Recommendation 23

HM Government · verbatim extract Acknowledged

NESO’s presentation of the SSEP pathway options to the Secretary of State; The Secretary of State’s selection of a pathway option; or NESO’s preparation for the consultation and community engagement activities. Yes, this is the agreed timeline. 24. The draft SSEP should be published for consultation by the end of February 2026 at the very latest and earlier if possible. The Secretary of State should decide upon the chosen SSEP pathway in sufficient time to enable this. NESO is reviewing the timeline to allow for sufficient preparation of the consultation following the Secretary of State decision on the chosen SSEP pathway, whilst giving time for full consultation and response before publication of the final SSEP at the end of 2026. There are also local and devolved government election periods that need to be accounted for within the timeline. 25. We have concerns about the effect of the proposed new policy, in paragraph 4.2.24 of EN-1, that measures to mitigate the environmental impacts of Critical National Priority (CNP) infrastructure are “unlikely to be considered to be appropriate” if they “result in a material reduction in generation capacity”. The word “material” is ambiguous. We are not persuaded that the government has sufficiently considered how this change of policy might affect the achievement of biodiversity targets in the UK or those adopted by the devolved administrations. See response to Conclusion 27. 26. National planning policy for CNP infrastructure should strongly encourage innovative strategies to reduce environmental impacts and, where appropriate, adjustments to site boundaries, layouts or the volume of electricity generation in specific areas for this purpose. See response to Conclusion 27. 27. The government should review whether the following sentence in EN-1, paragraph 4.2.24, is consistent with its own domestic and international biodiversity commitments, as well as those of the devolved administrations: “Measures that result in a material reduction in generation capacity for CNP infrastructure are unlikely to be considered to be appropriate as mitigation.” Government has considered the concerns of the Committee in relation to the proposed Critical National Priority wording in EN-1, as well as similar comments which were received as part of the public consultation on the NPSs. We have amended the wording in question, which now reads as follows: “Measures that result in a significant reduction in generation capacity for CNP infrastructure are unlikely to be considered to be appropriate as mitigation. There may be exceptional circumstances where the mitigation could have a significant benefit and warrant a small reduction in generation capacity and function. In these circumstances, the Secretary of State may decide that the benefits of the mitigation to reduce the effects outweigh the marginal loss of function.” We have amended the wording in EN-1 to make it clear that the focus of Critical National Priority policy is not to maximise generating capacity at the expense of important considerations regarding impacts on the environment. Replacing “material reduction” with “significant reduction” makes it clearer that small scale reductions in generation capacity can be appropriate if they achieve mitigation that has a significant benefit on the receptor being impacted. We have bolstered this change with the new sentence that follows, which aligns with text in EN-1 Section 5.5 (Civil and Military Aviation and Defence Interests) and Section 5.10 (Landscape and Visual) on circumstances where it may be considered acceptable to reduce the function of a proposed development in order to mitigate for an impact. 28. We welcome a more strategic approach to energy infrastructure planning that integrates the pursuit of climate and biodiversity goals and enables the early consideration of nature protection on a habitat-wide basis. We are encouraged to see this ambition reflected in the government’s Clean Power 2030 Action Plan, the Strategic Spatial Energy Plan (SSEP) Methodology, the Land Use Framework (LUF) and the National Energy System Operator (NESO)’s high-level methodology principles for the Centralised Strategic Network Plan (CSNP). We recognise that these plans are still in development. However, the decision to subject the SSEP and the CSNP to detailed environmental assessments strengthens our conclusion that, if they realise this ambition, these strategic plans should be given weight in the determination of applications for development consent. We share the Committee’s view that strategic planning aims to integrate climate and biodiversity goals early on in the process and welcome the conclusion that strategic plans should be given weight in consenting decisions. As highlighted by the Committee, the CSNP process will consider environmental impacts of options as part of NESO’s assessment. The final plan will also be subject to a Strategic Environmental Assessment and Habitats Regulations As