13/05/26
1. Why now?The Planning and Infrastructure Act 2025 (Act), NPPF 2.0 and Greater Manchester’s Places for Everyone Joint Development Plan (PfE) and a renewed national commitment to strategic planning have created a coherent legal and policy framework for transport-led placemaking that is not aspirational but deliverable.
The NPPF makes the relationship between transport accessibility and development density an explicit policy expectation. Schemes that under-deliver on density around a transport node are now vulnerable to challenge at application stage and on appeal. Those promoting higher-density, mixed-use development in transport-accessible locations have a stronger policy hook than at any previous point in the Framework’s history.
The NPPF 2.0, expected to be adopted Summer 2026, goes further if adopted with the key transport planning polices retained. Proposed policy TR1 introduces a vision-led approach to transport planning which is a departure from the predecessor model of ‘predict and provide’ that has dominated highway assessment. Rather than measuring capacity impact and working backwards, the vision-led approach asks first what kind of place is intended and what transport system would serve it. This matters profoundly for transport-led placemaking: it removes the principal objection tool that has stalled high-density, low-parking schemes at transport nodes, and replaces it with a policy framework that actively supports them.
The draft also proposes a presumption in favour of development for housing and mixed-use sites within reasonable walking distance of a railway station, including for development outside of settlement boundaries. If adopted in its consulted form, this would constitute one of the most significant shifts in development location policy since the original NPPF — and would directly expand the land supply available to transport-led regeneration schemes across the Northern city regions.
The grey belt concept introduced in the 2024 iteration of the NPPF — land previously developed, or contributing little to Green Belt purposes, that is now in principle releasable where sustainably located — substantially expands the available land supply adjacent to transport nodes in the urban fringe. Much of that land is former industrial, depot and infrastructure land that happens to be transport-adjacent. Promoters and local authorities should be systematically mapping grey belt land against transport investment pipelines as a matter of urgency. The interaction between grey belt, the station accessibility presumption in NPPF 2.0 and the SDS infrastructure-allocation framework creates a powerful tool for transport-led regeneration that was not available to developers twelve months ago.
PfE is the most significant piece of strategic planning to have been adopted anywhere in England outside of London in a generation, and its relevance goes beyond its geographic scope. It is a proof of concept — a demonstration that sub-regional strategic planning, properly done, can integrate transport investment and development allocation in a way that the local plan system alone cannot achieve.
PfE’s strategic growth allocations at Elton Reservoir, Hazelhurst, Mosley Common and elsewhere are explicitly transport-led, are intrinsically linked to Metrolink extensions and highway improvements. For practitioners advising clients in the Greater Manchester market, PfE creates a number of material advantages: an Inspector-tested policy presumption more resilient to challenge than individual local plan allocations; an infrastructure schedule against which Section 106 obligations can be calibrated to reduce viability disputes; and, critically for CPO, the strategic justification for compulsory acquisition where that is required. PfE is also the template for the national SDS programme and demonstrates that sub-regional strategic planning can do what local plans cannot: align transport investment, development allocation and land assembly within a single coherent framework. It is to Greater Manchester’s benefit that the government wants every city region to follow suit and have one in place by 2029.
Part 5 of the Planning and Infrastructure Act 2025 received Royal Assent on 18 December 2025 and a number of its CPO process reforms came into force on 18 February 2026. Notices can now be served electronically, newspaper notice requirements are simplified, decisions on unopposed orders can be delegated to the acquiring authority, and the land vesting process is accelerated.
Alongside these provisions ,which arguably bring CPO into the 21st Century, sits the ‘Hope Value Direction’ (HVD) power, which has its origins in the Levelling-up and Regeneration Act 2023 and enables the Secretary of State to direct that hope value, the element of market value attributable to the prospect of obtaining planning permission for more valuable development, be excluded from compensation in CPOs made to facilitate certain types of development scheme, with the effect potentially being a break in the intrinsic link between a landowner’s compensation entitlement and the value of an allocation created by the very planning framework the CPO is designed to implement.
One significant gap remains: the temporary possession powers in section 112, long awaited by CPO practitioners, are still not in force except for Highways Act schemes. Commencement regulations are expected but not yet laid. The home loss payment exclusion for negligent owners, removing the payment where neglect of a property has prompted the CPO, is also now in force, and has direct relevance for town centre regeneration schemes involving long-term dereliction.
The HVD itself is as yet untested. The first cases will be closely watched. We are advising clients to build robust evidence bases from the outset of any scheme that might benefit from an HVD, and to ensure that option agreements and conditional contracts entered into now properly address HVD risk.
The statutory framework for SDSs has been built in stages. The Levelling-up and Regeneration Act 2023 (LURA) first introduced the SDS concept for combined authorities and groups of LPAs outside London, and provides that adopted SDSs will form part of the development plan. Section 58 of the Planning and Infrastructure Act 2025 then introduced the duty on strategic planning authorities — combined authorities, combined county authorities, upper-tier county councils and unitary authorities — to prepare SDSs, and gives the Secretary of State power to make the necessary regulations. The English Devolution and Community Empowerment Bill will complete the picture by confirming the strategic authority structures that will ultimately hold the SDS duty. Adopted SDSs will shortly form part of the development plan and local plans must be in general conformity with them — a fundamental shift from the current position in which combined authority strategies operate only as material considerations. The government published its consultation on SDS geographies in February 2026, confirming that where mayoral devolution exists or is confirmed from April 2026, those are the preferred SDS footprints. Formal commencement of the SDS duty is expected summer 2026. Preparatory work can and should proceed now.
For transport-led placemaking, the SDS is potentially the most powerful tool the Act creates: aligning transport investment programming with development land allocation across a city region, fixing infrastructure contribution levels and, where CPO powers are available to the combined authority, providing strategic justification for acquisition at scale. The SDS consultation expressly confirms that SDSs will identify the infrastructure needed to support growth and can redistribute housing need between authorities, surely the clearest statement of intent that infrastructure and development allocation are to be treated as a single integrated exercise.
The Act also lifts existing restrictions on development corporations providing certain types of enabling infrastructure, and introduces a new duty on transport authorities to cooperate with development corporations. This has significant implications for urban extension and new community schemes where the development corporation model is the chosen delivery vehicle. The Act’s amendments to the Highways Act 1980 and the Transport and Works Act 1992 similarly streamline the consenting process for transport schemes in ways directly relevant to the enabling infrastructure schemes that underpin transport-led regeneration.
The government’s launch of Platform4 in July 2025 is perhaps the clearest signal yet of its commitment to transport-led regeneration as a delivery model. Formed from the merger of London and Continental Railways Limited and Network Rail’s property development team, Platform4 is a government-owned property company tasked with delivering up to 40,000 new homes over the next decade by transforming surplus railway land into thriving communities, attracting over £350 million in private investment and generating £1 billion of new development.
Manchester Mayfield is one of four initial sites already earmarked, with capacity for up to 1,500 new homes. The model, which establishes public sector land assembly and infrastructure investment with private sector development delivery whilst profits reinvested into the railway, is the transport-led placemaking opportunity in its purest institutional form. For Northern city region practitioners, Platform4 represents a new public sector body and opportunity alongside a potential template for structuring complex schemes involving brownfield land adjacent to a transport hub where land assembly, infrastructure delivery and development viability need to be integrated from the outset. TfGM and the Weaver Network should be taking note if they are not already.
Transport-led placemaking almost always requires land assembly, and land assembly in fragmented urban areas almost always requires compulsory purchase. CPO is sometimes characterised as a tool of last resort, which it absolutely must be given it involves the draconian taking of land from its owner by force. That said, used well and deployed early in a scheme’s development, CPO can be a delivery mechanism par excellence that de-risks land assembly, encourages negotiated acquisition and signals to the market that a scheme will be delivered. The legal framework, strengthened by Part 5 of the Act and by the policy support in the current and draft NPPF, is more supportive of that role than at any point in the past twenty years.
The key to successful CPO promotion in transport-led schemes is the quality of the justification. The acquiring authority must demonstrate that the acquisition is necessary and proportionate, that there is a compelling case in the public interest and that the scheme is viable, deliverable and consistent with the development plan. In transport-led schemes, each of those elements is strengthened by the existence of a strategic plan that identifies the site for development and the transport investment that serves it, whether that be via PfE, a live local plan allocation or an emerging SDS.
The Greater Manchester Combined Authority has demonstrated what Mayoral leadership can achieve. Andy Burnham’s programme of six growth areas targeting £10 billion of investment and 75,000 new homes is explicitly transport-led. PfE provides the statutory land allocation framework. GMCA’s CPO powers provide the land assembly mechanism. Transport for Greater Manchester is actively exploring the use of CPO powers to deliver enabling infrastructure on strategic and stalled schemes. Manchester Mayfield is the most visible current example of that practice. What is needed across the pipeline of Greater Manchester schemes is the confidence and experience in public sector bodies to thread those instruments together into deliverable projects.
The Liverpool City Region presents one of the most interesting transport-led regeneration opportunities in the country. A £1.6 billion investment package confirmed ahead of the 2025 Spending Review funds major rail upgrades, a new Rapid Transit network linking Liverpool city centre, John Lennon Airport and North Liverpool, and infrastructure to unlock city-scale regeneration projects in North Liverpool and South Sefton linked into the new Everton stadium. In Birkenhead, the Hind Street corridor investment is designed to unlock Wirral Waters and the Left Bank, a scheme with capacity for over 1,500 homes on brownfield land.
From April 2026, the LCRCA moves to an Integrated Settlement, providing Steve Rotheram with increased flexibility and longer-term certainty over investment decisions. Bus franchising begins in St Helens and Wirral from September 2026, as part of a shift towards a London-style integrated transport system. Crucially, the LCRCA is actively preparing its SDS, with public consultation expected in summer 2026, formal examination in early 2027 and adoption anticipated by the end of 2027. The window for influencing that SDS through evidence submissions and direct engagement is open now. Formal commencement of the SDS duty is expected from summer 2026, and the LCRCA has confirmed it is already undertaking preparatory evidence-base work.
West Yorkshire’s Spatial Development Strategy is in preparation, with the Combined Authority’s mass transit investment programme providing the structural spine around which land allocation decisions will be made. Three Yorkshire Mayors recently united under the White Rose Agreement to coordinate strategic planning across South, West and North Yorkshire, a direct example of the sub-regional cooperation that the SDS framework is designed to institutionalise. Similar dynamics are visible in the North East, where emerging combined authority governance creates new capacity for strategic planning alongside significant transport investment ambitions.
For developers, local authorities, combined authorities and investors active in Northern city regions, we consider the following to be key priorities:
Town Legal is a specialist planning law firm with deep expertise across the full range of instruments that transport-led placemaking requires. Our Northern team is based in Manchester and acts for clients engaged in transport-led regeneration across the Northern city regions — from combined authority CPO promotions and highway enabling schemes, to large-scale strategic allocations in Places for Everyone, to the emerging LCR SDS pipeline. We are not observing these changes from the outside; we are advising clients through them in real time.
The convergence of the current NPPF, the emerging draft NPPF, Places for Everyone, the Planning and Infrastructure Act 2025 and the devolution settlement represents the most significant shift in the planning and delivery landscape for Northern city regions in twenty years. The framework has arrived. The question for every developer, local authority and investor in this space is whether their legal team is equipped to use it.
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