Reflection on the September 2024 National Planning Policy Framework Consultation

As a renewable energy developer, we at Queequeg Renewables welcome many of the proposed revisions to the National Planning Policy Framework (NPPF). The shift towards a more supportive policy stance—particularly the increased weight given to renewable energy schemes—is a major boost for the industry. It paves the way for more planning approvals of renewable and low-carbon energy projects. But why stop there? We believe there’s room to take these revisions even further by emphasising the urgency of achieving Net Zero targets and prioritising energy infrastructure, in line with the approach taken by the National Policy Statements (NPSs) for Energy.

The previous policy encouraged LPAs to ‘consider identifying’ suitable areas for renewable energy. The proposed change mandates that LPAs ‘identify’ these areas—a welcome shift. However, this process should also take into account commercial and viability factors, which are often driven by technical considerations.

Without clearer guidelines on the criteria for what constitutes a ‘suitable area’, including technical specifics, the benefit of having sites within such ‘suitable areas’ remains uncertain.

Further guidance on how these ‘suitable areas’ will be balanced within the broader planning framework is essential.

It would also benefit the framework’s efficiency if renewable energy developers were involved in defining these areas, ensuring that LPA identification considers wider technical matters.

The proposed increase in thresholds—from 50MW to 150MW for solar PV projects and 100MW for onshore wind—is generally a positive move. In theory, it should allow more applications to be processed at the Town and Country Planning Act 1990 (TCPA) level, reducing developer costs and bypassing the extended timelines of the DCO/NSIP regime.

However, a few concerns arise:

• LPA Resource Constraints: Our primary concern with that approach relates to resourcing within LPAs. A significant increase in the number of applications could lead to immediate backlogs, hampering progress. We believe that further funding and resources should be allocated to LPAs to manage this increased workload efficiently.
• Potential Delays in Determination: Given the complexity and scale of these applications, can LPAs handle them within a reasonable timeframe? Do they have the necessary expertise in-house? Local government planners with experience in onshore wind are few and far between, largely due to previous governmental policies. Greater investment in training and upskilling LPA teams will be critical to ensuring timely and accurate determinations.
• Clarification on Thresholds: The rationale behind the selected thresholds is unclear. If the aim is to encourage renewable energy development, why are the thresholds different across technologies? There is currently a ‘dead zone’ between 50MW and 100MW. Will this gap merely be scaled up due to viability concerns?
• Land Rights for Expanded TCPA Projects: Land acquisition presents a significant challenge under the existing TCPA route, where land holdings are often fragmented and compulsory acquisition powers are absent. A holistic approach, including land constraints, is needed to deliver projects of such magnitude (e.g. up to 149.9MW). Assembling land across multiple owners is notoriously complex, and addressing this early on is crucial.

Having recently secured planning permission for an energy storage scheme and with multiple applications currently under review, it is encouraging to see planning policy evolving in support of renewable energy. These revisions mark another step forward in improving energy affordability and advancing our shared Net Zero goals.