Written evidence submitted by Institution of Civil Engineers (NPS0002)

ICE submission to BEIS Committee on Energy National Policy Statements

November 2021

Overview

This response from the Institution of Civil Engineers does not directly cover the energy National Policy Statements, instead drawing on the findings outlined in an ICE policy paper from earlier this year on evolving the UK’s strategic infrastructure planning regime, and the need for NPSs to reflect this.

Submission

Earlier this year, ICE published a discussion paper and consultation exercise seeking views on how to evolve strategic infrastructure planning in the UK.[1]

The Armitt Review in 2013 made a number of recommendations, chiefly that an independent National Infrastructure Commission (NIC) would be needed to sit at the heart of a UK strategic infrastructure planning framework.[2] This and a number of other recommendations were taken forward, and culminated in the publication of the National Infrastructure Strategy (NIS) in November 2020.[3] The NIS and the NIC’s Annual Monitoring Report marks the end of the first round of infrastructure planning in the UK using the new approach outlined when the NIC was founded in 2015.

One of the most notable recommendations from the Armitt Review not taken forward was the evolution of National Policy Statements to become Sector Infrastructure Plans. This part of the process would have taken the National Infrastructure Assessment and turned it into action at Departmental level.

The diagram on the next page, from the Armitt Review, summarises the main steps.

In the absence of Sector Infrastructure Plans, it is not clear how the NIS will inform decision making, including how National Policy Statements or regulators will be expected to give action to the NIS. As a result, the strategic intent in the government’s publication has not been fully embedded into decision making, with some National Policy Statements still not updated.

Following on from the aforementioned discussion paper and consultation on the strategic infrastructure planning regime in the UK, ICE published a policy paper with a number of recommendations.[4] Our paper suggested several recommendations to improve the process and ensure consistency and certainty.

Preparation and approval of the National Infrastructure Assessment[5]

Relevant to this call for evidence is the following recommendation:

Future National Infrastructure Strategies should be published either as, or with, National Policy Statements for infrastructure, and existing Statements should be updated.

This would close the loop to ensure strategy drives planning and development, including providing guidance for regulators for price reviews, which is crucial over the next decade. Existing National Policy Statements should also be reviewed and updated in light of NIS2020. The Department for Levelling Up, Housing and Communities published earlier this year guidance on reviewing National Policy Statements,[6] noting that a consideration on whether to conduct a review should be made at least every five years.

The Energy National Policy Statement is an example of an NPS that provides both a strategic overview as well as specific recommendations on energy infrastructure development. A single National Policy Statement for infrastructure[7] could achieve the same effect, with the NIS serving as the strategic element, or first chapter, of that single NPS and sector-specific annexes developed to add specifics for different infrastructure sectors. Such an approach would ensure consistency across sectors on issues such as noise limits.

The main outcome from any reform is to ensure the National Infrastructure Assessment informs strategy, which should then be reflected in infrastructure development plans by Departments, and backed up by statute so that clients can make investment plans with certainty. At present, National Policy Statements provide that outcome: clear plans backed by statute. In the absence of statutory underpinning for the NIC, an easy fix is to align National Policy Statements with the National Infrastructure Strategy.

By evolving the process of strategic infrastructure planning, policymakers can improve the accuracy of forecasting, which will, in turn, sharpen the focus on the benefits of infrastructure system interventions and help lower the cost of delivery.

About ICE

Established in 1818 and with over 95,000 members worldwide, the Institution of Civil Engineers exists to deliver insights on infrastructure for societal benefit, using the professional engineering knowledge of our global membership.

November 2021