While the new National Planning Policy Framework contains improvements in policy wording for the renewables industry, there are some key missed opportunities. Here Regen’s planning lead, Rebecca Windemer, sets out initial thoughts on the revised policy document.
Regen welcomes the publication of the new National Planning Policy Framework (NPPF), but we’re disappointed to see several missed opportunities that could have accelerated the deployment of renewable energy and storage projects.
Consideration of climate change
We are pleased to see the addition of paragraph 163, which states that “the need to mitigate and adapt to climate change should … be considered in preparing and assessing planning applications, taking into account the full range of potential climate change impacts”.
Paragraph 161 also states that: “The planning system should support the transition to net zero by 2050 and take full account of all climate impacts … and support renewable and low carbon energy and associated infrastructure.”
However, there is a significant missed opportunity to more explicitly prioritise action on climate change. In our consultation response we suggested that planning policies and all planning decisions must be in line with the objectives and provisions of the Climate Change Act 2008, including the 2050 net zero carbon target.
Significant weight for renewable energy projects
The new paragraph 168 states that, when determining planning applications for all forms of renewable and low-carbon energy developments and their associated infrastructure, local planning authorities (LPAs) should give significant weight to the benefits associated with renewable and low-carbon energy generation and the proposal’s contribution to a net zero future. While this is a step in the right direction, there was a missed opportunity to align this wording with the National Policy Statements, which require “substantial weight” to be applied to low-carbon infrastructure and which identify all forms of renewables as a Critical National Priority.
The document also passes up the opportunity to confirm that ‘renewable and low-carbon energy’ involves Battery Energy Storage System (BESS) projects.
Local authority renewable site allocations
Paragraph 165(b) has been reverted to its previous wording, wherein Local Plans should “consider identifying” rather than being required to identify suitable sites for renewable and low-carbon energy sources (and associated infrastructure). We see this as positive, enabling flexibility for LPAs, particularly given resourcing constraints. We are also pleased to see the introduction of the wording “and associated infrastructure”, although there may be a need for clarification on what this includes.
Renewables in the green belt
We are disappointed to see the absence of changed wording for developing renewables in the green belt, with the very special circumstances for allowing renewables in the green belt continuing to only include “the wider environmental benefits associated with increased production of energy from renewable sources”. But not including the “location and nature of any agreed point of connection to the electricity network” – which we suggested in our consultation response – could be a missed opportunity in the context of current grid constraints.
Repowering and life extension
We are very pleased to see that the inclusion of new policy wording (paragraph 168c) requiring LPAs to give significant weight to the benefits of utilising an established site when considering proposals for repowering and life-extension. We estimate that more than 150 UK onshore wind farms, totalling over 3 GW of capacity and more than 1,500 individual turbines, are expected to make repowering decisions by 2030. Getting repowering right is essential for ensuring that our overall onshore wind energy output does not decrease, and for maintaining the industry’s reputation when developing new sites, thus there will likely be a need for additional guidance for decision makers on key issues such as environmental and community improvements.
New thresholds for wind and solar NSIP
The new NPPF marks the re-introduction of onshore wind back into the Nationally Significant Infrastructure Project regime, with all projects above 100 MW being classed as such. The threshold for solar has also been moved to 100 MW. We welcome this change and are pleased to see the inclusion on a transitional window until the end of 2025, when the changes will formally come into effect.
The need to address resourcing
Policy change won’t have the desired impact unless we address local authority resourcing. The government has confirmed its commitment to hiring 300 new local authority planners, but this is not enough. LPAs do not have the resources required to meet the expected increase in renewable energy applications, particularly with the change in thresholds and the increased housing targets. We are therefore calling for the introduction of specialist renewable energy planners to work across local authorities.
In 2025 Regen will be developing our work on planning. To get involved you can sign up for the next Regen members’ working group on planning.