Written evidence submitted by National Grid (NPS0017)
National Grid sits at the heart of Britain’s energy system, connecting millions of people and businesses to the energy they use every day. We fully support the Government’s net zero ambition and are committed to playing a leading role in enabling the transition. We welcome the opportunity to respond to the BEIS Select Committee inquiry into the Draft National Policy Statements for energy infrastructure.
Energy infrastructure is critical to delivering on the ambition for the UK to be net zero by 2050 as outlined through the Energy White Paper and associated strategies. Our business is focused on delivering this ambition through investing and innovating across a range of net zero infrastructure solutions, including: enabling an affordable hydrogen economy; partnering with industry to pioneer CCUS technology; supporting with the increase in electricity capacity required for EV charging and heat decarbonization; and connecting 40GW of offshore wind by 2030 on the journey to a full zero carbon power system by 2035.
Delivering net zero requires a step change in how industry plans, consents, consults and constructs infrastructure, therefore the commitment within the Energy White Paper to review and update the National Policy Statements (NPS), was most welcome. However, whilst the revised NPS makes progress on several factors required to decarbonise the UK, its current drafting does not provide the step change needed to deliver the scale and pace of nationally significant infrastructure development that is required to meet Government’s net zero ambition.
In addition to our below response to the consultation, we have also included an annex. This is an independent review by Quod consultants, planning specialists, into whether the NPS as currently drafted would be effective in enabling industry to meet the Government’s target to connect 40GW of offshore wind energy by 2030. This review by Quod was commissioned by National Grid and their findings are drawn on throughout our response.
Having articulated a clear vision for a net zero economy through the Ten Point Plan, the Energy White Paper, the Net Zero Strategy and associated documents it is critical that the UK Government and industry now work together to translate this ambition into delivery at pace. This means that EN1 should be updated further to ensure that the context for the needs case is up to date and in step with the most recent government policy on energy and climate.
However, the draft NPS does not currently provide the step change needed to deliver the scale and pace of new energy infrastructure required to meet net zero and therefore risks the successful delivery of the Government’s net zero and related targets (for example the connection of 40GW of offshore wind by 2030). Delivering 40GW by 2030 requires significant investment to reinforce and develop the transmission network and connect this clean renewable electricity. For NGET this entails 15 major projects that need to be planned, consented and delivered in just over 8 years. Historically, these major projects have taken over 9 years to deliver, including significant consenting time. Therefore, to meet Government’s target, planning reform focused on accelerating key national infrastructure projects such as ours, is critical. Given the criticality of the infrastructure necessary, the revised NPSs should include:
These themes are expanded on in the Quod review included with our response.
The NPS should be updated further to ensure that it is up to date and in step with the latest government strategy and policy on energy and climate such as the Net Zero Strategy. As has already been noted, the NPS should be consistent with the Government targets such as 40GW of offshore wind by 2030 and the associated infrastructure to connect this ambition, additionally it should align with policy on nascent technologies that are identified as essential for achieving net zero, in particular CCUS, hydrogen and Multi-Purpose Interconnectors (MPIs).
Critically, there should be specific reference and explanation in the main body of EN1 (replacing the current footnote) to the OTNR and on the emerging HND, which is required to establish an onshore electricity infrastructure blueprint. Additionally, specific reference to the OTNR has wider importance, given its significance to decarbonisation, energy security and affordability and the likely influence on development and deployment of offshore wind and market to market interconnection.
Emerging policy on CCUS and hydrogen is noted, (e.g. reference to commercial models for industrial CCUS) but lacks detail on the significance of CCUS and hydrogen for reaching net zero, associated targets and the importance of key industrial clusters and the BEIS cluster sequencing approach. Reference to Decarbonisation Readiness should be added (to replace the text on Carbon Capture Readiness). Further comment on the need for more information on CCUS and hydrogen is provided in response to subsequent questions.
More broadly, as noted in NPS, the sixth carbon budget set in 2021 requires a reduction in GHG emissions by around 78% by 2035 compared to 1990 levels. The Energy White Paper and the Prime Minister’s Ten Point Plan for a Green Industrial Revolution were introduced in the context of the fifth carbon budget. The long-lead-in nature of energy NSIPs means that projects being developed now are relevant to both the fifth (2028 to 2032) and sixth carbon budget (2033 to 2037) which should be made clear within NPS.
Depending on the intentions for future review, the policy may be relevant to the seventh carbon budget due in 2026. Much has changed over the ten-year term of the existing EN1 (2011 to 2021), not least technological advancement and greater emphasis and urgency to decarbonise the energy system. Therefore, consideration should be given to how and when future reviews of NPS will be undertaken to ensure continued relevance of the policy whilst also avoiding policy instability for long-lead-in energy NSIPs.
We welcome the recognition that further technology specific NPS may be designated and added to the suite if it becomes appropriate to do so. It would be helpful to have further clarity on the process to be followed and the relevant timescales for this to ensure the NPS can keep pace with rapid developments in the energy sector (for example hydrogen infrastructure) to avoid the NPSs being a blocker to the infrastructure required to deliver net zero.