Written evidence submitted by Sir Bernard Jenkin MP (NPE0033)

Sir Bernard Jenkin MP

Sir Bernard Jenkin is Chair of OFFSET (Offshore Electricity Grid Task Force (2021-)), a cross-party group of MPs who are campaigning for more acceptable and affordable alternatives to new High Voltage Alternative Current Pylons, such as the Norwich to Tilbury proposal.  He was Chair of House of Commons Public Administration Select and Constitutional Affairs Committee (2010-19), Chair of the House of Commons Liaison Committee (2020-2024); and writes and speaks regularly about UK Energy policy.

Clean Power 2030

Do the draft updated energy National Policy Statements provide clear enough guidance to planning decision-makers, to allow them to prioritise nationally significant infrastructure projects that must secure development consent within these timescales?

The inclusion of Clean Power 2030 in EN-1 does not provide sufficient clarity or guidance to enable planning decision makers to prioritise the highest quality nationally significant infrastructure. It fails to provide a shift to High Voltage Direct Current (HVDC) transmission as the standard for new long-distance infrastructure.

HVDC is not only better suited to managing a grid increasingly reliant on intermittent renewables, but it is also far more efficient over long distances and far less environmentally disruptive when undergrounded. It is far cheaper to put underground than HVAC.  Undergrounded HVDC enjoys substantially greater public support than new overhead pylons which is an issue that NESO’s own Clean Power 2030 itself acknowledges, stating that “maintaining public support is vital to the delivery of clean energy ambitions.”[1]

Despite this, EN-1 continues to reinforce the default presumption in favour of overhead HVAC transmission, without requiring the consideration of HVDC alternatives. This is highlighted by the East Anglia Network Study[2] (EANS), published in March 2024 by NESO, which presented a compelling HVDC-based alternative (Option 8) to the Norwich to Tilbury OHL route. Option 8 would have routed offshore wind connections through underground HVDC to the Sealink interconnector, bypassing the need for the proposed EACN substation and avoiding sensitive areas such as the Dedham Vale National Landscape.

Despite Option 8 being only marginally more expensive (£1bn more in cost, but potentially cheaper overall once the £4.2bn annual cost of delay is accounted for, as noted in NESO’s Clean Power 2030 report[3]).

Without clearer guidance in EN-1 that prioritises HVDC, developers will continue to pursue outdated and unpopular OHL. This failure to integrate lessons from studies like EANS into infrastructure design guidance threatens not just individual projects, but the credibility of the entire Clean Power 2030 policy framework.

To support Clean Power 2030 goals, EN-1 must require early-stage HVDC assessment and provide explicit direction to OHL in sensitive or designated landscapes wherever possible.

Strategic planning  

How should the National Policy Statements for energy infrastructure interact with the strategic energy and network plans currently being developed by the National Energy System Operator? For example, the Strategic Spatial Energy Plan and the Centralised Strategic Network Plan. Is this relationship sufficiently clear?  

How should the National Policy Statements take account of emerging government policies affecting energy infrastructure projects and spatial management, such as the Planning and Infrastructure Bill and the Land Use Framework? Are any issues particularly relevant? 

The draft NPSs have been published ahead of key strategic frameworks including the Strategic Spatial Energy Plan (SSEP), the Centralised Strategic Network Plan (CSNP), and the Planning and Infrastructure Bill, all of which will directly shape energy infrastructure decisions.

As a result, planning authorities are being asked to make nationally significant decisions without the benefit of a clear strategic context. This creates uncertainty and risks misalignments between individual projects and broader national objectives. The relationship between the NPSs and these emerging plans is currently unclear and must be explicitly defined.

The NPSs should either be revised once these frameworks are in place or include a clear mechanism for integrating future strategic policies as they are adopted. Without this, there is a real risk of short-term decision-making that conflicts with long-term system planning.

The 2024 updates to the National Policy Statements for energy (EN-1 to EN-5)  

What are the most important changes needed to these National Policy Statements since the last update in 2024 and do the Government’s proposed drafts deliver these?  

How successful were the changes introduced in the last update, including the Critical National Priority policy presumption for low carbon infrastructure? Are any modifications needed?  

The most important change needed is stronger guidance to ensure energy infrastructure is delivered in a way that protects the environment, respects communities, and upholds the integrity of the planning system. The current draft NPSs, particularly the application of the CNP, do not achieve this.

The CNP has not improved the quality of applications. It has lowered the threshold for developers to gain consent, weakening incentives to assess sites properly, consult affected communities, or explore alternative routing. It prioritises speed over good planning and quality outcomes.

High-quality applications need to demonstrate careful routing, environmental sensitivity, and community support. The ESO East Anglia Network Study has shown that such alternatives do exist, including options that reduce visual and ecological impacts while maintaining or improving grid performance.

The Norwich to Tilbury project clearly illustrates how developers are already disregarding the requirements set out in EN-5. Despite the NPS’s emphasis on avoiding nationally designated landscapes, the proposed route passes directly through the Dedham Vale National Landscape. Alternatives that would have avoided this sensitive area entirely have been dismissed without adequate explanation or proper assessment.

Although the developer has proposed undergrounding the section of the cable that passes within the designated boundary, they have adopted an extremely narrow interpretation of EN-5. Pylons are still proposed immediately adjacent to the northern and southern borders of the Vale, except for a small section. These pylons will be visible across much of the landscape, undermining its natural beauty. No real effort has been made to reduce the impact and there has been little to no respect for the legal duty to protect and improve this special landscape.

National Grid’s own Strategic Options Lookback Review confirms that alternative routes which entirely avoid the Dedham Vale exist and are viable. The main reason cited for rejecting these alternatives is that work has already been undertaken on the current route. This is an inadequate justification and directly contradicts EN-5’s requirement to avoid harm to designated areas wherever feasible.

Since the introduction of the CNP policy, the developer has also withdrawn previously proposed mitigations in other sensitive landscapes. This indicates a belief that CNP status will override existing protections and enable the consent of substandard proposals, regardless of their environmental impact. Far from accelerating delivery, this approach is likely to lead to judicial reviews, which will delay progress rather than speed it up.

The risk is that CNP status becomes used to override legitimate concerns and viable alternatives in the name of urgency. This will only lead to greater public resistance, potential legal challenges and ultimately delays. Public support is crucial to delivering energy infrastructure at pace, as recognised in Clean Power 2030. It will not be secured if CNP is seen to silence communities or bypass proper scrutiny.

The current framing of the CNP policy does not sufficiently encourage higher-quality applications. It risks encouraging rushing proposals as a matter of national importance, rather than forcing developers to meet the highest standards.

Balancing competing considerations  

With regards to renewable energy projects and/or the design of electricity network infrastructure, do the draft updated statements allow for sufficient consideration of:  

• landscape impacts;  

• wildlife impacts;  

• heritage and archaeological impacts; and  

• the viability and feasibility of underground and offshore cable routes?  

Do the draft statements strike the right balance between reducing delays, consideration of national strategic spatial plans, and detailed scrutiny of individual projects?  

The draft NPSs, particularly EN-5, do not currently strike the right balance between speeding up delivery of energy infrastructure and ensuring careful consideration of landscape, wildlife, heritage, and undergrounding feasibility. While some positive additions have been made, inconsistencies and vague language undermine the effectiveness of safeguards.

The proposed changes to EN-5 weaken protection for nationally designated landscapes. In section 2.9.12 of the proposed EN5, the word ‘well’ has been removed from the paragraph: “However, in nationally designated landscapes () even residual impacts may well make an overhead line proposal unacceptable in planning terms.” The omission of "well" reduces the emphasis on the potential harmful impacts of OHLs on designated landscapes and should be reinstated to maintain consistency with previous versions.

In section 2.9.22, the phrase, “including their special qualities and key characteristics”
has been inserted after “natural beauty”. This phrasing risks implying that other defining features of designated landscapes may be excluded from consideration. It would be better to clearly state that all attributes contributing to designation are included.

Section 2.9.23 introduces new language, “regardless of the option, the scheme through its design, delivery and operation should seek to further the statutory purposes of the designated landscape.” This is a welcome addition because it includes the requirement to further the statutory purposes of the national landscape. However, this statement contrasts with the earlier point in section 2.9.12 that residual impacts may be unacceptable. If residual impacts are unacceptable, simply “minimising” them is not sufficient. The wording in both sections should be aligned to avoid conflicting interpretations of acceptable thresholds.

Section 2.9.25 sets out requirements on the Secretary of State. The following sentence should be added to clarify expectations in designated landscapes: “In respect of designated landscapes, the Secretary of State must ensure that proposals directly further the statutory aims of those particular landscapes.”

In section 2.9.26, the following paragraph should be struck out, “the potentially very disruptive effects of undergrounding on local communities, habitats, archaeological and heritage assets.” This paragraph is unbalanced and misleading. There is no equivalent paragraph detailing the disruptive effects of overhead pylons, which can have equally or more significant long-term impacts. The claim that undergrounding "will mean digging a trench along the length of the route" is inaccurate. Other methods such as tunnelling, boring, and cable ploughing exist which are far less destructive. This paragraph is also unnecessary as there is already language in the section requiring that the benefits outweigh the environmental impact.

Section 2.11.5 is a welcome new addition requiring developments to further the statutory purposes of protected landscapes, but it should go further by stating that “The requirement to further the purpose of the designated landscape must be taken into consideration in respect of both the landscape and its setting.”

Electricity network infrastructure  

Do the draft statements:  

• provide clear enough guidance on when pylons should be used for electricity transmission and distribution cables, and when they should be laid underground or offshore; and  

• establish a coherent and justified policy for determining when one of these route design options should be chosen over another?  

The draft NPSs, particularly EN-5, do not provide clear, balanced, or up to date guidance on when cables should be placed overhead, underground, or offshore. They also do not present a justified policy framework for making these decisions. The continued favoured option of OHL outside designated landscapes is inconsistent with modern technology and ignores public and environmental concerns.

For example, the following sentence in section 2.9.26, is unbalanced and misleading, “the potentially very disruptive effects of undergrounding on local communities, habitats, archaeological and heritage assets.” There is no equivalent paragraph detailing the disruptive effects of overhead pylons, which can have equally or more significant long-term impacts. The claim that undergrounding "will mean digging a trench along the length of the route" is inaccurate. Other methods such as tunnelling, boring, and cable ploughing exist which are far less destructive. This section is also unnecessary as there is already language in the section requiring that the benefits outweigh the environmental impact.

Another key concern is the proposal in EN-5 to “uphold the existing starting presumption for overhead lines outside of nationally designated landscapes” as this fails to reflect recent experience and evidence. Overhead pylons remain deeply unpopular, often face widespread public opposition and lead to lengthy planning delays. By contrast, HVDC undergrounding has shown itself to be faster to consent and comparable in cost when delays and opposition to pylons are factored in.

HVDC rather than HVAC should be the starting presumption. HVDC has greater public support than pylons which the as the government states is “vital” in their Clean power 2030 report[4], making HVDC a far less contentious option, substantially reducing the risk of legal challenges such as Judicial Reviews. Unlike overhead pylons, HVDC infrastructure can be more easily and cost-effectively undergrounded, requiring narrower trenches, causing less disruption to communities and the environment. Undergrounding the cables also provides greater resilience in the case of hostile attacks, thus protecting important national infrastructure.

HVDC also suffers far lower line losses over long distances in comparison to HVAC. DC transmission can also transmit more power than AC through the same cables. Interconnectors already rely on HVDC to minimise losses, so wider domestic adoption would support integration without the need for converter stations and landing points, reducing costs and minimising disruption to local communities. HVDC is also significantly better suited to a grid increasingly powered by intermittent renewables which have to cope with sudden oscillations in wind and sunshine improving overall stability. The recent Iberian grid outage further highlights the importance of resilience which something HVDC networks are far better equipped to deliver through their flexibility.

Renewable energy infrastructure   

• Is there clear enough guidance on how much weight should be given to the availability of a grid connection in considering the overall benefits and impacts of a proposed project, given the significance of this factor in determining site selection?  

• Do the draft statements provide sufficient clarity on how to manage trade-offs in how land is used and, in particular, when agricultural land grading should (or should not) count against the suitability of a site for renewable energy generation?  

• Should there be any amendments to the National Planning Policy Framework to align it with the updated energy National Policy Statements?  

Agricultural land use

There must be a clear policy that high quality agricultural land is off limits for renewable energy infrastructure. In the UK, where land is limited, the population is dense, and food security is increasingly critical, using productive farmland for energy projects is short-sighted. Energy generation must prioritise brownfield sites or lower quality land. This should be made explicit in the NPS to prevent avoidable conflicts and ensure sustainable land use.

Grid connection and site selection

The draft NPS does not give enough guidance on how to weigh the availability of a grid connection when assessing a proposed site. Grid connections should not be treated in isolation. From a planning perspective, the connection point, any necessary reinforcement works (including along their full length), and the renewable infrastructure must be considered cumulatively. Approvals should be based on the cumulative environmental and landscape impacts of the entire system and not just the generation site.

Aligning with the National Planning Policy Framework (NPPF)

The NPPF must be amended to reflect the updated NPSs and to require the application of the Treasury Green Book in assessing the cumulative impacts of all projects including associated grid reinforcements and landfall infrastructure. The Green Book is already mandatory and provides a consistent, evidence-based approach to weighing costs, benefits, risks, and long-term outcomes. Using it would improve the quality of decisions while minimising harm to communities and the environment.

May 2025

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