New UK National Policy Statements on Energy - but not nuclear!

The UK is revamping its energy plans, with, as noted in an earlier post, a new Net Zero Policy now out. In parallel it is revising its National Policy Statements (NPSs) on energy-related infrastructure planning.  National Policy Statements are overviews designated under the Planning Act 2008 to provide guidance for decision-makers on the application of government policy when determining development consent for major projects. So they set the ‘on the ground’ reality of policy. 

The current suite of NPS on energy were designated by the Department of Energy and Climate Change in 2011, and are now quite dated. The full set consists of the overarching EN1 NPS, EP 2 on Fossil fuel electricity generating infrastructure, EN3 on Renewable Energy Infrastructure, EN4 on Gas supply infrastructure & gas and oil pipelines, EN5 on Electricity Networks Infrastructure and EN6 on Nuclear Power Generation. The 2020 Energy White Paper Powering our Net Zero Future, committed the government to completing a review of the existing energy NPS to ensure they reflected current energy policy, and that the UK continued to have a planning policy framework which could deliver investment in the infrastructure needed for the transition to net zero. Time is now up for that review. 

The principal purpose of the new NPS consultation, launched in Sept, is to identify whether the revised energy NPS that has been presented are fit for purpose i.e. whether they provide a suitable framework to support decision making for nationally significant energy infrastructure. Most of its proposed adjustment are uncontentious, just updating the various targets, and planning regimes. Onshore wind is now mostly a matter for local council planners, while some smaller PV solar projects may also be exempted from central government review as Nationally Significant Infrastructure Projects, as may some storage systems, but not pumped hydro- that’s usually larger.  

However, some may want to challenge the assumed view that ‘our future generation mix will come from a range of sources including renewables, nuclear, low carbon hydrogen; with residual use of unabated natural gas and crude oil fuels for heat, electricity, transport, and industrial applications, as we transition’. And some may not be too happy with the assumptions that ‘our future energy system will also utilise a range of more nascent technologies, data, and innovative infrastructure projects including CCS, flexibility and green house reduction technologies’.

For good or ill though, these are the governments policies- so for now we are stuck with them- carbon capture and storage (CCS) included.  But it seems we are also to be stuck with an unchanged EN6 on nuclear. The consultation paper notes that ‘EN-6 currently sets out the planning and consents regime for nuclear projects deployable before 2025. A review of EN-6 has concluded that EN-6 will not be amended as there are no changes material to the limited circumstances in which it will have effect. As no amendments are being made to EN6, it is not part of this consultation’.

It’s hard to see a justification for that- the nuclear situation has changed dramatically in terms of costs and technology, and also planning issues such as flood risk/sea level rise, but evidently, with nuclear (funding!) policy still in flux, the government doesn’t want to be rushed into a new nuclear framework. So ‘EN-6 will continue to have the role set out in the 2017 Written Ministerial Statement during the development of any new nuclear NPS. It will continue to have effect for any nuclear electricity generation infrastructure deployable before 2025, or for applications to amend development consent for such generation. It also provides information, assessments and statements which may continue to be important and relevant for projects which will deploy after 2025. This may include those projects which enter examination before designation of any amendments to EN-1 (as outlined in section 1.6 of EN-1) as well as those that enter examination after designation of any amendments to EN-1’.

However, the Government says that at some point it envisages consulting on ‘a siting approach for new nuclear developments deployable post 2025, as the next stage in the process to develop any new draft nuclear NPS. Further information will be published in due course’. Well yes, with Small Modular Reactors on the agenda, they will need to do that, and more. The consultation says: ‘A new NPS for nuclear electricity generation infrastructure deployable after 2025 will be developed to reflect the changing policy and technology landscape for nuclear’. 

Clearly then, even if it doesn’t want to get into details now, the government sees nuclear as key issue. It is interesting that the revised EN1 overview includes a brief assessment of alternative approaches - for example, with nuclear and unabated gas-fired plants excluded. It says excluding them would have materially adverse impacts on Security of Supply as it would be ‘reliant on technologies still under development such as Hydrogen and Energy Storage at scale to ensure peak supply and maintain the stability and security of the electricity system.’ and there would also be ‘larger areas of land and sea required for renewables and natural gas with CCS to meet the same energy output as EN-1’. And it concludes that ‘none of these alternatives are as good as, or better than, the proposals set out in EN1 and therefore the government’s preferred option is to take forward the proposals set out herein’ i.e. with nuclear and some unabated gas, included. 

That might of course include the use of non-fossil gas. EN4, the gas NPS, says ‘in line with our hydrogen ambitions - 5GW by 2030 - we have included references to hydrogen generation in the introductory narrative. We have not however covered hydrogen in detail, since the policy surrounding hydrogen infrastructure is still in development. Our upcoming hydrogen strategy will provide further detail on our approach’.

Although it does not go into any more detail, the revised EN1 overview does however push nuclear strongly: ‘Nuclear plants provide continuous, reliable, safe low-carbon power. They produce no direct emissions during operation and have indirect life-cycle GHG emissions, comparable to off-shore wind. Power stations with an estimated lifetime of 60 years provide large amounts of low carbon electrical power, using a relatively small amount of land. Nuclear, alongside other technologies could also offer broader system benefits, such as low carbon hydrogen production through electrolysis, or low carbon heat. In addition, nuclear generation provides security of supply benefits by utilising an alternative fuel source to other thermal plants, with a supply chain independent from gas supplies’.  

Looking to the future, it adds ‘our analysis suggests additional nuclear beyond Hinkley Point C will be needed to meet our energy objectives. Nuclear technology is developing and opportunities for flexible use may grow as the energy landscape evolves. The role of nuclear power could be fulfilled by large-scale nuclear, Small Modular Reactors, Advanced Modular Reactors, and fusion power plants’.

So new nuclear is hard-wired into the whole thing, despite there being no EN6 review and no assessment of its comparative economics, which arguably has changed a lot since 2011! But maybe that, and the contentious issue of whether there is a demand-led need for nuclear, will be attended to in response to reactions to this new NPS consultation …and to the Net Zero plan. But maybe not- the Whitehall mood music at present seems to be all nuclear.