengthening ecological networks – or wildlife corridors – around the Forest in London and Essex. As part of our #LoveEppingForest Manifesto, ahead of the May 2026 local elections, we got candidates vying for seats in the local authorities surrounding the Forest to pledge to strengthen wildlife corridors. We are therefore happy to see national planning policy provide strong grounds for this.
Policy N6 complements this, by stressing that development proposals should only be supported if there would be no adverse effect (either individually or in combination with other developments) on sites of national and international importance. Epping Forest is both, being a “Special Area of Conservation” (SAC) and “Site of Special Scientific Interest” (SSSI). We support the noting of developments “in combination”, as we continue to be concerned about the cumulative impact of developments around Epping Forest.
There are exceptions to this, such as if the impact can be addressed through an Environmental Delivery Plan (EDP). Since EDPs are yet to be rolled out in the local authorities around Epping Forest, we are yet to see how this exception will be used.
4. What are the fresh concerns for the Forest?
4.1 Reduced restrictions on grey belt allocations.
Alongside the positive shifts outlined above, we have identified several more concerning moves, including reduced restrictions on grey belt allocation.
In the NPPF 2024, the definition of grey belt was caveated by footnote 7 of the Framework, whose function included to exclude land from a grey belt designation if the presence of a “habitat site” provided a strong reason for refusing or restricting development (NPPF 2024 Paragraph 11, Annex 2: Glossary). This includes Epping Forest’s SAC.
Footnote 7 has now been removed from the definition of grey belt (and removed from the NPPF entirely). From a planning policy perspective, this makes grey belt a simpler policy. Whereas previously Footnote 7 meant nature conservation played a role from the start, grey belt policy is now uncoupled from nature conservation policies. However, now concerns for the Forest-SAC no longer influence decisions around grey belt, the door is open for Green Belt land close to the Forest being given this designation.
The immediate result of this concerns the ongoing Epping Forest/Harlow District Green Belt Assessment. Within this assessment, Green Belt will be evaluated based on criteria set by the NPPF and grey belt will be assigned to particularly low-scoring sections of Green Belt. Currently, we have concerns about the Assessment’s Methodology (see our response to the consultation here) and this extends to the potential it leaves open for grey belt designation near the Forest.
4.2 Reduced restrictions on Green Belt development near well-connected stations.
Development on the Green Belt is no longer inappropriate in principle so long as it is within reasonable walking distance of a well-connected station. This means that these Green Belt developments would not have to demonstrate very special circumstances to be approved (GB7(h)(ii)).
Annex B provides a definition of “well-connected station”, which includes stations within a “top 80 Travel to Work Area”. The Central Line stations running down the east of Epping Forest, within EFDC (Epping, Debden, Chigwell, Grange Hill, Loughton, Roding Valley and Theydon Bois) all qualify as within the TTWA of London (no. 1 on the top 80 list). Roydon Station also qualifies. Accordingly, development on Green Belt around these stations would not be inappropriate.
Development near train stations, in one sense, signals a positive emphasis on development which can be supported by public transport. We hope that this will encourage a modal shift of transport around the Forest and support the reduction of atmospheric pollution from vehicles. However, we continue to be concerned, in principle, by any development which erodes the Green Belt surrounding the Forest.
Now this kind of development is supported by policy, we will scrutinise its practical application, paying close attention to how the definition of “reasonable walking distance” is approached by developers and EFDC, ensuring that any environmental benefits of development near stations are not undermined by too much car parking provision, and identifying and objecting to other aspects of the proposals which may damage the Forest.