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Hydrogen: The Invisible Option and the Missing Piece of the Net Zero Puzzle?
Hydrogen is exciting! As someone with a keen interest in how I can make changes to the way I live to reduce my carbon footprint I have noticed the growing awareness and publicity of this sector. Hydrogen is being termed as a central piece of the net zero puzzle (a puzzle that is becoming ever more challenging yet important), momentum is strong and industry players across the sector are willing and eager to invest.
Lichfields is working in the sector and is speaking to clients about hydrogen proposals and what the sector may look like in the future. So what are the implications for the planning sector and what role does and will a planning consultant play on hydrogen projects?
In this blog, we look at what hydrogen is, why it is identified as a solution and an opportunity for reaching net zero and what the challenges, unknowns and questions are for planning. We are keen to engage further with key stakeholders so please do get in touch.

 

What is Hydrogen?

Hydrogen is an invisible gas, estimated to contribute to 75% of the mass of the universe. Hydrogen is present in nearly all molecules in living things. It can be produced from a variety of resources, such as natural gas, nuclear power, biogas and renewable power like solar and wind.
Hydrogen comes in many colours and the different colours intend to provide information about how hydrogen is produced. The primary colours include grey, blue and green. Grey hydrogen is generated from natural gas through a process called steam reforming, producing GHG emissions. Most of today’s hydrogen is grey. Blue hydrogen is generated during the steam reforming process, a high proportion of carbon generated is captured and stored underground. Green hydrogen is made by using electricity from renewable sources to split water molecules into hydrogen and oxygen. Green hydrogen is the most spoken about in the sector at the moment.
Key players in the hydrogen market are terming hydrogen as ‘clean, powerful and abundant in nature’ as well as a ‘force of nature’.

An Option and Opportunity?

Achieving the net zero target by 2050 is challenging and it is going to fundamentally change every business and the way we go by our day-to-day lives.
Switching to cleaner hydrogen energy can meaningfully support the transition to a net zero future and the Government and many key stakeholders have published strategies to support this ‘switch’. There is a Hydrogen Council and our Government published its Hydrogen Strategy in August 2021 and its Hydrogen Roadmap in April 2023. In a net zero world, demand for clean hydrogen could reach approximately 22% of our final energy demand.
In real terms, the production of hydrogen includes the following stages:
Hydrogen could be used in the following sectors:
  1. Heat – by replacing natural gas and providing low or zero carbon heat for buildings and industrial uses.

  2. Transport – by replacing fossil fuels in sectors where electrification is not possible or practical (heavy goods vehicles, buses, trains and even ships and planes). This is likely to be the largest segment of the sector in 2050. Hydrogen can be scaled to fully decarbonise sectors, for ground mobility it can complement electrification, through batteries that require long ranges and swift refuelling.

  3. Industry – by replacing fossil fuels as reducing agents in steel making.

  4. Power – used to store low cost excess renewable electricity. This in turn would increase short term and seasonal system flexibility (i.e. during colder winters) and would support the integration of a high level of renewable generation in the energy system. It can also provide energy resilience by delivering continuous grid operation by balancing demand with supply. Hydrogen can be moved from source to where it is needed.
What is clear from our discussions with stakeholders in the sector is that the ambition is here, and it is here now. The Government has doubled its hydrogen ambition from 5GW to 10GW of low carbon hydrogen capacity by 2030, with at least half of this coming from electrified hydrogen. Last year the Government launched its first hydrogen allocation fund offering capital support from its Net Zero Hydrogen Fund and it has funded the study of different hydrogen projects around the UK, including but not limited to Gigastack, Hynet, Aldbrough Hydrogen Storage (which Lichfields is involved in), Octopus Hydrogen and Carlton Power

The Government’s roadmap sets out its ambitions for the next 10 – 15 years. Technology wise this is linked to production, hydrogen networks and use, starting off on small scale projects and end uses such as buses, early HGVs and neighbourhood heat trials to the mid 2030s when the aim is to increase the scale and range of production with regional and national networks and it being used within a full range of sectors. The Government recognises the need for policy support which is promising, including regulatory frameworks, market frameworks, grant funding and research and innovation.
So how do you bring innovations forward to a real world reality? What is clear from our research is that it needs investment and policy support to establish demand and reduce cost so it becomes a viable alternative. We also need a buy in from the public and private sector to incentivise the transition, support initial economic hurdles and set common standards across industries and geographical areas.

 

What are the implications, challenges and unknowns?

As with any emerging technology and sector, there are a lot of unknowns. Looking at this holistically, these include cost, technological advances, the need for ‘first of a kind investment’ and training and upskilling people. What will development actually look like, what land take and infrastructure will be needed, are there any locational requirements, what about grid connection and transportation, what about new development requirements and retrofitting and what about safety.
From our view and from a planning perspective what is clear is that to embed hydrogen and allow it to become a ‘piece of the puzzle’, a simple joined up policy and regulatory framework is needed and quickly. We need a clear and consistent direction from the Government to give confidence and certainty, whilst remaining flexible to adapt to new opportunities.
Within such a framework, it is our view that the following needs to be considered:

 

  • A national policy position within the National Planning Policy Framework (‘NPPF’) and in National Policy Statements. Positively, the Government has updated its National Policy Statements and NSP1 (Overarching Statement for Energy) sets out the Government’s position on hydrogen. NPS1 came into force last month. This sets out the in principle need, support and demand for hydrogen in meeting the net zero objective. It recognises that the energy system needs transforming to increase the supply of clean energy, such as hydrogen. Substantial weight should be given to need. The Government’s view is that a twin track approach of developing both green and blue hydrogen production will be needed to achieve the scale of production required for net zero. NPS1 also states that the Government is committed to providing more information on hydrogen planning, relevant to planning, and including guidance documents. We will watch this space! Will greater emphasis be given in the forthcoming planning reforms?

  • A clear route and set of requirements for local planning authorities – whether this be in the form of their own hydrogen commitments, investment plans and, or local planning policy requirements or supplementary planning guidance. At present, authorities have net zero policies, an example being a commitment to achieving a certain percentage of energy needs via a renewable energy source. Is this enough? What about site allocations and supporting developments and infrastructure? Hydrogen focused policies are needed quickly. How many authorities will be or will not be progressing local plan reviews to capture such policies?

  • Education, knowledge sharing and community engagement. This will be extremely important, especially the need to educate local communities. As with other forms of renewable energy, the Government needs to set a positive framework that allows communities and future developers to work together rather than place the decision on whether a development should come forward on the basis that impacts on the community have been ‘fully addressed’.

  • Leading on from community engagement, there is a general perception that hydrogen is not safe. Is there a role for the Health and Safety Executive (‘HSE’) and what is that? When submitting a planning application for any form of hydrogen development, should it be accompanied by a health and safety assessment, and will this be a validation requirement? What needs to be included in these assessments and who can undertake them?

  • Our blog has not touched on the exact types of hydrogen development and what they might look like (i.e. the type of development that is needed to charge a HGV versus a plant to heat a warehouse or supply electricity to an industrial unit). Are there any locational requirements and supporting or enabling infrastructure and development? Where are the strategically important locations and what communities will they serve?
Other stakeholders in the energy and planning sector have provided their own view on the way forward for hydrogen, including RenewablesUK. The key message is that the planning system needs an “overhaul”, noting there is limited national planning guidance specific to green hydrogen (i.e. that being made from renewable sources).
We are continuing to meet with clients and key stakeholders to understand the exact requirements for hydrogen projects and planning requirements and please do get in touch with your own view.
Hydrogen is exciting! We should act now to benefit from this energy opportunity.

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Putting wind into the sails of planning? A (small?) step in the right direction
If you work in the renewable energy or planning sector, last week’s announcements will not have gone unmissed.
On Tuesday 5th September, Michael Gove, the Secretary of State for Levelling Up, Housing and Communities, published a Written Ministerial Statement on onshore wind development. An Updated National Planning Policy Framework (‘NPPF’) was also published.
In previous blogs, I have discussed the role of wind energy, its current policy framework and the Government’s appetite for change. As someone who is keen to become more climate aware, I provide thoughts on the policy changes; changes that can best be described as tinkering around the edges.

What are the minor policy changes?

In his Written Ministerial Statement, Michael Gove commented that the Government has consulted on a number of proposed changes relating to onshore wind. The Government continue to believe that decisions on onshore wind “are best by local representatives who know their areas”. They also recognise that policy needs to strike the right balance “to ensure that local authorities can respond more flexibly to suitable opportunities for onshore wind energy, contributing to electricity bill savings and increasing our energy security”.
The changes include:
  1. Amending the planning tests for proposed onshore wind developments “to make it clear that suitable locations can be identified in a number of ways”.

  2. Adjusting policy so that local authorities “can more flexibly address the planning impacts of onshore wind projects as identified by local communities” (on which they intend to publish further guidance).
In addition to this, the Government is “clear that local areas that support hosting onshore wind should directly benefit” and they have consulted on proposals for improved rewards and benefits, such as potential energy bill discounts.

So how do these changes play out in the Updated NPPF?

The Government has set out positive and good intentions with the above changes and certainly when we read the Statement, we awaited the Updated NPPF with bated breath. So how has the NPPF been updated and what will it actually mean for the planning process?
The NPPF (July 2021) set a clear policy framework for onshore wind. Paragraph 158 b) stated that “when determining planning applications for renewable and low carbon development, local planning authorities should… approve the application if the impacts are (or can be made) acceptable” except for the exemptions in Footnote 54; a proposed wind energy development involving one or more turbines. These should not be considered acceptable unless it is an area identified as suitable for wind energy development in a development plan and, following consultation, it can be demonstrated that the planning impacts identified by the affected local community have been fully addressed and the proposal has their backing. This is a negatively worded policy position which has put a near block on development.
The Updated NPPF now reads (it is a game of spot the difference):
In respect of new renewable and low carbon development, Paragraph 158 remains the same.
A new Footnote (Footnote 53a) reads:
“Wind energy development involving one or more turbines can also be permitted through Local Development Orders, Neighbourhood Development Orders and Community Right to Build Orders. In the case of Local Development Orders, it should be demonstrated that the planning impacts identified by the affected local community have been appropriately addressed and the proposal has community support.”
Footnote 54 reads:
“Except for applications for the repowering and life-extension of existing wind turbines, a planning application for wind energy development involving one or more turbines should not be considered acceptable unless it is in an area identified as suitable for wind energy development in the development plan or a supplementary planning document; and, following consultation, it can be demonstrated that the planning impacts identified by the affected local community have been appropriately addressed and the proposal has community support”.
The NPPF also provides a new bullet point to Paragraph 158 (c). This states that “in the case of applications for the repowering and life-extension of existing renewable sites, give significant weight to the benefits of utilising an established site, and approve the proposal if its impacts are or can be made acceptable”.
[Lichfields emphasis]



A real change or just ‘hot air’?

Those people involved in the renewable energy and planning sector will have responded to the consultation on planning reforms at the start of this year (as did we) and were hopeful that national policy would be updated to positively plan for all forms of renewable energy as well as understand and reference the commercial backdrop to bringing forwards development.
Instead, the Updated NPPF retains the negatively worded policy. It includes ‘tinkered wording’ set in the context that wind energy developments should not be considered acceptable. An unfair hurdle. We discuss our thoughts below.
Looking at things holistically the changes are underwhelming when compared to the grand promise of last year. There is a real missed opportunity. Could the Government have waited and provided one wholescale update to national policy to reflect the importance of all forms of development, including housing, employment and renewable energy? They should come hand in hand. It would appear that a quick decision has been made with little understanding of the bigger planning picture. Does this rule out any more changes in the short or long term?
If we were to turn back the clock 10 months, people in the renewable energy sector were getting excited. The Government had released its growth strategy and recognised that it needed to address barrier to wind development by reducing the “unnecessary burdens to speed up the delivery of much needed infrastructure”. We have previously commented on what this might look like in previous blogs; everything from considering wind developments in the context of prevailing planning designations and a set of locational requirements (both geographically and in relation to grid connections), to what a material planning ‘hook’ might look like to achieve local community support. Instead, however the changes are minimal and, in our view, make no real difference in reality. The negative wording remains, and this means that new wind farms will not be considered solely on their planning merits.
Turning our attention to the revised NPPF wording, the new Footnote 53a states that wind energy can now be permitted through Local Development Orders (‘LDO’), Neighbourhood Development Orders (‘NDO’) and Community Right to Build Orders (‘CRBO’). These all grant permission for a specific type of development in local areas and a CRBO is a form of NDO which can be created by a local community organisation. The key message here is that they are all intended to involve or be brought forward at a local and community level. We have significant questions over whether this actually provides a more flexible policy position for commercially sized wind developments. As far as we are aware, there has been nothing stopping these orders coming forwards to date and if they need community support what actually changes? As we have previously suggested, what is needed is a joined up policy approach at a national and local level whereby sites are allocated, or identified for development (similar to all other forms of development) and where applications are decided on based on ‘planning merits’ and ‘planning balance’ by a local authority or Inspector.
There have been changes to the need for community backing. This is now referred to as “community support”. Planning impacts now need to be “appropriately addressed” rather than “fully addressed”. This is semantics and it is unclear as to what this means, whether in reality it does change policy and how it should be interpreted. What does community support look like, does it differ in each area and for each development? Earlier this year, Lichfields responded to the Government’s consultation on ‘Developing Local Partnerships for Onshore Wind in England’ on behalf of clients. We suggest that Local Plans should contain policies to encourage the use of community contribution payments as part of developer’s engagement with communities, maybe delivered through the Community Infrastructure Levy. The idea of discounted energy rates is not, at present, a matter than can be given weight as a material consideration in the determination of planning applications.
We will watch out for further guidance, a topic for a future blog maybe…?

Image Credit: Karsten Wurth, Unsplash

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