NPS EN-2 - National Policy Statement for Natural Gas Electricity Generating Infrastructure

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What EN-2 Does

EN-2 is the technology-specific National Policy Statement for onshore natural gas electricity generating infrastructure. Designated under the Planning Act 2008, it applies alongside the Overarching Energy NPS (EN-1) for all DCO applications for gas-fired generation NSIPs.

It is the shortest of the energy technology NPSs (18 pages) and does not repeat EN-1 material - it supplements it with gas-specific assessment requirements and site selection guidance.

Current version: Designated 17 January 2024. Not revised in the 2025 NPS review (which updated EN-1, EN-3, and EN-5). The 2024 EN-2 remains the live designated NPS.

Thresholds: - England: over 50 MW generating capacity - Wales: over 350 MW generating capacity

CCS Readiness Requirement

CCR (Carbon Capture Readiness) is the central policy requirement for new gas generation. The substantive requirement sits in EN-1 s.4.9, incorporated into EN-2 by cross-reference throughout.

What CCR requires: - Sufficient space on site for CCS equipment - Technical feasibility of CCS retrofit within the station's lifetime - Economic viability of CCS retrofit given reasonable assumptions

Hard condition: If CCS retrofit is not both technically and economically feasible, the Secretary of State must refuse consent. CCR cannot be waived.

Why it matters for planning: Only gas stations that are CCR qualify for Critical National Priority (CNP) treatment under EN-1 s.4.2. CNP status materially improves the planning balance - it shifts the weight on designated landscapes, heritage, SSSIs, and HRA assessments. Gas stations without CCR can still apply under EN-2 but face a harder planning balance.

EN-2 also introduces site-level CCR consequences: the site must be large enough for CCS equipment (s.2.4.1), COMAH chemical storage requirements may affect nearby land use (s.2.4.2), and the water supply must cover CCS process needs (s.2.4.10).

Role Alongside EN-1

EN-2 adds policy on five topics beyond the generic EN-1 framework:

1. Factors influencing site selection - land use, transport access, water demand, network connection. Note: these are background information, not government policy directives. The government does not direct applicants to particular sites.
2. Air quality and greenhouse gas emissions - NOx assessment mandatory, consulting EA and NRW; regulated via Environmental Permitting Regulations.
3. Visual impact - gas stations are large; visibility gets "limited weight" once location and design are judged appropriate.
4. Noise and vibration - sources include continuous turbine operation and air-cooled condensers; primary mitigation is through plant design and enclosure.
5. Water quality and resources - CCGT stations have high water demands; water cooling creates thermal, abstraction, fish impingement, and anti-fouling impacts.

Critical policy note on CO2: EN-2 s.2.6.3-2.6.4 explicitly states that the Secretary of State does not assess individual gas station applications against carbon budgets or net zero targets. Operational CO2 is acknowledged as "a significant adverse impact" but is left to the UK ETS and economy-wide instruments. Consent cannot be refused on carbon grounds provided CCR requirements are met.

Key Considerations for Gas Generation DCO Applications

Site: Must accommodate CCR, Decarbonisation Readiness (DR), and CCS infrastructure. Preferred locations are coastal, estuarine, or beside large rivers (cooling water demand). COMAH compliance affects land-use planning for CCR/CCS chemical storage.

Water: CCGT stations need large volumes for steam production, condensing, and CCS. Applicants must demonstrate availability at an early stage and address fish impingement/entrainment, thermal discharge, and anti-fouling in the ES.

NOx: Must be assessed with EA/NRW. Selective Catalytic Reduction (SCR) is the primary NOx mitigation but creates secondary impacts (ammonia handling, additional noise) that must themselves be assessed and mitigated.

Network connection: Information on connection route and environmental issues must be included in the application. For the connection infrastructure itself, EN-5 is the relevant NPS.

Climate resilience: Coastal/estuarine/riverside sites are exposed to flood risk, storm surge, erosion, and cooling water availability under climate projections. These must be assessed in the Environmental Statement.

Interaction with Energy Act 2023 CCUS Provisions

The Energy Act 2023 creates economic licensing and support frameworks for CCUS clusters (Track-1: HyNet in the north-west, East Coast Cluster). This creates a potential interaction with EN-2:

• EN-2/EN-1 require CCR as a hard pre-consent condition for gas generation. CCR means CCS retrofit must be technically and economically feasible.
• The Energy Act 2023 CCUS cluster model creates the infrastructure (CO2 transport and storage) to which a CCR gas station could eventually connect. That infrastructure is itself consented separately (EN-1 alone applies to CO2 transport and storage).
• A gas station DCO can be granted on a CCR basis even before the downstream CCS cluster is operational. CCR does not require CCS infrastructure to be live - only that it will be technically and economically viable in due course.
• The cluster licensing regime under the Energy Act 2023 therefore reinforces EN-2's CCR policy by making CCS economically viable in a way that would not otherwise be the case. As cluster infrastructure becomes operational, the economic feasibility argument for CCR at nearby gas stations strengthens.

In practice, this means gas generation DCO applications in areas close to Track-1 CCUS cluster infrastructure (Merseyside/Lancashire for HyNet, Teesside/Humberside for ECC) are better placed to satisfy the CCR economic viability test than stations remote from any planned CO2 transport and storage route.