This consultation focussed on proposed revisions to the Scottish Government’s Good Practice Principles (GPPs). Key points made in our response include:

• We are content for solar PV to be included within the scope of the GPP. However, it is not economically feasible to expect solar projects to provide community benefit contributions (either financial or in-kind) that are anywhere near the levels currently expected for onshore wind, due to a range of factors, as previously provided to Scottish Government and as discussed further in our response
• Based on the current logic of the existing community benefits system for electricity generation it would seem appropriate for both solar and wind power to pay community benefits, where they are co-located.
• We do not believe that the scope of the GPPs should be extended to BESS at this time – whether stand-alone or co-located with solar projects. As a relatively new technology at grid scale, we believe that more work is needed to understand the different project economics of this technology before guidance on community benefit can be considered. As a technology that supports renewable generation, and is not itself a generation technology, we also question whether seeking community benefits for this technology is appropriate.
• While community benefits are voluntary, it is worth noting that they none-the less have an impact on the cost of energy paid by consumers – as the costs of community benefits will need to be recouped by the renewable energy owner / operator.

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Solar Energy Scotland welcomes the opportunity to provide feedback on the Local Government, Housing and Planning Committees review of the Fourth National Planning Framework (NPF4). We strongly support its emphasis on climate and environmental goals and believe it has largely delivered on its objectives. However, we see the need for greater improvements to truly accelerate progress and keep Scotland on its 2045 net zero trajectory.

Despite being a national framework, NPF4’s application has varied across different levels of decision makers, from Scottish Government and Local Planning Authorities. A key challenge is the inconsistent application of NPF4 by local planning authorities, where subjective interpretations are being applied in a manner that deviates from national guidance. Misinformation, especially around solar technologies has contributed to this issue. Key areas of misinformation include solar and biodiversity, food security, and land use.:

Well-designed and well-maintained solar farms can enhance biodiversity, supporting the delivery of Policy 3 of the NPF4).
Solar farms do not threaten food security, the biggest threat to food security is climate change. They offer farmers an opportunity to diversify their income without compromising their ability to farm.
Solar farms require a small amount of land in Scotland. To reach Scotland’s net-zero targets, a minimum of 4-6 GW of solar capacity will need to be built by 2030. Approximately 3.5 GW of capacity will come from ground mounted solar farms, which would require only 0.08% of Scotland’s total land area.

To fully accelerate the consenting process and proper implementation of NPF4, resource gaps within planning departments and statutory consultees must be addressed. This could be achieved by securing additional funding for training and upskilling officers in Local Planning Authorities (LPAs) and statutory consultees to ensure they have the necessary expertise and resources to make informed decisions on solar planning applications.

Solar farms provide various benefits to the community. Alongside its primary function of delivering clean green energy, they can also support local economies through job creation, increase biodiversity, support agricultural businesses and provide education opportunities for local schools and community groups.

Please see our response in detail below.

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Solar Energy UK appreciates the opportunity to contribute to the Policy Consultation on Required Licence Changes.

We broadly agree that these licence changes are necessary to facilitate the policy intent of the reformed Connections Process.

We agree that adopting the proposed Code Modifications with the minimum necessary changes to the Licence is a sensible approach. However, the Gate 1 Agreements offer no real benefits to connecting parties, making the term “connection agreements” misleading. An exception is the “Gate 1 Agreements with Reservation,” which provide the advantages of Gate 2 Agreements with fewer obligations. These should be the only form of Gate 1 Agreement available, while other parties should be informed they are not eligible for a grid offer. This would improve industry and public understanding of the connection reforms.

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To achieve the CP30 targets and beyond, it is essential to have a regulator that is efficient, fair, and transparent. Ofgem’s role in shaping the long-term energy transition is pivotal, and its approach must evolve to reflect the urgent need to scale up clean power. The regulator must go beyond simply overseeing existing processes and instead actively drive change to build a grid that supports rapid deployment of renewable energy. By providing clearer investment signals, adopting a flexible regulatory framework, and committing to the enforcement of net-zero goals, Ofgem can help the energy sector flourish, driving long-term benefits for the wider economy. By eliminating unnecessary barriers, incentivising proactive grid investment, and ensuring policy stability, Ofgem can play a key role in fostering higher economic growth while also meeting the UK’s clean energy targets.

One urgent change Ofgem must address is fully embracing its net-zero mandate. At present, there is an artificial divide between accelerating renewable energy deployment and managing consumer costs. Ofgem must proactively enable the energy transition by holding network operators accountable and revising the 2035 Clean Power figures. In the case of residential solar, it is also essential that Ofgem collaborates with MCS in developing policies related to consumer protections. We expand on this point further in our response below.

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Solar Energy UK appreciates the opportunity to contribute to Ofgem’s End-to-End Review. It’s encouraging to see that much of the feedback we’ve provided regarding DNO performance has been referenced within the consultation.
As Ofgem is well aware, the grid presents the greatest challenge in achieving the UK’s Clean Power 2030 goals, making it vital that we have responsive and efficient DNOs to meet growing demand. Our members’ experiences with DNOs have often been strained, and much of this feedback has been shared directly with Ofgem through the Networks Subgroup of the Solar Taskforce.

We are hopeful that the End-to-End Review will address many of these negative experiences and lead to improvements. Additionally, we urge Ofgem to hold DNOs accountable not only for the outcomes of the End-to-End Review but also for the commitments made through the Solar Taskforce. Some of these requests are referenced in our response below.

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We support the overall aims of TMO4+ but strongly oppose rigid capacity caps and inflexible planning, which risk undermining solar and storage development. Current proposals contradict Ofgem’s objectives of accelerating clean energy deployment and maintaining investor confidence. Feedback from our members highlights growing concerns that these reforms are making the market more disorderly and damaging investment certainty.

NESO’s plan to impose a strict 2035 solar capacity limit by May 2025 and to rescind pre-2031 connection agreements require urgent intervention by Ofgem. Without greater flexibility, investor confidence will continue to erode, leading to a near-term investment hiatus and longer-term project delays. NESO’s approach does not sufficiently account for construction lead times, project attrition, and market dynamics.

Read more in our full response below

 

 

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Solar Energy UK appreciates the opportunity to respond to the NESO’s call for evidence on the introduction of a Financial Instrument as part of the connections reform process. This issue is highly significant for us, as the current grid challenges are creating substantial obstacles for the solar industry, limiting our ability to deliver clean, affordable energy to both consumers and businesses. Grid constraints are also hindering the Government’s goal of achieving a tripling of solar capacity by 2030 and affecting the UK’s progress towards its Net Zero and Clean Power 2030 targets.

For context, Solar Energy UK actively participates in the Connection Process Advisory Group and the Connections Delivery Board, contributing to the ongoing discussions on connection reform. While we acknowledge the difficulties faced by network operators in connecting projects, it is critical to the UK’s Net Zero ambitions that viable projects are not delayed or blocked. A large portion of our members believe that introducing a financial commitment fee would have this adverse effect, asserting that a well-designed and enforced milestone system is sufficient for demonstrating project readiness and filtering out unviable projects.

Read more in our full response below

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Our concerns regarding the current reform approach align closely with those raised in CMP434. That is, concerns around inadequate consultation timelines and unresolved issues at the Transmission/Distribution (T/D) interface. Support for the implementation depends on robust grandfathering provisions granted by NESO for existing advanced projects.

We believe that any sufficiently advanced project should be exempt from Gate 2 requirements – including projects with a connection date up to 2030, projects that have submitted planning applications, or those with a clear route to market (such as a CFD or PPA). It is essential to prioritise distribution projects, many of which already face delays despite having planning permission, to meet Clean Power 2030 targets, while we also strongly oppose any retrospective actions applied to the distribution queue.

Read more in our full response below

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In response to NESO on the implementation of connections reform – we support the WACM 3 proposal for reallocating capacity based on queue position, but have concerns about the Government’s potential for arbitrary intervention under the Designation process. This could disadvantage legitimate developers, particularly given the vague criteria for prioritising “new technologies” and “projects with long lead times.” Greater clarity on definitions and engagement with stakeholders are needed to ensure fairness and transparency.

To see our full response, download the consultation below

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Solar Energy UK welcomes the opportunity to respond to the Department for Energy Security and Net Zero’s (DESNZ) consultation on Contracts for Difference (CfD) Allocation Round 7 (AR7). As the UK’s solar industry continues to expand at pace, we strongly support measures that enhance investor confidence, drive down costs, and maximise deployment to meet the UK’s energy security and net-zero targets.

Solar power is one of the most affordable and scalable renewable energy technologies, with the potential to deliver over 70GW by 2035, as outlined in the UK’s Solar Roadmap. The CfD scheme has been instrumental in accelerating solar deployment, and AR7 presents a critical opportunity to refine the mechanism to ensure it remains fit for purpose in a rapidly evolving energy market.

We commend DESNZ for seeking industry input on key aspects such as the alignment of CFD duration with new market conditions and ensuring greater technological neutrality via enhanced time commissioning windows. Solar Energy UK urges the government to ensure that AR7’s design supports a diverse and competitive solar sector, facilitates co-location with storage, and aligns with the UK’s wider industrial strategy.

As the voice of the solar industry, we look forward to engaging constructively with DESNZ to shape a CfD framework that unlocks investment, fosters innovation, and delivers clean, low-cost power for consumers.. 

For detailed information, download our full response below.

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