Revised NPF: What’s New for the Energy Sector?

The long-awaited new National Planning Framework has been approved by the Government. There are some significant changes, especially to energy policy and objectives. Our Planning & Environment team considers the key changes.

What you need to know

• The Government has adopted the new National Planning Framework (NPF), but it will not take effect until approval has been received from both Houses of the Oireachtas.
• When approved, it will replace the existing NPF, which was adopted in 2018.
• The NPF is one of the most important documents for planning policy in Ireland as it sets the Government’s high-level, strategic plan for future development.
• The new NPF introduces a number of significant changes to energy policy and increases the emphasis on the importance of renewable energy generation.
• One of the biggest changes is the introduction of regional renewable energy capacity targets, which will require local authorities to identify land for the delivery of set amounts of onshore wind and solar.

The Government has announced that it has approved the revised National Planning Framework (NPF). The new NPF is still subject to the approval of both Houses of the Oireachtas, but Government approval is a huge milestone. The process to update the 2018 version of the NPF has been underway since June 2023, including a three-month public consultation held over summer 2024.

What is the NPF?

The NPF is the Government’s high-level, strategic plan for future development in Ireland.

It is one of the most important documents for planning policy in Ireland as it sets out the guiding principles and strategy. Regional and local planning policy sits below, and must be consistent with, the NPF.

The NPF will play an even more important role under the new Planning and Development Act 2024 framework, which places a greater emphasis on a strategic, long-term approach to planning policy. This is aligned with the ‘Vision’ section of the revised NPF, which identifies a need for a “more active approach to the management of land”. This more strategic, plan-led approach is a theme throughout the revised NPF.

What are the changes for energy sector policy?

There is an increased emphasis on the importance of renewable energy development and the infrastructure needed to support this. Chapter 9 acknowledges that the “accelerated delivery of additional renewable energy generation is…essential for Ireland to meet its climate targets.”

A number of new or amended National Policy Objectives (NPOs) have been proposed in order to achieve this objective. We’ve summarised some of the key changes below.

Onshore renewable energy

Regional Renewable Energy Capacity Allocations

Table 9.1 sets regional renewable energy capacity allocations for wind and solar energy. These targets require each region to plan for sufficient wind and solar energy development so that Ireland achieves the overall national target of 9GW onshore wind and 8GW onshore solar by 2030.

Table 9.1 is extracted below:

New NPO 74 requires each Regional Assembly to plan, through their Regional Spatial and Economic Strategy, how and where to deliver the required capacity set out in Table 9.1 by identifying capacity allocations for each Local Authority in its area.

New NPO 75 requires Local Authorities to plan, through their City and County Development Plans, for the delivery of the energy capacity target that they have been allocated.

New text in Chapter 9 acknowledges that meeting these regional capacity targets will require the “development and expansion of the electricity grid, at a national and local level, in a coordinated manner.”

This is a major change in policy approach compared to the previous NPF. It represents a more active and prescriptive approach to land use planning for renewable energy development. It is likely to have a significant impact on the location of future onshore renewable energy projects in Ireland. However, it will take some time to cascade into local policy as it requires each Regional Assembly and Local Authority to implement plans that align with the targets.

Co-location of Renewable Energy

New text in Chapter 9 identifies the benefit and opportunity offered by the co-location of renewable energy with complementary uses, such as industrial and agricultural uses. It notes that co-location supports both a reduction in carbon emissions of agriculture and/or industry, and diversification of land use.

New NPO 73 supports co-location of renewable energy technologies with other technologies and land uses at appropriate locations. This is an increase in the level of support for co-location of renewables, compared with the previous NPF.

Repowering

New text in Chapter 9 acknowledges that the recast Renewable Energy Directive EU/2023/2413 (or ‘RED III’) introduces streamlined and simplified procedures for repowering of existing renewable energy projects.

Interestingly, text included in the first draft of the new NPF, which acknowledged the “significant potential” of repowering in achieving renewable energy targets, has not been carried through to the final version.

Given the importance of repowering in achieving Ireland’s ambitious renewable energy targets, and ensuring that we don’t go backwards in terms of renewable energy capacity, it is surprising that the NPF is not more explicit in its support of repowering.

There was no mention of repowering in the previous NPF, so the revised NPF does represent an increased level of acknowledgement of the role of repowering. However, the revised NPF includes very little text on this topic and does not go as far as introducing a specific NPO which supports repowering.

Grid and interconnection

Grid

New NPOs 71 and 72 provide increased support for the development, upgrading and interconnection of onshore grid infrastructure, compared with the previous NPF.

Interconnection

NPOs 61 and 72 seek to strengthen an all-island interconnection. This is unchanged from the previous NPF (previous NPO 47) except for the addition of a reference to exploring “the potential for strategic cooperation on offshore wind energy development”.

There is reference in the revised NPF to the importance of international interconnection, but limited new text on this as compared to the previous NPF. New NPO 55 supports “the sustainable development of… international grid connectivity enhancements”, but this is unchanged from the previous NPF (previous NPO 42).

Offshore renewable energy

Offshore Potential

There is a new section 7.5 on offshore renewable energy in Chapter 7. This acknowledges Ireland’s ambitious offshore generation targets. The section outlines the strategic, plan-led approach being adopted to offshore development outlined under the National Marine Planning Framework (NMPF) and the ‘Designated Maritime Area Plans’ (DMAP) process.

While the previous NPF was supportive of offshore renewable energy development, for example, NPO 42, the revised NPF places greater emphasis on this. However, the NMPF is the core planning policy document for the offshore sector, not the NPF. One therefore needs to look to the NMPF for details on the planning strategy for offshore renewable energy. Please see our previous article for details.

Ports

There is increased recognition of the critical role played by ports in facilitating renewable energy development and the need for new and improved port infrastructure. New text added in section 7.3 of Chapter 7 acknowledges the positive contribution that ports can make to offshore renewable energy (ORE) and states that “work to identify and resolve barriers to the delivery of ports infrastructure to facilitate ORE, while ensuring protection of biodiversity in line with national and EU legislation, the National Biodiversity Action Plan and forthcoming National Nature Restoration Plan will be advanced by the Department of Transport.”

New NPO 51 seeks to “support the sustainable delivery of port and harbour infrastructure to facilitate the development, maintenance and operation of offshore renewable electricity generating developments".

New text added in NPO 55 supports the sustainable development of “port infrastructure for the marshalling and assembly of wind turbine components and for the operation and maintenance of offshore renewable energy projects.”

Other renewable energy sources

Hydrogen

The previous NPF did not include any reference to hydrogen. The revised NPF includes new text in section 9.2, which acknowledges that “Renewable Hydrogen also has a potential role as a zero-emission energy source in the coming decades.” It also refers to the Government’s National Hydrogen Strategy which sets out Ireland’s strategic vision on the role of hydrogen. There is no further detail on hydrogen in the NPF, so it seems that developers will need to look to the National Hydrogen Strategy rather than the NPF for the Government’s approach to this.

Bio-economy

New text in Chapter 9 places increased emphasis on the importance of the circular bio-economy to Ireland’s economy and sustainability goals. The bio-economy is defined as “the production of renewable biological resources – such as crops, forests, fish, animals, and micro-organisms and the conversion of these resources and waste stream residues, by-products or municipal solid waste into value added products, such as food, feed, bio-based products and bio-energy.”

The Chapter acknowledges the important role of biomethane, referring to the recently published National Biomethane Strategy which sets a target of production of 5.7TWh of indigenous biomethane by 2030. It acknowledges that in order to meet this target “a large number of anaerobic facilities will need to be developed.” We analysed the new National Biomethane Strategy in a previous article.

Comment

There are a number of significant changes proposed to energy policy and objectives, generally indicating increased support for renewable energy development and associated infrastructure.

Arguably, the most significant change is the introduction of regional wind and solar capacity allocations. However, it will take some time to see the effects of this as it requires updates to regional and local plans.

Some additional supportive text has been added on repowering and international interconnection, but neither benefits from a new, topic-specific NPO. This is surprising given the amount of EU action on these topics and their importance in the creation of a reliable, secure renewable energy supply.

Overall, the revised NPF proposes a more active and prescriptive approach to the management of the use of land in order to meet Ireland’s climate and energy targets. This is aligned with other recent Government action, such as the National Marine Planning Framework, the Future Framework Policy Statement for Offshore Renewable Energy and the Designated Maritime Area Plan process.

For more information and expert advice on successfully navigating the complex, changing landscape of renewable energy development, contact a member of our Planning & Environment team.

The content of this article is provided for information purposes only and does not constitute legal or other advice.