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UTILITY WEEK | APRIL 2023 | 21 Policy & regulation consultees and infrastructure developers to address "oen complex issues" before appli- cations are submitted and hopefully leading to shorter examinations. The government has also vowed to imple- ment a new Offshore Wind Environmen- tal Improvement Package to accelerate the delivery of new offshore wind infrastructure that oen faces delays due to environmental concerns. The planning process is a key factor in the delays for offshore wind projects, says Aurora's Padelkar, who argues that the gov- ernment's 50GW offshore wind ambition by 2030 will be "impossible" to meet based on current delivery timescales. RWE's Glover said offshore wind projects currently appear able to secure permis- sion only if ministers overrule the Planning Inspectorate's recommendations. "Clearly, the planning process of policy is not aligning with what the government wants to deliver so there needs to be a fun- damental review," he said. "Although we get very positive signals and initiatives from the government about wanting to move it from four years to one, on the ground we see zero in terms of real progress and in fact consent- ing seems to be taking even longer." The publication of the action plan is, though, a "positive" move, says Sharpe: "It gives us confidence that what the govern- ment has previously said is still their inten- tion and has given us some slightly clearer deadlines in terms of when those reforms are likely to come through." Padelkar welcomes the introduction of enhanced pre-application advice, which should help developers to get their projects in a good shape when submitted, and the potential fast-track consenting service for certain projects. However, Sharpe expresses concerns that while front-loading discussions into the pre- application phase may cut the time for deter- mining applications, it won't necessarily have a "massive" impact on the four years it takes for projects to get through the planning process. He says: "On paper, it will appear that the planning and consenting times are shorter but it means that developers will spend more time in the pre-application phase having these discussions with the communities and other stakeholders." Another necessary changes not addressed in the action plan, Sharpe says, is the "greater certainty" required for non-material changes to DCOs. "There's still no statutory timescale for the government to decide on non-material changes. That's a huge issue because if you're building a nuclear power station and you've got a change that requires a non- material amendment, not knowing how long that change may take is going to cause a huge cost and delay. "That lack of certainty discourages devel- opers from making the change in the first place and potentially delivering a scheme that could have been done better." The lack of set timescales for non- statutory changes means they tend to be given less priority by already "overstretched" planning inspectors, he says. "They'll be tempted to prioritise fresh applications that do have statutory timescales over ones that don't. That's inevitable." And while glad to see the action plan's aspiration for the energy NPS to be adopted by the midpoint of this year, Sharpe feels this is "quite ambitious". But publishing an up-to-date set of NPSs is essential, says one senior infrastructure figure: "It's causing a lot of issues because it creates gaps in terms of the up-to-date policy framework. "That is at the heart of the delays we are seeing across energy, across water and across transport. I suspect that is then concertina- ing down throughout the process, leading to much greater risk aversion and mitigation. "The key thing government must urgently do is get these NPSs up to date. They [inspec- tors] can't be second guessing policy and planning, especially in the examination phase." One of the issues overlooked in the action plan is the role of ministers in the decision- making process, which has been the source of delays for a number of major recent off- shore wind projects. However, these logjams may be the result of issues not being resolved until they have landed on the secretary of state's desk, they say. And while the steps outlined in the action plan are worthwhile, they are probably too incremental for the scale of changes required to enable the UK to hit net zero by 2050. "I'm not sure in and of itself it is a big enough shi to get us back to the consenting times when the original regime was intro- duced in 2010, which should be our aim and feels realistic, although tough. "We've got to have staying power to push this stuff through because if we don't, we won't be meeting the sixth carbon budgets." David Blackman, policy corespondent