Regen has submitted a response to the government consultation on the National Policy Statements (NPS). The NPS set out national energy policy and provide the legal framework for planning decision making for Nationally Significant Infrastructure Projects. The NPS consists of the following five documents:
- Overarching National Policy Statement for Energy (EN-1)
- National Policy Statement for natural gas electricity generating infrastructure (EN-2)
- National Policy Statement for renewable energy infrastructure (EN-3)
- National Policy Statement for natural gas supply infrastructure and gas and oil pipelines (EN-4)
- National Policy Statement for electricity networks infrastructure (EN-5)
Our response to the consultation highlighted some of the key policy opportunities and issues that ultimately shape how renewable energy is developed. Here we set out some of the positive changes to the NPS, as well as what we think was missing from the consultation.
Offshore wind as a Critical National Priority
Perhaps the biggest change in this consultation was the classification of offshore wind (including associated onshore and offshore network infrastructure) as a Critical National Priority (CNP).
This means that there is effectively a presumption in favour of offshore wind which we hope will speed up the time taken to secure panning permission for new developments. The only exceptions are if the impacts present an unacceptable risk to human health, national defence, navigation or for the impacts of Habitats Regulation Assessment. However, under no circumstance should this classification ever be extended to support non-renewable forms of energy as it should solely be used to help increase the speed of the transition to renewables.
We also want to stress that the support for offshore wind shouldn’t end with just the new classification. This must just be one change in a suite of support for offshore wind, such as changes to CfD.
New guidance for electricity network infrastructure
The NPS provides new wording on strategic planning to support the need for new electricity network infrastructure. This addition recognises the importance of coordinated network infrastructure. We hope that this helps to reduce the long development timelines and enables the faster delivery of vital network capacity.
It also clarifies that overhead lines should be used outside nationally designated landscapes due to the lower cost compared to underground cables. Within nationally designated landscapes (National Parks and Areas of Outstanding Natural Beauty), the NPS highlights that electricity cables should be underground, unless the area can be avoided altogether. We agree with this approach as it provides greater clarification for both applicants and decision makers.
We are pleased to see the NPS recognising that land type should not be the key factor in determining the suitability of a site for solar and acknowledging that some agricultural land may need to be utilised. Research undertaken by Regen in 2022 showed that, at most, solar farms will need 0.5% of UK farmland by 2050, predominantly on low value, poor quality land.
Community engagement and onshore wind
We are disappointed not to see consideration for community engagement in the new NPS. Effective engagement is key to ensuring that new energy infrastructure secures public support. Without effective engagement, there is a risk that projects do not consider specific local issues and concerns, causing backlash from the community.
We also want to recognise the importance of onshore wind, as well as offshore. While we did not expect to see onshore wind in this consultation, we must emphasise that the policy in England needs to change. Since 2015 it has been almost impossible to get planning permission for new onshore wind farms in England due to the policy wording contained in the National Planning Policy Framework (NPPF).
Earlier this year, the government consulted on changing the NPPF policy on onshore wind. However, the proposed changes did not go far enough as it still included a requirement of demonstrating that a wind farm proposal has community support. While local engagement and support is important for a project, this planning requirement is very difficult to achieve or measure. The NPPF also kept a requirement for local authorities to allocate suitable areas for onshore wind.
While we are hoping that the government will change the NPPF, one alternative way of bringing back onshore wind is through making it Nationally Significant Infrastructure. This idea was recently suggested by the National Infrastructure Commission.
Overall, we are pleased to see the much-needed updates to the NPS, particularly the new classification of offshore wind as a Critical National Priority. These policy statements are key to ensuring that renewable energy development can proceed without delay. Given the pace of change in the sector we are also pleased to see the commitment to reviewing these documents at least every five years.
We are now calling on the government to take the NPS one step further in the final versions and write in provisions for community engagement. This revision will help enable a just transition by ensuring that communities are fully engaged and involved in energy decision making – ultimately helping to accelerate the development of renewable energy and meet our net zero goals.
Read our full response to the NPS consultation below: