How the Onshore Wind Strategy changes the landscape for planning applications
By Chris Calvert, Director of Planning
Onshore Wind Strategy
On the back of a deluge of Government announcements supporting the development of infrastructure across the UK, including this week’s UK Solar Road Map and the recent Industrial Strategy, which seeks to reduce energy costs for some of the UK’s main industrial consumers, a further step has been taken today in the publication of the Onshore Wind Strategy. Today’s Strategy puts forward six policy themes and 42 resultant actions that are intended to continue to help revive the development of onshore wind in England – these six themes being:
- Site selection, preparation and consenting
- Networks and system planning
- Communities and public perception
- Aviation and defence
- Finance and route to market
- Supply chain, skills and workforce
The fundamental tone is that the Government is pushing ‘radical action to unlock 27-29GW of onshore wind by 2030 across Great Britain’. This is quoted as being around 10-12GW more than would have been deployed under historic growth rates, with England contributing around 2GW by 2030. The strategy seeks to address the barriers to onshore wind development across the UK.
Seeking to follow in the footsteps of the Scottish Government’s 2022 onshore wind policy statement, the Government has outlined a clear and concise direction of travel for development in this Onshore Wind Strategy, while affording developers a degree of flexibility that they need to succeed.
Out of the themes and 42 actions announced today as part of this Onshore Wind Strategy, we have identified the following key points that are set to have a lasting impact on planning applications and approvals in England.
1. Site selection
The Government recognises that developers will take into account a whole range of site selection criteria, stating that they have a ‘mature approach’ to the use of data. However, planning authorities and consultees do not have access to that data. The strategy seeks to address this and develop a prototype data tool for their use, combining industry data with other relevant data.
In our experience, the Government is quite correct about the mature approach to site selection by developers, it is hoped that this correlation of data will result in a greater acceptance of those factors and assist in the decision-making process – but as we all know, how any data tool is deployed and interpretated can be subject to other factors when it comes to decision-making itself.
How this all links up with the Strategic Spatial Energy Plan (SSEP) remains to be seen, particularly as the SSEP is expected to assess and identify ‘the optimal locations, quantities and types of energy infrastructure required for generation and storage, including onshore wind, to meet our future energy demand with the clean, affordable and secure supply that we need.’
2. Ambitious new reforms to improve the planning system, resulting in streamlined consenting.
The focus here being updating planning policy and guidance to ensure that planning decisions are based on up-to-date technical information and evidence.
This is to drive meaningful change through the planned overhaul of national planning policy and guidance documents. To say that the National Policy Statements for Energy Infrastructure (NPS) and the Renewable and Low Carbon Energy Planning Practice Guidance (PPG) are long overdue would be an understatement. The last onshore wind NPS dates back to 2011, and the PPG has not been substantially updated since 2015 (in respect of onshore wind). Technology has advanced significantly over the last decade, with modern wind turbines often double the size of their predecessors. This has left existing guidance outdated and inefficient, with a ‘laggy’ policy framework.
Helpfully, the Government has today laid out a new timeline for the reintegration of onshore wind into the NSIP regime, with promises to designate an updated NPS by the end of 2025. An updated PPG will follow in Autumn 2025, with a full alignment of planning policy and guidance across the system expected in Spring 2026.
Alongside this, the Government has committed to working with key stakeholders to refresh supporting documents and methodologies, including reviewing best practice guidance on landscape and visual impact assessments so that it aligns with approaches taken in Scotland.
This should all be welcomed and represents a significant opportunity to streamline planning processes, reduce ambiguity, and ensure decisions are informed by contemporary evidence and experience. However, questions remain over the ‘localised effect’ of onshore wind and further guidance is still needed on the role that spatial guidance can play in development.
3. Reintroduction of onshore wind into the NSIP regime
As part of the reversal of the de facto ban on new onshore wind farm development, onshore wind will be reintroduced into the NSIP regime with a new threshold of 100MW. The statutory instrument enacting this change is due to come into force on 31st December this year.
While well-rehearsed, the reintroduction brings welcome consistency, with onshore wind recognised as key part of the UK’s 2030 Net Zero ambitions. When it comes into force later this year, the Planning and Infrastructure Bill will also give the Secretary of State the power to disapply the requirement for a project to be ‘nationally significant’ in order to seek consent under the NSIP regime, providing further flexibility for developers.
Yet, the effectiveness of the revised NSIP regime is not guaranteed and we will need to see further directional guidance from the Government that strikes a careful balance of not being overly prescriptive and still providing a faster paced, proportionate and workable framework, all the while noting the Government’s target to have fast tracked decisions on 150 NSIP proposals by the end of this Parliament.
4. Modernising the existing system of environmental assessments
As stated in today’s announcement, the current approach to onshore wind development (as with lots of other types of development) could lead to a disproportionate amount of assessment.
For what could be a potentially grey area, further clarity in this area will be needed and it’s positive to see the Government delivering in today’s Strategy with a promise to modernise the existing system of environment assessments through the introduction of Environmental Outcome Reports and a Nature Restoration Fund. The Government also announced plans later this year to scope a data tool that will help identify suitable sites for onshore wind and better facilitate engagement when assessing these sites. As with all things, the devil will be in the detail, how local authorities will wield this tool; how such a data tool realises and understands commercial viability alongside the nuances of site design and balanced decision making. By the end of the year, we will have more details on the procedure behind the Environmental Outcome Reports, and the Nature Restoration Fund is expected to be brought in as part of the Planning & Infrastructure Bill.
5. Launch of a consultation to update permitted development rights
One of the more potentially more controversial proposals relates to small-scale onshore wind and whether changes to permitted development rights can be made to support its wider uptake. With the Government announcing plans to launch a consultation exploring whether current permitted development rules remain fit for purpose; examining the potential for development that helps support the decarbonisation of the agricultural industry and the repowering or replacement of existing turbines.
Whilst worth exploring, this is an area that may prove particularly difficult to enact. The inherent challenge lies in how to allow larger turbines to be permitted development particularly when considering the potential cumulative environmental, landscape, aviation and noise impact. Our initial thought is that any revised regulations would require some form of assessment that would not be to dissimilar to a planning application – thus actually diminishing the value of what could be determined as permitted development. The consultation will need to grapple with this tension and set clear parameters for what constitutes a low enough impact to be permitted development.
6. Extending time-limited planning consents (implementation and operation) and more guidance for repowering/life extension of existing sites
Longer operational consent timelines and more adaptable commencement periods are being signalled, providing a more realistic window for delivery and operation in today’s challenging energy landscape. Effectively we now have a very clear position that wind farms can and should operate for well in excess of the typical 25 years. This comfortably sits alongside the NPPF’s emphasis upon supporting the repowering and life extension of wind farms where we have secured multiple consents for increased operational times by up to 15 years in some cases.
The NPPG is signalled as being updated to provide more information to developers and planning authorities towards repowering and life extension schemes. This is a positive move, particularly for repowering sites as these become more relevant.
With planning consents granted under the Town and Country Planning Act 1990 currently requiring development to commence within three years or risk expiry, today’s announcement acknowledges the practical constraints that comes with this territory. While intended to prevent speculative applications, in practice the rule has become a stumbling block for many developers, with delays in grid connections and market uncertainty often causing delays that prevent projects from breaking ground within the prescribed timeframe.
7. Community Benefits
Action 15 sets out the Governments position that it will embed best practice principles of engagement into planning guidance, setting a high standard for consultation methods. This sits alongside action 16 and consideration of making community benefits a mandatory element of a proposal.
The Government has actually delivered on these actions this morning, with the publication of updated ‘Community benefits guidance for onshore wind in England’ and updates to ‘Community engagement from onshore wind developments: good practice guidance for England’.
Onshore wind, like most forms of renewable energy has always undertaken extensive consultation and in most cases above and beyond many other forms of development, so I see little change in emphasis or impact here. The making of community benefits mandatory will be gearing change and closing out a grey area and the Government has recently consulted on this – so watch this space!
Industrial Strategy
The recently announced Industrial Strategy is an encouraging signal of intent from the government with a clear focus on providing energy security, economic security, and energy diversification in the UK. Failing to get our house in order in terms of delivering enough homes, such as through the removal of planning barriers, and on this critical energy supply issue will lead to the UK falling further behind other countries in terms of productivity growth, which will be sharply followed by a stark decline in the country’s quality of life. These recent decisive governmental strides are important; however, it is concerning that onshore wind and solar energy only get one mention each in this 160 paged 10-year plan, especially when considered in the context of the UK’s plans to become a clean energy manufacturing and innovation superpower.
A shift in pace and tone
Today’s Onshore Wind Strategy marks a notable shift in the tone and approach to onshore wind in England, making the UK a more attractive place to build and invest. Over the next five years, onshore wind output will need to double if the UK hopes to hit its Net Zero targets, and while many of the Reforms will take time to implement, today’s announcement lays the groundwork for a more coherent, flexible and modernised planning regime that gives us a fighting chance to get there.