Reflections on NIPA Annual Conference – 29 June 2023

Major infrastructure is key to boosting the UK economy, securing energy supplies, as well as delivering Net Zero to tackle the challenge of climate change. There is increasing pressure for updates to the consenting process for major infrastructure projects to enable quicker action to meet national decarbonisation targets. As infrastructure planning professionals, it is our responsibility to act now and seize Net Zero as the sustainable economic growth opportunity that is central to decision-making around future investments and frameworks. This blog considers how we can “Make Infrastructure Planning Great Again” to realise these challenges.

The change we are seeing in this space spans operational reform; consideration to fast-track consenting, post-consent changes, cost-recovery and more, which will have a fundamental impact on how major infrastructure developments are consented moving forward.

The following takeaways summarise the infrastructure debate undertaken at the National Infrastructure Planning Association (NIPA) 2023 annual conference, where Deloitte colleagues from Real Assets Advisory (RAA) exchanged insights with peers in the industry on this critical topic and debated the necessary changes to Nationally Significant Infrastructure Projects (NSIPs).

We came away with the following key priorities that summarize the evolution in our approach to development consenting going forward:

The structure of DCO applications is changing

Since the Planning Act 2008, Development Consent Orders (DCO) were introduced to speed up consenting for major infrastructure projects in the UK. Increased delays in decision-making indicate stress within the current system and have instigated the proposed reforms which consider how to streamline the structure of DCO applications, through shorter examinations.

A co-ordinated cross-governmental approach

A strengthened role for coordination between multiple governmental departments, professional bodies and organizations is essential. This should take place through ongoing conversations and sharing of best practices between industries and sectors. We must be willing to innovate through cross-party frameworks and across sectors. We must be willing to leverage funding across both public and private sectors with an openness and willingness to support one another and hold each other accountable to deliver on time and on budget. Net Zero targets will not be met in isolation but require a continued and sustained approach across governmental bodies and sectors.

An example of this ambition has been set out by the National Infrastructure Commission (NIC) which has played a vital role in shaping the policy recommendations and the NSIP planning reform as they are responsible for providing the government with impartial expert advice on infrastructure challenges. Their recent report (April 2023) provides recommendations on the current approach to National Policy Statements (NPSs) and identifies how the planning system could create greater certainty for infrastructure investors, developers, and local communities. It highlights that most stakeholders are in favour of keeping the current system that initially worked well but has slowed in more recent years. NIC intend to follow this by publishing its second National Infrastructure Assessment in Autumn 2023 and Infrastructure Progress Review by Spring 2024.

Leverage benefits for local communities and local authorities

With the scale of the projects under review, we must not forget that amendments to our infrastructure policy directly impact local people and communities. We must improve early engagement on projects and maintain ongoing dialogue with local communities throughout. Local Planning Authorities (‘LPAs’) should be supported to ensure the volume of schemes being moved through the process have an appropriately diverse and resilient resourcing model to ensure the system’s capability. We recognize the limitations in capacity and expertise in local communities and/or authority to understand the complexity of the NSIPs. County Council leaders have recently been known to highlight with town and parish councils that they may not have adequate resources or expertise to respond to complex consultations and environmental issues.

The system must adapt to coordinate more smoothly between multiple technologies and sectors. This will help to avoid cliff edges in policy and address matters head on in pre-application discussions. The role of the pre-application process should also be strengthened to enable more effective and proportionate consultation with the local community and authority. We must adapt to increased requirements for digital technology.

Size matters

Size does matter when it comes to decision-making both in geographical extent and development component parts. This applies to both changes within projects, and how policy fits in accordingly. Where we draw the red-line boundary influences different levels of local, national and global impact.

Size also presents a new challenge, in how cumulative impacts take place, are measured and standardized. We must consider how alternatives are treated. The interrelatedness and co-location of clustered developments themselves create challenges. How we coordinate land uses should be considered early in CPO and land negotiations. Getting this delivery perspective correct is key to realising better outcomes for the natural environment.

Market Insights

We analysed the data released by the Planning Inspectorate (PINS) and identified that there is a growing demand for DCO applications, including 20 offshore wind farms by 2029, and 17 energy transmission consents by 2027. In the next two years, there will be approximately 40 projects for potential submission to the PINS. We understand that the PINS has been exploring ways to improve its services to meet the growing demand for DCO applications. This includes integrating metadata for inputs and outputs, considering the implications of artificial intelligence (AI) for the process, and exploring new technologies to examine more complex and multi-sectoral projects.

Upcoming focus – Environmental Impacts

While there is a growing demand for DCO applications, we must not undermine the emerging challenge of addressing climate change, and we should fully assess and appropriately mitigate environmental impacts. In the context of NSIPs, we expect two topics to dominate the headlines: Biodiversity Net Gain (BNG) and Environmental Outcomes Reports (EORs). Firstly, the Government confirmed that BNG will apply to NSIPs that will come into effect later this year. Secondly, the Government published its consultation on replacing both Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA). We have been monitoring very closely the development of these two emerging topics.

Summary

The UK is world-leading in both its ambitions towards meeting Net Zero, and the steps that it has taken to date to evaluate its current consenting projects. While we are seeing immense pressure guided towards this development, we are proactive in playing our part to help improve the system and reform the planning regime. The next few years are undoubtedly crucial in how we orchestrate persistent and engaged professional organisations to adopt a shared vision and approach achieve a fundamental shift in how delivery and consenting take place. In the words of the NIPA chair, we look forward to “Make Infrastructure Planning Great Again”, and for Deloitte to continue to lead this conversation, in alignment with its core value to “Make an Impact that Matters”.