On 13 December 2024, the government published its Clean Power 2030 Action Plan (CP30 Action Plan), responding to advice from the National Energy System Operator (NESO) on how to achieve a GB clean power system by 2030. The level of deployment set out in the plan will require an estimated £40 billion on average per year between 2025 and 2030, much of which will be private investment. This article outlines 10 key takeaways from the CP30 Action Plan.

The government has confirmed it will follow NESO’s proposed definition of ‘clean’ power which includes renewables, nuclear, biomass and plants using carbon capture and storage (CCS). The government expects a clean power system to use at least 95% of these sources, with unabated gas providing less than 5% of generation. This will involve reducing the carbon intensity of electricity generation from 171gCO2/kWh in 2023 to well below 50gCO2 /kWh in 2030.

  1. ‘DESNZ Clean Power Capacity Range’

    NESO’s advice set out two pathways to achieving a clean power system: ‘Further Flex and Renewables’ and ‘New dispatch’. ‘Further Flex and Renewables’ had the highest levels of consumer engagement with residential and industrial demand flexibility, more storage and fast deployment of renewables but no new dispatchable power. ‘New dispatch’ saw growth in renewables but at a lower level compared to Further Flex and Renewables and deployment of new low carbon dispatchable power (CCS and hydrogen) alongside the highest levels of nuclear capacity.

    DESNZ has not committed to either pathway in the CP30 Action Plan but instead developed a ‘Clean Power Capacity Range’ ‘using these scenarios, alongside an assessment of maximum feasible deployment based on current knowledge of the project pipeline.’ For most technologies, the New dispatch figures form the lower end of the range and the Further Flex and Renewables figures the upper end. DESNZ expects there will be more clarity over time and has therefore left the door open to refining the pathway with a more precise capacity mix to emerge.

  2. Planning reform

    The CP30 Action Plan addresses the urgent need for a wide-ranging reform programme to the planning system. This follows the publication of the revised National Planning Policy Framework (NPFF) on 12 December 2024. The action plan states that government will be bringing forward a Planning and Infrastructure Bill to streamline the delivery of critical infrastructure in the planning process, including accelerating upgrades to the grid and boosting renewable energy which will benefit local communities. There will also be a continued reassessment of the judicial review process to ‘strike the right balance between reducing delays to infrastructure projects and maintaining access to justice.’ The action plan also confirms the government will be updating the Nationally Significant Infrastructure Project (NSIP) regime to reintroduce onshore wind at a new threshold of 100MW and alter the existing threshold for solar to 100MW.

  3. Technology pots for connections reform

    The grid connections reform annex to the CP30 Action Plan provides GB-level capacity ranges for different technologies and regional breakdowns for onshore wind, solar and batteries (by transmission and distribution). For technologies already subject to a coordinated design exercise or technologies where there are discrete projects, such as offshore wind and nuclear respectively, DESNZ considers GB-level capacity ranges to be sufficient for NESO to deliver efficient connections reform. These capacity ranges or technology pots will inform what is considered strategically ‘needed’ for the purposes of the connections queue. 

    DESNZ expects NESO will use the top end of the government’s 2030 pathway to underpin connection offers for projects in and before 2030. The 2035 capacity ranges in the annex (derived from NESO’s 2035 Future Energy Scenarios (FES 2035)) will underpin connection offers out to 2035. The 2035 ranges do not constitute a government pathway but are intended to provide longer term certainty ahead of the SSEP due to be published in 2026. However, DESNZ does not expect the introduction of SSEP to alter connections offers already issued for projects using the FES derived ranges.

  4. A note on onshore wind beyond 2030

    DESNZ considers the FES 2035 range for onshore wind capacity no longer accurately reflective of the potential for onshore wind deployment over the next decade. DESNZ internal analysis indicated a significant upside potential for onshore wind deployment beyond the 31GW FES figure by 2035 and instead between 35 and 37GW. For the onshore wind capacity ranges, given the locational uncertainty in the pipeline following the lifting of the de facto ban, DESNZ have decided on a two-zone split between Scotland (16GW) and England & Wales (21GW) for onshore wind (with no split between transmission and distribution) for 2035. 

  5. Changing up the Contract for Difference (CfD) scheme 

    The significant deployment of offshore wind envisioned in the CP30 Action Plan will depend on unprecedent delivery under the CfD scheme. DESNZ estimates there is currently around 31GW of either constructed or contracted offshore wind capacity, which will need to rise to between 43 to 50GW in 2030. The government is therefore looking to secure 12GW across the next two to three allocation rounds – AR7, AR8 and, depending on the speed at which projects deploy, AR9. Following on from an earlier consultation on changes to AR7, DESNZ is also considering further changes to the CfD scheme.

    This includes changes to auction timings and parameters (including approaches to the reference price), what information is used to inform the final budget for fixed-bottom offshore wind and relaxing CfD eligibility criteria for fixed-bottom offshore wind to award CfDs at an earlier stage. DESNZ also intends to consult on changes to CfD contract terms to give longer term market certainty once contracts are awarded.

  6. An update on Review of Electricity Markets (REMA) 

    On 13 December 2024, DESNZ also published a REMA update which summarised stakeholder responses to its second REMA consultation. In the CP30 Action Plan, DESNZ commits to a decision on REMA by around mid-2025 in time for CfD AR7 and supporting interim measures from NESO and Ofgem, in the balancing market and on TNUoS respectively, whilst the REMA programme is completed. The development phase of REMA will therefore conclude in mid-2025 with final decisions from DESNZ to commit to introducing either zonal pricing or reformed national pricing at this point.

  7. Low Carbon Flexibility Roadmap

    DESNZ will publish alongside Ofgem and NESO a Low Carbon Flexibility Roadmap in 2025 to consolidate existing and further new actions to drive both short and long-duration flexibility for clean power in 2030 and net zero by 2050. The roadmap will also provide a framework for planning and tracking the delivery of these key flexibility measures. The CP30 Action Plan sets out battery specific and consumer-led flexibility specific hurdles as well as planned actions.

  8. Integrating clean power and the natural environment

    The CP30 Action Plan emphasises that there should be an integrated delivery of climate and nature targets, with new energy infrastructure being built in a way that ‘doesn’t simply avoid or compensate for damage to nature, but constantly innovating to deliver the target in a nature positive way’. Government will therefore be launching an engagement exercise in early 2025 seeking views on how government can best encourage nature positive best practice into energy infrastructure planning and deployment. This follows on from previous announcements which include establishing industry-funded Marine Recovery Funds in respect of offshore wind projects.

  9. More on Great British Energy (GBE) project development 

    The CP30 Action Plan confirms that GBE will look to accelerate the delivery of onshore and offshore clean energy projects by leading or co-leading (alongside public and private sector partners) projects through the pre-development phase and, in some cases, construction and operation. On private land, this will involve identifying locations for new generation projects where additional capacity is needed to support spatial plans and on public land, GBE will look to unlock additional generation capacity on government-owned estates. 

  10. Supply chains and workforce

    Alongside the CP30 Action Plan, DESNZ also published the ‘Assessment of the Clean Energy Skills Challenge’ to evidence 2030 workforce requirements and support targeted skills planning. Next steps will include convening a new industry forum to work on supply chain and workforce planning and also publishing a new industrial strategy ‘Invest 2035’ in Spring 2035 which will include a sector plan for clean energy.

The Freeths Clean Energy team advise on all aspects of clean energy projects, including industry policy, regulation and legislation. Please contact Shraiya Thapa,  Clare King, Deborah Harvey and Liam O’Flynn if you have any questions or for further information. 

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The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.

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