England has had a summer marked by heatwaves, drought and wildfire damage to homes and habitats. The National Planning Policy Framework published on 17 August 2026 responds with something national planning policy has never had before: a policy telling applicants to design against fire spreading in from the landscape.
It is a short paragraph. It is also, for a certain kind of site, the thing that changes your landscape strategy and your boundary treatment specification.
What CC3(1)(e) actually says
Policy CC3, “Adaptation to climate change”, is a national decision-making policy. It opens by requiring development proposals to take into account the current and potential impacts of climate change over the lifetime of the scheme, then lists what that means in practice — flood risk, coastal change, SuDS, overheating, and now this:
“Incorporate proportionate measures to mitigate against wildfires, where opportunities to do so exist and wildfires pose a particular risk (for example as a result of the combined effect of topography, prevailing wind direction and being located within or adjacent to heavily vegetated areas). Such measures should be designed to limit fuel loads for fires, and to create defendable spaces, such as by avoiding timber panel fences and incorporating firebreaks into development layouts and planting schemes.”
Three things are worth pulling out of that.
It is conditional, not universal. The duty bites “where opportunities to do so exist and wildfires pose a particular risk”. Most urban infill will not engage it. The trigger the policy gives is a combination — topography, prevailing wind direction, and being within or adjacent to heavily vegetated areas. Heathland, forestry, moorland edge, gorse-covered slopes, plantation boundaries.
It names a specific product. “Avoiding timber panel fences” is unusually prescriptive for the NPPF. Close-boarded timber fencing running from a vegetated boundary into a housing layout is a continuous fuel path, and the Framework says so in as many words. If your standard boundary detail on a rural-edge site is a 1.8m closeboard fence, that is now a policy conversation.
“Defendable space” is a design concept, not a buffer strip. The wording asks for measures “designed to limit fuel loads” and to create defendable spaces, including firebreaks in development layouts and planting schemes. That is a masterplanning and landscape input, not something you bolt on at reserved matters — which means it needs to be in the layout at outline stage.
And CC1 puts it into plan-making
The plan-making counterpart, CC1: Planning for climate change, requires development plans to take a proactive approach to adapting to climate change
“taking into account the implications of extreme weather and long-term climate trends including overheating, wildfires, drought, flood risk, coastal change, water supply, biodiversity and landscapes”
— and then to address “any specific risks from climate change in their proposed allocations for development, and necessary adaptations, both of which should be considered for the anticipated lifetime of the development”.
So wildfire is now something an emerging local plan is expected to have thought about when it allocates land. Expect it to start appearing in site-specific allocation policies and in the evidence base for rural and urban-fringe allocations over the next plan-making round.
Where this sits next to the rest of the climate chapter
Chapter 5 is compact — CC1 for plan-making, CC2 for mitigation, CC3 for adaptation — and CC3 now bundles four adaptation duties into one list: flooding, coastal change, sustainable drainage under policy F8, overheating under DP3(2)(b), and wildfire.
That grouping matters. It means a single planning officer, reading one policy, is now looking for evidence on all four. On a rural-edge site in a hot, dry catchment you could plausibly be asked at validation for a drainage strategy, an overheating assessment and a note on wildfire mitigation — three things that until this month sat in three different places, two of them in Building Regulations rather than planning.
There is also a tension worth naming. CC3(1)(d) asks for green infrastructure and tree planting to minimise overheating risk. CC3(1)(e) asks you to limit fuel loads. On most sites those pull in the same direction — shade trees near dwellings, managed grassland, irrigated planting. On a dry heathland edge they do not, and the policy gives no hierarchy. Someone will have to reconcile that in a design and access statement, and the sooner your landscape architect is in the room the cheaper that is.
What we’d suggest doing
Work out whether you’re actually in scope. The test is topography plus prevailing wind plus adjacency to heavy vegetation. If your red line abuts forestry, heath, moorland or unmanaged scrub on the upwind side of a slope, assume the question will be asked and get ahead of it. If you’re in a town centre, it won’t be.
Look at your boundary treatment standard detail now. Timber closeboard is named in national policy as the thing to avoid. Substituting masonry, metal railings or hedge-on-post on the vegetated boundary is cheap at design stage and expensive at condition-discharge stage.
Put firebreaks in the layout, not the landscape schedule. The policy talks about “development layouts and planting schemes” together. Layout is fixed at outline; planting is not. If the mitigation lives entirely in the soft landscaping, you have less room to move later.
Don’t let it undercut your overheating design. Part O has not changed — the 2021 edition is still the one in force while the promised full review runs its course — and CC3(1)(d) still expects overheating to be designed out. Wildfire mitigation should reshape where the planting goes and what species, not delete it.
If you’re already doing the overheating work
For most of our clients, the practical effect of chapter 5 is that climate adaptation evidence is now something planning asks for, months before Building Control does. Overheating is the one that costs money if you get it wrong late — a TM59 failure at Part O stage on a scheme already consented with a fixed glazing ratio is an expensive conversation.
If you have a site coming forward on a rural or urban-fringe edge and you’d like the overheating, drainage and adaptation evidence lined up before validation rather than after, get in touch and we’ll tell you what we’d want to see modelled first.
Sources: National Planning Policy Framework, August 2026 (PDF), GOV.UK — chapter 5, policies CC1 and CC3 · National Planning Policy Framework guidance page, MHCLG, 17 August 2026 · Revised National Planning Policy Framework published: what it means for ecology and environmental management, CIEEM, 20 August 2026