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The Government recently published its Clean Power 2030 Action Plan (CP30 Plan), setting out how its mission of clean power by 2030 will be delivered. The newly established National Energy System Operator (NESO) has said that achieving the government's mission requires a "once in a generation shift in approach", which prioritises pace over perfection.

The CP30 Plan forms just one part of a series of strategic plans, which will see a fundamental change in how energy assets are planned and developed in Great Britain (GB). The developer-led approach taken since privatisation of the electricity sector in 1990, of investors deciding where to build generation assets, followed by incremental network build-out, is moving towards a much more co-ordinated, whole system planning approach with a central role being taken by the Government and the newly established NESO (created in October 2024 to carry out the role of system planning across the whole energy system, including electricity, gas, hydrogen and carbon).

With £40 billion annual investment estimated to be required, largely from the private sector, to achieve clean power by 2030, it is important for investors to understand what this means for them.

We summarise what the key plans will cover and when they're expected to be produced, as well as some of the practical impacts these plans may have on investors in GB power assets.

 

What is it and what impact could it have?

Period covered

Timing

(existing/ indicative)

Clean Power 2030 Plan (CP30 Plan)

 

  • The government's plan for delivering clean power by 2030. It sets out one pathway for achieving clean power by 2030, with a range of capacity anticipated for each in-scope technology type needed to achieve the 2030 target. It consolidates existing and new actions to be taken across the energy sector to achieve the 2030 goal.
  • Prepared using NESO's independent advice on the potential pathways and energy infrastructure needed to deliver a clean power system by 2030.
  • The plan assumes clean power sources will produce at least as much power as GB consumes in total, and at least 95% of GB's generation, in a typical weather year and that there will be early electrification of heat, transport and industry.
  • The connections reform annex (the CR Annex) provides GB-level capacity ranges for the periods to 2030 and 2031-2035 for each key generation technology and regional breakdowns for onshore wind, solar and batteries for the purpose of grid connection offers, following the proposed connections reform (see below for further detail). Most generation projects seeking to connect to the grid between 2027 and 2035 will need to align with the CP30 Plan.

2025-2030

  • November 2024NESO advice published.
  • December 2024 - CP30 Plan published.
  • 29 January 2025 – connection application pause commences for directly-connected generation in anticipation of upcoming connections reform.
  • 21 April 2025 - connection application pause commences for directly-connected demand in anticipation of upcoming connections reform.
  • Q2 2025 – proposed alignment of grid connections queue with the CP30 Plan.

Strategic Spatial Energy Plan (SSEP)

  • NESO's longer-term GB-wide spatial energy plan for large-scale electricity and hydrogen generation and storage (future versions may have a wider scope). It will forecast energy supply and demand characteristics and map potential zonal locations, quantities and types of generation and storage. It will not map individual project locations.
  • The plan will aim to define the optimal mix and locations of generation and storage technologies needed to deliver net zero by 2050, based on 4-6 options to be presented to government, which will then confirm a single pathway to be taken forward for public consultation.
  • Connection reforms propose that grid connection offers for connections beyond 2030 are aligned with the SSEP (see below for further details).
  • Network investment decisions will be made on the basis of the SSEP (through development of the CSNP (see below)) and it is intended to inform government policy.
  • It is intended that the SSEP becomes part of the planning systems framework across GB (see below for further details).

2030-2050

  • October 2024NESO commissioned to prepare SSEP.
  • December 2024- January 2025 - methodology consultation.
  • Q2 2025 – final methodology to be published.
  • Q4 2025 – pathway options to be presented to Government.
  • Q2 2026 – consultation on draft SSEP.
  • Q4 2026 – final publication.

Centralised Strategic Network Plan (CSNP)

  • NESO's long-term plan for the onshore and offshore electricity transmission networks and interconnectors.
  • It will aim to coordinate reinforcements and anticipate investment ahead of need, ensure efficiency and accelerate delivery.
  • The first transitional CSNP (tCSNP1) (Pathway to 2030 Holistic Network Design report) set out the offshore and onshore transmission infrastructure required to connect 50GW of offshore generation by 2030. It has been used to identify 17 Accelerating Strategic Transmission Infrastructure (ASTI) projects which are being accelerated as critical for achieving net zero 2030 goals.
  • The second transitional CSNP (tCSNP2) (Beyond 2030 report) identified further offshore and onshore transmission reinforcements that are needed through the 2030s. It is being used to identify the first CATO projects (see our upcoming article).
  • tCSNP2 is being refreshed to re-examine some of the options now that more information is available to identify projects sufficiently mature to enter the delivery pipeline and to determine the base network for the first enduring CSNP.
  • The enduring CSNP will be refreshed every 3 years and future iterations are expected to include gas transmission and hydrogen.

tCSNP1: up to 2030

tCSNP2: 2030-mid-2030s

CSNP: 25-year horizon

Regional Energy Strategic Plans (RESPs)

  • A coordinated whole energy system plan for each region (proposed to be 11 regions across GB) to be delivered by NESO and fully updated every 3 years.
  • A key objective will be to support the coordinated development of the distribution system to enable long-term investment. It is intended to be fully "whole system", including electricity and gas – but also potentially heat and hydrogen.
  • Each plan is expected to include a short-term 5-10 year pathway and multiple long-term 25-year net zero pathways that show energy supply and demand projections.
  • Will align with the SSEP to provide more granularity in relation to each region.

5-25 year horizons

  • Aug 2024consultation on RESP policy framework.
  • Early 2025 – Ofgem decision expected.
  • 2025 – RESP methodology consultation.
  • Q1 2026 – transitional RESP output for DNO ED3 price control business planning.

Future Energy Scenarios (FES)

  • Identifies strategic choices that can be made to decarbonise the energy system, covering electricity, hydrogen, methane and gas. It sets out pathways to net zero by 2050 and gives projections of whole energy system supply and demand.
  • The Government has largely adopted the Holistic Transition pathway for 2031-5 from FES 24 for the purposes of connections reform in the CR Annex (with adjustments for onshore wind and unabated gas).

To 2050

  • July 2024FES 24 published.
  • Summer 2025: FES 25 to be published.

Gas Network Capability Needs Report (GNCNR)

  • Sets out NESO's views of the capability of GB's gas transmission system to meet current and future network requirements. Analysis carried out based on the gas supplies and demands projected in the FES.
  • Based on the GNCNR, National Gas will develop network options in its Strategic Planning Options Proposal. NESO will use that proposal to prepare a Gas Options Advice Document (GOAD).
  • The GNCNR will be built upon in a whole-system CSNP.
  •  
  • December 2024 – GNCNR published.
  • Early 2025: Stakeholder feedback and input on the draft methodology for the GOAD.
  • Q4 2025 – GOAD to be published.

 

Impact on grid connections

The combination of the CP30 Plan and the proposed connections reform is already having a significant impact on projects seeking to obtain a grid connection in GB. The existing queue for most grid connections in GB is expected to be reordered in 2025 so that it only contains projects which are "ready" and "needed" (see our article here for further detail on the proposed reforms). New connection offers are also proposed to be issued on this basis and a pause in new connection applications has been introduced from 29 January 2025 for directly-connected generation and 21 March 2025 for directly-connected demand to facilitate the implementation of connection reforms.

The CR Annex sets out how much of each technology is "needed" and, for onshore wind, solar and batteries, in which zones, for the periods 2026-30 and 2031-35. With limited exceptions, only those projects which are aligned with the capacity ranges set out in the CR Annex will receive a connection offer following the reordering of the queue.

There will be some winners and losers of the queue reordering. Projects which are well progressed and can demonstrate that they are "ready" and "aligned" with the CP30 Plan could see their connection dates accelerated as less viable projects are removed from the queue. Investors will need to be sure to have the required "readiness" evidence in order to submit in the first application window (expected to be in Q2 2025).

By contrast, technologies such as batteries are oversubscribed, with some viable projects set to lose their existing grid connections. Although there are some protections for projects close to commissioning (e.g. projects due to connect by the end of 2026), there is a risk of an investment hiatus this year for certain types of projects as developers wait to see whether their project is determined to align with the CP30 Plan.

It is expected that connection offers will be aligned with the SSEP, once published, such that on an enduring basis the SSEP determines which projects receive a connection. Although this could result in a change to the 2035 permitted capacities (initially to be based on FES 24 (as adjusted for onshore wind and unabated gas in the CP30 Plan)), NESO has confirmed it will not affect connection offers already existing for pre-2036 connections when the SSEP is published.

 

Impact on planning processes

Within the 'Objectives' to the SSEP's commission, the Government notes their ultimate intention for the SSEP "to become part of the framework of planning systems across GB". Implicitly, the same is likely to be true for the CSNP, given that the SSEP will directly feed into and inform the production of the CSNP.

Exactly how this integration is to be achieved, and to what extent the outputs of the strategic plans become a key factor in planning decisions, remains to be seen. There is concern by some, that this lack of clarity could lead to investment being delayed until the plans' impact on individual projects is better understood. However, it is clear that both plans will provide a 'spatial planning' element to the design, and anticipated location, of the energy system in GB and, consequently, be informed by Strategic Environmental Assessment and plan-level Habitat Regulations Assessment. This will add complexity and could well delay their ultimate production, but would allow for a level of subsequent reliance to be placed on the content of the strategic plans by planning authorities in making planning decisions for individual projects.

The Government will consider whether the existing National Policy Statements (NPS) should be amended to incorporate the SSEP, such that the Secretary of State is required to decide planning applications in accordance with the SSEP (unless an exception applies). The suite of Energy NPS were reviewed, updated and re-designated in 2024, and the Government confirmed within the CP30 Plan that it will carry out a further review and update to ensure that "the Planning Inspectorate and other organisations involved in examining projects are given the clarity they need to provide robust advice on infrastructure critical in delivering Clean Power 2030". The exact timescales and scope for this review and update remain to be seen and it may be that it is concluded prior to the SSEP/CSNP workstreams, meaning any attempted coordination is more prospective in narrative.

However, it is not obvious in any case that the production of the SSEP/CSNP should necessitate any review of the NPSs – they are complimentary in both supporting the delivery of energy infrastructure and the NPSs as written would not be inconsistent with the SSEP/CSNP, which would remain capable of being important and relevant considerations to decision-making on applications.

 

Impact on electricity market reform

The CP30 Plan sets out the Government's proposed shorter-term reforms to meet GB's 2030 clean power target. The REMA programme (policy development phase expected to conclude in mid-2025) focuses on longer-term electricity market reforms (see our upcoming article for further detail). The government sees the CP30 Plan, the SSEP and REMA reforms as working in tandem to "unleash a wave of clean power" by combining greater strategic planning with more effective market signals.

Shorter-term market measures in the CP30 Plan include:

  1. committing to swift and clear delivery of wholesale market reform through the REMA programme;
  2. Capacity Market reforms to better facilitate the decarbonisation of unabated gas plants (see our upcoming article on Decarbonisation Readiness requirements for further detail) and better incentivise flexible capacity;
  3. accelerating balancing markets, system operability and network charging reforms; and
  4. timely delivery of Market-wide Half Hourly Settlement to drive consumer-led flexibility.

How much are REMA proposals to increase locational signals necessary where the Government is directing where projects should be built? NESO still considers locational pricing to be "the best way" to incentivise a decarbonised power sector even though many investors are concerned that introducing locational pricing will put the brakes on investment at a time when acceleration is key for net zero targets.

The Government's REMA Autumn Update stated that both zonal pricing and reformed national pricing are still under "equal consideration". If the less transformative option of reformed national pricing is adopted, the Government has flagged that the policy measures proposed in the CP30 Plan would likely need to be strengthened (which could include going further with plans for centralised system and generation planning and connections reform).

If you would like to explore what the strategic plans will mean for your projects, please contact us.

 

Key contacts

Silke Goldberg photo

Silke Goldberg

Partner, London

Silke Goldberg
Sarah Pollock photo

Sarah Pollock

Partner, London

Sarah Pollock
Kate Laidlow-Singh photo

Kate Laidlow-Singh

Senior Associate, London

Kate Laidlow-Singh
Ian Mack photo

Ian Mack

Senior Associate, London

Ian Mack
Silke Goldberg Sarah Pollock Kate Laidlow-Singh Ian Mack