Rethinking national planning for energy infrastructure

We need community-supported, good value and environmentally sensitive upgrades to our energy infrastructure. Yet, the current draft updates to the National Policy Statements (NPS) for energy fail to provide the clarity or guidance necessary to achieve this.

In fact, they risk entrenching outdated technologies, overlooking innovative solutions, and bypassing essential planning principles that could make grid expansion cheaper, faster, and more sustainable. The consultation ends on 29 May but before that, there's a call for evidence, "National planning for energy infrastructure" which closes on 12 May. It's crucial to submit evidence to the committee, in order for them to make representations.

1. Premature drafting

The updated NPS documents are being developed ahead of critical frameworks such as the:

• Strategic Spatial Energy Plan (SSEP)
• Centralised Strategic Network Plan (CSNP)
• Electricity Transmission Design Principles
• Planning & Infrastructure Bill
• Land Use Framework.

This risks policy confusion.  It also represents a breach in the Gunning principles – one of which is a requirement to have sufficient information to give intelligent consideration.   Seeing as the Electricity Transmission Design Principles are not even available in draft, it is certainly not possible to consider them!  Likewise, the relationship between the NPS and emerging frameworks like the SSEP and CSNP remains unclear and impossible to comment on. These strategic plans are still in development—yet the NPS amendments are racing ahead.

2. Critical National Priority Projects, a misguided approach

Labelling controversial projects like Norwich to Tilbury as "Critical National Priority" only reinforces flawed decision-making. This particular proposal is:

• Under-costed
• Harmful to communities, heritage, businesses and the environment
• The worst of all options – excellent alternatives exist

Moreover, the NPS still omits reference to the Treasury Green Book—a mandatory guide for government decision-making. This is a serious oversight. The Green Book ensures decisions are economically sound, socially beneficial, and environmentally responsible. Ignoring it results in slower approvals, higher costs, and poor long-term outcomes.

We should not be fast-tracking projects that ignore better, cheaper, and less damaging options.

4. Outdated preferences for overhead lines

The presumption in favour of overhead lines is outdated and counterproductive. Here's a proposed sequential test for grid upgrades:

• Upgrade existing grid first – Technologies exist (like TS Conductor) to triple capacity on existing pylons with less environmental and financial cost.
• Coordinate offshore infrastructure – Integration has been proven repeatedly to save money and reduce land impact. 
• Consider brownfield sites – Use land close to demand, not remote rural areas.
• Use HVDC undergrounding – Not only cheaper over its lifetime, but also far less damaging and more acceptable to communities.
• Use pylons only as a last resort – Given their environmental footprint, hidden costs and public opposition, pylons should no longer be the default.

5. Government misunderstandings (deliberate or ignorant?)

The government’s Sustainability Appraisal alongside the NPS consultation misrepresents undergrounding by failing to distinguish between High Voltage Alternating Current (HVAC) and High Voltage Direct Current (HVDC) undergrounding. The latter:

• Requires fewer cables
• Uses narrower construction swathes (40m vs 80m for pylons and 220m for AC undergrounding)
• Has lower lifetime costs
• Is already proposed in major UK projects like Eastern Green Link 3 & 4 where National Grid has stated that it is less risky, quicker and has lower lifetime costs than pylons.

Government continues to ignore cable ploughing rather than open trenching. This further reduces disruption and cost - see ATP Cable Spiderplow underground Cable Ploughing.

6. How many times do we have to say it? “Follow the Treasury Green Book!”

Treasury Green Book guidance should be embedded in the NPS. Its absence is contributing to:

• Misjudged project costs (e.g., Norwich to Tilbury could cost four to eight times more when full socio-economic impacts are considered)
• Environmental destruction
• Economic inefficiency
• Community unrest and legal challenges

7. The grid connection system needs to be subject to planning approval

Grid connection decisions are currently made without adequate integration into the planning system. This has led to poorly located “energy hubs” in rural areas like Ardleigh (Essex), Bramford (Suffolk) and Friston (Suffolk), where multiple pylons projects, cable trenchings, huge substations and enormous converter stations are planned without strategic oversight.

These connections should instead be:

• Coordinated offshore
• Landed near major demand centres on brownfield sites, not prime agricultural land far from where the power is needed.

8. Protect farmland, communities and heritage

The current approach does not balance environmental, heritage, or archaeological considerations. In fact, the government's own Sustainability Appraisal shows all impacts as negative—yet nothing in the NPS seeks to reverse this.

Best and most versatile farmland must not be sacrificed.

9. Conclusion: we need up-to-date and case-by-case thinking

The government must move on from its reliance on the outdated, 2012, Parsons Brinckerhoff study. Ofgem and NESO must stop taking what National Grid says at face value and begin to scrutinise and challenge the proposals put in front of them.

Policies should include the following:

• Remove the overhead line presumption
• Mandate the use of modern technologies to upgrade existing infrastructure
• Enforce coordinated offshore transmission
• Prioritise HVDC undergrounding
• Align the NPS with the Treasury Green Book
• Evidence-based approach! For example, the carbon impact of each project needs to be calculated.

If these principles are followed, the UK can deliver a cleaner, faster, fairer, and more affordable energy future—with fewer legal challenges, greater public support, and a lighter environmental footprint.

Want to know more? You can read our Essex Suffolk Norfolk Pylons campaign's detailed report, Leaders not Laggards: 📄 Read the Report