Key provisions
A new chapter for energy infrastructure
Reflecting its importance, the NPPF contains a new chapter dedicated to improving the delivery of energy and water infrastructure (Chapter 10). This forms part of the wholesale restructuring of the NPPF, which now establishes overarching topic-based objectives and distinguishes between policies for ‘plan-making’ and those for ‘decision-making’.
It confirms that the overarching objective of the policies in the chapter is to support the development and operation of energy infrastructure “in ways which align with wider development, clean power and net zero objectives (including the delivery of clean power by 2030)”.
Plan-making policies
The NPPF requires local authorities and other stakeholders to be more proactive in creating the conditions necessary to support and facilitate renewable and low carbon energy development.
Development plans must be informed by much greater engagement with utility providers, regulators, and network operators, and must consider the implications of relevant strategic infrastructure plans such as the Strategic Spatial Energy Plan.
They must also make provision for development required to support new or enhanced renewable and low carbon energy development and electricity network generation. Measures to avoid constraints on the operation and future operation of energy infrastructure must be set out (Policy W1).
In addition, plans must be prepared positively to facilitate an increased supply of renewable and low carbon infrastructure. They should maximise the potential for development by identifying areas suitable for energy infrastructure, including for re-powering and life-extension, where this would help secure delivery (Policy W2).
Plans are also encouraged to require new development to identify opportunities to draw heat or energy from decentralised networks (such as district heat networks), renewable or low carbon energy supply systems (Policy W2).
The requirement for local planning authorities to engage with and positively plan for renewable and low carbon energy at the plan-making stage is extremely positive. It also creates opportunities for developers to engage in the plan-making process in a more proactive manner by promoting sites for allocation, including where this may assist with re-powering and life-extension proposals.
Decision-making policies
The weight to be applied to the benefits of improving energy security, supporting economic development and the transition to a net zero future is elevated from ‘significant’ to ‘substantial’. As is the weight to be applied to the benefits of utilising an established site (in the case of re-powering and life-extension), and the contributions of small-scale and community-led projects to emissions reduction and their associated economic and social benefits (Policy W3).
This update is hugely positive, particularly in relation to the repowering and life- extension of existing assets which, as the identification of suitable new development sites becomes increasingly challenging, makes the optimisation of existing operational sites ever more attractive.
The policy changes are even more significant when read in conjunction with the provisions of Policy S5 (which relates to development outside settlement boundaries: which would apply to most energy infrastructure projects).
Policy S5 confirms that proposals for energy infrastructure “should be approved” unless the benefits of doing so would be “substantially outweighed” by any adverse effects, when assessed against the national decision-making policies in the NPPF.
This adjustment in policy is extremely welcome. Together, these policies create a positive framework within which to bring schemes forward. The revised wording materially increases the weight afforded to the benefits of energy infrastructure and raises the threshold at which adverse impacts may justify refusal; the dial has shifted to the extent that adverse effects (either individually or cumulatively) would need to be of a magnitude that they would “substantially outweigh” the benefits of a scheme.
In practical terms, the revised policies should improve the prospects of proposals such as solar farms, battery energy storage systems, onshore wind development, heat recovery, grid infrastructure and schemes involving the repowering of existing renewable energy facilities securing permission, particularly where adverse impacts can be effectively managed. It will also support industrial decarbonisation proposals, including carbon capture, utilisation and storage, as well as low-carbon fuels, such as hydrogen, biomethane and sustainable aviation fuels.
The policy changes could also support the promotion of schemes at a greater scale, or in locations previously considered more challenging from a planning perspective, subject to site-specific considerations and good design.
Whilst the amendments are positive, proposals for renewable and low-carbon energy generation/storage in the Green Belt remain subject to separate policy tests. Applicants will therefore continue to need to demonstrate Very Special Circumstances (which Policy GB6 confirms may include the wider environmental benefits associated with increased production of energy from renewable sources), and the favourable provisions of Policy S5 would not provide the same degree of assistance as they would elsewhere.
It is however encouraging to see under Policy GB7 that electricity network infrastructure, required in a Green Belt location, is “not inappropriate”, provided the impact on the openness of the Green Belt is minimised, and there would not be a significant conflict with the Green Belt purposes.
Revocation of WMS and other planning policy
Annex 1 confirms that the content of various Written Ministerial Statements and other documents, where it relates to planning policies or decisions concerning renewable and low-carbon energy, has either been fully or partially incorporated within the NPPF or no longer represent up-to-date Government policy.
This should provide greater clarity for applicants and decision-makers by consolidating relevant policy provisions within the NPPF itself and reducing reliance on a dispersed suite of ministerial statements and associated guidance.
Concluding thoughts
The Government has outlined its ambition for Britain to be a ‘clean energy superpower’, and the revised NPPF gives practical effect to this. It creates the most positive planning policy framework in which to promote proposals for renewable and low-carbon energy for over a decade. Further clarity is anticipated through the forthcoming update of Planning Practice Guidance, which is expected to add additional support to the development of energy infrastructure.
However, as those who have worked with the energy sector for many years will recall, energy policy can be subject to shifting political ideologies and this positive policy environment will not last forever.
Whilst remaining mindful of the other constraints to project delivery such as grid connection reform, and the need to ensure that sites are carefully selected and schemes sensitively designed, the NPPF provides clear encouragement.
For developers, landowners and investors, the message is clear: the policy framework is now strongly supportive of renewable and low-carbon energy development, and those seeking to bring forward projects in England should carefully consider how best to take advantage of this opportunity.
To discuss the impacts of the revised NPPF on energy infrastructure, please get in touch with a Mark Worcester, Thomas Lord or Nicola Riley.
4 September 2026
