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) |
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2025-2030 |
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Strategic Spatial Energy Plan (SSEP) |
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2030-2050 |
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Centralised Strategic Network Plan (CSNP) |
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tCSNP1: up to 2030 tCSNP2: 2030-mid-2030s CSNP: 25-year horizon |
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Regional Energy Strategic Plans (RESPs) |
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5-25 year horizons |
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Future Energy Scenarios (FES) |
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To 2050 |
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Gas Network Capability Needs Report (GNCNR) |
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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:
- committing to swift and clear delivery of wholesale market reform through the REMA programme;
- 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;
- accelerating balancing markets, system operability and network charging reforms; and
- 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.
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Disclaimer
The articles published on this website, current at the dates of publication set out above, are for reference purposes only. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action.