Overall, the direction of travel in December’s draft National Planning Policy Framework (NPPF) for energy policy is clear. Substantial weight is to be given to renewable and low‑carbon energy development, with an expanded definition that rightly now includes technologies such as energy storage. This is welcome and unsurprising.
Where draft policy remains weaker, however, is not in ambition but in delivery mechanics. The challenge is no longer whether energy infrastructure should come forward, but how the planning system — and in particular the Local Plan — can genuinely support timely, investable delivery that aligns with grid capacity, development risk and technological change.
The draft NPPF places renewed emphasis on plan‑making as a vehicle for delivering the infrastructure needed to meet energy targets, whether that be 2030, 2035 or beyond. Yet in its current form, it risks only scratching the surface of what is required.
Rather than searching for broad areas suitable for energy development, Local Plans could adopt a site‑specific, evidence‑based allocation process designed specifically for energy infrastructure. Lichfields' Advanced Energy Group describes this as the Integrated Energy Allocation Model.
The model is built around six interlinked components, intended to provide earlier certainty while retaining flexibility and avoiding premature or inefficient planning applications.
The Integrated Energy Allocation (IEA) Model
No.1: Call for Sites; not Search for Areas
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Local Plans would include a targeted call for energy sites exercise, inviting submissions from energy developers and infrastructure providers who have identified specific sites with a demonstrable grid connection opportunity at a point in time.
Crucially, this shifts the emphasis from theoretical suitability to deliverability, allowing sites to be assessed individually through the plan‑making and examination process.
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No.2: Proportionate, parameters-based evidence
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At present, grid connection processes — particularly the Gate 1 / Gate 2 framework operated by NESO — strongly favour schemes with full planning permission as a proxy for construction readiness. This incentivises developers to secure permissions earlier than is optimal, often well in advance of a realistic connection date.
The result is a mismatch between planning implementation periods and grid delivery timescales, leading to avoidable cost, inefficiency and, in some cases, token partial implementation simply to preserve permissions. An alternative approach would allow developers, particularly for medium to longer term projects (2030 onwards), to submit proportionate, parameters based evidence instead. This would identify the energy type and assess maximum extents, scale, operational characteristics and environmental effects, alongside evidence of grid connection opportunity, without locking schemes into fixed designs too early.
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No.3: Independent Examination and Energy Allocation
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Sites would be independently examined through the Local Plan process. Where the evidence is accepted, the site would be allocated for energy infrastructure.
This allocation would function primarily as site safeguarding — protecting neighbouring land from incompatible development and providing clarity over intended energy use for the lifetime of the plan, unless evidence later demonstrates that the connection opportunity has fallen away.
As with housing allocations, communities and statutory consultees would engage through the examination process.
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No.4: Permission In Principle for energy use
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The most significant step would be the introduction of a Permission in Principle linked to the energy allocations in Local Plans. This would require legislative and policy change, but its impact would be transformative.
An Energy Permission in Principle would establish:
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the approved energy use or uses;
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maximum physical parameters; and
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an upper limit on generating or storage capacity.
This would give developers and infrastructure providers a level of certainty that the current system cannot offer, without having to freeze detailed design prematurely. They would be incentivised to engage in the call for energy sites exercise process and to provide the necessary evidence.
The energy developer / infrastructure provider would then maintain its options on the allocated site, safe in the knowledge that permission in principle has been established.
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No.5: Specification approval closer to delivery
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Detailed specification, layout and technology would be approved at a later stage, closer to the grid connection date. This reflects the pace of technological change in the energy sector and would reduce the need for repeated amendments.
The process would be analogous to reserved matters, with the principle of development no longer in question and conditions tightly focused.
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No.6 Flexibility for ‘windfalls’
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The call for energy sites process would lead to Local Plans identifying a range of suitable sites to provide a pipeline of energy development in that area, based on known connection opportunities, existing and planned.
Importantly, this approach would not be exclusive. Network capacity ebbs and flows, and connection opportunities will continue to arise outside the snapshot moment of plan preparation.
Consistent with draft Policy W3, substantial weight would continue to apply to energy proposals on non allocated sites, ensuring flexibility and responsiveness to changing circumstances.
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Making it work in practice
For the Integrated Energy Allocation model to function effectively, alignment with NESO and Distribution Network Operators would be essential. In particular, Local Plan energy allocations would need to be recognised within grid connection processes, potentially through early‑stage, “subject to allocation” agreements.
Guardrails would also be required to avoid over‑allocation and land sterilisation, ensuring that the extent of safeguarded sites broadly aligns with anticipated network capacity and connection availability.
Distribution Network Operators could also choose to promote sites through the Local Plan process. If an allocation is then forthcoming, the connection agreement would run with the land and be available for a developer to secure.
From aspiration to delivery
If Local Plans are to be genuine delivery vehicles for energy infrastructure, rather than statements of intent, they need mechanisms that reflect how projects are financed, connected and built.
The Integrated Energy Allocation Model offers one way of bridging the gap between policy ambition and delivery reality — providing earlier certainty, reducing wasted effort, and supporting the timely infrastructure needed to meet the UK’s energy targets.
This is not a finished blueprint, but it is a starting point for a more practical conversation about how planning can better support the energy transition.
