Recommendation 38

HM Government Accepted

39. The government should, in its response to this Report, provide any evidence which it has that the proposed 100 MW threshold for onshore wind developments to fall under the Nationally Significant Infrastructure Projects regime will aid in the development of onshore wind projects, or whether the threshold should be lowered. The process for introducing onshore wind into the NSIP regime was legislative and included public consultation on the threshold. The questions on what the NSIP threshold should be for onshore wind were part of the wider consultation on ‘Proposed reforms to the National Planning Policy Framework and other changes to the planning system’ which ran from 30th July to 24th September 2024. Changes to the NPS do not introduce the threshold but reflect the results of the legislative process, providing guidance to applicants and decision-makers. Government published a full impact assessment6 as part of bringing forward the Statutory Instrument to reintroduce onshore wind into the NSIP regime at 100MW that sets out the rationale in further detail.7 The purpose of the NSIP regime is to provide the largest and most important projects with a single approach to seeking development consent balancing local impacts against the wider national benefits of strategic projects. 6 https://www.legislation.gov.uk/uksi/2025/694/impacts 7 https://www.legislation.gov.uk/ukia/2025/56/pdfs/ukia_20250056_en.pdf. The RPC opinion is available here: https://www.gov.uk/government/publications/the- infrastructure-planning-onshore-wind-and-solar-generating-stations-order-2025- impact-assessment-rpc-opinion-green-rated A 100MW threshold ensures that only the largest and most important projects, which are genuinely nationally significant, enter the NSIP process. Mid-sized projects can then progress using the local planning route under the Town and County Planning Act 1990, which is typically quicker and cheaper for these types of projects. The government has set the 100MW NSIP threshold for onshore wind projects following technological advancements in turbine technology. Over the past ten years, the rated capacity of turbines used in UK projects has approximately doubled to around 5 megawatts on average, with some of the very latest projects proposing 6 or 7 megawatt turbines. The original 50MW threshold set in 2008 when onshore wind was first part of the NSIP regime could now be met with as few as 7–10 turbines – we do not consider this to be of a significant scale, impact or complexity that is proportionate to using the NSIP regime. There is also a risk that setting the threshold too low will lead to impacts seen with solar, where developers have artificially capped themselves below 50MW to avoid entering the NSIP regime, making potentially inefficient use of limited land and grid connections. 40. Building renewable energy infrastructure on peatland is counterproductive to the achievement of net zero if this results in the release of accumulated carbon stores into the atmosphere. Given this context, and the Climate Change Committee’s recommendations for peatland restoration in the Seventh Carbon Budget, it is surprising that the government’s proposed new guidance for onshore wind in EN-3 does not contain a presumption against building on deep peat, though we recognise that there are areas in which such development would be unavoidable. The weakness in the guidance also appears to undermine efforts of the Department for Environment, Food and Rural Affairs to protect peatland. See response to