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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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Building, growing, daring enough? A revised NPPF and long-term plan for housing update
The Government has issued a revised national planning policy framework (NPPF) and a written ministerial statement (WMS) “The Next Stage in Our Long Term Plan for Housing Update” . Both include policies or proposed policies that also affect non-residential development.
To launch both, the Secretary of State (SoS) gave a 30 minute speech, in which he promoted the reasoning behind the changes made, those still to come, his desire for the nation to be “building, growing, daring” and “falling back in love with the future”.
The Government’s response to the December 2022 consultation of reforms to planning policy, published on the same day, includes a detailed explanation of the changes made to the NPPF, as well as consultation outcomes that will take effect or be consulted upon further in due course.
The Housing Delivery Test 2022 results were also published (having been expected in January 2023 based on the year ending March 2022).
The revised NPPF updates the previous September 2023 NPPF, which was the July 2021 NPPF plus the changes to onshore wind energy policy.
The changes to the NPPF are outlined in this blog and discussed in more detail in these blogs:

Changes to 5YHLS under the revised NPPF: Not Great, Not Terrible by Harry Bennett

Housing need cannot be ignored like an unwanted Christmas present by Simon Coop

No Excuses: Unlocking Local-Plan Making? by Isabella Tidswell

The WMS summarises (in the Government’s words, of course) the key changes to the NPPF and the reasoning behind them.
This is followed by reference to a variety of new performance measures, including, local plan interventions, and an independent review of the London Plan. Planning application performance measures include changes to extension of time policy and the designation of two new s62A planning authorities (Chorley and Fareham).
The WMS also announces a Cambridge Development Corporation, a new traveller policy (following a court judgment) and intended new building regulations relating to water efficiency in new homes and an interim approach to agree tighter standards, in areas under water stress.
In addition, the WMS makes reference to immediate changes and to proposals for the future, including introducing provisions in the LURA, notably enforcement provisions, in the short term. And there will be “a consultation on measures to improve build out rates once the Competition and Markets Authority has published its final report as part of their housebuilding market study in 2024".
The WMS also reminds councils that “development should proceed on sites that are allocated in an adopted local plan with full input from the local community unless there are strong reasons why it cannot; councils should be open and pragmatic in agreeing changes to developments where conditions mean that the original plan may no longer be viable, rather than losing the development wholesale or seeing development mothballed; and better use should be made of small pockets of brownfield land by being more permissive, so more homes can be built more quickly, where and how it makes sense, giving more confidence and certainty to SME builders”.
Some of the announcements in the WMS that will take effect immediately or imminently are discussed in these blogs:

All stick and no carrot - New planning performance measures and a crackdown on the extension of time by Sean Farrissey

Khan you do it like that? Or Cam you do it like this? Gove’s targeted housebuilding armament by Paddy Hynes

Overall, the 20 December 2023 planning announcements and publications are wide ranging and have more than a housing focus. However, the most immediately impactful are those relating to planning for housing.
Lichfields will undertake more analysis on the revised NPPF in the coming weeks. Subscribe to our blog for updates.
 
 

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