Whilst much of the attention in respect of the proposed reforms to the NPPF has focused on policies relating to housing, viability, and what constitutes a reasonable walking distance to a well-connected train station, there are significant policy changes proposed for all types of development.
Renewable and low carbon energy development and electricity network infrastructure are no exception, and in this article I take a whistle-stop review of the updates that are proposed and how they would shift the position for the consenting of these projects, so that there is a greater certainty of them being consented and delivered to meet the challenges of the energy trilemma.
Those policies would also be brought into effect following the increase of thresholds for solar and onshore wind projects to be NSIPs requiring a DCO to 100 MW following the coming into effect of the Infrastructure Planning (Onshore Wind and Solar Generation) Order 2025 on 31st December 2025, and provisions included in the Planning and Infrastructure Act 2025 allowing NSIPs to opt-out of the Planning Act 2008 (yet to come into force), meaning there will be greater instances where the NPPF policies are a primary material consideration for renewables and low carbon energy developments.
Extended and new definitions
What constitutes “Renewable and low carbon energy” has been subject to amendment, to clarify and extend the scope of such projects and in turn the application of relevant policies. The revised definition, with the additions underlined and emboldened below, is as follows:
Renewable and low carbon energy: Includes energy for heating and cooling as well as generating electricity. Renewable energy covers those energy flows that occur naturally and repeatedly in the environment – including from the wind, the fall of water, the movement of the oceans, from the sun and also from biomass and deep geothermal heat. Low carbon technologies are those that can help reduce emissions (compared to conventional use of fossil fuels). This includes, but is not limited to, nuclear power and supporting infrastructure, as well as low carbon fuels such as biomethane, hydrogen and heat from recoverable sources, such as heat recovered from data centres, as well as the storage of renewable and low carbon energy, such as Battery Energy Storage Systems (BESS).
This revised definition includes some interesting additions, such as “heat from recoverable sources, such as heat recovered from data centres” which would potentially allow for policies supporting renewable and low carbon energy to lend further support to data centre developments which include for the recycling of waste heat (aside from considering co-located data centre and power projects).
There is also the explicit recognition of biomethane related development as the government prepares for upscaling of production to meet some the Country’s continuing need for gas into the future, further to the publication by NESO of the first annual Gas Security of Supply Assessment and within this the identification of a near three-fold increase of biomethane production capacity by 2036.
In addition, there is also now a definition included for ‘electricity network infrastructure’, as reference to this is added to policies relating to plan making and decision-taking focused on securing clean energy developments:
Electricity network infrastructure: Infrastructure that facilitates the transmission of electricity from generation sources to end users, including transmission, distribution, and interconnection. This infrastructure is essential for the operation and expansion of the electricity network and includes components such as substations, converter stations, interconnectors, and cables.
Policies W1 and W2 – Co-ordinated and more forceful plan making requirements
Central to the delivery of a more pro-growth and pro-infrastructure planning system is the centralisation of the plan-approach to follow a tiered national, regional and local hierarchy, and within the NPPF policies are proposed to ensure the co-ordination of plan-making for energy development with the ongoing work of the NESO.
Paragraph 156 of current the NPPF which is the key plan-making policy relating to renewable and low carbon energy development is, in my view, weak. It requires (inter alia) a “positive strategy” to “help increase the use and supply or renewable and low carbon energy” whilst “ensuring that adverse impacts are addressed appropriately” and for plan makers to “consider identifying suitable areas or renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development”. Not exactly full-throated support for much needed renewable and low carbon energy development, possibly because it has been the role of NSIPs and the associated energy NPSs to provide the policy basis for this infrastructure, somewhat siloed from the TCPA regime.
But that is no more, as policies W1 and W2 provide a much clearer instruction for how developments plans must be produced to ensure that energy development forms a central element.
This includes that “[t]he development plan should be informed by early engagement between the relevant plan-making authority, utility providers, regulators and network operators, so that there is a clear understanding of energy supply and network capacity … and associated requirements for additional infrastructure provision” and that “[t]his engagement should take into account the impacts of planned growth, changing consumption patterns and climate change, as well as relevant infrastructure plans, and be used to address potential constraints to development arising from current or anticipated infrastructure shortfalls.”
The strategic plans that should be taken into account include, once they are published, the Strategic Spatial Energy Plan (SSEP), Centralised Strategic Network Plan (CSNP) and Regional Energy Strategic Plans (RESPs) currently being prepared by NESO. Needing to account for the content of those plans which are still in production may have some knock-on implications for the production of new spatial development strategies and local plans, as in the short-term plan-making timings become complicated by overlapping emerging policy and plans in multiple respects.
Building on the above plan-making requirements, Policy W1 will further require the development plan to “[make] provision for development which is required for new or enhanced renewable and low carbon energy development [and] electricity network infrastructure … whether as part of wider development proposals or as stand-alone developments”, and that they should also “[set] out any measures to avoid constraints on the operation or future expansion of renewable and low carbon energy development and electricity network infrastructure … as a result of neighbouring (or nearby) development”, thereby more positively providing for the delivery of and protection for this type of development from other forms of development, as opposed to placing the emphasis on such development to show how it has addressed its adverse impacts.
Policy W2, which is more particularly focused on how the development plan will secure the delivery of renewable and low carbon energy and electricity network infrastructure, will also require developments to identify (in place of the current requirement for plan-makers to only consider identifying) “[a]reas which are suitable for renewable and low carbon energy development and electricity network infrastructure, including for future re-powering and life extension, where this would help secure their development”.
Policy W2 will also introduce a clearer requirement for the identification of “ [o]pportunities for development to draw its heat or energy supply from decentralised networks (such as district heat networks), renewable or low carbon energy supply systems, and for co-locating potential customers and suppliers of surplus heat or energy”, drawing out the need to address decentralised heat and energy systems in equal measure in the development plan.
Policy W3 – More supportive decision making policies
Having required a much clearer and positive approach to planning for the delivery of renewable and low carbon energy and electricity network infrastructure, the national decision-making policies provide for increases to the weight which should be applied to the benefits of renewable and low-carbon energy development and electricity network infrastructure.
Policy W3, which is the replacement of paragraph 168 in the current version of the NPPF, provides that “substantial weight should be given to … the benefits of such development for improving energy security, supporting economic development and moving to a net zero future”, in replacement for “significant weight” being given only to the “the proposal’s contribution to a net zero future”.
Substantial weight would also be required to be given to the additional benefit of utilising an established site in the case of applications for the re-powering and life-extension of existing sites, so in addition to the substantial weight that is required to be given to the benefits of such development more generally. This would replace the current NPPF requirement to only give significant weight to the benefits of such applications on a non-addition basis.
Substantial weight is further required to be given to “[t]he contribution that small-scale and community-led renewable and low carbon energy projects can make to reducing emissions, along with their associated economic and social benefits”, in place of the previous requirement to only recognise that such projects make a valuable contribution to cutting greenhouse gas emissions.
The proposed decision-making policies far more clearly relate to addressing all elements of the energy trilemma instead of only focusing on net zero and would provide a much more positive basis on which to address the adverse impacts of such projects in the planning balance, by virtue of the substantial weight which must be given to the holistic benefits of such projects.
Policy W3 would also provide that applicants should not be required to demonstrate the need for renewable or low carbon energy development and electricity network infrastructure, which is a shift from the current policy at paragraph 168 of the NPPF that applicants should not be required to demonstrate “the overall need for renewable and low carbon energy”.
The policy would also provide greater scope for such development to come forward outside of areas which have been identified as suitable for them, by providing that “they should be acceptable when assessed against the national decision-making policies in this Framework, taken as a whole”, in place of the requirement currently provided for at paragraph 169 of the current NPPF for such projects to demonstrate that “the proposed location meets the criteria used in identifying suitable areas”. This may prove to be a very helpful policy update in the transitional period whilst updated development plans are produced.
Increased green belt and grey belt prospects
And leading on from the above, there is also a more positive policy position for renewable energy and low carbon development and electricity network infrastructure proposed on green belt land.
Policies in relation to inappropriate development in the green belt remain largely unchanged. Whilst there is no longer policy which states that when located in the green belt elements of many renewable energy projects will comprise inappropriate development, policy is again included to identify that “[i]n the case of proposals for renewable and low carbon energy development, very special circumstances may include the wider environmental benefits associated with increased production of energy from renewable sources”. Of course, unless accounted for within the scope of what is not to be taken as “inappropriate development” in the green belt, such development would be just that.
However, substantial weight will now need to be given to the benefits of renewable energy projects in accordance with Policy W3 and accounted for when considering whether the potential harm to the Green Belt by reason of inappropriateness and any other harm resulting from the proposed development is clearly outweighed, meaning such proposals have a greater prospect of securing consent.
That prospect is also potentially assisted by being able to assess the acceptableness of such development against the other decision-making policies in the NPPF, taken as a whole, to determine whether it is acceptable, as opposed to being required to demonstrate that the proposed location of a project, in the green belt, meets the criteria used for identifying suitable areas for such development (which in all but very few circumstances would not be achievable).
It is also proposed that electricity network infrastructure is included within the scope of development which is not inappropriate development in the green belt where it can be shown that the impact on the openness of the green belt is minimised and there would not be a significant conflict with green belt purposes.
And it is also worth noting that as the need for renewable and low carbon energy development and electricity network infrastructure should not be required to be demonstrated and is therefore assumed, such development also has the potential to not be inappropriate development where this is located on grey belt land and it can be shown how the other relevant tests now provided at draft policy GB7 (g) (or paragraph 155 in the current NPPF) are satisfied.
Concluding remarks
The proposed changes to national planning policy would ensure thorough regional and local planning for the delivery of renewable and low carbon energy development and electricity network infrastructure, and would also place such development in a much more positive position from a decision-making perspective.
The decision making policies in the new NPPF will come into effect from the date the new NPPF is published, and development proposals will benefit from the proposed policy that any development plan policies which are inconsistent with the national development management policies introduced in the new NPPF are to be given “very limited weight”, as discussed in my recent article on planning reform more generally in 2026 published in the Estates Gazette.
As such, there are likely to be significant opportunities for projects to benefit from the more favourable national decision making policies in the transitional period as new plans come forward, and not to be held back by development plan policies which do not yet comply with what those policies provide for whilst new development plan documents are produced.
The consultation on the new NPPF runs to 10 March 2026, and it is important that where the changes are supported responses are given to this effect.
If you have a proposal which may be impacted by the proposed updates and would like more information on them and their impact, including how to plan for your project to benefit from the policy changes in due course, please do get in touch.