The planning system must be adequately resourced to handle both the current workload and the expected growth. However, as it stands the system is chronically under-resourced, leading to severe delays.

We welcome the commitment in the CPAP to review resourcing in key planning organisations. It is important that this review is conducted as soon as possible. In particular, it should ensure that it supports training for Local Planning Authorities (LPAs) in England where very few onshore wind applications have been brought forward over the past decade.

In Scotland, planning decisions for energy capacity of any scale are devolved. The National Planning Framework 4 (NPF4) clearly sets out the need case for onshore wind in Scotland, in the face of climate and nature crises and gives additional weight to projects that directly tackle these challenges, resulting in demonstrable improvements in consenting success rates in Scotland.

This clarity and certainty should be replicated in England and Wales, in order to ensure alignment with the CP2030 ambition across all departments at both devolved and national level.

In Wales, whilst we welcome steps recently taken by Welsh ministers to streamline planning decisions, projects are still faced with multiple challenges with the Welsh government’s threshold of acceptability much higher than in other parts of the UK.

In England, whilst we welcome the recent amendment to the National Planning policy Frame (NPPF) to remove the de-facto ban on new onshore wind, the framework must be strengthened even further to give renewable energy developments priority status, in line with the recently revised National Policy Statements (NPS) for larger projects.

Lack of access to grid capacity is currently the single biggest challenge to the deployment of low carbon projects. In addition to securing a timely grid connection, developers are frequently seeing mounting costs and delays for connections that have already been agreed.

Action by government and the regulator – including Ofgem’s approval in April of a new streamlined process – is an important step forward. Whilst we welcome the action that the National Energy System Operator (NESO) is now taking to reprioritise the connections queue, it does create considerable uncertainty for developers working towards the next Contract for Difference (CfD) auction. Early clarity is now key. Grid offers must be issued to eligible projects prior to bidding to to ensure that successful projects are energised within their commissioning window.

Even once grid connections have been secured, we are also seeing supply chain challenges on the part of network operators, that are impacting projects’ ability to connect. The prioritisation of long-lead time components, such as grid transformers, is therefore essential. However, there is little to no recourse for developers when network operators are unable to deliver against agreed connection dates. It is important that incentives are aligned so that customers can be confident in their grid connection date and associated costs. As a first step to ensuring network companies are held to account for actions within their control, we recommend that Ofgem requires network companies to report quarterly on their progress to deliver planned network upgrades. 

Furthermore, to make best use of the grid, network operators should prioritise co-located projects that can utilise existing infrastructure. For example, RWE could deliver an additional 270 MW of battery storage within the next 12 months across 10 solar projects that are expected to be commissioned in 2025. The network infrastructure to connect this additional storage capacity is already in place, and there would be little to no additional cost to network operators to accelerate the delivery of these projects. However, we have not received a connection offer any earlier than 2032 for these projects and there is a risk they will be further delayed by the proposed treatment of battery storage projects in the connections queue reordering process.

In addition to overcoming planning and grid barriers, all projects must ultimately also secure a route-to-market, for example via a Contract for Difference (CfD). The CfD is a gold standard mechanism which gives certainty to investors and supports project delivery. The government recently consulted on several proposals to reform the CfD scheme. We believe the following reforms will help accelerate the deployment of onshore wind and solar:

Positive reforms to CfDs

1. Removal of the budget cap for all technologies and replacement with ‘capacity ambition’ targets, and a clear schedule for future auction rounds. However, removing the pre-auction view of the CfD budget must be accompanied by a capacity ‘minima’ to give adequate certainty over auction volume. Future capacity targets must be clear until at least AR10 (2028) and ambitious i.e. reflective of the existing pipeline and the additional capacity required to achieve CP2030. This would provide greater certainty and transparency and allow developers to enter more projects into future auction rounds.
2. Increase the length of the CfD contract from 15 to at least 25 years. This would increase revenue certainty for developers, which in turn would lower the strike price vs what it would otherwise have been with a shorter contract. This is particularly important given the current uncertainty over electricity market arrangements in the long-term.
3. Allow an extension to the target commissioning window for solar PV from 3 to 12 months. The Government consultation proposed an extension from three to six months, but in light of increasing grid delays discussed above, we believe it is necessary to extend this window to provide more flexibility for projects to deliver within their commissioning window.
4. Allow for onshore wind projects seeking to repower to participate in auctions. Enabling projects to repower is vital to retain existing capacity. Projects seeking to undertake full repowering should be eligible to enter future auction rounds, as they have similar capital costs to new-build projects. Retaining this existing capacity will make it easier to meet CP2030.
5. Allow an additional Delivery Year for onshore wind and solar. ‘Delivery Years’ refers to the financial years by which a project must commission. Although not part of the recent consultation, allowing an additional delivery year would provide much needed flexibility and additional certainty.

Wales has an ambition to meet 100% of Welsh energy needs from renewable sources by 2035. As it stands, just under 10% of GB’s operational onshore wind and solar capacity is in Wales, including RWE’s Clocaenog Forest project (96 MW) which, in 2019, was the last commercial scale onshore wind project to be commissioned in Wales. 

Since then, only two onshore projects totalling 6 MW have been commissioned and there are very few projects currently under construction. The pipeline of renewable energy projects is also low compared with other countries – just 12% of onshore wind projects and 5% of solar farms in development in GB are located in Wales. Since 2015, across all technologies, less than 2% of the total capacity awarded a CfD was located in Wales. 

The absence of adequate grid infrastructure, particularly in mid-Wales is a key barrier affecting the deployment of new renewable capacity in the region. For example, in February 2023, network operators began scoping a North-South Wales grid connection; however, it has been indicated that any such upgrade works may not be complete until 2037. It is critical that investment in new grid infrastructure in Wales is secured as soon as possible. 

In addition, it is important that the proposed new National Park¹ in north-east Wales does not block new critical renewable energy and grid projects. If taken forward, several of RWE’s onshore projects would be in closer proximity to a nationally designated landscape, which poses a significant consenting risk. The presumption in favour of undergrounding grid within nationally designated landscapes will also increase costs to the consumer.

¹ Wales’s new national park is proposed on the Clwydian Range and Dee Valley Area of Outstanding Natural Beauty.

Further, targeted reforms to tackle specific challenges are needed, to scale up the build out of onshore renewables to the level required.

1. Radar
   Aviation monitoring systems across the UK pose significant challenges to the deployment of onshore wind projects. Put simply, many onshore wind projects are either refused planning approval or have restrictions placed on them because of potential impacts on radar monitoring systems. The legacy radar systems at Cardiff Airport and Clee Hill alone are impacting the progression of several GWs of new onshore wind deployment in England and Wales.
   Wind farm compliant radar systems can effectively and safely monitor radar activity in proximity of wind farms and are readily available. However, despite over a decade and millions of pounds that the industry has spent on studies, trials and deployments of mitigation solutions, the Department for Transport’s and the Ministry of Defence’s wind mitigation policy for air traffic control radars remains at odds with CP2030. We urge the UK Government to place an obligation on NATS, the Ministry of Defence, and airports to prioritise the upgrades required of non-wind farm compliant radar systems, providing funding support if necessary.
2. Peatland
   Across the UK, but particularly in Wales and Scotland, the belief that onshore wind is at odds with peatland restoration is constraining deployment.  However, onshore wind can successfully deliver privately funded major peatland restoration projects to support climate and biodiversity goals. Such an example can be seen at RWE’s Clocaenog Forest Wind Farm, where via our Habitat Management Plan we have restored over 7.6 hectares of peatland. We urge all governments to recognise the benefits that onshore wind projects can help deliver for peatland.

The CPAP estimates that installed capacity of solar will increase from 47.0 GW in 2030 to 69.4 GW by 2035. The government have acknowledged that the 2035 target, taken from the NESO’s (earlier) Future Energy Scenarios, does not align with the more ambitious CPAP target, and is therefore presented as an ‘interim’ target. It is expected to be updated as part of the Strategic Spatial Energy Plan (SSEP), which is due to be published in 2026. 

However, the queue reordering process overseen by NESO is expected to commence in Q2 2025. We are concerned that waiting for the SSEP in 2026 to revise the 2035 capacity targets will be too late and projects with connection dates after 2030 will be deprioritised. As with the 2035 onshore wind targets for Scotland, the GB wide 2035 targets for solar risk creating an unintended drop in deployment post-2030. The 2035 capacity targets for solar must therefore be urgently revised to avoid creating a development cliff-edge.

The UK has made progress on onshore renewable energy deployment, but to meet ambitious CP2030 targets, significant acceleration is required. Addressing the key barriers impacting onshore renewable energy projects will be crucial to scaling up deployment. 

These reforms will not only deliver clean, low-cost energy but also strengthen the UK’s energy independence, create jobs, and drive economic growth. Governments across the UK must also continue to work closely with industry stakeholders to rapidly implement these changes, so that investors like RWE can build the infrastructure required to ensure the UK remains a global leader in clean energy.