Does England’s national networks planning guidance already need an update?

The ink was still wet on the second National Networks National Policy Statement (NNNPS 24) when the new UK government arrived in July.

The NPS framework sets planning guidance for nationally significant infrastructure projects (NSIPs).

The National Networks NPS covers road, rail, and strategic rail freight interchange schemes in England.

The second version was published in May, two months before Labour came to office, with very different policies and a sharper focus on decarbonisation.

So, what’s changed in the May 2024 National Networks NPS? And does Keir Starmer’s new government need to do a rapid rewrite to deliver the change it promised?

Let’s start with a recap.

A brief history of National Policy Statements

For years, the planning and consenting process for big infrastructure projects in the UK has been a long and frustrating process. For example, Heathrow’s Terminal 5 took a record-breaking eight years from application to consent.

Under the last Labour government, the Planning Act 2008 established National Policy Statements (NPS) as a central part of the consenting process for NSIPs.

This change worked. Securing consent for major projects was relatively quick, or at least predictable – for a while.

But we now see investment decisions for big infrastructure stuck in costly, time-consuming processes.

The new government has made it clear that it wants to up the pace of delivery. The NPS framework is fundamental to achieving that.

And arguably, national networks – the primary rail and road networks in England – are central to achieving the economic and social change we all desire.

What’s new in the May 2024 National Networks NPS?

Coming nine years after the first edition, the May 2024 National Networks NPS is a long-overdue update.

It addresses many gaps in the first version and reflects the rapidly changing world in which we live.

It recognises a much broader set of drivers for investment.

Where the previous version focused on straightforward capacity and congestion, the May 2024 version covers economic growth, carbon reduction, and network performance.

Importantly, it also recognises that building more infrastructure isn’t always the only option, clearly flagging sustainable travel options as an alternative.

Updates and transitions

There’s a welcome commitment for this NPS to be updated at least every five years, to ensure it remains relevant to current needs.

Helpfully, there’s also an explicit statement on transition arrangements, making clear that projects already submitted for consent shouldn’t be judged solely on this new statement. This should ease the risk of further delays.

What’s missing?

It’s always harder to spot what’s not there. But a slow read of NNNPS 24 does expose a few gaps.

The subject of carbon emissions continues to be a thorny one. There’s no distinction between ‘residual’ (i.e. tolerable) and ‘unacceptable’ carbon emissions arising from a project, saying it depends on overall decarbonisation progress at the time.

This is a hugely subjective area, leaving project promoters and planning inspectors alike to grapple with a lot of ambiguity.

The new edition also fails to grasp the key underlying factor of demand – or more importantly, demand reduction.

Demand reduction means balancing rising population and economic activity with the need for less transport.

This edition acknowledges that freight and personal traffic growth is highly likely. But we also see reluctance to restrict the access we should all have to affordable travel.

All this has led the Climate Change Committee to say that inconsistency between revised roads policy and emissions objectives has weakened the policy landscape around transport demand.

So, what does the revised statement mean for future transport projects?

On one level, a new policy statement should help NSIPs through the development and consenting process, if only because the criteria for assessing project proposals is up to date.

And it will certainly set a clearer context for the third Roads Investment Strategy (RIS3), due very soon, and for any rail investment plans that follow.

While NNNPS 24 helps smooth the path for proposed large projects, the real influence will come from the choices and overall priorities of the new government.

It seems likely that this Parliament will start fewer totemic ‘grand projects’ of the scale of HS2 and Lower Thames Crossing.

Instead, we can expect a shift towards smaller interventions that improve reliability, economic growth, and carbon reduction – and, importantly, are deliverable at pace.

Does the National Networks NPS need another update?

I believe the answer is a clear ‘yes’.

NNNPS 24 represents a maturing of the NPS format. But it showed a reluctance to direct public travel choices, and an unwillingness to change investment to reflect the clear (and difficult) environmental goals facing us all.

So, yes: we need NNNPS 25.

Fortunately, the government has committed to update all National Policy Statements within its first year.

What should an updated National Networks NPS cover?

A refresh of the NNNPS should be just that – a refresh.

Many of the needed changes from the 2015 version are already there. The real changes needed now are:

• To embed the new government’s wider policy objectives into the supporting statement.

  Transport Secretary Louise Haigh set out five clear objectives when she took office and is looking again at the department’s portfolio of capital projects.

  NNNPS 25 must reflect these new policy objectives.

• To use expert bodies as intended.

  The National Infrastructure Commission (NIC) was established to translate wider policy goals into cross-sector infrastructure recommendations.

  When the proposed National Infrastructure and Service Transformation Authority (NISTA) supersedes NIC, it must retain its expertise and independence.

• Recognise that England is part of the United Kingdom.

  The national networks in England are there to help all four UK nations thrive together.

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