Resilient neighbourhoods, powered by low-carbon energy

Executive Summary

Decarbonising the UK power sector is central to the country achieving net zero greenhouse gas emissions. To do this, there needs to be a substantial increase in investment in and development of three main renewable energy technologies: solar, onshore wind and offshore wind.

This report examines the role of the planning system in hampering as well as facilitating these renewable energy technologies. In recent years, planning policy concerning renewable energy infrastructure in England has been beset by a stop-and-go dynamic, where development booms get followed by periods of bust because of sudden shifts in public policy, undermining investor confidence.

There has not only been significant inconsistency in planning policy for each of the main three renewable technologies, but also across them. With two key technologies, namely solar power and offshore wind, planning is often framed as a barrier to new infrastructure, which requires streamlining to accelerate project consenting, without considerations of whether this facilitates the best possible route to net zero. But in the context of onshore wind, planning has been deliberately used to construct a ’triple veto’ test for projects that is all but unassailable. This inconsistent reasoning can obscure the need to learn and develop policies that achieve an effective and durable balance between delivery, public engagement and environmental sustainability regardless of the technology involved.

This report identifies the following four principles to put planning policy on a durable footing and, by doing so, contribute to the sustained growth on renewable energy generation capacity that net zero requires.

The UK needs to pursue the best net zero energy transition, not simply the quickest.
Planning processes need to strike an effective compromise between development delivery, community engagement and protecting the environment.
The role of planning in energy decarbonisation varies depending on the decarbonisation pathways pursued, including the technologies prioritised and the balance between technical and behavioural solutions.
The role of planning should not be viewed in isolation, but as interconnected with other public policy instruments.

The recommendations of this report are grouped into four categories: increasing the development of onshore wind, increasing the development of solar power, increasing the development of offshore wind, and cross-cutting recommendations for increasing the development of all three of those key renewable energy technologies.

Increasing onshore wind

Recommendation one: Abolish the ‘triple veto’ planning policy for onshore wind from the National Planning Policy Framework (NPPF).

Recommendation two: Adjust the NPPF to positively encourage Local Planning Authorities (LPAs) to plan for onshore wind.

Recommendation three: Amend the NPPF to adopt a presumption in favour of onshore wind development within all industrial and commercial sites, as well as promote the development onshore wind at all sites with sufficient grid capacity for large-scale low-carbon energy development.

Recommendation four: Create an Onshore Wind Acceleration Taskforce.

Increasing solar power

Recommendation five: Use the Solar Taskforce to collate evidence on planning outcomes from Local Planning Authorities (LPAs) that already issue non-statutory guidance on acceptable greenfield locations for solar PV.

Increasing offshore wind

Recommendation six: Use the Marine Management Organisation to draw up marine spatial plans for English offshore waters that demarcate more closely those areas likely to be the most acceptable for offshore wind, gas and oil development and those which are more sensitive and should be avoided.

Cross-cutting recommendations

Recommendation seven: Enable LPAs that seek to encourage more renewable energy development through proactive spatial zoning to access a pot of central government resources.

Recommendation eight: Deliver a precise Land Use Framework for England to provide a useful knowledge base for LPAs.

Recommendation nine: Institute a minimum level of community benefits at £5,000 per MW per year by making it a requirement of Contract for Difference (CfD) applications for renewable energy developments.

Chapter One: Introduction

Decarbonising the power sector is pivotal to addressing the climate crisis. The power sector – by which we mean the sector responsible for the generation and provision of electricity[2] – is a major source of UK greenhouse gas (GHG) emissions in its own right, responsible for 20% of all UK emissions as of 2021.[3] However, achieving net zero emissions for the heating and transport sectors will also mean replacing the fossil fuels on which those sectors currently depend with electricity instead, significantly increasing power demand. As a consequence, decarbonising the power sector must proceed in tandem with expansion in generation capacity, and so, in the size of the power sector itself.

Our future energy systems must not only be decarbonised, but also secure and affordable. The decarbonisation scenarios envisaged by the Climate Change Committee (CCC) all make considerable use of renewable energy technologies, especially solar and wind power, both onshore and offshore.[4] These energy sources are intermittent; they produce a varying supply of power due to external, uncontrollable factors, such as wind speed and sunlight intensity. The expansion of these intermittent renewable energy sources thus needs to be coordinated with investment in energy storage, demand flexibility and interconnectors to power supply systems in other nations, which enable troughs in supply from renewables to be met and surpluses to be fully exploited.

That said, the UK’s power sector has already decarbonised significantly: carbon emissions from UK power stations in 2021 were 73.4% below 1990 levels.[5] Nonetheless, there is scope for the power sector to decarbonise further and faster. Consequently, in 2021, the UK Government made a commitment to fully decarbonise the power system by 2035, and to get 95% of the way there by 2030.[6]

It is almost universally acknowledged that decarbonising the power sector requires very significant and rapid investment in new energy infrastructure. The last 30 years in the UK have seen more than 50GW of renewable energy generation capacity installed across Britain, but scenarios through to 2050 envisage the need for generation capacity to still increase fivefold or more.[7]

Energy and planning

With the clock ticking, and major investment required before the 2030s, policymakers are thinking about the problems facing the delivery of new renewable infrastructure. Such thinking frequently alights on planning. Indeed, the UK’s energy decarbonisation journey has been peppered with concerns that planning is a “key barrier for investments in renewable energy and energy networks”[8] and a source of “delays”[9] that risk “undermining net zero”.[10]

While creating a net zero energy system certainly creates challenges for the planning system, it is important not to reduce complex issues to planning policy failure. Policy frameworks for renewable energy in the UK, and particularly in England, have been beset by a stop-and-go dynamic, where development booms get followed by periods of bust as a result of sudden and drastic shifts in public policy, undermining investor confidence. Shifts in planning policy have often become causal factors in boom and bust, when, in fact, planning ought to be central to smoothing out boom-and-bust cycles in the power sector, creating a consistent, predictable framework for renewable energy investment.

This report examines the role of the planning system in hampering as well as facilitating a low-carbon energy system and outlines how, with the use of planning policy, we can make greater progress on realising a net zero energy system.

By ‘the planning system,’ we mean the town and country planning regime, as framed by the 1990 Town and Country Planning Act, plus the planning policy and consenting regimes for major infrastructure that build on the 2008 Planning Act. The marine planning regime falls within the scope of this report, too.[11] The report focuses on the planning powers available to the Westminster government, which apply principally to England.[12] Nevertheless, because devolution in the UK has given very significant power over the planning system to the devolved nations, this has enabled different approaches to emerge. Lessons from Scotland and Wales will be drawn upon where relevant.

The report will focus principally on the relationship between planning and the three main renewable energy technologies: solar power, onshore wind and offshore wind. It takes this focus because these low-carbon technologies are forecast to provide the majority of power in a future net zero energy system.[13]

By solar power, we principally mean the conversion of sunlight into electricity through solar photovoltaic panels (solar PV). This technology can be used in small-scale schemes, where single panels or small clusters are deployed, typically attached to buildings, often referred to as ‘rooftop’ schemes, with capacities measured in kilowatts (kW). Solar power can also be organised into much larger schemes, using ground-mounted panels, often referred to as ‘field-scale’ or ‘commercial’ schemes, with capacities that can, in the largest cases, deliver hundreds of megawatts (MW) of capacity. In total, solar power delivered 4.1% of the UK’s electricity in 2022,[14] with major new schemes providing electricity at £47.00 per Megawatt hour (MWh).[15]

Onshore wind harnesses the power of the wind by using wind turbines located on land, with the collection of multiple turbines into a single development referred to as a ‘wind farm.’ In total, onshore wind provided 10.8% of the UK’s electricity in 2022, with recently approved projects offering to supply electricity at £52.29/MWh.[16]

Offshore wind power is the provision of energy from turbines located in the UK’s coastal and marine waters. The turbines deployed in offshore wind farms have increased greatly in scale, from 2MW average installed capacity per turbine in the early projects, to 9MW as of 2023, with further scale increases anticipated. The dominant technology to date involves mounting turbines in foundations built on the sea floor, but investment is increasing in ‘floating offshore wind,’ where turbines are mounted on platforms that are moored to the sea floor, allowing projects to be built in deeper water. In 2022, offshore wind provided 13.8% of the UK’s electricity, with new schemes offering to supply electricity at £37.35/MWh. [17]

Most scenarios for a net zero power system produced by key bodies – the National Grid Company (NGC ESO), central government and the CCC – assume that electricity generation capacity needs to increase: to meet growing power demand, to enable the electrification of transport and heating, and to accommodate the intermittency of renewable energy supplies. In addition to this, renewable energy technologies also tend to have lower load factors – deficiencies in solar radiation or wind speeds that mean they deliver less power per year than their theoretical maximum – than fossil or nuclear power. This means that more generation capacity from the three main renewable energy technologies must be installed to deliver a given energy output.

For these reasons, scenarios from the NGC ESO suggest total power generation capacity requirements by 2050 – when we have a legal obligation to meet net zero emissions across the UK economy – of between 281 and 298GW. As for the potential contribution of the three main renewable energy technologies to this capacity, this is discussed in Box 1.1. below.

Box 1.1. Forecast requirements for installed capacity of the three main renewable energy technologies until 2050.

Solar power: NGC ESO scenarios for net zero suggest requirements of between 58 and 92GW of solar by 2050, as do Department for Business, Energy & Industrial Strategy (BEIS) and CCC scenarios.[18] Scenarios produced for 100% Renewable UK Ltd, on the other hand, which model 100% renewable energy systems, project a need for 300GW of solar by 2050.[19]

Onshore wind: NGC ESO scenarios suggest requirements of between 34 and 48GW; BEIS suggests between 24 and 50GW; and the CCC only between 25 and 30GW. The NGC ESO scenarios suggest that the vast majority of new onshore wind capacity – between 68% and 79% – will come from Wales and Scotland, with England a smaller player.

Offshore wind: NGC ESO scenarios suggest requirements of between 89 and 110GW by 2050; BEIS suggests between 73 and 100GW; and the CCC between 65 and 40GW. The NGC ESO scenarios suggest that approximately 50% of the new offshore wind capacity will be in Welsh and Scottish waters and approximately 50% in English waters.

The scenarios outlined above bear multiple implications for planning policy. First, different renewable energy technologies are in different positions when we consider the growth of new generation capacity required against present development rates. Most scenarios suggest that solar power may and offshore wind need to increase capacity more than sevenfold from their present position, but current annual development rates are increasing and, for offshore wind, our 2050 requirements are not far above present development pipelines, granted that one should expect attrition as projects fall by the wayside. With onshore wind, conversely, the requirements for capacity increases look more modest, but current development rates in England are negligible, and so need significant improvement. Thus, the requirements for planning policy change differ between technologies.

Second, scenarios should not be treated as inevitable outcomes or concrete requirements. They vary, and the assumptions behind them reveal trade-offs and different choices. The biggest of those is regarding demand reduction and flexibility. Behavioural change by the public and businesses can affect the scale of future energy demand and thus the scale and costs of the infrastructure required to supply it. For example, the extent to which the public pursue walking, cycling and public transport is a major differentiator between BEIS’ ‘high-demand’ and ‘low-demand’ scenarios. There are also trade-offs between renewable energy technologies. For example, onshore wind has a higher load factor than solar power, requiring less capacity to be installed to achieve a given output, but has a higher landscape impact.[20]

We also face choices in how the future power system should be organised; notably, the balance to be struck between maximising large-scale power projects such as offshore wind, or prioritising smaller-scale, decentralised generation, woven into our urban fabric. The planning system is deeply implicated in these trade-offs and choices.

Third, one of the most important trade-offs is between energy generation and other land use; a trade-off in which the planning system plays a significant role. Most future scenarios tend to deal only in cursory terms with land use and planning challenges,[21] making the tacit assumption that enough space for projected generation requirements can be found. One problem of this spatial myopia in future scenarios is that, where difficulties arise in securing the desired generation capacity, the problem is either blamed on uncooperative citizens acting as ‘NIMBYs’ or on the planning system. Instead, focus should be given to the intense challenges entailed in finding sufficient, socially-acceptable sites and the spatial insensitivity of current forecasts and policy. This challenge is only likely to increase as the sites that are easiest to access for development are used up.

This land dimension also informs this report’s decision to focus on the three main renewable energy technologies – solar, onshore wind and offshore wind – because they make extensive use of space and land and can put pressure on the physical environment. Indeed, prices for electricity from these three renewable technologies have fallen rapidly: by 59% between 2010 and 2022 for offshore wind, by 69% over the same time interval for onshore wind and by 89% for solar power.[22] This means that cost is diminishing as a barrier to development, whilst land use and siting – and therefore planning policy – are becoming the more pressing problems. As such, it is the expansion of these three renewable technologies that will put the greatest pressure on the planning system.

Box 1.2. Other low-carbon energy sources.

This report takes no view on the merits of nuclear power overall and does not offer any planning policy recommendations for this technology. It takes this stance because there is little evidence to suggest that securing planning consents for new nuclear power stations has proven to be the major impediment to expansion, with most projects targeting existing nuclear sites.[23] The development of further nuclear capacity is rather constrained by limited financing; a reflection of the very high risk of construction overruns and doubts about the likely price competitiveness of any electricity that new nuclear power such sources might produce.
Our future energy system may also make use of hydrogen and Carbon Capture and Storage (CCS). These choices raise a host of technical, economic and environmental risks, but it is as yet unclear whether planning be the most challenging element affecting their development. The strong propensity for such facilities to cluster within existing industrial complexes or former fossil fuel power station sites, where planning consent already exists or is easy to acquire, suggests that it might not be.[24]

The focus of this report

This report examines the impact of, changes to and ideas for planning policy for the three main renewable energy technologies.

The key research questions are:

What are the most economically and environmentally beneficial forms of low-carbon energy infrastructure for the UK?
What are the main barriers to decarbonising our energy production?
How effective is existing planning policy in enabling new low-carbon energy infrastructure?
How can we overcome the barriers related to the expansion of low-carbon energy infrastructure?

The report is structured as follows:

Chapter Two summarises existing planning policies for the three main renewable energy technologies and their effects on development delivery;
Chapter Three examines and evaluates ongoing and prospective revisions to planning policy for the three main renewable energy technologies;
Chapter Four offers new policy recommendations to reform the planning system to support an increase in suitable development of the three main renewable energy technologies.

Chapter Two: The nature and effects of planning policy on the development of the main renewable energy technologies

This chapter begins by outlining the main planning policy measures that UK Governments have applied to facilitate renewable energy infrastructure and then summarises post-2010 changes to planning policy for three main renewable energy technologies: solar power, onshore wind and offshore wind. The chapter concludes by assessing the extent to which planning policy has affected the deployment of these three renewable energy technologies.

There is a range of planning policy measures that can be applied to facilitate energy infrastructure development, including renewable energy infrastructure. The three broad measures include:

Central determination of consent, for Nationally Significant Infrastructure Projects (NSIPs).

Since the post-war period, central government has held powers to determine consents for major power generation stations, usually over 50MW installed capacity, as well as for major grid lines. In the past, this has been the consenting route for coal, oil and gas-fired power stations, and it is now the main consenting route for larger renewable energy facilities, such as offshore wind farms. The Planning Act 2008 designated such projects Nationally Significant Infrastructure Projects (NSIPs) and instigated a set of measures by which central government has been able to accelerate consenting processes, notably by instituting statutory timeframes for key parts of the process. The NSIP approach also mandates early, front-loaded consultation with statutory bodies and the public.

Determination of consent by Local Planning Authorities (LPAs)

For power generation facilities below the 50MW size threshold, applications for planning consent are decided by Local Planning Authorities (LPAs), as per the Town and Country Planning Act 1990, in much the same way as developments such as housing. This has been the main route by which onshore renewable energy capacity in England, both solar and wind, has been developed to date. Applications are judged primarily against Local Development Plans (LDPs), which set down policies for guiding development across an area.

Permitted Development Rights (PDRs).

Central government has long held the power to grant PDRs to certain categories of development, thus removing the requirement to go through the usual planning approval process. PDRs have been granted to certain small-scale renewable energy facilities. For example, adjustments to PDRs in 2012, enacted through an amendment to the Town and Country Planning Act 1990, increased the scope to attach solar PV panels to buildings without requiring planning consent.

The UK government can also set the policy framework against which applications are determined, affecting the criteria to be considered and the weight to be attached to them. For energy infrastructure projects that go through the NSIP consenting route, outlined above, the Government produces National Policy Statements (NPSs), which set down national objectives for the technology in question and the factors that should be considered in project consent decisions.

For those applications requiring local consent, however, LPAs have been steered through national planning policy guidance – since 2012, the National Planning Policy Framework (NPPF) – which sets out how applications are to be determined and the policies that LPAs should incorporate in their LDPs.

Box 2.1. The NPPF and renewable energy technologies.[25]

The broad tenor of the NPPF is positive and encouraging towards renewable energy technologies. Paragraph 155 states that plans should “provide a positive strategy for energy from these sources, that maximises the potential for suitable development, while ensuring that adverse impacts are addressed satisfactorily.” This includes “identifying suitable areas for renewable and low carbon energy sources … identifying opportunities for developments to be supplied by decentralised energy sources [and] supporting community initiatives for renewable and low carbon energy”.[26]

LPAs are asked not to challenge the need for such generation, and to approve applications when “the impacts are (or can be made) acceptable”.[27] This positive stance has been supplemented and qualified for onshore wind to deliver a more restrictive planning approach, as discussed below.

Because of their scale and potential for environmental impact, some energy generation projects are required to undergo Environmental Impact Assessment (EIA), and thus are affected by the regulations governing that process. EIA is mandatory for all thermal power stations of 300MW capacity or more and for the largest electricity transmission lines. EIA is also likely to be required for any other energy production facilities occupying more than 0.5 hectares and for wind farms consisting of more than two turbines, or more than 15m in height.[28] Compliance with biodiversity conservation legislation – notably the requirements of the Endangered Habitats Directive – also imposes a series of tests for planning applications that affect species or habitats listed under the Habitats Directive.

Besides the statutory legislation and policy mentioned above, there is a raft of non-statutory government advice and guidance on planning for renewable energy development, often produced with the close input from the energy industry. This includes advice on community engagement and more detailed facets of project design, discussed later in this chapter.

Non-statutory guidance is an important vehicle for advice on the provision of community benefits – the provision of funds or assets to communities that host or are affected by new energy infrastructure development. The provision of community benefits has become routine for onshore wind and is being increasingly applied to grid network development, too.[29]

In sum, government has great scope to adjust planning policy to be applied to energy project development. Over the last two decades, many such adjustments have been made, as successive governments have sought to recast the balance that planning strikes between infrastructure delivery, community engagement and environmental sustainability. In fact, different adjustments have been made regarding different renewable energy technologies, creating a shifting picture of development risks and opportunities, as successive planning changes facilitate or thwart expansion.

We now turn to summarise post-2010 changes to statutory planning policy and non-statutory guidance regarding the main renewable energy technologies.

Recent developments in planning policy on renewable energy

Solar Power

There are currently more than 1.3 million UK homes with solar panel installations.[30] However, because of their smaller scale, the total installed solar capacity of solar PV on residential and commercial roofs has amounted to less than a quarter of the UK total solar capacity (3.3GW out of 14.8GW, as of 2023).[31]

Since 2010, successive governments have sought to encourage solar energy. One key mechanism for this has been to simplify or remove non-statutory guidance. To achieve this, Permitted Development Rights (PDRs) – introduced earlier in this chapter – have been extended to enable small-scale solar PV projects to be constructed without the need for planning consent, with important additions introduced in 2012 through an amendment to the 1990 Town and Country Planning Act. This conferred the right to install solar panels attached to dwellings or non-domestic buildings, or within their curtilage, subject to size and locational constraints; for example, limiting these rights to schemes that do not raise the height of buildings.

For larger, field-scale solar projects there has been less specific policy encouragement. Solar power projects that exceed the rights conferred by PDRs, but fall below the 50MW threshold that would render them NSIPs – as detailed in Box 2.1 – require planning permission from the LPA. Indeed, the broadly positive message on renewable energy development given in the NPPF applies to solar PV, but it offers no specific advice on this technology. Advice on determining solar PV applications is instead given only in the planning practice guidance on renewable and low-carbon energy.[32] Meanwhile, only a small number of solar power developments, such as the East Yorkshire Solar Farm, have been determined centrally through NSIP procedures.

A key issue facing field-scale solar projects, which governments have needed to navigate, is whether such facilities should be allowed to be sited on higher-quality agricultural land. This is usually interpreted as grades 1-3a in the Agricultural Land Classification system, because it is the land that is classed as ‘Best and Most Versatile’ for growing crops. Although this has frequently been the subject of high-profile ministerial comment,[33] policy has been more stable. Both non-statutory guidance for smaller solar schemes and the National Policy Statements for schemes over 50MW have maintained the long-term convention that solar developments should be steered away from land of grades 3a and above, and that poorer quality agricultural land should be prioritised instead.[34]

Onshore wind

As of 2022, there were over 1,500 operational onshore wind farms in the UK,[35] with a combined capacity of 14.8GW.[36]

Of all the low-carbon energy technologies in the UK, onshore wind has been subjected to the greatest shifts in planning policy, with most of the changes prioritising responding to public disquiet above development delivery.

In the period prior to 2010, statements of national planning policy guidance encouraged LPAs to be supportive of onshore wind development.[37] The guidance documentation set down the criteria that were relevant to determining consents, while warning LPAs against seeking to spatially steer wind energy development through preferred development or exclusion zones in their LDPs.[38] Instead, Regional Planning Bodies, then operating for England, were encouraged to identify broad areas for renewable energy development. However, this resulted in spatial planning guidance only for onshore wind in the North East, with no areas being identified by Regional Planning Bodies in any of the rest of England.

This limited government interest pre-2010 in using the planning system to spatially steer onshore wind energy development in England is in marked contrast to Wales and Scotland. There, local government used national planning policy guidance and LDPs to steer onshore wind projects towards preferred development areas.[39]

From 2010, significant changes to planning policy for onshore wind in England were introduced. The Conservative-Liberal Democrat Coalition Government introduced reforms to the planning system, all designed to institute a new, ‘localist’ approach. Regional Planning Bodies were abolished and the NPPF was created in 2012 – which replaced previous planning guidance consisting of hundreds of pages of Planning Policy Guidance Notes (PPGs), Planning Policy Statements (PPSs) and Planning Circulars. The NPPF also removed any wind-specific planning policy.

New detailed planning practice guidance to the NPPF was introduced by the government in 2013, requiring wind farm developers to engage in pre-application consultation with the local community and giving more weight to grounds for refusal by LPAs.[40] Then, after the 2015 general election, the Government took forward its manifesto commitment to “halt the spread of subsidised onshore wind farms” and “change the law so that local people have the final say on wind farm applications”.[41] Consequently, new non-statutory guidance for onshore wind was added to the NPPF, as follows: “Except for applications for the repowering of existing wind turbines, a proposed wind energy development involving one or more turbines should not be considered acceptable unless it is in an area identified as suitable for wind energy development in the development plan; and, following consultation, it can be demonstrated that the planning impacts identified by the affected local community have been fully addressed and the proposal has their backing”.[42]

In effect, this change to the NPPF set up three additional tests for the development of onshore wind projects:

Spatial zones. New wind energy developments need to be in an area identified as suitable within the LDP.
Impacts. Any planning impacts identified by the affected local community must be “fully addressed.”
Community backing. It must be demonstrated that proposals have the backing of the affected local community.[43]

This ‘triple veto’ created significant barriers for the development of new onshore wind schemes in England. There has been no obligation on LPAs to identify areas suitable for onshore wind to support the first test, without which wind energy development is precluded. In addition, onshore wind farms over 50MW were taken out of the fast-tracked, central, NSIP consenting processes, and instead passed to local authorities to determine, subjecting them to the same triple veto.

This change was the result of a highly-organised grassroots and parliamentary campaign, which put the Conservative-Liberal Democrat Coalition Government under significant pressure, including from members of the Conservatives, Liberal Democrats and the UK Independence Party.[44]

Alongside these major changes to planning policy, government has worked with the industry to create non-statutory guidance on community engagement and benefits.[45] The ‘Community Benefits Protocol’ encouraged wind farm developers to commit to providing a package of at least £5,000 per megawatt per year to host communities. This advice was updated most recently in 2021,[46] though such changes are of limited practical effect, given that the triple veto policy largely extinguished new onshore wind projects in England.

Offshore wind

As of 2022, there were over 2,600 offshore wind turbines off UK shores,[47] with a combined capacity of 13.9GW.[48]

Successive UK Governments have encouraged the expansion of offshore wind, and this technology has been an important beneficiary of efforts to institute fast-track consenting planning processes. Because most offshore wind schemes are large in scale – over 100MW – they fall within the ambit of the centralised NSIP processes, explained earlier in this chapter.[49]

Box 2.2. The role of the Crown Estate in the planning process for offshore energy development.

Prior to the planning process for offshore wind developments, important planning work is undertaken by the Crown Estate, which is the body responsible for awarding seabed rights for offshore renewable energy. As part of this role, the Crown Estate subjects potential development areas to an assessment of constraints, including: technical issues such as inadequate sea-bed conditions and excessive water depth; conflicting user demands, such as with Ministry of Defence exercise areas and shipping lanes; and environmental matters, such as visual sensitivities and potential wildlife impact. On the basis of this work, seabed development areas may be refined further before being made available to prospective bidders in leasing rounds.[50]

In contrast to onshore wind, planning policy for determining offshore wind consent has been stable and consistently supportive since 2010. However, as the sector has expanded, so concerns have mounted about the potential risks that the projects pose to marine biodiversity; especially the UK’s internationally important seabird populations. This has led to increased questioning of the way that planning policy balances encouraging project delivery against ensuring environmental sustainability where it comes to offshore wind development.[51]

The input of planning policy on renewable energy development

Having charted the evolution of planning policy for solar power, onshore wind and offshore wind developments since 2010, we now examine the impact that planning policy has had on the development of those technologies.

Chart 2.1 below shows the significant expansion of renewable energy capacity that has unfolded across the UK in the last twenty years, from about 3.5GW installed capacity in 2003 to almost 50GW by 2021, with 80% of that capacity coming from wind power, onshore and offshore, and solar power – and the remainder from hydropower and bioenergy.[52]

While the overall upward trajectory is clear, Charts 2.2, 2.3 and 2.4 below show the rather more turbulent patterns of development per year for the main three renewable energy technologies in England. This raises the question of to what extent the planning system is responsible for said patterns.

Solar power

For solar power, the significant fluctuations in annual deployment levels, illustrated in Chart 2.2 below, are best explained by economics.[53]

The higher unit cost of power from solar power at the start of the twenty-first century meant that deployment was minimal until market support was provided, in the form of Feed-in-Tariffs (FITs), in 2010, which guaranteed payments at a tariff determined by the government for the energy that solar projects produced.

However, governments have struggled to set FITs at levels that were sufficient to stimulate consistent and sustainable levels of investment. This has precipitated boom-bust investment patterns, with investment nose-diving in 2016, as illustrated in Chart 2.2 above; the year that most FITs for solar power were cut to minimal levels.

Since 2019, however, the continually falling costs of solar development and rising power prices have made more projects investable. Some segments of the market – most notably rooftop solar schemes – have even become subsidy free. Larger, field-scale solar projects have also been assisted by inclusion within the government’s Contracts for Difference (CfD) support programme: CfDs offer stable prices for projects for a set time period, and developers bid for CfDs for their projects in auction ‘Rounds.’ In the CfD Round completed in 2023 (Round 5), solar power generation projects were awarded CfDs at power prices of £47.00/MWh,[54] which is below the long-term average price for gas generation of £50/MWh,[55] even disregarding price shocks arising from Russia’s invasion of Ukraine. Almost 4GW of new solar capacity was granted planning consent in the UK in 2022. Moreover, reports suggests that the pipeline of prospective solar projects has dramatically increased in scale, estimated at 37GW of capacity in early 2022,[56] and reaching 85GW by July 2023;[57] a 130% increase over only a year and a half.

Any effects exerted by the planning system on solar power development rates looks thereby secondary to the influence of economics. PDRs mean that small-scale solar schemes, as explained earlier, are currently not very restricted by planning regulation. For schemes requiring local planning consent, the proportion of schemes being granted planning consent has exceeded 80% for the period since 2017.[58] One should be careful, however, in interpreting consent rates in relation to the efficacy of planning: consent rates may depend on the number of planning applications, quality of schemes and the availability of acceptable, low-impact sites. Moreover, they do not always factor in subsequent consent at appeal. Nevertheless, one could reasonably judge that, to date, planning policy has been predominantly supportive of solar power development.

Prior to 2022, relatively few solar power developments have been of sufficient scale to require consent via the NSIP route, though this is set to change in the future, as larger, ‘utility-scale’ solar farm schemes exceeding 50MW come forward in increasing number. This interest in larger schemes has been stimulated by helpful policy and a positive economic context, as explicated further in Chapter Three.

Offshore wind

As Chart 2.3 below shows, offshore wind has seen a strong upward trajectory of growth.[59]

This growth has been, again, propelled by economics. Offshore wind has been the major beneficiary of the Government’s CfD market support programme, which has helped to stabilise revenue and incentivise major commercial investment. Support for research and development and the adoption of larger, more efficient turbines, assembled in bigger projects, has helped push down the price of power from offshore wind to as low as £37.35/MWh (CfD Round 4).

Initially, the latest CfD Round (Round 5) did not take into account the rapid increases in the production cost of wind turbines due to recent interest rate increases. Instead, it retained the same price as the previous allocation round, making bidding for any new offshore windfarm contracts less commercially viable. Following pressure from Bright Blue, the Government announced an increase in the maximum Contract for Difference (CfD) maximum strike price for offshore wind projects by 66%.[60]

As of June 2023, the total pipeline for offshore wind energy projects for UK waters – which includes projects at every stage of development: operational, under construction, consented and planned – had reached 100GW.[61] Of this, 6.8GW is under construction and 7.3GW is preparing for construction. With those construction projects complete, installed capacity for offshore wind is set to double from 2023 levels to about 28GW, as visible in Chart 2.3, by the end of the decade.

For much of the post-2010 period, planning policy for offshore wind has been supportive. Very few offshore wind farms have been ultimately refused consent; of the ones that have, in many cases the decision was later overturned. Projects that failed tended to be close to shore and highly visible from protected and valued coastal landscapes, where public objections have been a major factor. It is difficult to determine the exact proportion of projects that have been refused consent, but, overall, they have been a minority. As schemes increasingly focus on marine areas further offshore, so the level of public opposition tends to fall. Given the scale of the prospective development pipeline, and looking at planning outcomes, it is hard to claim that the planning framework has deterred investment interest in offshore wind development.

If planning outcomes are ultimately mostly positive, there has nevertheless been growing industry disquiet at the gradually lengthening time taken to make decisions on offshore wind applications.[62] Various factors are at work here. According to Chris Skidmore MP’s Net Zero Review, planning authorities and environmental regulators – such as Natural England – are under-staffed, especially relative to the massive increase in applications and therefore in workload.[63] Sector growth has also increased the requirements for more and larger onshore grid connections, each raising their own environmental concerns and, in some instances, public resistance. This prompted reforms to the hitherto prevailing infrastructural model whereby each offshore wind scheme develops its own individual connection to the nearest point of the grid network. This is set to be superseded by a more strategic approach to offshore wind, which relies on coordinating onshore connections to the grid between different electricity generation schemes.

Another factor delaying consenting for offshore wind developments has been the need to address the impacts on biodiversity. Problems have arisen because the UK has significant, internationally-important nature conservation interests, such as birds, cetaceans and basking sharks, in its marine environment. Those species can be placed at risk by offshore wind development, both at the construction stage and when fully operational. At the same time, how species utilise the marine environment is often poorly understood – especially as we move further offshore. This has meant that a growing number of offshore wind applications have reached an advanced stage of the consenting process, only to find that further survey and analytical work is required to fully assess the likely biodiversity impacts and the efficacy of any mitigation measures.[64]

Onshore wind

Finally, for onshore wind, the effects of planning policy seem to be more pronounced. Policy changes from 2012 onwards, such as the removal of supportive, wind-specific planning policy and the reinforcement of grounds for application refusal, saw fewer UK onshore wind farm application consents in 2013 and 2014 compared to the 2012 peak, as shown in Chart 2.4 below.[65]

The 2015 policy changes to the NPPF – the requirements for projects to be in a spatial zone, to fully address impacts and to attain community backing, the so-called triple veto – all prioritised local control over delivery and the effect was the evaporation of new onshore wind energy development in England. From 2016 to 2022, only 14 applications for onshore wind projects were submitted. Only 12 of those were subsequently approved, totalling a mere 21 turbines, with a combined installed capacity of 48MW – a figure just 2.85% of the level of capacity granted consent in the period between 2009 and 2014, which was 1624MW.[66]

Moreover, only about 10% of English LPAs have instituted preferred development areas for onshore wind in their LDPs: a pre-requisite for onshore wind development of any scale to be approved.[67]

Onshore wind development was also affected by the ending of ROC (Renewable Obligation Certificate) support in 2016. Under this scheme, electricity suppliers were under an obligation to meet a growing percentage of their supply from renewable sources, enabling renewable energy generators to sell certificates to these suppliers, creating additional income to the revenue they received from selling electricity. Onshore wind was also then also almost entirely excluded from the first three rounds of CfD support.

However, falling costs for onshore wind, and its admission to the CfD system in December 2021, have shown the diminishing significance of financial constraints in shaping the prospects of future onshore wind development, while throwing the effects of planning into sharper relief. In the fourth CfD round, onshore wind projects were secured with a strike price of £42.47/MWh but, while 0.9GW of capacity was awarded in Scotland with a further 0.6GW on the Scottish islands, no projects were awarded in England.

Conclusion

This chapter has established the key ways that the planning system affects the main renewable energy technologies in England and examined the impact of planning policy and guidance relative to the other factors influencing development rates. Looking back, it is clear that economic circumstances have often been the most significant barrier to greater levels of renewable energy development – especially for solar and offshore wind development. Furthermore, constraints in grid connection and capacity have now emerged as a yet further leading barrier.[68]

However, planning constraints remain relevant, and the effects of planning also vary between technologies. Post-2015 planning policies for onshore wind have clearly all but curtailed development, but by political design rather than by accident. For solar power and offshore wind, planning processes have been facilitative, but the picture is continually evolving. Especially as economic circumstances make renewable energy increasingly affordable, economics will diminish as a factor in hindering the development of renewable energy infrastructure, and planning policies may become a more significant barrier.

The next chapter outlines and examines the current Conservative Government’s proposals for future legislative and policy change for planning in respect of the three key renewable energy technologies we are focused on.

Chapter Three: Ongoing or proposed changes to planning policies for renewable energy

Having established the nature and effects of planning policy on renewable energy technologies in England since 2010, we now turn to examine the leading ongoing proposed policy changes to planning policy and guidance for the three key renewable energy technologies, which have been adopted by the current Conservative Government. The chapter first describes the ongoing or proposed changes to planning policy and guidance for each of the three key renewable energy technologies and concludes by evaluating them.

Solar power

The current UK Government is preparing a raft of measures designed to encourage the expansion of solar power. At the strategic level, the Government recently affirmed a target of deploying 70GW of installed capacity across the UK by 2035, is establishing a taskforce to achieve this goal and will publish a roadmap to drive forward the necessary actions in 2024.[69]

Changes to planning policy are one component of these measures to boost solar power capacity. The Government has again clarified the acceptability of solar power developments on low- and medium-grade agricultural land, as described in Chapter Two, and offered a positive view on the potential complementarities between solar power and farming as “[supportive of] each other financially, environmentally and through shared use of land”.[70] For projects over 50MW, a positive stance has also been adopted in the March 2023 revision to the National Policy Statement for Renewable Energy (EN-3) by underlining the need for solar power.[71]

The major substantive changes to planning policy have been to PDRs to facilitate the development of solar power, including larger solar projects, in a wider range of contexts. The Government has recently consulted on proposed extensions to PDRs for solar PV to include: buildings with flat roofs; increased scope for standalone solar PV within the curtilage of homes;[72] removing capacity limits for solar PV on non-domestic buildings to replace the current PDRs which only apply up to 1MW;[73] and creating new PDRs to enable the construction of solar canopies on non-domestic car parks, for example at supermarkets and retail parks.[74]

Offshore Wind

Offshore wind has been placed centre stage in the current UK Government’s vision of a decarbonised energy system. The 2022 British Energy Security Strategy raised ambitions for installed offshore wind capacity from 40GW to 50GW by 2030, including up to 5GW of floating offshore wind.[75] This exacting time frame and mounting concerns from the energy industry about slowing project delivery,[76] as discussed in the previous chapter, have prompted a raft of government proposals on planning policy concerning offshore wind.

The Levelling Up and Regeneration Act 2023 includes powers to amend the Planning Act 2008 to empower the relevant Secretary of State to set a shorter timeframe for one of the main decision-making stages for NSIP projects – the public examination – than the normal six months. As noted in Chapter Two, almost all offshore wind projects are consented as NSIPs under the Planning Act 2008 procedures. The Bill will also allow any government agencies with vital technical expertise[77] to charge developers for their services in the aforementioned NSIP process, which may be used to fund extra staff capacity, thus reducing staffing constraints in the handling of offshore wind projects.[78]

Revisions to the NPS for Renewable Energy (EN-3), published in March 2023, instituted a new ‘Critical National Priority’ presumption for offshore wind, meaning that “subject to any legal requirements, the urgent need for offshore wind to achieving our energy objectives, together with any national security, economic, commercial and net zero benefits, will in general outweigh any other residual impacts not capable of being addressed by application of the mitigation hierarchy”.[79] The definition of ’Critical National Priority infrastructure‘ includes supporting onshore and offshore network infrastructure and related network reinforcements. The intention there is to tip the planning balance in favour of development delivery.

The current Government has also sought to re-engineer the way that marine biodiversity impacts are addressed in offshore wind consenting processes, for which a key component is the Offshore Wind Environmental Improvement Package (OWEIP). This is designed to “help to reduce offshore wind consenting time from up to four years to one year, whilst ensuring we continue to meet our environmental commitments”.[80] The OWEIP is being taken forward in the Energy Act 2023. The Act received royal assent in October 2023 and makes provision to, among other things, allow developers to collaborate in developing biodiversity impact compensation schemes rather than being required to develop their own measures, reducing the time burden on the developer and, potentially, delivering greater ecological benefits. Moreover, the Bill sets up a marine recovery fund that developers can pay into to help deliver these schemes.

Other reforms in the Levelling Up and Regeneration Act, such as supplanting the Environmental Impact Assessment (EIA) detailed in the previous chapter with Environmental Outcome Reports, are also aimed at streamlining the planning application process. Environmental Outcome Reports are designed to make assessment simpler, by focusing assessment solely on the government’s environmental priorities.

It is clear that considerable policy effort is going into the development and systematisation of compensatory measures for renewable energy infrastructure, justified by the Government in large part in relation to smoothing the path for development. Much less attention has been given, however, to measures that might help the most sensitive biodiversity areas be avoided. Major conservation organisations have expressed concerns that England’s marine spatial plans – non-statutory guidance concerning the management of the UK’s marine environment – have lacked the required level of spatial specificity to identify the least environmentally-sensitive areas for marine renewables development. Data on marine biodiversity is inadequate and has struggled to keep up with the effects of climate change or avian influenza or growing knowledge of the impact of offshore wind on bird populations.[81] These inadequacies result in decisions about how best to avoid and mitigate impacts being delegated to individual projects, at which point development sites have already been chosen and fewer options for ameliorating harms are available.[82]

Offshore wind has also been one of the major beneficiaries of wider, non-planning policy changes. The Government has moved to increase the frequency of CfD auction rounds from every two years to holding them annually.[83] It also recently increased the maximum Contract for Difference (CfD) strike price for offshore wind projects by 66% from the previously-set level, a policy that Bright Blue has called for.[84] Such steps are designed to accelerate the deployment of low-carbon electricity generation, and the former also means that, where planning application processes take more time than expected, such that the developer misses a CfD window, the waiting time to the next opportunity is reduced.[85]

Onshore wind

Recent Government planning policy proposals for onshore wind have been tepid in comparison to the outlined proposals for solar power and offshore wind. There have been some positive developments in the last couple of years, such as allowing onshore wind back onto the government’s CfD support programme in 2021, but those have been of limited effect, and more support for onshore wind is still required. As can be seen in Chart 2.4 earlier, additions to installed onshore wind capacity in England have remained at a very low level even in the most recent years.

Late last year,[86] the Department for Levelling Up, Housing and Communities (DLUHC) consulted on revisions to the NPPF, including adjustments to planning policies for renewable energy technologies. The consultation proposed more supportive policies for the repowering of existing onshore windfarms, advising LPAs to “approve an application for the repowering and life-extension of existing renewables sites, where its impacts are or can be made acceptable. The impacts of repowered and life-extended sites should be considered for the purposes of this policy from the baseline existing on the site”.[87]

This proposed adjustment to the NPPF was welcomed by the renewable energy sector.[88] Repowering enables older wind farms to be re-equipped with newer, higher-capacity turbines.

Nonetheless, the effect of this policy adjustment to the NPPF on total installed capacity of onshore wind is likely to be modest. Some estimates suggest repowering could deliver more than 1GW of additional capacity in England,[89] which would be a 30% increase on the 3GW currently installed, as visible in Chart 2.4 above, but this is probably optimistic.[90] While there is good reason to believe that the repowering of existing onshore wind power sites would be subject to less local resistance than the development of new ones, that may not be the case in all locations.[91] On some sites, using fewer, larger turbines may be considered a visual improvement, while in others it may, conversely, be considered more visually intrusive.

Beyond repowering, planning policy for new onshore wind proposals remains largely unchanged by the current Government in most important respects, despite some recent announcements from this Government that relax planning restrictions on onshore wind.[92] This is despite widespread criticism, including from Bright Blue.[93] Applications for onshore wind development are still required to be for an area identified in LPPs or a supplementary planning document as suitable for wind energy development, without mandating that LPAs identify such areas, as demonstrated in the previous chapter. The requirement for addressing impacts has only changed to requiring impacts identified by the local community to be “appropriately addressed,” rather than “fully addressed,” which still opens anything short of a full address open to a legal challenge, insofar as one can consider a full address the only appropriate address. Finally, the previous requirement for local community “backing” has now shifted to a requirement to demonstrate community “support.”

Placing these three tests together, the ‘triple veto’ planning policy – the requirements for zoning, appropriately addressed impacts and community support, as described in the last chapter – maintains a de facto ban on onshore wind energy development in England. Until recently, it was near impossible to define the community support requirement in a consensual and coherent way that enables it to be met.[94] A ministerial statement claims that, since Autumn of 2023, non-statutory planning guidance seeks to “provide clarity on how policy [including regarding community support] should be applied in practice,” but it remains unclear how effectively said guidance will address this issue.[95] Unsurprisingly, therefore, onshore wind remains the only major renewable energy technology to still lack an official UK government target. The result of this is the effective curtailment of a proven and low-cost source of low-carbon renewable energy, adding to energy prices.

Any attempt to restart the expansion of onshore wind in England with smaller or medium-sized turbines that might better fit the English landscape also faces the problem that eight years of restrictive planning policy has largely dissipated the supply chain of smaller turbines. It would require secure prospects of growth to return, as well as a stable, supportive planning policy framework.

That said, in May 2023, the new Department for Energy Security and Net Zero (DESNZ) initiated a consultation on measures to improve community engagement and community benefits for onshore wind development.[96] The intervention could be depicted as ‘back to the future,’ insofar as the proposals were all in policy circulation a decade before. The proposed measures include: promoting early engagement between developers and local communities; using feedback to improve projects, including through the use of digital and online approaches to involve communities; and tailoring the system of community benefits – such as reducing the electricity bills of households in communities host to onshore wind developments – to particular community needs.

Extensive research suggests that these actions to facilitate community engagement and benefits would be likely to have a positive effect on the local acceptability of wind farm proposals and reduce opposition.[97] However, this effect has its limits. High-quality community engagement cannot insulate all onshore wind farm proposals from the possibility of significant resistance.[98] Not everyone will regard the negative landscape impacts of onshore wind as something that can be adequately substituted by any benefits offered to them or their community.

Whatever the merits of these recent proposals from the current Conservative Government, they remain moot for as long as onshore wind energy remains subject to the trio of planning tests that, together, deter almost all project developers.

Box 3.1. Grid networks.

Decarbonising the energy system has major implications for power transmission and distribution networks. Such networks need to increase in capacity to accommodate the growth in power demands that will come from electrifying heat and transport; they need to shift geographically to support the spatial distribution of new renewable energy sources, such as offshore wind; and they will need to accommodate the mass dispersion of small-scale generation, such as rooftop solar PV. UK Government policy in the last five years has greatly intensified the attention given to network reform, with a focus on three core problems: grid access, grid configuration and coordination and network consenting.

Grid access

Here the problem is the mounting queue of projects waiting to secure grid access. As of February 2023, the UK had some 257GW of prospective installed capacity in the queue for connections, with many projects facing a wait of over a decade.[99]

The Prime Minister recently announced the Government’s intention to take steps to enable projects at the most advanced state of readiness to be connected to the grid first.[100] Consequently, the National Grid has been pursuing measures to encourage developers of behind-schedule or dormant projects to relinquish their place in the queue to be connected to the grid.[101]

Moreover, in the Autumn Statement, the Chancellor claimed that “the government will remove barriers to investment in critical infrastructure by reforming the UK’s inefficient planning system and speeding up electricity grid connection times.” According to an analysis from DESNZ, those reforms could increase energy infrastructure investment temporarily by an average of £10 billion per year over the next ten years.[102]

Grid configuration and coordination

An enduring problem in the UK is how to efficiently allocate resources to invest in new, additional grid capacity in advance of the delivery of new renewable energy generation. The problem is the broadly reactive nature of energy network regulation, in which firm and specific demonstrations of likely need are usually required to trigger spending on new or upgraded networks. There are good reasons for being cautious – it reduces the risks of creating stranded assets where new generation does not materialise – but it also makes it difficult to coordinate the expansion of renewables with new grid development in a timely fashion or to consider community and environmental impacts at an earlier stage.

Important steps have been taken to foster strategic approaches to the planning of energy networks instead. The NGC ESO published the Holistic Network Design in June 2022, a coordinated plan to serve the development of 50GW of offshore wind by 2030. The plan is incorporated into planning policy through National Policy Statement NPS EN-5 on networks, which pushes developers of offshore wind schemes to move beyond individual, project-specific connections to the onshore network, and encourages developers to instead coordinate and share the transmission connection requirements of their projects. The goal there is to reduce the potential number of onshore connections.[103] Ofgem – one of the bodies involved in authorising new grid investments – has also been granted a new net zero remit in the 2023 Energy Act. This might encourage them to take a more strategic approach to authorising said investments, in anticipation of the requirement of significant grid expansion in order to meet net zero targets.

Network consenting

August 2023 saw the publication of the recommendations of the government-appointed Electricity Networks Commissioner, advising the Government on how to reduce the development time for transmission network projects, like new high voltage lines.[104]

One high-profile recommendation is the provision of community benefits to settlements impacted by new high voltage lines. In response, the Government expressed the hope that providing community benefits will help ensure that power infrastructure projects can be built without undue delay.[105] Yet evidence that community benefit provisions, of themselves, do much to shift public attitudes towards high-voltage transmission lines is limited, as explained earlier in this chapter in relation to onshore wind development.

Analysis of planning policies concerning renewable energy technologies

The last two years have seen an unprecedented level of new statutory planning policy and non-statutory guidance to support the development of renewable energy provision. Whether these policies are sufficient, and how helpful they are likely to be, depends on the type of renewable energy technology involved.

In truth, what the analysis shows is an inconsistent and asymmetric approach to the deployment of planning in relation to different renewable energy technologies.

First, on inconsistency. For onshore wind, the overwhelming emphasis from government is on the so-called ‘localist’ approach, which maintains significant veto powers for local communities. Meanwhile, for solar power and especially offshore wind, the emphasis from government is more firmly on delivery, with much attention being given to accelerating project consenting process. Such inconsistent treatment pays too little heed to the requirement for significant increases in investment across all three technologies.

Indeed, both approaches have risks. With onshore wind, the localist approach imposes such heavy risks on developers that it stymies most new projects. With solar power and offshore wind, on the other hand, the concern is that most measures seek to de-risk and accelerate development by rolling back planning controls or smoothing environmental assessment and impact mitigation requirements. This results in a degree of moral hazard. One reason why projects may be delayed is that they, due to their siting, design or scale, risk creating significant impacts that require careful consideration.[106] By reforming planning policy in ways that squeeze out delay, disincentives to making risky choices are removed. Moreover, the need to learn and develop better solutions to avoid future risks and delays is also diminished.

One area where this is evident is social acceptability. Polling may show strong levels of public support for energy decarbonisation and renewable energy technologies,[107] but it cannot be inferred from such evidence that the public will necessarily always accept specific projects, or that public resistance to specific renewable energy projects will not foment more significant dissent affecting wider decarbonisation policies; especially where public perceive that their influence over decision-making processes is diminished.

However, the present, inconsistent planning arrangements around renewable energy technologies leave community engagement either marginalised by the relentless pursuit of swift project consenting – as in some offshore wind and solar power developments – or exercising effective veto powers over major developments – as in onshore wind developments.

There is little sign that this undesirable binary pattern of policy development is disappearing. The Sunak Government has stated that, “[g]iven the scale and speed of low-carbon infrastructure development needed, we expect that more planning reform will be required”,[108] indicating a doubling-down on measures to accelerate consenting process.

Box 3.2. The path less travelled: local and community energy systems.[109]

Reflecting on the efforts by successive Governments around renewable energy and planning also reveals a second, significant asymmetry in the treatment of different potential pathways to a next zero energy systems.

Efforts are dominated by how effectively the planning system is seen to expedite large-scale new generating facilities and major, long-distance grid lines. This emphasis ignores other pathways to 2050 that focus on the creation of local energy systems. These sit within national infrastructures and markets, but consist of local efforts on demand reduction, efficiency, flexibility, local power supply and decarbonised heat and transport systems.[110 ] Those efforts can be tailored to the variations in local built environment, sense of place, communities and patterns of inequality. Indeed, they have strong prospects of achieving net zero at lower costs than uniform, centralised approaches. According to one 2022 study conducted by researchers from Imperial College London, such efforts could save as much as £1.7 billion per year by reducing the need for more large-scale power network investment.[111] Government-sponsored reviews, too, recognise the need to expand scope for “more place-based, locally-led action on net zero”.[112]

Yet the above review of planning policy for renewable energy reveals the subordinate positioning of local energy system pathways within wider energy policy. We see this in the uneven distribution of priorities, favouring offshore wind and other predominantly large-scale generation technologies, but discounting energy efficiency, demand reduction or active travel.

In Chapter Four we propose ways to reform planning statutory policy and non-statutory guidance to help keep the UK on track for net zero by 2050.

Chapter 4: Policy Recommendations

So far, this report has concluded that the role of planning policy in renewable energy development in England often lies on a binary spectrum. With two key technologies, namely solar power and offshore wind, planning is often framed only as a problem to be got rid off, without considerations of whether this facilitates the best possible route to net zero. But in the context of onshore wind, planning has been deliberately used to construct a ’triple veto’ test for projects that is all but unassailable. This inconsistent reasoning can obscure the need to learn and develop policies that achieve an effective and durable balance between delivery, public engagement and environmental sustainability regardless of the technology involved.

The planning policy recommendations offered in this report seek to go beyond this binary, place the role of planning on a durable footing and, by doing so, contribute to the sustained growth on renewable energy generation capacity that net zero requires.

The policy recommendations in this chapter flow from the following principles:

The UK needs to pursue the best net zero energy transition, not simply the quickest. Decision speed alone is an inadequate way of judging the performance of the planning system, and this is equally true in the energy sector. There is a legitimate role for planning in ensuring that our future energy systems are comprised of high-quality projects and that potentially harmful schemes are rigorously assessed. Many facets of creating new, decarbonised energy systems create profound challenges for places and people, such as in the case of expanding large-scale wind or solar in rural landscapes. Given this, there needs to be caution in pursuing ever-faster planning permission consenting times.
Planning processes need to strike an effective compromise between development delivery, community engagement and protecting the environment. We require all these qualities of our future energy systems, and planning is a key mechanism for delivering all three of them. Recognising this is not inimical to effective delivery. History provides numerous instances of where the excessively gung-ho promotion of development at the expense of community engagement or environmental protection generates a backlash that leads to policy retrenchment and delays to development in the long run.[113]
The role of planning in energy decarbonisation varies depending on the decarbonisation pathways pursued, including the technologies prioritised and the balance between technical and behavioural solutions. Pathways that major on very large, centralised facilities, such as offshore wind or major field-scale solar, create a very different planning challenge to pathways that give greater scope to energy efficiency and demand management or smaller-scale decentralised energy production. The latter pathways, for instance, entail important roles for planning in shifting patterns of household energy consumption, integrating local energy systems and supporting behavioural change in areas like travel.
The role of planning should not be viewed in isolation, but as interconnected with other public policy instruments. Some problems that become visible in the course of project planning processes more accurately have their cause in other parts of the policy landscape. Market support arrangements, financing, grid network investment, supply chains and a host of other factors impact on the trajectories of energy development and may be more important foci for remedial policy action. Similarly, the types of energy projects encouraged by other policies – their scale, form, patterns of ownership, the distribution of costs and benefits and their social acceptability – can exacerbate problems that planning processes need to address, but where planning is not their cause. Blaming planning and seeking planning reform may be a poor substitute for policy action better directed elsewhere.

Our recommendations begin with onshore wind, as this presents the thorniest challenges for planning policy, but the recommendations also have relevance to other renewable energy technologies. The recommendations then address measures for solar power and offshore wind, before ending with a set of cross-cutting suggestions.