Appendix 2 – Call for Evidence on the National Policy Statement for Ports
a. Does the proposed revised Ports National Policy Statement provide clear guidance to the ports sector and appropriate support for growth in the sector?
The revised Ports National Policy Statement (NPSP) makes some welcome progress in recognising the importance of ports to the UK economy and in supporting the market-led approach that has underpinned successful port investment for decades. However, the revised NPSP does not yet go far enough in either clarity or ambition to fully support the long-term growth of the ports sector.
Clarity and certainty for a ‘foundational’ sector
The NPSP is a critical document for providing clarity and certainty to both developers and decision-makers. In its current form, we believe the NPSP falls short in three key respects:
- Status and presumption: The revised NPSP should clearly and explicitly confirm its status as the primary basis for decision-making on port NSIPs, in line with the Planning Act 2008. A clear statement of the presumption in favour of port development—in cases where the NPSP is up to date and relevant—is essential to give developers confidence.
- Scope of applicability: The NPSP should clarify its relevance and weight in other development regimes beyond the NSIP system—particularly for port developments brought forward under the Town and Country Planning Act or Transport and Works Act, and for infrastructure delivered by statutory harbour authorities. This will improve consistency and reduce delays caused by legal uncertainty.
- Alignment with wider regimes: Port development is increasingly constrained by overlapping regulatory systems and environmental requirements, including marine licensing, habitats assessments, and Biodiversity Net Gain (BNG). The NPSP should provide clearer direction on how these regimes should interact, and call for better coordination between regulators and consenting authorities to reduce regulatory friction.
Support for growth and job creation
The NPSP rightly acknowledges the dynamic, market-led nature of the ports sector. However, it does not yet provide a strong enough framework to enable the scale and pace of development required to meet future demand. This includes:
- Modernising forecasting assumptions: The NPSP’s evidence base remains largely anchored in traditional tonnage-based metrics. It needs to better reflect the non-tonnage-related growth in the sector—such as support for offshore wind, clean energy infrastructure, and growing cruise and ferry markets. These segments are central to net-zero delivery and regional regeneration, yet are poorly captured by historic forecasting models.
- Recognising increased vessel sizes: Ports are facing growing pressures to accommodate larger vessels across multiple sectors (container, bulk, cruise, RoRo). This trend has direct implications for berth length, channel depth, turning circles, and landside infrastructure. It would be helpful if the NPSP’s forecasting section commented explicitly on this trend, to provide a policy reference point for ports when making the case for deeper or wider navigation channels or when safeguarding growth capacity in shared or contested waterspace (e.g. where cables or other assets are present).
- Forecasts must inform, not constrain: The NPSP should state explicitly that demand forecasts are contextual rather than determinative. They must inform development decisions but not be used to limit or challenge the justification for new port infrastructure, particularly where needs relate to emerging or rapidly evolving sectors that are not well captured by backward-looking models. Much of the UK’s future port growth will come from such non-traditional areas, and planning policy must enable rather than inhibit their development.
- Addressing enablers of delivery: Many port developments are delayed not by the port infrastructure itself but by uncertainty around connecting infrastructure (road, rail, and grid) and the costs and risks associated with securing them. The NPSP should do more to highlight the need for strategic coordination and equitable funding mechanisms to unlock this enabling infrastructure, particularly where the benefits are national rather than local.
Conclusion
While the revised NPSP includes positive elements, it does not yet provide sufficient clarity or strength of policy to support the long-term growth of this strategically vital sector. A more assertive and better-integrated NPSP is essential to unlock the investment, resilience, and decarbonisation outcomes that ports can deliver for the UK.
b. Whether and in what ways the proposed revised NPSP is likely to be more effective than the current version, and whether any opportunities to further improve its effectiveness have been missed?
The revised NPSP represents a meaningful improvement over the current version in several important ways:
- Greater strategic recognition of ports’ role: The revised NPSP explicitly acknowledges the sector as a key enabler of the UK’s clean energy transition, economic growth, and modal shift ambitions, which was less clearly articulated in the previous document. This enhances the policy’s strategic relevance and better aligns ports with wider Government priorities such as net zero and industrial regeneration.
- Support for a market-led approach: The draft more clearly endorses the market-led nature of port development, recognising that investment decisions are best driven by commercial dynamics rather than prescriptive planning targets. This reflects sector realities better than the previous version’s more rigid tone.
- Improved articulation of sector challenges: The revised NPSP highlights some of the operational and infrastructure challenges ports face, including the need for investment in connectivity, energy infrastructure, and adaptability to changing vessel sizes, which were not as explicitly covered before. This helps raise awareness among decision-makers about factors influencing delivery times and costs.
- Inclusion of emerging and rapidly evolving sectors: The draft better recognises growth sectors such as offshore wind, clean energy infrastructure, and emerging logistics markets that are critical to the UK’s net-zero and economic ambitions. These sectors, however, operate in areas where there is little historical data or established trends, making traditional forecasting models less reliable. The revised NPSP takes initial steps towards acknowledging these limitations, although further emphasis is needed to ensure forecasts are used as contextual guides rather than rigid constraints on development.
- More explicit references to safeguarding and futureproofing: While still limited, the revised draft acknowledges the importance of safeguarding land and waterspace for future port needs to a greater extent than before.
However, despite these improvements, the revised NPSP remains somewhat cautious and leaves several significant opportunities unaddressed, limiting its overall effectiveness as a delivery tool:
- The presumption in favour of development remains insufficiently explicit, weakening investor confidence compared to what could be achieved.
- The revised NPSP stops short of designating offshore wind port capacity as a Critical National Priority, a vital step to unlock timely investment and coordination.
- Clearer, more authoritative guidance on how the NPSP applies across different planning regimes and interacts with overlapping regulatory frameworks (including marine licensing and Biodiversity Net Gain) is still lacking.
- Forecasting guidance remains anchored to traditional metrics and does not fully reflect the increasing vessel sizes or emphasise sufficiently that forecasts should inform, not constrain, development—particularly in fast-evolving sectors where backward-looking data is scarce or unrepresentative.
- The connection to the Government’s Industrial Strategy and wider infrastructure priorities could be strengthened to better embed ports’ role in national growth and decarbonisation agendas.
In conclusion, the revised NPSP builds on the previous version by providing a more strategic and sector-relevant framework and improving recognition of emerging challenges and opportunities. Yet it still falls short of delivering the clarity, policy strength, and integration needed to accelerate port infrastructure delivery at the scale and pace required. Addressing these gaps would significantly enhance its effectiveness as a national policy tool and has to be a critical consideration.
c. Do you agree with the conclusion of the Appraisal of Sustainability that there are not likely to be any significant effects from the proposed revised NPSP, and that there is the potential for long-term minor positive effects in some areas?
We broadly agree with the Appraisal of Sustainability’s (AoS) conclusion that the revised NPSP is unlikely to result in significant adverse environmental effects at a national level. The NPSP provides a strategic framework rather than site-specific proposals, so detailed impacts will be assessed during individual project consents.
The potential for long-term minor positive effects is appropriate, particularly given the NPSP’s role in enabling:
- The UK’s energy transition through supporting offshore wind, alternative fuels, and decarbonisation infrastructure.
- Improved freight efficiency and modal shift, contributing to reductions in emissions and pollution.
- Job creation and regional economic regeneration linked to port growth.
However, the AoS should also recognise:
- The growing national demand for port capacity to handle increasing volumes of goods and complex logistics requirements, which underpins the UK’s economic resilience and trade competitiveness.
- The critical need for a clear, coordinated national strategy to manage ship emissions and other wider environmental impacts, rather than leaving these challenges to be addressed piecemeal by individual ports. Without a strategic approach, issues such as air quality and carbon emissions risk being shifted between ports or inadequately mitigated, as reflected in legal precedents like the Finch case.
- The ongoing competition for scarce marine space among multiple users and industries, which requires effective planning and regulatory cooperation to balance interests and prevent cumulative negative effects.
- The uncertainties posed by climate change on coastal and marine environments, which could affect port infrastructure and operations in the long term.
In summary, port development guided by the revised NPSP should be seen as a positive enabler of the UK’s economic and environmental goals. Achieving these outcomes will depend on strong, coordinated policy frameworks and regulatory oversight at the national level, ensuring that environmental impacts and infrastructure needs are managed comprehensively rather than left to individual ports alone.
(d) Does the proposed revised NPSP appropriately balance the objectives of:
- Support for local communities
- Protection of the natural environment and biodiversity
- Ability for the ports sector to expand, develop and contribute to economic growth
- Decarbonisation and improved environmental performance of the maritime sector
- Strengthening the resilience of freight transport
While the revised NPSP is a step in the right direction, it does not yet strike the right balance across these objectives.
In particular, it underplays the strategic importance of ports as essential national infrastructure as a foundational sector. It also fails to provide the clarity and support required to unlock their full contribution to the UK’s economic, environmental and social priorities.
Ports and national economic priorities – ports are how
Ports are critical enablers of the UK economy. They facilitate 95% of the UK’s trade by volume and underpin the success of key government missions, including the energy transition, export growth, securing materials for new housing and delivering on free trade agreements. They are not simply local developments, but strategic infrastructure whose impacts are felt across supply chains and regions.
The final NPSP must do more to reflect this strategic role and provide the policy certainty required to encourage long-term investment and competitiveness in a rapidly changing global trade and energy landscape.
Contribution to communities, employment and skills
Ports make a sustained and positive contribution to local economies, some of which still blighted by economic deprivation over several decades. They offer high-quality jobs and a range of career paths, supported by well-established apprenticeship and graduate schemes, as well as opportunities for people to reskill and enter the sector later in life.
With the growth of automation and digital technologies, ports are seeing the emergence of new, more flexible roles that appeal to a wider range of skill sets and help to diversify the workforce. These developments should be recognised more fully in the NPSP, with greater weight given to ports’ role as drivers of local prosperity and opportunity.
Environmental performance and proportionate regulation
Ports and harbour authorities have a strong track record in environmental management. Many larger ports have dedicated environmental specialists and ongoing programmes of improvement. Across the sector, there are excellent examples of proactive and innovative practices, including the creation of habitat banks, use of lidar and mapping technologies, and work on blue carbon valuation.
That said, the current regulatory environment is often unnecessarily complex and can impose disproportionate burdens on port development. Of particular concern is the application of Biodiversity Net Gain in coastal and intertidal areas. The metric, as currently applied, does not reflect the realities of these dynamic environments and risks delaying or deterring investment due to uncertainty and a lack of suitable compensation options.
Decarbonisation and power constraints
Ports are committed to supporting decarbonisation, through electrifying port operations, enabling shore power, and facilitating clean energy generation and distribution. However, their ability to deliver on these ambitions is increasingly constrained by limited access to grid capacity and delays in securing power infrastructure upgrades.
Grid availability and cost have become a major barrier to growth and clean energy deployment at ports. Without a clearer enabling framework and better coordination between planning and electricity infrastructure delivery, the UK will struggle to meet its net zero and resilience targets.
Freight resilience and modal shift
Ports are a vital part of the UK’s freight resilience, offering flexibility, redundancy and efficiency. The NPSP rightly acknowledges the importance of modal shift, but should go further in supporting freight investment that reduces emissions and congestion, including rail enhancements, coastal shipping opportunities, and improved first and last mile connectivity.
Conclusion
The revised NPSP presents the right high-level ambitions, but needs to go further in reflecting the true economic and strategic importance of ports and in removing the policy and infrastructure barriers that currently limit their ability to deliver. A more proportionate and joined-up approach across planning, environmental regulation and power infrastructure is essential to unlocking the sector’s full contribution to national and local objectives.
(e) Does the proposed revised NPSP give enough clarity on how land can be used, and does it align with the National Planning Policy Framework?
The revised NPSP should provide clarity on land use issues relevant to ports and their wider operational footprints. While the draft broadly aligns with the National Planning Policy Framework (NPPF), it does not adequately reflect the specific challenges and requirements associated with safeguarding land for port development and associated infrastructure.
Ports need long-term certainty to secure, protect and invest in land required for future growth. This includes not only land within existing port boundaries, but also adjacent land necessary for modal shift infrastructure, freight logistics, energy infrastructure and value-added activities that support supply chain resilience and decarbonisation. Many of these uses are interdependent, and they must be considered holistically.
Current planning policy does not provide sufficient protection or flexibility for port land. There is growing pressure from other development interests, particularly residential and mixed-use schemes, which can constrain port operations or prevent future expansion. This is exacerbated by local planning frameworks that do not always recognise the strategic nature of ports and their national importance.
The final NPSP should set clearer expectations for safeguarding land for port-related uses, including stronger guidance on how local plans should take account of national port infrastructure priorities. It should also reinforce the need for coordination between different policy areas, such as energy, transport and economic development, to ensure land needed for nationally significant port infrastructure is identified, retained and effectively utilised.
Without this clarity, ports, a foundational sector, risk being locked out of future growth opportunities and unable to deliver on key government ambitions, from decarbonisation and clean energy to global trade and industrial growth.
(f) How effectively does the proposed revised NPSP interact with energy infrastructure National Policy Statements? Will it support development of offshore renewable energy and sustainable energy supply at ports?
The proposed revised NPSP takes positive steps in recognising the important role ports play in supporting offshore renewable energy and sustainable energy supply. Ports are essential gateways for clean energy, providing critical infrastructure for the assembly, storage and distribution of offshore wind components, and other emerging low-carbon technologies.
However, permissions for port developments can often take a long time. While we are seeing energy projects prioritised in the planning system, the same level of support is not consistently extended to the important supporting infrastructure needed at ports. Energy infrastructure has been given higher status in national policy, but this is unhelpful if it does not also apply to the supply chain infrastructure in ports that enables offshore wind and other energy projects to succeed.
Given that the government’s updated Industrial Strategy has been published since this draft NPSP, there is a clear opportunity to improve the narrative, especially around developments supporting offshore wind and energy. Without careful coordination and support for port infrastructure, there is a real risk that much of the UK’s offshore wind ambition will be deployed but supported by non-UK ports and communities, undermining local economic benefits and national strategic goals.
Stronger alignment and integration between the NPSP and energy infrastructure National Policy Statements is needed. Clearer cross-referencing and coordination would help ensure that ports’ unique infrastructure needs are fully accounted for in national energy infrastructure planning. This would support efficient, timely delivery of infrastructure vital to the UK’s net zero ambitions.
Ports face significant barriers in delivering the infrastructure required to support clean energy supply, notably constraints around grid connections and electricity infrastructure. These bottlenecks risk delaying or limiting the electrification of port assets and the rollout of alternative fuels, which are central to decarbonising maritime operations and freight transport.
The revised NPSP should therefore explicitly recognise these challenges and set out measures to improve access to energy infrastructure at ports, in close coordination with the relevant energy NPSs. This would help create the conditions for ports to scale up their role in the energy transition, enabling them to support government missions such as offshore wind growth, hydrogen production and wider clean energy generation.
In summary, while the draft NPSP is a good foundation, enhanced integration with energy infrastructure policy and a stronger focus on addressing infrastructure constraints would better support the sustainable energy ambitions of the ports sector.
(g) How effectively does the proposed revised NPSP interact with the NPS for National Networks and other transport policies, and how should it align with the forthcoming Integrated National Transport Strategy?
The revised National Policy Statement for Ports (NPSP) recognises the vital role of ports as multimodal freight hubs, connecting sea, road, rail, and inland waterways. This connectivity is essential for an efficient UK transport system and underpins the movement of goods crucial to the economy.
However, the interaction between the NPSP and the National Policy Statement for National Networks (NPSNN), as well as other transport policies, could be made clearer and more coordinated. Ports rely heavily on effective connections to the strategic road and rail networks to facilitate smooth freight movement. Any disjointed approaches risk inefficiencies, delays, and underutilisation of port capacity. Moreover, such disjointedness can deter investors who seek clear strategic plans for improving connectivity. Investors want to see certainty that infrastructure improvements will unlock further investment in ports, supporting growth in trade and the development of manufacturing and logistics hubs within the UK.
Since the publication of the UK’s Industrial Strategy, ports have been explicitly recognised as a foundational sector for economic growth and trade. This status underscores the need for clear policy and infrastructure alignment to support the sector’s critical role. The NPSP should reflect this foundational role by ensuring ports are fully integrated within the wider transport and industrial infrastructure plans.
The forthcoming Integrated National Transport Strategy (INTS) provides an important opportunity to establish a more holistic, joined-up approach to transport infrastructure planning. The NPSP should align closely with the INTS principles by emphasising the seamless integration of ports within wider transport networks, supporting modal shift where possible, and ensuring that freight resilience is maintained.
A major opportunity exists for ports to support decarbonisation and resilience through greater use of rail and water freight. This requires proactive government support through investment, planning alignment, and policy incentives. The NPSP should explicitly support modal shift by better integrating with national freight and transport strategies, helping reduce road congestion and emissions while strengthening supply chain resilience.
A critical gap remains in many transport strategies and publications, which often focus predominantly on passenger transport, leaving freight underrepresented. We need transport strategies that give much more explicit attention to freight. It is vital to communicate clearly to the public that freight matters too. Making space for freight on roads and rail networks is essential not only for the efficient movement of goods but also for improving journeys for everyone. Changing the perception that freight is unimportant is crucial. More open discussion and education about freight’s needs, challenges, and the choices involved will help build broader understanding and support for freight infrastructure and services.
Another important consideration is the cumulative burden of planning obligations, whether relating to connectivity, design expectations, or environmental mitigation. These can act as significant barriers to delivering essential port infrastructure. The final NPSP should embed the principle of proportionality, ensuring that requirements on ports are realistic, justified, and consistent with their national strategic role. This will help to avoid unnecessary delays or costs that could undermine investment and growth.
Key areas for stronger alignment include:
- Explicit recognition in the NPSP of the critical importance of timely and adequate investment in connecting infrastructure, including roads and rail serving ports.
- Clear mechanisms to ensure coordination between consenting processes for port developments and associated national networks infrastructure to avoid project delays.
- Support for sustainable freight movement aligned with wider transport decarbonisation goals, including encouraging rail freight and low-emission last-mile connections.
- Consideration of resilience and capacity needs to respond to future growth in freight volumes, climate impacts, and changing supply chains.
- Embedding proportionality in local impact requirements and planning obligations placed on ports.
The revised NPSP should therefore be framed as a vital element within an integrated transport system, reflecting the government’s broader transport, decarbonisation, and economic growth objectives as set out in the INTS and the Industrial Strategy. This would help secure the necessary infrastructure investment and regulatory alignment to unlock the full potential of the UK’s ports and freight network.
(h) Does the proposed revised National Policy Statement satisfy the Secretary of State’s duties under the Planning Act 2008, particularly those under section 10 relating to having regard to climate change and good design?
The revised NPSP shows positive intent in meeting the Secretary of State’s duties under Section 10 of the Planning Act 2008, particularly regarding sustainable development and climate change. However, the current draft would benefit from greater clarity, context, and practicality in how it addresses the operational realities of ports, especially when it comes to good design and the delivery of climate objectives.
Climate Change and Sustainable Development
Ports are central to the UK’s transition to net zero and wider environmental goals. As the gateways for 95% of UK trade, they will play a critical role in:
- Importing and producing low-carbon fuels including hydrogen and ammonia
- Enabling carbon capture, usage and storage (CCUS) via shipping-based transport networks
- Supporting offshore renewable energy deployment, such as fixed and floating offshore wind
Ports are also decarbonising their own operations by investing in shore power, electrification of plant and equipment, hydrogen-ready infrastructure, and the digitisation of port operations.
However, despite this commitment, real barriers persist. Most notably, grid capacity and availability are now among the biggest obstacles to port decarbonisation. The NPSP should be clearer in identifying these as strategic constraints and supporting timely grid reinforcement for major port locations.
Additionally, while energy generation projects are increasingly prioritised, the same is not consistently true for the supporting infrastructure that enables them, such as ports. Without an aligned approach, the UK risks delivering offshore wind and clean energy ambitions using overseas ports and supply chains, undermining the economic and industrial benefits for UK communities. The final NPSP should reflect the publication of the Industrial Strategy and treat ports as foundational infrastructure that underpins the energy transition and clean growth.
Good Design
While the visual appearance of infrastructure is often prioritised in design policy, truly high-quality and inclusive design must go beyond aesthetics, particularly for industrial infrastructure such as ports. The current NPSP references to “good design” need clearer context and more practical application to be meaningful for the sector.
Ports are inherently operational, industrial and secure environments. Good design in this context means infrastructure that is:
- Fit for purpose, facilitating the safe and efficient flow of goods, including abnormal loads like offshore wind components
- Flexible, allowing for the movement of large plant, vehicle turning circles, container stacking, and multimodal logistics
- Secure, including clear sightlines, fencing, surveillance and access controls to meet safety and border security requirements
- Efficient and sustainable, minimising land take, optimising resource and energy use, and enabling clean energy infrastructure such as rooftop solar and on-site renewables
Design expectations must reflect these realities. For example:
- Landscaping and tree planting, while visually appealing, may not be appropriate in operational zones where they can restrict visibility, reduce stacking heights, complicate cleanliness and food hygiene, or attract vermin
- Screening and bunds can provide visual or noise mitigation in some settings, but space constraints often limit their feasibility
- Public-facing enhancements, such as design around cruise terminals or visitor access points, may be more appropriate locations for visible aesthetic improvements
The draft NPSP’s requirement that “every effort be made to embed the principles of good design” risks being too vague and open to unhelpful interpretation. For ports, good design must prioritise functionality, operational safety, security and flexibility, with visual considerations playing a supportive rather than leading role.
(i) How robust are the Government’s port freight demand forecasts, and have their implications been reflected adequately in the proposed revised NPSP?
The updated port freight demand forecasts presented in the draft NPSP offer useful context on likely trends in port traffic. However, while these forecasts provide valuable background, it is essential that the final NPSP clarifies their role, scope, and limitations within the planning and decision-making process for new port infrastructure.
The forecasts should inform, not constrain, development. They must be clearly described as contextual indicators rather than determinative limits on investment. Ports operate in a highly competitive and commercial environment, where responsiveness to changing market conditions and emerging sectors is critical. Relying solely on central demand forecasts risks unnecessary delays, deters investment, and may prevent the UK from seizing new growth opportunities. We welcome paragraph 2.3.11 of the draft NPSP, which acknowledges that individual ports take their own commercial views and risks on their traffic forecasts. The final NPSP should reinforce this principle and explicitly allow for project-specific forecasts to diverge from national projections where justified.
Moreover, much of the growth in port demand lies outside historic trends captured by traditional forecasting models. The continued reliance on pre-2008 peak volumes or GDP-based models risks obscuring important growth sectors such as clean and green energy infrastructure (including hydrogen, offshore wind, and carbon shipping and storage), transhipment and international redistribution, and cruise and passenger traffic. These sectors often involve high-value, low-tonnage cargoes, which are not well reflected in conventional volume metrics like million tonnes per annum. The NPSP must acknowledge this to ensure strategic investment is not undermined.
Building strategic capacity ahead of demand is a key priority. In a global environment of supply chain shocks, shifting trade patterns, and rapid energy transition, the UK must create resilience, redundancy, and flexibility to adapt to future challenges and emerging markets, particularly in clean energy and advanced manufacturing. Given the long lead times for port infrastructure projects, it is vital that ports can invest early and confidently without being limited by forecasts that fail to anticipate future opportunities. This includes supporting projects under section 35 of the Planning Act 2008 with the same policy weight as designated Nationally Significant Infrastructure Projects (NSIPs) where they enhance national resilience, energy security, or critical supply chains.
The NPSP should also reflect the role of ports as foundational to the UK’s Industrial Strategy. Ports are not passive infrastructure but active enablers of growth across multiple sectors that drive economic competitiveness, sustainable growth, and jobs, particularly in coastal communities. The NPSP should therefore support proactive port development that anticipates future strategic needs rather than relying solely on historical demand patterns, avoiding artificial constraints on investment through over-reliance on freight forecasts.
Additionally, the NPSP’s forecasting approach should explicitly recognise the ongoing trend towards larger vessel sizes, including containerships and cruise ships, which require deeper and wider navigation channels and berths. For example, modern large containerships often have draughts of 14 to 16 metres, with expectations that even deeper vessels will enter the market. Larger cruise ships similarly require expanded infrastructure. Recognising these trends is important to help ports and local authorities plan for safeguarding navigation channels and port infrastructure, particularly as competing uses such as offshore wind cables and interconnectors increase.
In summary, while the Government’s port freight demand forecasts provide a helpful baseline, the revised NPSP must explicitly clarify that these forecasts are indicative rather than prescriptive. It must reflect the dynamic and foundational nature of the ports sector, support early and flexible investment, and recognise the strategic importance of ports in delivering the UK’s economic and industrial ambitions.
