From the article Onshore wind, solar power, and the new NPPF – Not just “hot air” by Liora Lederman (Nathaniel Lichfield & Partners Blog, 9 January 2025)

Summary

This article (generated with the help of NotebookLM) summarises the key changes to the National Planning Policy Framework (NPPF), specifically concerning onshore wind and solar power projects, as outlined in a blog post dated 9 January 2025. The revised NPPF, published in December 2024 following a consultation process, marks a significant shift in government policy, particularly with the reintroduction of large-scale onshore wind projects into the Nationally Significant Infrastructure Project (NSIP) regime. The thresholds for NSIP inclusion for both onshore wind and solar projects have been adjusted, impacting the planning routes for medium-sized developments. These changes are expected to be formally implemented through the Planning and Infrastructure Bill in Spring 2025, with a transitional period until the end of the year.

The overall conclusion we take from the article is that renewable energy companies much prefer to use the local planning process rather than what they see as a much more time consuming and expensive national planning process. This helps to explain Cubico’s haste to get their application through as soon as possible.

Key Themes and Important Ideas/Facts Relevant to Cubico’s Proposals

1. Reintroduction of Onshore Wind into the NSIP System

• A major outcome of the NPPF revision is the reintroduction of onshore wind projects into the centralised NSIP system, reversing a 2015 decision.
• This move aligns with the Government’s Policy Statement on Onshore Wind (July 2024), which committed to “double onshore wind energy by 2025” and removed previous policy tests that made approvals difficult.
• The current Labour Government views onshore wind as crucial for meeting its clean energy targets and the “Government’s Clean Power Mission “to tackle the climate crisis””.
• The threshold for onshore wind projects to be considered NSIPs will be raised to those generating at least 100MW of power (which is the stated output for Cubico). Projects below this capacity will proceed through the regular local planning route under the Town and Country Planning Act 1990 (TCPA).
• The government aims to create a “more even playing field for large-scale onshore wind projects and accord them the same importance as large-scale offshore wind and nuclear projects.”

2. Rationale and Implications of the Changes

• The government believes the reintroduction of onshore wind into the NSIP process reinforces the importance of the Development Consent Order (DCO) process for the nation’s largest infrastructure projects.
• While acknowledging the “challenges presented by the DCO process including time and expense,” the author argues it is “appropriate that large-scale NSIP schemes with wide-reaching impacts should be considered against national criteria… with the Government as the key decision-maker.”
• Those in the renewable energy industry were “broadly evenly split between those advocating the DCO process and those opposed” during the consultation.
• The increased NSIP thresholds aim to streamline the planning process, with larger projects considered nationally and medium-sized projects progressing locally.

3. Transitional Arrangements and Future Outlook

• The Planning and Infrastructure Bill, planned for Spring 2025, will formalise these legislative changes.
• A transitional window until the end of 2025 will allow the industry time to prepare and provide flexibility for ongoing projects.
• Developers will still have the option to “‘opt in’ to the DCO process” for projects below the threshold under Section 35 of the Planning Act 2008 by requesting inclusion from the Secretary of State.
• The inclusion of more onshore wind projects in the DCO process “will potentially provide greater certainty on planning timelines for developers and other relevant stakeholders.”
• Medium-sized solar and onshore wind projects may see “increased speed” in the local planning system, particularly given the government’s prioritisation of solar energy.
• The government has acknowledged the need for “increased resourcing” within the NSIP system to handle a potential rise in onshore wind applications.
• It remains uncertain whether developers will consistently submit projects just below the 100MW threshold to avoid the DCO process, as was the trend with 49.9MW solar farms.
• The changes “reassert the Government’s commitment to both onshore wind and solar power projects” and signify a continued reliance on the DCO process for large-scale infrastructure.
• Increased applications through the local planning system for medium-sized projects could potentially lead to “longer timescales than originally anticipated due to increased local authority caseloads.”
• The ultimate impact on the government’s renewable energy ambitions will depend on how the industry adapts to these new thresholds and processes.

Conclusion

The revised NPPF, as detailed in this blog post, represents a significant policy update for the renewable energy sector in the UK. The reintroduction of onshore wind into the NSIP regime and the increased thresholds for both wind and solar projects will reshape the planning landscape for these technologies.

While the government aims to streamline the process for larger projects and provide greater certainty, the potential impact on local authority resources and the strategic decisions of developers regarding project scale remain key considerations for the future of onshore wind and solar deployment.