CLEAN POWER 2030 – NOW WITH ACTIONS

Last Friday the Government published its action plan for delivering CP2030, and did so RUTHLESSLY on the day after our Christmas party. We opted to husband our meagre remaining braincells onto briefing clients, and have yet to have the opportunity to set out our public views.

But the passage of a week has given us time to reflect, and I certainly have some views. Everything is moving in the right direction, and yet, and yet, and yet. I want to talk about three topics where I have the greatest concern, and then a little flourish at the end.

PLANNING REFORM - Current rating: CARDINAL.

Much of the Action Plan slightly smacks of, “Here’s a list of everything individual Departments are doing,” something I’ve written about before. But this is particularly the case in this section where it is manifest that DEFRA and MCLG absolutely do not get it.

The document claims that our current planning system is built on solid foundational principles. This is simply false; it represents a manifest distortion of incentives on local authorities to deliver, a total confusion about how to write rules that aren’t vague enough to create significant legal risk, and too many statutory consultees that cannot make meaningful trade-offs.

Rather than confront this more existential question, the Action Plan instead asks, “What if the same, but slightly faster?” More staff for consultees and planning authorities, further contradictory obligations on LAs, and more requirements on developers so that pre-development takes more time – which doesn’t count towards time in the planning system.

More detail on this will be available next year, but if the refreshed National Policy Statements don’t say, “Everything in the Clean Power 2030 bucket gets approval, nothing counts against this,” I will be very concerned. There is a glimmer of light in the commitment to look at judicial review risk, but nothing on the section in Lord Banner’s review where he carefully doesn’t say, “RETHINK AARHUS FOR GOODNESS’ SAKE.”

The single most impressive measure in this section is a commitment for the Clean Power 2030 Unit to convene developers, planners and communities around particularly complex projects to speed delivery. Using central Government resource to ensure that the projects Central Government cares about – and thereby exposing officials to the madness of the present system – is an excellent recipe for delivery and reform.

THE TARGET - Current rating: TOPAZ

I am extremely relaxed about a 95% target, because it reflects the reality of a power system in which the only really available source of molecular storage is natural gas. Hydrogen is waaay too expensive to take that role any time soon, and it’s questionable whether it ever will be able to.

However, what’s missing from the target is an assurance for 1/1/31. There’s a plan to deliver a system in 2030 that could deliver carbon emissions at the 5% level, but what’s considerably less clear is how performance is guaranteed after this date.

This is because there’s no mechanism to respond to changes in demand. In the event that demand increases more quickly than expected – perhaps there’s some kind of global revolution in some kind of energy-hungry mechanical brain – then the system as currently designed would need to respond by increasing output from gas plant.

This means CP2030 leaves open the possibility that once we’ve reduced emissions down to below 50g/kwh we could see them hit 75-100g/kwh in subsequent years. There is no mechanism to meaningful constrain gas generation in the plan. And more than that, there’s no mechanism to constrain islanded generation.

That may seem vague, but people I’ve spoken in the mechanical brain sector are genuinely looking at a mix of a small grid connection, some batteries and a bunch of gas reciprocating engines behind a circuit breaker to enable them to trade off power and gas prices.

You don’t need to be particularly bullish on gas prices to see what impact that could have on our emissions.

CONSUMER COST - Current rating: ULTRARED

If there is one thing that will derail CP2030, it’s the perception that it will increase costs to consumers. The debate on this is already heating up and will only grow worse as time goes on. The document is very careful to only refer to NESO’s claims in this space and makes no specific claim itself.

The document only makes the vague claim that Government will scrutinise everything it’s doing in order to see whether it will increase bills. Given that this is literally saying, “Government will keep doing impact assessments,” this almost certainly isn’t good enough.

Given the all consuming political risk consumer bills represent, now is the time to go line by line through all those existing – not new – measures that each were justified individually on the grounds that they’re only a few pounds on the bill, all those measures that increase costs for developers for trade-offs that might be justified individually but aren’t in aggregate, and all those measures that prevent competition – and figure out how to get rid of them all.

Finally, one last thing: please, please, please make a decision on locational pricing. I don’t care what is chosen, just make a choice.

And do have a merry electric Christmas, one and all.