Planning & Infrastructure and the Net Zero Review

'Mission Zero', which we will refer to as the Report, is the output of the review.

The Report is notable for its breadth and depth, clocking in at almost 340 pages. This is the product of over 1800 responses to the Review's Call for Evidence and more than 50 roundtables – all delivered since September 2022.  It is comprised of two parts and an Executive Summary. Part 1 is (in the Report's own words) a "scene setting" section that analyses the challenges and the opportunities of net zero. Part 2 considers how the UK can deliver a robust net zero 'delivery ecosystem', and so contains the "meat" of the review's recommendations. &nbsp

Inevitably given the ambitious scope of the Review, the recommendations within the Report are far ranging, cross-sector and relate to multiple different stakeholders, including public bodies, businesses, communities and individuals. The conclusions of Part 1 and 2 can essentially be distilled to, respectively, "Net zero is good" and "The UK must go further and faster". But identifying all the recommendations within the Report is not a straight-forward task. Part 1 sets out 7 conclusions and Part 2 identifies 6 "key pillars" for achieving net zero, each of which then contains its own key recommendations and "missions".  The Executive Summary itself sets out 25 key actions for 2025 and 10 "priority missions" for 2035.

We have picked out below the findings/recommendations from the Report that we consider to be particularly notable from a planning and infrastructure delivery perspective.  However, taken as a whole the Report underscores that the UK's path to net zero needs to be supported by measures across the board which meet the tests of certainty, continuity, clarity and consistency.  The Report does not hold back in identifying where current government policy interventions could better deliver on one or more of those requirements.

One of the recurring refrains in the Report is the need for planning reform, with the planning process identified as a general 'blocker' and source of delay.

There are the inevitable recommendations to streamline and speed up the planning process (in particular a rapid review is recommended to identify bottlenecks in the planning system for local energy efficiency and renewable energy projects). Other notable planning-related recommendations include:

• Introduce a statutory duty for local authorities to take account of the UK's net zero targets, along with a clear framework for local roles and responsibilities;
• Devolve net zero powers to enable a more locally focussed approach to net zero. It recommends that the Government should "fully back at least one Trailblazer Net Zero City, Local Authority and Community with the aim for these places to reach net zero by 2030";
• Reform the local planning system and the National Planning Policy Framework as soon as possible to provide a clearer vision on net zero with an intention to move towards a net zero test for all developments; and
• Give greater clarity and guidance on when local areas can exceed national standards and on how they can go further on net zero should they wish to, including using Local Area Energy Planning (LAEPs) and the creation of 'Net Zero Neighbourhood' plans. The Report notes that devolved governments in Scotland and Wales have already issued clear guidance on LAEP, but England has not.

The Report recognises infrastructure's key role in the delivery of net zero, and that scale and speed is required. In particular:

Energy network infrastructure: The Report recognises the need for the electricity network to keep pace with the government's renewable energy ambition, recommending:

• The policy and regulatory framework should move from the current approach where grid development only takes place on a project-by-project basis once sufficient demand has been identified to a system wide approach based on long-term planning to facilitate anticipatory investments.  
• As part of this, the planning regime needs to reflect the importance of energy networks expansion, the consenting process needs to be smoother, and the National Policy Statements for Energy (which apply to England and Wales) need to provide clear direction.  We still await further revised energy NPS a full year and a half since their publication for public consultation in September 2021. During that period multiple significant energy projects have progressed to planning/DCO application or determination irrespective of the unhelpful policy position. The Report may go some way to ensuring the delay does not continue indefinitely.

Solar, wind and nuclear:  The Report recommends setting up taskforces and deployment roadmaps for each of these forms of energy with clear milestones to 2035.  Specifically:

• Solar: The full deployment of solar is needed to reach up to 70GW by 2035, including via a "rooftop revolution" that should be facilitated by the removal of the requirement for planning permission to install solar panels on the rooftops of domestic and commercial buildings.
• Onshore wind: Greater onshore wind provision is required, with the Report opining that there is no reason why onshore wind cannot be deployed at scale where local communities are willing. As well as streamlining the planning process in England and Wales, the Report indicates that the government needs to ensure that clear guidance is in place to support decision-making and to set out a framework for community benefits, as Scotland has already done.
• Nuclear: Nuclear investments need a stable long-term policy environment, along with streamlining regulatory processes, including planning. The Report recommends that the Government should implement the reforms already set out in the British Energy Security Strategy, such as setting up Great British Nuclear in early 2023.

Emerging net zero technologies: There is a need for a plan for industry decarbonisation and long-term investment in emerging net zero technologies.  It underscores the role of long-term storage, multi-purpose interconnectors and carbon capture to create more supply-side flexibility. It recommends that, before autumn 2023, the government should conduct and publish a review of how regulation for net zero technologies should be changed to accelerate their introduction. Specific recommendations include:

• Hydrogen: The Report states that hydrogen "will have a vital role in our future energy mix", recommending that by the end of 2023 a 10-year delivery roadmap for scaling up hydrogen production should be developed.
• Carbon Capture Usage and Storage (CCUS): The Report recommends that the government should "act quickly to re-envisage and implement a clear CCUS roadmap showing the plan beyond 2030", including in terms of cluster selection, progression and funding. (The current BEIS cluster sequencing process for CCUS regional clusters does not look beyond the end of the 2020s.  Meanwhile, the complex and multifaceted business model development to provide investor certainty and confidence for the delivery of CCUS and hydrogen deployment is taking longer than those taking forward substantial 'first of a kind' projects through the planning system would have hoped and expected).  
• Geological net zero: As part of part of transitioning away from fossil fuels, the Review recommends that the government should consider setting domestic fossil fuel producers a 10% storage obligation target to restore carbon dioxide to the geosphere by at least 2035.

There has effectively been a change of government since the Report was commissioned, so only time will tell how much interest the current government has in taking forward any of the Review's recommendations.  

The Report does draw together the numerous ongoing workstreams being taken forward by government for planning and the infrastructure sector.  Examples include the ongoing review of the Energy National Policy Statements and Project Speed, the government's existing initiative to reduce the cost and time of implementing infrastructure projects.  The Report also serves as a neat summary as to where the multifaceted emerging business models and policy framework for emerging technologies such as hydrogen and CCUS stand. It acts as a clarion call to ensure current government workstreams are taken forward expeditiously to their conclusion, and in some cases, expanded to deliver greater ambition.  

There are some potential 'quick wins' for the government in the Report's recommendations.  Perhaps an early test of the Report – and the government's response - will be to see whether its recommendations have any impact on the government's current consultation on updating the draft NPPF (which as proposed would be adopted in updated form without any reference to net zero at all) or the proposals for changes to the planning system included in the Levelling-up and Regeneration Bill.  

In the meantime, let's hope that 'Mission Zero' does not end up being too apt a name for the Review.