Air Quality Assessments Under the NPPF 2026: What's Changed

The air quality NPPF 2026 change worth understanding first is a structural one: air quality no longer has a paragraph of its own. It is now one limb of policy P3, "Living conditions and pollution", in Chapter 17, sitting alongside noise, artificial light, water and soil. The August 2026 Framework replaces the December 2024 version, and while the direction of travel is familiar, several of the words that changed will change what your assessment has to demonstrate.

Where air quality sits now

Chapter 17 is "Pollution, public protection and security" and runs six policies, P1 to P6, at printed pages 78 to 82: P1 Planning for clean and safe places, P2 Ground conditions, P3 Living conditions and pollution, P4 Impact of development on existing activities, P5 Maintaining public safety and security, and P6 Land and operations for defence and public safety.

Air quality is P3(2)(c). The chapter carries a boxed objective about ensuring new development "is appropriate for its location, taking into account risks posed by pollution and other hazards", but paragraph 10 is explicit that those chapter objectives are "for context only and should not be applied as either plan-making or decision-making policy". Do not cite the objective box as policy in a planning statement. It will be picked up.

Under December 2024, the equivalent material sat at paragraph 199 as a free-standing air quality paragraph. Worth also remembering the wider split the 2026 document makes between plan-making and decision-making policies, with paragraph 8 confirming that plan-making policies "should not be used when making decisions on development proposals". The old habit of quoting one paragraph at both stages does not survive that.

What changed from December 2024

December 2024 paragraph 199 said that planning policies and decisions "should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas", and that planning decisions should ensure new development in AQMAs and Clean Air Zones is consistent with the local air quality action plan.

P3(2)(c) now reads: "Sustain and contribute to compliance with relevant limit values or national objectives and targets for air pollutants including PM2.5. Development proposals should take account of Air Quality Management Areas and be consistent with the objectives of relevant Air Quality Action Plans, Clean Air Plans and Local Air Quality Strategies".

Five differences matter.

PM2.5 is named

December 2024 referred to "pollutants" without naming one. P3(2)(c) names PM2.5, and adds "targets" alongside limit values and national objectives. The Framework sets no numbers itself; it points at the values, objectives and targets that sit outside it. In practice, an assessment that reports NO2 and PM10 in detail and mentions PM2.5 in passing will not answer the policy. Expect to report annual mean PM2.5 in µg/m³ against the applicable objective and target, alongside NO2 and PM10, and to say something evidenced about the development's contribution.

The document list is broader

Paragraph 199 named Air Quality Management Areas and Clean Air Zones, and required consistency with "the local air quality action plan". P3(2)(c) keeps AQMAs and asks for consistency with the objectives of relevant Air Quality Action Plans, Clean Air Plans and Local Air Quality Strategies. Two of those three are new to the Framework, and Local Air Quality Strategies in particular are documents many assessments have never cited. The wording no longer names Clean Air Zones. If you have a report template with a policy section, it needs editing.

Receptor sensitivity is written into the policy

P3(1) requires that "consideration should be given to the potential sensitivity of the site, and its intended occupiers and users, as well as that of the environment and population in the surrounding area (including where certain groups could be particularly vulnerable to its effects, such as children and older people)". Paragraph 199 had no equivalent. If you are proposing a nursery, a school, a care home or supported housing on a busy corridor, that sentence is the hook for a more demanding assessment, and we expect officers and environmental health teams to use it.

Pre-existing conditions are squarely in policy

P3(1) captures effects "whether these effects are on or off-site; and whether this is as a result of the development itself or the product of preexisting conditions in its vicinity". The exposure of new residents to poor air quality the development did not cause is therefore a Framework matter, not just a local plan one. On constrained urban sites, exposure assessment stops being an optional extra.

Air quality is read with noise, light, water and soil

P3(2) runs from (a) to (f): healthy living conditions and daylight at (a), pollution effects on neighbours at (b), air quality at (c), noise at (d), artificial light at (e), and water quality at (f), which asks that impacts be assessed and mitigated where development "could have an unacceptable adverse effect on water quality, especially in relation to sensitive water bodies such as chalk streams". One policy, one set of tests. In our view that pushes towards a single, internally consistent environmental case rather than four unconnected appendices, and it makes contradictions between them much easier to spot.

The mitigation expectation at P3(2)(a) and (b)

P3(2)(a) asks that development provide healthy living conditions "in terms of adequate access to light and avoiding exposure to levels of air, noise, artificial light or other sources of pollution which could have an unacceptable adverse effect on health and the quality of life", and adds that "Where necessary suitable mitigation measures should be incorporated to secure acceptable living conditions".

P3(2)(b) looks the other way, asking that the development not give rise to unacceptable levels of air, noise, artificial light, water, soil or other pollution on or beyond the site, with adverse impacts of that nature "avoided where possible, or else mitigated".

The two limbs run in both directions: protecting the people you are putting on the site, and protecting everyone else from what the site produces. The hierarchy at (b) is explicit. Avoid first, mitigate second. On air quality that means layout, orientation and separation before mechanical fixes.

One drafting point. December 2024 paragraph 199 referred to opportunities to improve air quality through traffic and travel management and green infrastructure. That sentence does not appear in P3(2)(c). We do not read that as licence to drop those measures: P3(2)(a) still asks for suitable mitigation where necessary, and local plans and validation lists have not changed. But if you were quoting paragraph 199 to justify a green infrastructure package, you need a different reference now.

P3(3) and other regulatory regimes

P3(3) preserves a useful assumption. Unless there is clear evidence to the contrary, it should be assumed "that separate regulatory regimes for the control of pollution will operate effectively, as set out in policy DM7", which means "it will be appropriate to take into account emissions limits set through those other regimes".

If your scheme sits next to a permitted industrial process, an energy-from-waste plant or a regulated combustion source, you can take the permit limits as the basis for assessment rather than re-arguing the permit through the planning application. The counterweight is the phrase "clear evidence to the contrary". Where monitoring records or a complaint history suggest the regime is not delivering on the ground, the assumption can be displaced. Policy P4, "Impact of development on existing activities", is the companion policy where the existing operator's ability to keep operating is what is at stake.

Annex C and the information requirement

Annex C, "Information requirements", now carries a row for "Living conditions and pollution" against P3: "Such information as required to demonstrate compliance with relevant aspects of Policy P3."

That is deliberately open. It prescribes no form of assessment and creates no national validation threshold. What it does is give validation officers a national hook for requesting air quality information, sitting on the same list as the flood risk assessment requirement against F4 and the SuDS statement against F8. We expect it to be quoted in validation correspondence well beyond the cases where a full assessment is genuinely warranted.

What assessment do you actually need

The Framework does not tell you, and never has. Proportionality still comes from professional guidance, in practice the IAQM and EPUK document "Land-Use Planning & Development Control: Planning for Air Quality", and from the authority's own validation requirements. What the 2026 wording changes is the evidence that needs to be in the report when you make the call.

Screening and qualitative assessment

For most small and medium schemes outside an AQMA, with modest traffic generation and no significant emissions source, a screening assessment against background maps and local monitoring remains proportionate. It now has to address PM2.5 explicitly, identify the relevant Air Quality Action Plan, Clean Air Plan and Local Air Quality Strategy rather than just the AQMA, and deal with the sensitivity of intended occupiers. Our air quality assessment page sets out what a screening report covers, and the AQMA screening tool will tell you quickly whether a site falls inside a declared area.

Detailed dispersion modelling

Where the site is inside or close to an AQMA, where traffic generation is material, where combustion plant or an industrial source is involved, or where sensitive receptors are proposed on a corridor with concentrations near the objective, detailed modelling (ADMS or equivalent) is the answer. Both the P3(1) sensitivity wording and the pre-existing conditions wording push more schemes towards that end of the range, and that is our expectation for how casework will move over the next couple of years.

Construction dust

Construction phase effects fall within P3(2)(b) as impacts on or beyond the site. A construction dust risk assessment using the IAQM method, with mitigation secured by condition or through the construction environmental management plan, is the normal route. It is also the requirement most often missed on smaller applications, and the easiest to fix before validation.

Ventilation and exposure mitigation

Where exposure at the facade cannot be designed out, the mitigation is a ventilation strategy: intake locations away from the source, mechanical supply with appropriate filtration, and in some cases restricted opening. That is a design decision taken with the architect, not a document bolted on at discharge of conditions stage. Our ventilation strategy for planning page covers what a statement needs to contain. The policy anchor is P3(2)(a) and its requirement for suitable mitigation where necessary.

London

London continues to run ahead of national policy. The London Plan's Air Quality Neutral benchmarks, Air Quality Focus Areas and the ULEZ all still apply, and nothing in P3 relaxes them. Inside Greater London, Air Quality Neutral compliance is usually the harder test to pass, so check Focus Area status at the outset rather than at submission.

Getting ready

• Update your policy sections. Any report still citing December 2024 paragraph 199 needs rewriting to P3(1), P3(2)(a) to (c) and P3(3), with paragraph-level references.

• Add PM2.5 to your reporting as standard, in µg/m³, against the applicable objective and target, not as a footnote.

• Pull the relevant Air Quality Action Plan, Clean Air Plan and Local Air Quality Strategy for the authority before you write, and address their objectives specifically. Naming the AQMA alone no longer covers P3(2)(c).

• Identify the intended occupiers and users early. Where the scheme houses children, older people or other groups the policy calls particularly vulnerable, say so and let it drive the scope.

• Treat existing background concentrations as a policy matter, not context. P3(1) covers pre-existing conditions in the vicinity.

• Check whether P3(3) lets you rely on permit limits for a neighbouring regulated source, and record the check either way.

• Co-ordinate the air quality, noise, lighting and water inputs. They now answer to one policy and inconsistencies between them are visible.

• Fix the ventilation strategy at design stage where exposure mitigation is likely, so the drawings and the assessment agree.

Frequently asked questions

Does the NPPF 2026 require dispersion modelling?

No. The Framework specifies no method, and Annex C asks only for "Such information as required to demonstrate compliance with relevant aspects of Policy P3". The choice between screening and detailed modelling remains a professional judgement made against IAQM and EPUK guidance and the local validation list. What has changed is that P3(1) gives officers a clearer basis for asking for more.

Is PM2.5 assessment now compulsory?

P3(2)(c) names PM2.5 expressly, where December 2024 paragraph 199 named no pollutant at all. We read that as meaning any assessment relying on P3(2)(c) should address PM2.5 alongside NO2 and PM10 rather than referring to it in passing. How far it goes remains proportionate to the scheme.

My site is outside an AQMA. Do I still need an air quality assessment?

Possibly. P3(2)(c) asks you to take account of Air Quality Management Areas, but P3(1) is about the sensitivity of the site and its intended occupiers and the effects of pre-existing conditions in the vicinity, wherever the site happens to be. A nursery or care home on a busy road outside a declared area can still warrant assessment, and the local validation list may require one regardless.

What if the pollution comes from a permitted operation next door?

P3(3) lets you assume, absent clear evidence to the contrary, that the separate pollution control regime operates effectively, and to take account of emission limits set through it. That is a genuine saving in scope. Where monitoring or complaints suggest otherwise, the assumption can be displaced, and policy P4 addresses the effect your development has on the existing operator.

If you have a scheme where air quality is in play, whether that is a screening report to satisfy validation, ADMS modelling on an AQMA site, a construction dust assessment or an Air Quality Neutral case in London, we can tell you quickly what level of assessment the application needs and what it will cost. Send us the address, the proposal and the authority: get a quote.