Hydrogen projects

Navigating planning policy in the absence of a settled national strategy

As hydrogen continues to move from policy ambition to commercial reality, promoters face a familiar challenge: how to secure planning consent in the absence of a clear, up-to-date national hydrogen strategy.

In practice, hydrogen projects - spanning production, storage, transport and end-use - are not currently determined against bespoke ‘hydrogen policy’. Instead, they must be positioned within the existing planning framework, making effective use of the National Planning Policy Framework (NPPF), the energy National Policy Statements (NPSs), and broader decarbonisation policy signals.

This article considers where that support currently sits and how promoters can maximise it to secure consent.

Policy lag vs delivery ambition

There is little doubt that hydrogen is a key part of the UK’s energy transition. However, the connection between the strategic ambition for hydrogen deployment and the planning policy framework has not yet evolved to provide hydrogen-specific and unifying policy in the manner which other sectors currently benefit from. The current Hydrogen Strategy was published in August 2021 and is due to be superseded to reflect changes since then. Although DESNZ has recently indicated that an updated Strategy is due later this year, it not yet clear exactly when it will be published.

For promoters, the key implication is clear: projects are won or lost on how effectively they are framed within existing, more generic, policy, rather than the existence of hydrogen-specific support.

The policy architecture: where hydrogen fits today

1. The NPPF and other national statements

‍The current NPPF contains strong support for low carbon development but is largely technology neutral. It provides a clear national policy basis for:

Supporting the transition to a low carbon economy;
Approving renewable and low carbon energy development; and
Recognising the importance of energy infrastructure and decarbonisation.

While hydrogen is not addressed explicitly, the NPPF’s approach is intentionally technology neutral. This allows hydrogen projects to be framed as enabling low carbon energy systems; supporting economic growth and industrial transition; and contributing to climate change mitigation.

A raft of other national statements and documents provide similarly broad support for hydrogen projects: see for example the Clean Power 2030 Action Plan (April 2025) and the Clean Flexibility Roadmap (July 2025).

In practice, well-developed hydrogen schemes can secure support by aligning with these broader objectives and demonstrating good planning, environmental and design discipline.

2. Energy National Policy Statements (NPSs): a powerful (but underused) tool?

For Nationally Significant Infrastructure Projects (NSIPs) the energy NPSs (notably EN-1) are the most important policy framework. Importantly however (and in our experience this is often overlooked), the NPSs are not relevant exclusively to NSIPs. Paragraph 1.2.1 of EN-1 for example confirms that it may be a material consideration in decision making on applications submitted under the Town and Country Planning Act 1990.

Although not currently hydrogen-specific, the energy NPSs:

Establish a presumption in favour of nationally significant energy infrastructure, subject to impacts being appropriately managed. Projects are likely to qualify as ‘critical national priority’ (CNP) infrastructure, for which there is very strong support;
Provide a structured framework for assessing need, alternatives and benefits; and
Recognise the importance of a secure, resilient and decarbonised energy system.

Hydrogen infrastructure - particularly large-scale production, storage and transport and end-use - can be positioned within this framework by demonstrating:

Its role in supporting energy system decarbonisation and flexibility;
Its contribution to security of supply and system resilience; and
That it meets the established standards of assessment, mitigation and deliverability expected of NSIPs.

The practical takeaway is that hydrogen projects can often succeed without bespoke policy, provided promoters deploy the NPS framework in a disciplined and evidence-led way.

3. Local policy

At a local level, very few local plans will contain hydrogen-specific policies. However, local policies should align with national policies, particularly those in the NPPF, and will typically support:

Low carbon energy and industrial development in principle;
Allocations for employment or infrastructure uses; and
Economic growth and regeneration objectives.

While not always determinative, these factors can materially strengthen the planning balance, particularly where projects demonstrate tangible local and regional benefits. Promoters may need to work with local planning authorities to aid their understanding of the hydrogen sector, as many will not have experienced a planning application for a hydrogen project before.

Making policy work harder: practical steps for promoters

In this landscape, success depends less on identifying a single policy ‘hook’ and more on how effectively a project is positioned within the wider policy framework.

Based on our direct experience advising on hydrogen projects, several themes consistently emerge.

1. Frame hydrogen as an enabling solution

Hydrogen projects should be clearly positioned as enabling industrial decarbonisation; clean transport networks; energy system integration and flexibility; and/or security of supply. This reframes the discussion away from the novelty of hydrogen as a technology, and towards its role in achieving established policy objectives.

2. Develop a robust, evidence-led case for need

In the absence of explicit hydrogen policy, the case for need becomes central. Strong applications typically demonstrate the project’s role within wider decarbonisation pathways; clear links to demand (including identified or anticipated offtakers); and integration with existing or planned energy infrastructure (e.g. in the HyNet and Humber clusters). National policy, particularly in the NPSs, is likely to significantly assist with robustly demonstrating the case for need.

3. Focus on deliverability from the outset

Planning risk is frequently driven as much by delivery uncertainty as by policy gaps.

Promoters should prioritise:

Clear and well-defined project parameters;
Alignment between environmental assessment and design assumptions;
Early engagement on and resolution of land, grid and third-party interface issues; and
A consent strategy that anticipates scrutiny by the decision-maker.

This reflects a consistent theme across infrastructure consenting: credible, deliverable projects attract policy support more readily than theoretical ones. Promoters should not be afraid to acknowledge any potential limitations (for example, uncertainty about the precise timing of a hydrogen supply), but in doing so should explain to the decision-maker why any such limitations should not prevent the grant of planning consent. Promoters can draw from lessons learnt in other sectors in making these arguments.

4. Use engagement to help build the policy narrative

Given varying levels of familiarity with hydrogen, engagement should be used proactively to:

Educate stakeholders and decision-makers;
Build confidence in the project’s benefits, role and impacts; and
Reduce the risk of unresolved issues emerging during the decision stage.

This is particularly important where policy is evolving, as engagement can help fill the gaps in the policy framework. For NSIPs, we are expecting the removal of pre-application statutory consultation requirements imminently, but engagement will continue to play an important role for most projects.

5. Future-proof the consent

Similar to other technologies, hydrogen is a rapidly developing sector. Promoters should consider how their consent accommodates future technological evolution; builds in appropriate flexibility; and manages uncertainty without undermining confidence.

Getting this balance right can reduce the need for subsequent changes and strengthen the overall planning case.

Looking ahead

The planning policy framework for hydrogen is likely to evolve as deployment accelerates and projects scale up. The Hydrogen Strategy should provide much-needed specific support. We are aware that some promoters are watching and waiting before making further decisions on some of their projects.

In the interim, consents (both TCPA and NSIP) continue to be secured, and there is a clear pathway for projects to proceed using the existing support of the NPPF, the energy NPSs and local policies, and by demonstrating strong alignment with system-wide decarbonisation objectives and policy statements.

Conclusion

The absence of an up-to-date hydrogen strategy does not prevent projects from securing consent, but it does require a strategic and disciplined approach to planning policy.

Promoters who succeed are those who:

Align clearly with existing policy frameworks;
Demonstrate robust need and, where relevant / possible, integration within wider systems; and
Focus on deliverability and risk management from an early stage.

In doing so, hydrogen projects can move forward now, helping to shape both the energy system and the policy framework that will ultimately support it.

At TLT we are actively advising the promoters of various hydrogen projects, including NSIPs. To find out how our experience could help your project succeed, please contact John Arthur.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at June 2026. For more information see our terms & conditions.

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