The new Government wants to increase the threshold for projects to qualify as Nationally Significant Infrastructure Projects (NSIPs). Currently, projects in England that would generate more than 50MW would be considered an NSIP and require development consent from the relevant Secretary of State to go ahead.
Current consultations propose the reintroduction of English onshore wind to the NSIP regime at a threshold of 100MW and to increase the solar project threshold to 150MW. The question is, will it make any difference? And if so, to what type of project?
Solar
Planning applications for ground-mounted solar photovoltaics fall into two classes of projects. Those below 50MW and those above. Between 2010 and 2024, 1,844 ground-mounted solar photovoltaic projects have successfully applied for planning permission or are currently awaiting a decision. Only 12 of those exceed 50 MW. The average capacity of those is 392 MW, with the smallest being 138 MW.
Some projects may not be cost efective
Developers are electing to ‘go big’, or go away from the NSIP process altogether. A recent report by RenewableUK, CPRE and the Aldersgate Group noted that the NSIP process is not seen as cost-effective for projects that only just cross the 50MW threshold for designation as an NSIP. It would therefore appear that the decision to increase the threshold to 150MW could unlock a new class of solar project between 50MW and 150MW.
The NSIP regime provides greater certainty around timelines and likelihood of consent than the conventional local planning regime. Would the Government enjoy more success by applying its red tape-busting objectives to the NSIP process itself, rather than turning projects over to the mercy of local politics? Only time will tell.
What’s the future for Scottish projects?
Scottish projects have been excluded: they made up a minority of applications for solar projects and the changes proposed by the Labour Government will not reach into Scotland as planning regulation is devolved. Yet when it comes to wind, Scotland is leading the way in planning applications. For every 10 planning applications made between 2010 and 2024 (successful or awaiting a decision), around seven were Scottish.
All else being equal, a comparison of approaches on each side of the border would now take place to determine the impact of NSIP regulation.
But all else is not equal.
England has been subject to an effective ban on onshore wind since 2015 due to two footnotes in the National Planning Policy Framework and the removal of 50MW+ wind from the NSIP regime in 2015. These have been the chief obstacles to onshore wind and, while they now being addressed by the new Government, the impact of NSIP restrictions has been obscured. Decisions on undertaking wind projects are also governed by wind resource; the linear, more predictable risk profile that comes with increasing the size of solar projects is not found with wind projects.
No miracle cure
If NSIP restrictions are rolled back, it will make for one less obstacle to renewable energy deployment, with solar farms in England being the section of the market where the most transformation is likely to occur. Even so, the changes will not necessarily precipitate a flood of additional projects or capacity. While larger solar projects may be brought forward, they must still contend with food security concerns.
The planning process is now less resistant to onshore wind, with changes to the NPPF and this change to NSIP regulations, but appropriate site selection in England will remain tricky as there is simply less suitable land available for development when compared to Scotland. In addition, every kind of project must contend with a congested electricity grid. One month on from assuming power, the new Government has set about removing obstacles to renewable energy.
Coherent strategy needed
The ambition is there as the government continues to make policy changes. But now the hard work of developing a clear and coherent energy strategy is a far greater challenge and one that must be tackled promptly if the new government is to meet its 2030 zero-carbon electricity target.
Apart from wholly new grid connected solar and wind projects in England other future possibilities are:
• Behind the metre (BTM) wind installations
• Wind turbines co-located with existing solar arrays and batteries
• Expansion of existing solar and wind installations above 50MW.
Reconditioned machines replaced elsewhere with bigger turbines may also feature in English settings. Additionally, there is some interest in vertical axis turbines in more urban locations.
