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As the SSEP approaches a major milestone – with one of six pathways set to be chosen by the Secretary of State this summer – Regen's just transition lead, Grace Millman, explores how strategic coordination can enable more equitable outcomes and calls on NESO to ensure the SSEP follows core guiding principles on justice and transparency.
The Strategic Spatial Energy Plan (SSEP) is one of NESO’s suite of strategic plans, which aim to ensure the transition to low-carbon energy is both efficient and aligned with national goals for net zero. The first SSEP will be a GB-wide plan, mapping potential zonal locations, quantities and types of electricity and hydrogen generation and storage. It's intended to accelerate and optimise the transition to clean, affordable and secure energy across GB.
The SSEP is currently in development, with one of six potential pathways to be chosen this summer by the Secretary of State. By determining where key infrastructure is needed, the plan will shape investment flows and economic opportunities for decades. The SSEP is, therefore, an important opportunity to support a just transition.
While the development of new infrastructure is designed to benefit society, there will also be impacts that need to be carefully considered, fairly distributed and reasonably mitigated.
Lessons from past transitions show that benefits rarely align neatly with burdens, with marginalised and disadvantaged communities consistently bearing the brunt of the disruption – take, for example, the closure of numerous coal mines in the 1980s. To avoid exacerbating these patterns of inequality, the SSEP should consider the wider aims of society for its energy system – not only the carbon intensity and costs, but also energy security and resilience, alleviating fuel poverty, delivering jobs and local investment, and protecting the environment and heritage of our communities.
In addition to better democratising energy planning through the use of strategic governance and coordination, NESO can support a just and equitable transition via the SSEP function in three main ways:
NESO has been very clear in its methodology that community views are at the heart of the SSEP, stating that it intends to listen to the views of the public and interested parties as the plan is developed. It is essential that the SSEP comprehensively reflects the needs, values and ambitions of society in relation to the energy transition. To do this, NESO needs to engage with a more diverse array of stakeholders, including citizens and underrepresented groups, in an inclusive and meaningful way.
NESO has established a number of working groups to guide the development of the SSEP, including a societal working group made up of representatives from 14 ‘interest groups’. These include farming and land use, cost of living, housing, people with disabilities, and charities and third sector. NESO has also held a number of workshops with developers and published data transparency updates on its progress to date.
While these are positive steps, the current approach to engagement is insufficient if there are genuine concerns with the modelling outcomes. Energy UK, in its response to the SSEP methodology consultation, expressed concern that engagement was consultative, rather than co-decisive, given that the first consultation comes after the Secretary of State has selected a single pathway.
The development, selection and presentation of the earlier pathway options is arguably the key decision to be made by the NESO, and it is essential that this is guided by the principles of fairness and justice. Each pathway is likely to represent a balance of trade-offs between cost optimisation, competing demands on land and sea, local impacts and opportunities, and public support. To make the decision on a single pathway in a fair and just way, participation needs to be influential in the process to identify genuine concerns and discuss these underlying trade-offs. This is particularly important to avoid path dependency – where once a plan is identified, development pressure follows, and local democratic processes are eroded.
We urge NESO to use its established working groups to review and provide feedback on the six pathways being explored, ahead of the Secretary of State’s decision. Beyond this, NESO should ensure that the consultation process is meaningful, with genuine opportunities to shape the final pathway design and clear feedback on the outcomes of the consultation.
NESO has stated that the GB-wide spatial energy plan will consider public views, environmental considerations, known constraints and cross-sectoral demands on land and sea. Societal views, in particular, will be “used to develop analysis and metrics that will inform NESO’s spatial evaluation, including potential opportunities for infrastructure development in areas with high levels of societal support”.
While it is positive to see social and environmental factors being recognised in the SSEP methodology, these are typically qualitative considerations that are not easily captured and are hard to quantify. A core concern, therefore, is that cost and technical feasibility dominate the SSEP, optimising for system-wide cost and efficiency and risking uneven local impacts. Cost optimisation at a national scale can concentrate infrastructure in certain regions and impose local environmental and social burdens without proportional local benefit.
Greater transparency as to how environmental and societal considerations are weighted against costs, and how non-economic value (e.g. cultural landscapes, community identity, biodiversity and heritage) is adequately captured would be welcome. While some information is available online in the SSEP Spatial Evaluation Framework, it is not clear how each factor is weighted in the assessment.
In addition, the factors considered, including heritage sites, green spaces, protected landscapes, and land-based employment, are all presented as constraints within the framework, and factors that could benefit from the development of energy infrastructure are not included. For example, land-based employment is only included as a constraint within the framework when, in reality, renewables can offer income diversification for farmers and protection from volatile international markets. This was echoed in the UK government’s Land Use Framework, which states that “coordinated spatial planning of electricity networks will encourage investment in rural areas”.
While energy infrastructure investment tends to concentrate jobs during the construction phases, it does not typically provide long-term industries around the development site. This unequal distribution of costs and benefits is particularly important when considering resource-rich areas (such as Scotland for onshore wind), where energy is produced to be used in other areas of the country.
NESO should conduct a distributional analysis of the six pathway options to understand which communities are hosting infrastructure and how this relates to broader social, economic and cultural landscapes. Regen produced similar distributional analysis of SSEN’s Distribution Future Energy Scenarios, highlighting where networks may be unwittingly planning upgrades unfairly (i.e. only in more affluent areas to support new heat pumps). This analysis should be presented to an expert working group for feedback, and should form part of the presentation to the Secretary of State.
Beyond exploring these distributions and working to equalise the role of communities in delivering net zero, NESO should set out expectations for community benefit, appeal or revision (in collaboration with stakeholders) and redistributive investment, and work with DESNZ on the mechanisms to implement these. Regen has made recommendations on community benefits from transmission network infrastructure and published best-practice guidance for community engagement.
There are several important investment decisions that could be sensibly centrally planned as a direct outcome of the SSEP assessment. However, achieving net zero requires thousands of smaller-scale investments and operational decisions made at the local level. This is where Regional Energy Strategic Plans (RESPs) come in. As a bottom-up vision of energy, developed adhering to just transition principles and incorporating localised democratic input, it is essential that the RESPs are not overruled or disregarded because of the choice of the SSEP pathway.
While the SSEP was never intended to identify or recommend specific projects to be delivered, it determines where investment in the transmission network is focused. As we have seen with the recent connections reform process, capacity headroom on the transmission network can have a significant impact on the feasibility of distribution-connected projects. Hence, if the investment signals sent by the SSEP are unaligned with the ambitions of local places reflected in the RESPs, many local places may face significant delays in securing grid connections, or worse, see projects abandoned altogether.
It is clear that strategic plans will form an integral part of this next phase of the net zero transition. As NESO prepares the six pathways for Secretary of State review, work must be conducted to consider the wider aims of society and avoid the SSEP exacerbating existing patterns of inequality. It should do this by engaging early, widely and meaningfully, and working to fairly distribute the costs and benefits of new network infrastructure.
It should also ensure it recognises and upholds the democratic processes that have gone into the development of the RESP, to ensure that the ambitions of local places and communities are enabled through the SSEP.
Regen continues to engage closely on the development of the SSEP and RESP. Members can join our special SSEP planning working group on 16 June, at which NESO will give a 40-minute overview of the current pathways, including emerging thinking, key assumptions and next steps in the process. The session will then open for questions and discussion, giving members the opportunity to explore the implications for renewable energy and storage development and future network coordination.
If you are not a member but are interested in finding out more about membership, you can find more information here or contact Hannah Stanley to discuss. To find out more about our work on planning, please click here or reach out to Rebecca Windemer.
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