Energy UK response to consultation on proposed reforms to the National Planning Policy Framework and other changes to the planning system

Executive Summary

• Energy UK is very strongly supportive of onshore wind returning to the NSIP regime. 
• The NPPF must match up with spatial planning policies being proposed by Ofgem and later NESO, namely the Strategic Spatial Energy Plan (SSEP), the Centralised Strategic Network Plan (CSNP), and the Regional Energy Strategic Plan (RESP). Failure to link these risks creating policy clashes in future.  
• The consultation focuses heavily on generation, but part of the need to marry up spatial planning is that the NPPF does not have enough focus on networks. Network infrastructure needs to be a priority in the NPPF due to implications for generation, economically prioritised infrastructure, and development on green and grey belt land.   
• A focus on economically important infrastructure like Gigafactories is welcome. However, if the aim is to facilitate Net Zero aligned economic growth, why is it limited to the four proposed developments (Gigafactories, data centres, laboratories, and freight hubs) and not wider parts of the supply chain for key technologies? 
• Coupled to the above, if an aim of these reforms is to change the planning system to facilitate Net Zero growth industries, more projects should be in scope of the NSIP regime. But NSIP consenting timelines have already doubled to an average wait time of 4 years. Wider questions need to be answered on how the planning system can be adequately resourced. 
• Consideration of new housing plans must align with the Future Homes Standard, ensuring a high standard for energy efficiency, heat pumps, heat networks, and smart buildings as standard. The FHS is not mentioned in the NPPF consultation.  
• Some Permitted Development Rights changes for smaller scale energy projects could work to reduce barriers in the NPPF, such as for smaller solar projects. 
• Changing Megawatt thresholds for onshore wind and solar entry to the NSIP are an area of various member views. We understand a lower MW threshold for onshore wind may help the sector, given the decade long lack of capacity in the English supply chain. We believe there should be an increase in the solar threshold.