About the RTPI
The Royal Town Planning Institute (RTPI) champions the power of planning in creating sustainable, prosperous places and vibrant communities. We have over 27,000 members in the private, public, academic, and voluntary sectors. Using our expertise and research we bring evidence and thought leadership to shape planning policies and thinking, putting the profession at the heart of society's big debates. We set the standards of planning education and professional behaviour that give our members, wherever they work in the world, a unique ability to meet complex economic, social environmental and cultural challenges.
This response
While National Policy Statements relate to both England and Wales, the following RTPI response relates to England only.
Further information on the Welsh Energy Policy Framework can be found in Energy Wales: A Low Carbon Transition and Energy Wales: A Low Carbon Transition Delivery Plan. Future Wales - The National Plan 2040 and Planning Policy Wales also refers to energy infrastructure in Wales,
The RTPI's comments in relation to England are set out below.
Clean Power 2030
1. To what extent do you think the inclusion of Clean Power 2030 policy in EN-1 provides sufficient guidance for developers to bring forward relevant projects?
The inclusion of Clean Power 2030 policy in EN-1 provides important linkage between energy and spatial planning, and hence will improve policy clarity for developers. It gives guidance on what applicants can do to adhere to time scales and to bring forward prioritised projects.
However, the guidance to decision makers could be strengthened. EN-1 can further set out the urgent need to deliver these projects by 2030 and 2050. Furthermore, the RTPI would wish to see a clarification that the regional capacity ranges are not to be interpreted as targets and do not represent a cap or limitation on localities who should be encouraged to go quicker and beyond the ranges if possible.
Stakeholders such as local authorities and statutory nature conservation bodies are also important stakeholders in the process. Sufficient and appropriate resources should be made available to them.
These are not currently present. An MHCLG survey found 45% of local authorities in England having a skill gap in energy and climate change. This is in line with the knowledge gap the RTPI observed in the report Spatial Approaches to Local Energy Planning.
Resources and guidance to help these stakeholders properly engage with the process will help manage conflicts and limit delay further down the line.
2. To what extent do you think updates to the Critical National Priority policy help bring forward higher-quality?
The draft EN-1 now provides clearer guidance on how applicants, local authorities and statutory consultees should engage with the consenting process. It is particularly positive to see the needs of local planning authorities and statutory advisors for assessable information addressed in 4.2.14 – given the resource constraints mentioned in our response to Question 1.
EN-1 would benefit from clarification that Critical National Priority (CNP) applies to projects which fall within the remit of the Clean Power 2030 Action Plan and to the relevant genres of low-carbon infrastructure set out in paragraphs 4.2.17 – 4.2.18 and defined in the Glossary.
The government has tabled amendments to the Planning and Infrastructure Bill to remove the statutory requirement for pre-application consultations. Guidance on engagement is expected to be published to shape future pre-application consultation processes. To ensure the quality of applications, it will be important that the guidance is written in a clear manner and takes communities’ needs into account.
While the amendments will not come into force for some time, the NPS should provide policy in relation to effective and meaningful engagement, rather than focusing on processes as at present.
More generally, provisions in the Planning and Infrastructure Bill and the introduction of the Land Use Framework are not yet reflected in the draft NPS. It will be important that these developments are fully accounted for to ensure alignment and consistency.
Onshore Wind
3. Do you have any comments or amendments on any aspects of the new guidance for onshore wind?
The RTPI warmly welcomes the provision of the new guidance bit notes that EN-3 could benefit from clarity on what is required around onshore windfarms and Protected Landscapes, this is particularly relevant in regards to compliance with the duties in section 245 (Protected Landscapes) of the Levelling-up and Regeneration Act 2023.
Offshore Wind
4. Do you have any comments on any aspects of the updated guidance for offshore wind?
No comment.
Electricity Networks Infrastructure
Endorsement of the Centralised Strategic Network Plan
5. Do you agree with the proposal in EN-5 to endorse the electricity transmission recommendations set out in the CSNP to accelerate consenting times and support the upgrade of the electricity grid?
Yes. It is positive to see that there will be alignment between EN-5 and the CSNP.
Beyond the CSNP, a clearer relationship and hierarchy should be set out between various plans and strategies. These include the Strategic Spatial Energy Plan, CSNP, Land Use Framework, the 10-Year Infrastructure Strategy and other emerging national-scale spatial plans. This can come in the form of a National Spatial Framework, as the RTPI has suggested.
The NPS should sit at the top of the hierarchy, defining policy objectives and intended outcomes. This will avoid unnecessary debates on weight and priority in examination and determination.
6. Do you have any comments on the proposal?
No comment.
Reference to the Electricity Transmission Design Principles
7. Do you agree with the proposal in EN-5 to reference the ETDP and to set out that developers should have regard to the ETDP, as relevant, in addition to the Holford and Horlock rules?
No comment.
8. Do you have any comments on this proposal?
No comment.
Other content you might be interested in
RTPI Scotland response to consultation on Community Benefits from Net Zero Energy Developments
RTPI submission to the Energy Security and Net Zero Committee inquiry
