Comment
Year of COP26: the green energy sector in England
With the UN Climate Change Conference of Parties (COP26) taking place at the end of the month, the second insight in our green energy series focuses on England, providing an overview of the latest position and our asks to UK Government.
In the period since autumn 2020, a range of national strategies relating to the energy sector and the development of energy infrastructure have been published; beginning with the National Infrastructure Strategy (NIS) and, more recently, with the commencement of consultation on a suite of draft National Policy Statements (NPS) and publication of the Net Zero Strategy.
In addition, and in response to the recommendations of the Climate Change Committee (as set out in the Sixth Carbon Budget), legally binding targets to deliver a 78% reduction in carbon emissions by 2035 have been confirmed.
Each of these strategies reinforces the Government’s commitment to achieving ‘net-zero emissions’ by 2050; to meeting future energy requirements through a blend of renewable and low carbon technologies; supporting the development of carbon capture utilisation and storage projects and accelerating the commercialisation of innovative low carbon technologies.
And, with the recent difficulties relating to oil and gas supplies ongoing, the need for domestic security of energy supply has, along with the need to address the challenges of climate change, never been more apparent.
The latest position
Set out below are recent publications which relate to energy and the deployment of energy infrastructure in England.
National Infrastructure Strategy (November 2020)
The NIS sets out Government’s vision for an infrastructure revolution including the path to tackling the climate emergency, the commitment to off-shore wind and hydrogen, and boosting local economies. This strategy provides long term certainty in terms of strategic policy direction and investment from which the private sector can draw confidence. The green agenda is front and centre building on the climate emergency declarations. Read more on this here.
Ten Point Plan for a green industrial revolution (November 2020)
The Prime Minister’s Ten Point Plan provides a blueprint to deliver the UK’s net zero 2050 target. The Plan outlines proposals for some £12 billion of investment across all green sectors addressing targets for offshore wind capacity, job creation, nuclear and hydrogen production capacities. It also provides support for electric vehicle production and promotion of sustainable modes of travel with aspirations to become a world leader in carbon capture and storage. Support is also offered for the development of new facilities for the production of Sustainable Aviation Fuels (SAF); the Governments ‘Jet Zero Aviation Strategy’ (2021) recognises the potential to develop a thriving domestic SAF industry creating highly skilled jobs. Read more on this here.
The Energy White Paper (December 2020)
Building on the Prime Minister’s Ten Point Plan, the Energy White Paper addresses a range of issues relating to the generation, supply and use of energy with the drive towards net zero by 2050 at its core, along with energy efficient buildings and lower household bills. There is strong support for offshore wind, hydrogen, nuclear and energy storage. The potential for contributions from biomass (with CCUS), wave and tidal is to be subject to further evaluation. Read more on this here.
Industrial Decarbonisation Strategy (April 2021)
In April the UK became the world’s first major economy to present a net zero Industrial Decarbonisation Strategy. UK industry accounts for around one sixth of the UK’s total emissions and transformation of manufacturing processes is essential if the net-zero targets are to be achieved. The strategy identifies how the UK can continue to compete within the global economy whilst also decarbonising its industrial base. Read more on this here.
UK Hydrogen Strategy (August 2021)
The Government’s Ten Point Plan for a Green Industrial Revolution highlights how the development of a thriving low carbon hydrogen sector is critical to achieving decarbonisation of the UK economy. Thus, the publication of the UK Hydrogen Strategy was long awaited. The strategy presents a vision to support a world-leading hydrogen economy by 2030, unlocking £4 billion of investment and aiding 9,000 UK jobs. It also confirms how a hydrogen economy can help to meet the legally binding commitments of net-zero by 2050 and the Sixth Carbon Budget; offering support for the provision of 1GW of hydrogen production capacity by 2025 and 5GW by 2030.
The strategy supports both the production of green-hydrogen (produced through the use of renewable energy) and blue hydrogen (carbon capture enabled production). Low carbon hydrogen production has a particular role to play in decarbonising the ‘hard to electrify’ industrial sectors. With virtually no low carbon hydrogen production in the UK at present, realising its benefits will require the rapid scaling-up of production facilities in the coming years.
Draft National Policy Statements (NPS) (September 2021)
Consultation has commenced (and is ongoing) on revised National Policy Statements for Energy Infrastructure which are intended to replace existing documents published a decade ago. Once finalised the NPS’s will guide decision makers in determining applications for Nationally Significant Infrastructure Developments.
The draft documents (EN-1 and EN-3) recognise the need for energy infrastructure to be ‘urgent’ and considerable support is offered to hydrogen, nuclear and renewable sources such as offshore wind. The incorporation of supportive policies for solar (considered unviable at scale a decade ago) is particularly noteworthy. Decision makers are advised to give substantial weight to ‘innovative technologies’ which will assist with achieving decarbonisation targets.
Net Zero Strategy: Build Back Greener (October 2021)
This week the Government published its Net Zero Strategy for the UK which sets out the next steps it intends to take in reducing emissions, seizing the economic opportunities which exist and leveraging further private sector investment: to delivering the commitments outlined in the Ten Point Plan of 2021 and fully decarbonising our power supply by 2035.
The strategy re-states its commitment to supporting the delivery of 40GW of offshore wind and 5GW of hydrogen production capacity by 2030; the delivery of four carbon capture utilisation and storage clusters (CCUS) and becoming a world leader in the production of Sustainable Aviation Fuel; with £180million of funding available to support the development of new production facilities. There is also commitment to securing a final investment decision on a large-scale nuclear plant by the end of the current Parliament. The strategy also restates its commitment to a review of the National Policy Statements (above); streamlining of the decision making process for national significant infrastructure projects (NSIPs) and reform of the National Planning Policy Framework (NPPF).
What else is expected in 2021 and beyond?
Over the coming months and into 2022, numerous local development plans across England will continue to be the subject of review and updating. It is essential that this next generation of development plans fully reflects the climate change emergency and the national objectives around net-zero. They should seek to incorporate strategic policies to promote renewable and low carbon energy and, wherever possible, seek to proactively identify areas suitable for renewable energy development by liaising with and inviting input from industry and recognising the potential to link new site allocations for housing and employment development with new energy infrastructure provision.
Our asks: consultation and consistency
The range of documents and strategies issued by UK Government relating to the energy sector and deployment of energy infrastructure has notably increased in the period since autumn 2020, reflecting the Government’s desire to demonstrate its climate change leadership credentials ahead of COP26 and also to ensure that a clear strategy for, and pathway to, net-zero by 2050 and legally binding targets within the Sixth Carbon Budget are established. We would make the following requests to UK Government:
- Commencement of consultation on new draft NPS documents is welcomed and provides the opportunity for national planning policy to ‘catch-up’ with the emergence and evolution of new and more established technologies, as well as to create the flexibility within the planning system to support innovative technologies as they emerge in the current years.
- Once finalised, a clear and consistent suite of revised NPS will provide industry with the certainty and confidence to continue to invest in energy infrastructure, at scale as will a streamlined decision making process for NSIP’s; early consultation on which would be welcome. Recognition of the ‘climate emergency’ as a material consideration in the decision making process (as is the case within the emerging NPF4 in Scotland) would also be a welcome addition.
- A review of NPPF policies. NPS policy documents are only directly relevant to Nationally Significant Infrastructure Projects and, whilst material considerations in the determination of applications under the Town and Country Planning Act regime, we welcome the proposed review of NPPF policies relating to energy infrastructure.
- Policies within the NPPF have failed to keep pace with the evolution of existing / emerging technology and there is an increasing risk that proposals for hydrogen production (green and blue) and energy storage in particular may face into a policy vacuum at national level that subsequently causes further difficulties in the formulation of individual development plans. Such a review would also provide the opportunity to consider a relaxation of the effective moratorium against onshore wind energy in England, and resolve the current conflict with the Energy White Paper which recognises the important role that established technologies such as onshore wind have to play in the immediate term in the journey to net-zero by 2050.
For more information on the climate emergency, green energy or our work in England, please contact Mark Worcester. To find out more about the Scottish position, please click here.
21 October 2021