GNLP 2045 Regulation 20 Scoping Consultation
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GNLP 2045 Regulation 20 Scoping Consultation
Question 8
Representation ID: 26555
Received: 21/09/2026
Respondent: National Grid Electricity Transmission
Agent: Fisher German LLP
NGET advocates the high standards of design and sustainable development forms and understands that contemporary planning and urban design agenda require a creative approach to new development around high voltage overhead lines and other NGET assets.
There are significant challenges and viability pressures associated with the delivery of housing in the Greater Norwich Area, ongoing major projects have staggered, thus resulting in a need for wider allocation of sites for development.
There is an increased risk of interaction between development sites and NGET assets. Where interaction occurs, NGET consider future iterations of the Local Plan should include wording within site specific policies or an appropriate overarching policy (such as one setting out approach to development of allocations) which appropriately recognises and responds to the presence of NGET assets.
Wording appropriate for a site specific policy:
“Development will include a strategy for responding to the NGET Overhead / Underground Cable Route present within / adjacent to the sites which demonstrates how the NGET Design Guide and Principles have been applied at the masterplanning stage and how the impact of the assets has been reduced through good design.”
Wording for an overarching policy:
“take a comprehensive and co-ordinated approach to development including respecting existing site
constraints including utilities situated within sites.”
Where future policy proposals interact with NGET assets, there should be appropriate acknowledgment to ensure proposals are deliverable.
Dear Sir /Madam,
Greater Norwich Local Plan 2045 Scoping Consultation August – September 2026
Representations on behalf of National Grid Electricity Transmission (NGET)
National Grid Electricity Transmission has appointed Fisher German LLP to review and respond to local planning authority Development Plan Document consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document.
About National Grid Electricity Transmission (NGET)
National Grid Electricity Transmission plc (NGET) owns and maintains the electricity transmission system in England and Wales. NGET manage not only today’s highly complex network but also to enable the electricity system of tomorrow. Their work involves building and maintaining the electricity transmission network – safely, reliably and efficiently. NGET connect sources of electricity generation to the network and transport it onwards to the distribution system so it can reach homes and businesses.
National Grid Electricity Distribution (NGED) are the electricity distribution division of National Grid and are separate from National Grid Electricity Transmission’s core regulated businesses. Please also consult with NGED separately from NGET.
National Grid no longer owns or operates the high-pressure gas transmission system across the UK. This is the responsibility of National Gas Transmission, which is a separate entity and must be consulted independently.
National Grid Ventures (NGV) develop, operate and invest in energy projects, technologies, and partnerships to help accelerate the development of a clean energy future for consumers across the UK, Europe and the United States. NGV is separate from National Grid’s core regulated businesses. Please also consult with NGV separately from NGET.
National Energy System Operator (NESO) has taken over the electricity and gas network planning responsibility from National Grid Electricity System Operator Limited (NGESO) as of 1st October 2024. Early engagement with NESO is recommended in order to establish available supply capacity to any potential development sites and what, if any, reinforcement is required to ensure adequate continued supply. Please consult with NESO separately from NGET.
Proposed Policies affecting NGET’s Assets or Statutory Duties
Following a review of the above Scoping Document, we have identified that one or more proposed policies conflict with NGET’s assets or statutory duties as an electrical transmission operator. A list of NGET assets falling within the Council’s administrative area is detailed below. A discussion on specific policy conflicts identified follows the below table:
List of Assets:
Overhead Transmission Lines:
PGG ROUTE: 132kV Overhead Transmission Line route: NORWICH MAIN - NORWICH TROWSE 3.
4VV ROUTE TWR (001 - 223): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 1 - NORWICH MAIN - WALPOLE 2.
4VV ROUTE TWR (223 - 223A ): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 2.
4VV ROUTE TWR (223 - 224): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 1.
4YM ROUTE TWR (001 - 195): 400kV Overhead Transmission Line route: BRAMFORD - NORWICH MAIN 1 - BRAMFORD - NORWICH MAIN 2.
PHC ROUTE: 132kV Overhead Transmission Line route: NORWICH MAIN - NORWICH TROWSE 1.
Underground Cables:
PGG001A - PGG001 CABLE SECT 01.
NORWICH MAIN - NORWICH TROWSE 1.
SGT2 132KV CABLE.
SGT4 132KV CABLE.
Decommissioned DC Cable (x2)
Electrical Substations:
NORWICH 400KV S/S
NORWICH TROWSE 132KV S/S
Landownership:
National Grid Electricity Transmission Plc – Freehold – Norwich Main (x2)
Plans showing details of NGET assets within the Plans combined jurisdiction are attached to this letter. Please note that these plans are illustrative only. NGET also provides information in relation to its assets at the website below.
https://www.nationalgrid.com/electricity-transmission/network-and-infrastructure/network-route-maps
NGET Electricity Network Infrastructure
The security and reliability of the UK’s current and future energy supply is highly dependent on having an electricity network which will enable the existing and new electricity generation, storage, and interconnection infrastructure that the country needs to meet the rapid increase in electricity demand required to transition to net zero, while maintaining energy security.
In general, NGET does not own the land crossed by its overhead lines but has responsibility for maintaining the equipment and safe supply of electricity. The increasing pressure for development is leading to more development sites being brought forward through the planning process on land that is crossed by NGET assets.
Despite this NGET is not a statutory consultee in the plan-making process but it is recommended that NGET are consulted at the earliest possible opportunity in order that advice and guidance can be taken into account on development near overhead lines, or wider policies that may affect the existing or future supply of electricity.
With the above context in mind, the Council should ensure that development proposals located near transmission assets demonstrate that they will not compromise safety, operability, maintenance access, asset replacement or future network expansion. The Council should safeguard existing and potential access routes required for the delivery and removal of Abnormal Indivisible Loads (AILs) associated with the construction, replacement and maintenance of transmission-scale equipment, including large transformers at strategic substations and resist development or highway alterations that would prejudice, constrain or render impractical AIL access unless suitable mitigation or alternative agreed routes can be secured.
Proposed Policies affecting NGET’s Assets or Statutory Duties (Commentary)
Question 8 - What measures could the councils take to improve housing delivery rates through the local plan?
NGET advocates the high standards of design and sustainable development forms promoted through national planning policy and understands that contemporary planning and urban design agenda require a creative approach to new development around high voltage overhead lines and other NGET assets.
Section 7 of the Scoping Consultations sets out that there are significant challenges and viability pressures associated with the delivery of housing in the Greater Norwich Area, noting that ongoing major projects have staggered, thus resulting in a need for wider allocation of sites for development.
Given the above context, there is an increased risk of interaction between development sites and NGET assets. Where interaction occurs, NGET consider future iterations of the Local Plan should include wording within site specific policies or an appropriate overarching policy (such as one setting out approach to development of allocations) which appropriately recognises and responds to the presence of NGET assets. Wording to the following effect (Red Italics) may be appropriate for a site-specific policy. In addition, it would also be beneficial to have wording within an overarching policy (blue Italics), but not as a replacement for site-specific policy:
“Development will include a strategy for responding to the NGET Overhead / Underground Cable Route present within / adjacent to the sites which demonstrates how the NGET Design Guide and Principles have been applied at the masterplanning stage and how the impact of the assets has been reduced through good design.”
“take a comprehensive and co-ordinated approach to development including respecting existing site
constraints including utilities situated within sites.”
Where future policy proposals are identified to interact with NGET assets, there should be appropriate
acknowledgment. Without such acknowledgment, policies of the Local Plan and as such its ability to facilitate housing delivery may not be as effective as such proposals may not be deliverable as proposed, unencumbered by the constraints posed by the presence of NGET infrastructure.
Question 20 - Do you consider that our proposed approach to engagement at the statutory consultation stages correctly identifies the target audience(s) at each stage?
It is acknowledged the Council, at Section 12, refer to a list of who will be engaged in Local Plan consultations which includes what it considers to be the relevant ‘Stakeholders and Consultees’’ within the district. Given NGET have a number of existing assets within the Local Plan area, it is essential that they are included specifically as a General Consultation Body to be consulted from the earliest stages of Local Plan production to allow for effective and timely engagement with Development Plan Documents to aid in the effective production of the Local Plan where NGET assets and proposals of the Local Plan may interact. In relation to this, we would draw your attention to the guidance provided at the beginning of this letter under ‘About National Grid Electricity Transmission (NGET)’ which clarifies the relationship between various companies operating under the National Grid title but which are separate from one another. In view of this, NGET requires direct engagement.
Where Development Plan Documents do not suitably consider NGET assets within the area, there is a risk that those assets will unduly impact on the effectiveness of Local Plan proposals; in particular on the ability for allocations to come forward where NGET assets interact. Importantly, the presence of NGET assets within a proposed allocation does not preclude it from development; we only ask that such interactions are appropriately recognised and responded to. To this end, we kindly request the following email is included within the Council’s consultation database:
NG Planning ngplanning@fishergerman.co.uk
New Infrastructure
Demand for electricity is expected to rise significantly as the way we power homes, businesses and transport evolves. As the UK transitions towards net zero, fossil fuels will be replaced by increasing volumes of low-carbon electricity, including from offshore wind and other renewable sources.
The UK Government has committed to achieving net zero emissions by 2050, requiring a balanced approach to greenhouse gas emissions and removals. Decarbonising the energy system is central to meeting this national objective.
National Grid Electricity Transmission (NGET) is delivering a range of infrastructure projects across England and Wales to support this energy transition and ensure that the transmission network can accommodate the rapid growth in low-carbon generation.
The way NGET generates electricity in the UK is changing rapidly, and NGET are transitioning to cheaper, cleaner and more secure forms of renewable energy. NGET need to make changes to the network of overhead lines, pylons, cables and other infrastructure that transports electricity around the country, so that everyone has access to clean electricity from these new renewable sources. These changes include a need to increase the capability of the electricity transmission system between the North and the Midlands, and between the Midlands and the South. It is also needed to facilitate the connection of proposed new offshore wind, and subsea connections between England and Scotland, and between the UK and other countries across the North Sea. Taking this context into account, In planning for the area the Council should:
•
Safeguard all existing NGET transmission assets, including overhead lines, underground cables and substations.
•
Support future reinforcement and expansion, including works required for the Great Grid Upgrade and other strategic national infrastructure projects.
•
Ensure development proposals located near transmission assets demonstrate that they will not compromise safety, operability, maintenance access, asset replacement, or future network expansion.
•
Safeguard existing and potential access routes required for the delivery and removal of Abnormal Indivisible Loads (AILs) associated with the construction, replacement and maintenance of transmission-scale equipment, including large transformers at strategic substations.
•
Resist development or highway alterations that would prejudice, constrain or render impracticable AIL access, unless suitable mitigation or alternative agreed routes can be secured.
•
Encourage early engagement with NGET to identify and resolve any potential impacts at the earliest possible stage of the planning process.
Protecting existing assets and enabling future network development will ensure that the Council contributes effectively to national decarbonisation targets while supporting local growth, resilience and energy security.
Further Advice
NGET is happy to provide advice and guidance to the Council concerning their networks. Please see attached information outlining further guidance on development close to National Grid assets.
If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us.
To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, NGET wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets. Please remember to consult NGET on any Development Plan Document (DPD) or site-specific proposals that could affect our assets.
Attachments:
- GNLP Scoping Consultation NGET Response (2.78 MB)
Comment
GNLP 2045 Regulation 20 Scoping Consultation
Question 20
Representation ID: 26556
Received: 21/09/2026
Respondent: National Grid Electricity Transmission
Agent: Fisher German LLP
it is essential that NGET are included as a general consultation body to be consulted from the earliest stages of local plan production to aid in the effective production of a local plan where NGET assets and proposals may interact. The full response clarifies the relationship between the various companies operating under the National Grid title but which are separate from one another. In view of this, NGET requires direct engagement.
Dear Sir /Madam,
Greater Norwich Local Plan 2045 Scoping Consultation August – September 2026
Representations on behalf of National Grid Electricity Transmission (NGET)
National Grid Electricity Transmission has appointed Fisher German LLP to review and respond to local planning authority Development Plan Document consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document.
About National Grid Electricity Transmission (NGET)
National Grid Electricity Transmission plc (NGET) owns and maintains the electricity transmission system in England and Wales. NGET manage not only today’s highly complex network but also to enable the electricity system of tomorrow. Their work involves building and maintaining the electricity transmission network – safely, reliably and efficiently. NGET connect sources of electricity generation to the network and transport it onwards to the distribution system so it can reach homes and businesses.
National Grid Electricity Distribution (NGED) are the electricity distribution division of National Grid and are separate from National Grid Electricity Transmission’s core regulated businesses. Please also consult with NGED separately from NGET.
National Grid no longer owns or operates the high-pressure gas transmission system across the UK. This is the responsibility of National Gas Transmission, which is a separate entity and must be consulted independently.
National Grid Ventures (NGV) develop, operate and invest in energy projects, technologies, and partnerships to help accelerate the development of a clean energy future for consumers across the UK, Europe and the United States. NGV is separate from National Grid’s core regulated businesses. Please also consult with NGV separately from NGET.
National Energy System Operator (NESO) has taken over the electricity and gas network planning responsibility from National Grid Electricity System Operator Limited (NGESO) as of 1st October 2024. Early engagement with NESO is recommended in order to establish available supply capacity to any potential development sites and what, if any, reinforcement is required to ensure adequate continued supply. Please consult with NESO separately from NGET.
Proposed Policies affecting NGET’s Assets or Statutory Duties
Following a review of the above Scoping Document, we have identified that one or more proposed policies conflict with NGET’s assets or statutory duties as an electrical transmission operator. A list of NGET assets falling within the Council’s administrative area is detailed below. A discussion on specific policy conflicts identified follows the below table:
List of Assets:
Overhead Transmission Lines:
PGG ROUTE: 132kV Overhead Transmission Line route: NORWICH MAIN - NORWICH TROWSE 3.
4VV ROUTE TWR (001 - 223): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 1 - NORWICH MAIN - WALPOLE 2.
4VV ROUTE TWR (223 - 223A ): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 2.
4VV ROUTE TWR (223 - 224): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 1.
4YM ROUTE TWR (001 - 195): 400kV Overhead Transmission Line route: BRAMFORD - NORWICH MAIN 1 - BRAMFORD - NORWICH MAIN 2.
PHC ROUTE: 132kV Overhead Transmission Line route: NORWICH MAIN - NORWICH TROWSE 1.
Underground Cables:
PGG001A - PGG001 CABLE SECT 01.
NORWICH MAIN - NORWICH TROWSE 1.
SGT2 132KV CABLE.
SGT4 132KV CABLE.
Decommissioned DC Cable (x2)
Electrical Substations:
NORWICH 400KV S/S
NORWICH TROWSE 132KV S/S
Landownership:
National Grid Electricity Transmission Plc – Freehold – Norwich Main (x2)
Plans showing details of NGET assets within the Plans combined jurisdiction are attached to this letter. Please note that these plans are illustrative only. NGET also provides information in relation to its assets at the website below.
https://www.nationalgrid.com/electricity-transmission/network-and-infrastructure/network-route-maps
NGET Electricity Network Infrastructure
The security and reliability of the UK’s current and future energy supply is highly dependent on having an electricity network which will enable the existing and new electricity generation, storage, and interconnection infrastructure that the country needs to meet the rapid increase in electricity demand required to transition to net zero, while maintaining energy security.
In general, NGET does not own the land crossed by its overhead lines but has responsibility for maintaining the equipment and safe supply of electricity. The increasing pressure for development is leading to more development sites being brought forward through the planning process on land that is crossed by NGET assets.
Despite this NGET is not a statutory consultee in the plan-making process but it is recommended that NGET are consulted at the earliest possible opportunity in order that advice and guidance can be taken into account on development near overhead lines, or wider policies that may affect the existing or future supply of electricity.
With the above context in mind, the Council should ensure that development proposals located near transmission assets demonstrate that they will not compromise safety, operability, maintenance access, asset replacement or future network expansion. The Council should safeguard existing and potential access routes required for the delivery and removal of Abnormal Indivisible Loads (AILs) associated with the construction, replacement and maintenance of transmission-scale equipment, including large transformers at strategic substations and resist development or highway alterations that would prejudice, constrain or render impractical AIL access unless suitable mitigation or alternative agreed routes can be secured.
Proposed Policies affecting NGET’s Assets or Statutory Duties (Commentary)
Question 8 - What measures could the councils take to improve housing delivery rates through the local plan?
NGET advocates the high standards of design and sustainable development forms promoted through national planning policy and understands that contemporary planning and urban design agenda require a creative approach to new development around high voltage overhead lines and other NGET assets.
Section 7 of the Scoping Consultations sets out that there are significant challenges and viability pressures associated with the delivery of housing in the Greater Norwich Area, noting that ongoing major projects have staggered, thus resulting in a need for wider allocation of sites for development.
Given the above context, there is an increased risk of interaction between development sites and NGET assets. Where interaction occurs, NGET consider future iterations of the Local Plan should include wording within site specific policies or an appropriate overarching policy (such as one setting out approach to development of allocations) which appropriately recognises and responds to the presence of NGET assets. Wording to the following effect (Red Italics) may be appropriate for a site-specific policy. In addition, it would also be beneficial to have wording within an overarching policy (blue Italics), but not as a replacement for site-specific policy:
“Development will include a strategy for responding to the NGET Overhead / Underground Cable Route present within / adjacent to the sites which demonstrates how the NGET Design Guide and Principles have been applied at the masterplanning stage and how the impact of the assets has been reduced through good design.”
“take a comprehensive and co-ordinated approach to development including respecting existing site
constraints including utilities situated within sites.”
Where future policy proposals are identified to interact with NGET assets, there should be appropriate
acknowledgment. Without such acknowledgment, policies of the Local Plan and as such its ability to facilitate housing delivery may not be as effective as such proposals may not be deliverable as proposed, unencumbered by the constraints posed by the presence of NGET infrastructure.
Question 20 - Do you consider that our proposed approach to engagement at the statutory consultation stages correctly identifies the target audience(s) at each stage?
It is acknowledged the Council, at Section 12, refer to a list of who will be engaged in Local Plan consultations which includes what it considers to be the relevant ‘Stakeholders and Consultees’’ within the district. Given NGET have a number of existing assets within the Local Plan area, it is essential that they are included specifically as a General Consultation Body to be consulted from the earliest stages of Local Plan production to allow for effective and timely engagement with Development Plan Documents to aid in the effective production of the Local Plan where NGET assets and proposals of the Local Plan may interact. In relation to this, we would draw your attention to the guidance provided at the beginning of this letter under ‘About National Grid Electricity Transmission (NGET)’ which clarifies the relationship between various companies operating under the National Grid title but which are separate from one another. In view of this, NGET requires direct engagement.
Where Development Plan Documents do not suitably consider NGET assets within the area, there is a risk that those assets will unduly impact on the effectiveness of Local Plan proposals; in particular on the ability for allocations to come forward where NGET assets interact. Importantly, the presence of NGET assets within a proposed allocation does not preclude it from development; we only ask that such interactions are appropriately recognised and responded to. To this end, we kindly request the following email is included within the Council’s consultation database:
NG Planning ngplanning@fishergerman.co.uk
New Infrastructure
Demand for electricity is expected to rise significantly as the way we power homes, businesses and transport evolves. As the UK transitions towards net zero, fossil fuels will be replaced by increasing volumes of low-carbon electricity, including from offshore wind and other renewable sources.
The UK Government has committed to achieving net zero emissions by 2050, requiring a balanced approach to greenhouse gas emissions and removals. Decarbonising the energy system is central to meeting this national objective.
National Grid Electricity Transmission (NGET) is delivering a range of infrastructure projects across England and Wales to support this energy transition and ensure that the transmission network can accommodate the rapid growth in low-carbon generation.
The way NGET generates electricity in the UK is changing rapidly, and NGET are transitioning to cheaper, cleaner and more secure forms of renewable energy. NGET need to make changes to the network of overhead lines, pylons, cables and other infrastructure that transports electricity around the country, so that everyone has access to clean electricity from these new renewable sources. These changes include a need to increase the capability of the electricity transmission system between the North and the Midlands, and between the Midlands and the South. It is also needed to facilitate the connection of proposed new offshore wind, and subsea connections between England and Scotland, and between the UK and other countries across the North Sea. Taking this context into account, In planning for the area the Council should:
•
Safeguard all existing NGET transmission assets, including overhead lines, underground cables and substations.
•
Support future reinforcement and expansion, including works required for the Great Grid Upgrade and other strategic national infrastructure projects.
•
Ensure development proposals located near transmission assets demonstrate that they will not compromise safety, operability, maintenance access, asset replacement, or future network expansion.
•
Safeguard existing and potential access routes required for the delivery and removal of Abnormal Indivisible Loads (AILs) associated with the construction, replacement and maintenance of transmission-scale equipment, including large transformers at strategic substations.
•
Resist development or highway alterations that would prejudice, constrain or render impracticable AIL access, unless suitable mitigation or alternative agreed routes can be secured.
•
Encourage early engagement with NGET to identify and resolve any potential impacts at the earliest possible stage of the planning process.
Protecting existing assets and enabling future network development will ensure that the Council contributes effectively to national decarbonisation targets while supporting local growth, resilience and energy security.
Further Advice
NGET is happy to provide advice and guidance to the Council concerning their networks. Please see attached information outlining further guidance on development close to National Grid assets.
If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us.
To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, NGET wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets. Please remember to consult NGET on any Development Plan Document (DPD) or site-specific proposals that could affect our assets.
Attachments:
- GNLP Scoping Consultation NGET Response (2.78 MB)
Comment
GNLP 2045 Regulation 20 Scoping Consultation
Question 16
Representation ID: 26559
Received: 21/09/2026
Respondent: National Grid Electricity Transmission
Agent: Fisher German LLP
Demand for electricity is expected to rise significantly. As UK transitions to net zero fossil fuels will be replaced by low carbon electricity including from off shore wind and other renewable sources. NGET is delivering a range of projects to support this energy transition using cheaper, cleaner and more secure forms of renewable energy. This means some changes are needed to the network of overhead lines, pylons, cables and other infrastructure including increasing the capacity of the electricity transmission system.
In planning for the area the Council should:
- Safeguard all existing NGET transmission assets
- Support future reinforcement and expansion
- Ensure development proposals near transmission assets will not compromise safety, operations, maintenance access, or future replacement or expansion
- Safeguard existing and potential access routes
- Resist development or highway alterations that would affect access
- Encourage early engagement with NGET
(See attached response for full details)
Dear Sir /Madam,
Greater Norwich Local Plan 2045 Scoping Consultation August – September 2026
Representations on behalf of National Grid Electricity Transmission (NGET)
National Grid Electricity Transmission has appointed Fisher German LLP to review and respond to local planning authority Development Plan Document consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document.
About National Grid Electricity Transmission (NGET)
National Grid Electricity Transmission plc (NGET) owns and maintains the electricity transmission system in England and Wales. NGET manage not only today’s highly complex network but also to enable the electricity system of tomorrow. Their work involves building and maintaining the electricity transmission network – safely, reliably and efficiently. NGET connect sources of electricity generation to the network and transport it onwards to the distribution system so it can reach homes and businesses.
National Grid Electricity Distribution (NGED) are the electricity distribution division of National Grid and are separate from National Grid Electricity Transmission’s core regulated businesses. Please also consult with NGED separately from NGET.
National Grid no longer owns or operates the high-pressure gas transmission system across the UK. This is the responsibility of National Gas Transmission, which is a separate entity and must be consulted independently.
National Grid Ventures (NGV) develop, operate and invest in energy projects, technologies, and partnerships to help accelerate the development of a clean energy future for consumers across the UK, Europe and the United States. NGV is separate from National Grid’s core regulated businesses. Please also consult with NGV separately from NGET.
National Energy System Operator (NESO) has taken over the electricity and gas network planning responsibility from National Grid Electricity System Operator Limited (NGESO) as of 1st October 2024. Early engagement with NESO is recommended in order to establish available supply capacity to any potential development sites and what, if any, reinforcement is required to ensure adequate continued supply. Please consult with NESO separately from NGET.
Proposed Policies affecting NGET’s Assets or Statutory Duties
Following a review of the above Scoping Document, we have identified that one or more proposed policies conflict with NGET’s assets or statutory duties as an electrical transmission operator. A list of NGET assets falling within the Council’s administrative area is detailed below. A discussion on specific policy conflicts identified follows the below table:
List of Assets:
Overhead Transmission Lines:
PGG ROUTE: 132kV Overhead Transmission Line route: NORWICH MAIN - NORWICH TROWSE 3.
4VV ROUTE TWR (001 - 223): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 1 - NORWICH MAIN - WALPOLE 2.
4VV ROUTE TWR (223 - 223A ): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 2.
4VV ROUTE TWR (223 - 224): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 1.
4YM ROUTE TWR (001 - 195): 400kV Overhead Transmission Line route: BRAMFORD - NORWICH MAIN 1 - BRAMFORD - NORWICH MAIN 2.
PHC ROUTE: 132kV Overhead Transmission Line route: NORWICH MAIN - NORWICH TROWSE 1.
Underground Cables:
PGG001A - PGG001 CABLE SECT 01.
NORWICH MAIN - NORWICH TROWSE 1.
SGT2 132KV CABLE.
SGT4 132KV CABLE.
Decommissioned DC Cable (x2)
Electrical Substations:
NORWICH 400KV S/S
NORWICH TROWSE 132KV S/S
Landownership:
National Grid Electricity Transmission Plc – Freehold – Norwich Main (x2)
Plans showing details of NGET assets within the Plans combined jurisdiction are attached to this letter. Please note that these plans are illustrative only. NGET also provides information in relation to its assets at the website below.
https://www.nationalgrid.com/electricity-transmission/network-and-infrastructure/network-route-maps
NGET Electricity Network Infrastructure
The security and reliability of the UK’s current and future energy supply is highly dependent on having an electricity network which will enable the existing and new electricity generation, storage, and interconnection infrastructure that the country needs to meet the rapid increase in electricity demand required to transition to net zero, while maintaining energy security.
In general, NGET does not own the land crossed by its overhead lines but has responsibility for maintaining the equipment and safe supply of electricity. The increasing pressure for development is leading to more development sites being brought forward through the planning process on land that is crossed by NGET assets.
Despite this NGET is not a statutory consultee in the plan-making process but it is recommended that NGET are consulted at the earliest possible opportunity in order that advice and guidance can be taken into account on development near overhead lines, or wider policies that may affect the existing or future supply of electricity.
With the above context in mind, the Council should ensure that development proposals located near transmission assets demonstrate that they will not compromise safety, operability, maintenance access, asset replacement or future network expansion. The Council should safeguard existing and potential access routes required for the delivery and removal of Abnormal Indivisible Loads (AILs) associated with the construction, replacement and maintenance of transmission-scale equipment, including large transformers at strategic substations and resist development or highway alterations that would prejudice, constrain or render impractical AIL access unless suitable mitigation or alternative agreed routes can be secured.
Proposed Policies affecting NGET’s Assets or Statutory Duties (Commentary)
Question 8 - What measures could the councils take to improve housing delivery rates through the local plan?
NGET advocates the high standards of design and sustainable development forms promoted through national planning policy and understands that contemporary planning and urban design agenda require a creative approach to new development around high voltage overhead lines and other NGET assets.
Section 7 of the Scoping Consultations sets out that there are significant challenges and viability pressures associated with the delivery of housing in the Greater Norwich Area, noting that ongoing major projects have staggered, thus resulting in a need for wider allocation of sites for development.
Given the above context, there is an increased risk of interaction between development sites and NGET assets. Where interaction occurs, NGET consider future iterations of the Local Plan should include wording within site specific policies or an appropriate overarching policy (such as one setting out approach to development of allocations) which appropriately recognises and responds to the presence of NGET assets. Wording to the following effect (Red Italics) may be appropriate for a site-specific policy. In addition, it would also be beneficial to have wording within an overarching policy (blue Italics), but not as a replacement for site-specific policy:
“Development will include a strategy for responding to the NGET Overhead / Underground Cable Route present within / adjacent to the sites which demonstrates how the NGET Design Guide and Principles have been applied at the masterplanning stage and how the impact of the assets has been reduced through good design.”
“take a comprehensive and co-ordinated approach to development including respecting existing site
constraints including utilities situated within sites.”
Where future policy proposals are identified to interact with NGET assets, there should be appropriate
acknowledgment. Without such acknowledgment, policies of the Local Plan and as such its ability to facilitate housing delivery may not be as effective as such proposals may not be deliverable as proposed, unencumbered by the constraints posed by the presence of NGET infrastructure.
Question 20 - Do you consider that our proposed approach to engagement at the statutory consultation stages correctly identifies the target audience(s) at each stage?
It is acknowledged the Council, at Section 12, refer to a list of who will be engaged in Local Plan consultations which includes what it considers to be the relevant ‘Stakeholders and Consultees’’ within the district. Given NGET have a number of existing assets within the Local Plan area, it is essential that they are included specifically as a General Consultation Body to be consulted from the earliest stages of Local Plan production to allow for effective and timely engagement with Development Plan Documents to aid in the effective production of the Local Plan where NGET assets and proposals of the Local Plan may interact. In relation to this, we would draw your attention to the guidance provided at the beginning of this letter under ‘About National Grid Electricity Transmission (NGET)’ which clarifies the relationship between various companies operating under the National Grid title but which are separate from one another. In view of this, NGET requires direct engagement.
Where Development Plan Documents do not suitably consider NGET assets within the area, there is a risk that those assets will unduly impact on the effectiveness of Local Plan proposals; in particular on the ability for allocations to come forward where NGET assets interact. Importantly, the presence of NGET assets within a proposed allocation does not preclude it from development; we only ask that such interactions are appropriately recognised and responded to. To this end, we kindly request the following email is included within the Council’s consultation database:
NG Planning ngplanning@fishergerman.co.uk
New Infrastructure
Demand for electricity is expected to rise significantly as the way we power homes, businesses and transport evolves. As the UK transitions towards net zero, fossil fuels will be replaced by increasing volumes of low-carbon electricity, including from offshore wind and other renewable sources.
The UK Government has committed to achieving net zero emissions by 2050, requiring a balanced approach to greenhouse gas emissions and removals. Decarbonising the energy system is central to meeting this national objective.
National Grid Electricity Transmission (NGET) is delivering a range of infrastructure projects across England and Wales to support this energy transition and ensure that the transmission network can accommodate the rapid growth in low-carbon generation.
The way NGET generates electricity in the UK is changing rapidly, and NGET are transitioning to cheaper, cleaner and more secure forms of renewable energy. NGET need to make changes to the network of overhead lines, pylons, cables and other infrastructure that transports electricity around the country, so that everyone has access to clean electricity from these new renewable sources. These changes include a need to increase the capability of the electricity transmission system between the North and the Midlands, and between the Midlands and the South. It is also needed to facilitate the connection of proposed new offshore wind, and subsea connections between England and Scotland, and between the UK and other countries across the North Sea. Taking this context into account, In planning for the area the Council should:
•
Safeguard all existing NGET transmission assets, including overhead lines, underground cables and substations.
•
Support future reinforcement and expansion, including works required for the Great Grid Upgrade and other strategic national infrastructure projects.
•
Ensure development proposals located near transmission assets demonstrate that they will not compromise safety, operability, maintenance access, asset replacement, or future network expansion.
•
Safeguard existing and potential access routes required for the delivery and removal of Abnormal Indivisible Loads (AILs) associated with the construction, replacement and maintenance of transmission-scale equipment, including large transformers at strategic substations.
•
Resist development or highway alterations that would prejudice, constrain or render impracticable AIL access, unless suitable mitigation or alternative agreed routes can be secured.
•
Encourage early engagement with NGET to identify and resolve any potential impacts at the earliest possible stage of the planning process.
Protecting existing assets and enabling future network development will ensure that the Council contributes effectively to national decarbonisation targets while supporting local growth, resilience and energy security.
Further Advice
NGET is happy to provide advice and guidance to the Council concerning their networks. Please see attached information outlining further guidance on development close to National Grid assets.
If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us.
To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, NGET wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets. Please remember to consult NGET on any Development Plan Document (DPD) or site-specific proposals that could affect our assets.
Attachments:
- GNLP Scoping Consultation NGET Response (2.78 MB)
Comment
GNLP 2045 Regulation 20 Scoping Consultation
Question 22 - Is there
Representation ID: 26560
Received: 21/09/2026
Respondent: National Grid Electricity Transmission
Agent: Fisher German LLP
Following a review of the Scoping Document we have identified that one or more policies conflict with NGETs assets or statutory duties. The full response details the list of NGET assets falling with the Councils administrative area with accompanying plans.
In general NGET does not own the land crossed by its overhead lines but has responsibility for maintaining the equipment and safe supply of electricity. The increasing pressure for development is leading to more sites being brought forward on land crossed by NGET assets. despite this NGET is not a statutory consultee in the plan making process but it is recommended that they are consulted at the earliest opportunity so their advice and guidance can be taken into account. The Council should ensure that development proposals located near transmission assets demonstrate that they will not compromise safety, operability, maintenance access, asset replacement or future network expansion.
Dear Sir /Madam,
Greater Norwich Local Plan 2045 Scoping Consultation August – September 2026
Representations on behalf of National Grid Electricity Transmission (NGET)
National Grid Electricity Transmission has appointed Fisher German LLP to review and respond to local planning authority Development Plan Document consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document.
About National Grid Electricity Transmission (NGET)
National Grid Electricity Transmission plc (NGET) owns and maintains the electricity transmission system in England and Wales. NGET manage not only today’s highly complex network but also to enable the electricity system of tomorrow. Their work involves building and maintaining the electricity transmission network – safely, reliably and efficiently. NGET connect sources of electricity generation to the network and transport it onwards to the distribution system so it can reach homes and businesses.
National Grid Electricity Distribution (NGED) are the electricity distribution division of National Grid and are separate from National Grid Electricity Transmission’s core regulated businesses. Please also consult with NGED separately from NGET.
National Grid no longer owns or operates the high-pressure gas transmission system across the UK. This is the responsibility of National Gas Transmission, which is a separate entity and must be consulted independently.
National Grid Ventures (NGV) develop, operate and invest in energy projects, technologies, and partnerships to help accelerate the development of a clean energy future for consumers across the UK, Europe and the United States. NGV is separate from National Grid’s core regulated businesses. Please also consult with NGV separately from NGET.
National Energy System Operator (NESO) has taken over the electricity and gas network planning responsibility from National Grid Electricity System Operator Limited (NGESO) as of 1st October 2024. Early engagement with NESO is recommended in order to establish available supply capacity to any potential development sites and what, if any, reinforcement is required to ensure adequate continued supply. Please consult with NESO separately from NGET.
Proposed Policies affecting NGET’s Assets or Statutory Duties
Following a review of the above Scoping Document, we have identified that one or more proposed policies conflict with NGET’s assets or statutory duties as an electrical transmission operator. A list of NGET assets falling within the Council’s administrative area is detailed below. A discussion on specific policy conflicts identified follows the below table:
List of Assets:
Overhead Transmission Lines:
PGG ROUTE: 132kV Overhead Transmission Line route: NORWICH MAIN - NORWICH TROWSE 3.
4VV ROUTE TWR (001 - 223): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 1 - NORWICH MAIN - WALPOLE 2.
4VV ROUTE TWR (223 - 223A ): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 2.
4VV ROUTE TWR (223 - 224): 400kV Overhead Transmission Line route: NORWICH MAIN - WALPOLE 1.
4YM ROUTE TWR (001 - 195): 400kV Overhead Transmission Line route: BRAMFORD - NORWICH MAIN 1 - BRAMFORD - NORWICH MAIN 2.
PHC ROUTE: 132kV Overhead Transmission Line route: NORWICH MAIN - NORWICH TROWSE 1.
Underground Cables:
PGG001A - PGG001 CABLE SECT 01.
NORWICH MAIN - NORWICH TROWSE 1.
SGT2 132KV CABLE.
SGT4 132KV CABLE.
Decommissioned DC Cable (x2)
Electrical Substations:
NORWICH 400KV S/S
NORWICH TROWSE 132KV S/S
Landownership:
National Grid Electricity Transmission Plc – Freehold – Norwich Main (x2)
Plans showing details of NGET assets within the Plans combined jurisdiction are attached to this letter. Please note that these plans are illustrative only. NGET also provides information in relation to its assets at the website below.
https://www.nationalgrid.com/electricity-transmission/network-and-infrastructure/network-route-maps
NGET Electricity Network Infrastructure
The security and reliability of the UK’s current and future energy supply is highly dependent on having an electricity network which will enable the existing and new electricity generation, storage, and interconnection infrastructure that the country needs to meet the rapid increase in electricity demand required to transition to net zero, while maintaining energy security.
In general, NGET does not own the land crossed by its overhead lines but has responsibility for maintaining the equipment and safe supply of electricity. The increasing pressure for development is leading to more development sites being brought forward through the planning process on land that is crossed by NGET assets.
Despite this NGET is not a statutory consultee in the plan-making process but it is recommended that NGET are consulted at the earliest possible opportunity in order that advice and guidance can be taken into account on development near overhead lines, or wider policies that may affect the existing or future supply of electricity.
With the above context in mind, the Council should ensure that development proposals located near transmission assets demonstrate that they will not compromise safety, operability, maintenance access, asset replacement or future network expansion. The Council should safeguard existing and potential access routes required for the delivery and removal of Abnormal Indivisible Loads (AILs) associated with the construction, replacement and maintenance of transmission-scale equipment, including large transformers at strategic substations and resist development or highway alterations that would prejudice, constrain or render impractical AIL access unless suitable mitigation or alternative agreed routes can be secured.
Proposed Policies affecting NGET’s Assets or Statutory Duties (Commentary)
Question 8 - What measures could the councils take to improve housing delivery rates through the local plan?
NGET advocates the high standards of design and sustainable development forms promoted through national planning policy and understands that contemporary planning and urban design agenda require a creative approach to new development around high voltage overhead lines and other NGET assets.
Section 7 of the Scoping Consultations sets out that there are significant challenges and viability pressures associated with the delivery of housing in the Greater Norwich Area, noting that ongoing major projects have staggered, thus resulting in a need for wider allocation of sites for development.
Given the above context, there is an increased risk of interaction between development sites and NGET assets. Where interaction occurs, NGET consider future iterations of the Local Plan should include wording within site specific policies or an appropriate overarching policy (such as one setting out approach to development of allocations) which appropriately recognises and responds to the presence of NGET assets. Wording to the following effect (Red Italics) may be appropriate for a site-specific policy. In addition, it would also be beneficial to have wording within an overarching policy (blue Italics), but not as a replacement for site-specific policy:
“Development will include a strategy for responding to the NGET Overhead / Underground Cable Route present within / adjacent to the sites which demonstrates how the NGET Design Guide and Principles have been applied at the masterplanning stage and how the impact of the assets has been reduced through good design.”
“take a comprehensive and co-ordinated approach to development including respecting existing site
constraints including utilities situated within sites.”
Where future policy proposals are identified to interact with NGET assets, there should be appropriate
acknowledgment. Without such acknowledgment, policies of the Local Plan and as such its ability to facilitate housing delivery may not be as effective as such proposals may not be deliverable as proposed, unencumbered by the constraints posed by the presence of NGET infrastructure.
Question 20 - Do you consider that our proposed approach to engagement at the statutory consultation stages correctly identifies the target audience(s) at each stage?
It is acknowledged the Council, at Section 12, refer to a list of who will be engaged in Local Plan consultations which includes what it considers to be the relevant ‘Stakeholders and Consultees’’ within the district. Given NGET have a number of existing assets within the Local Plan area, it is essential that they are included specifically as a General Consultation Body to be consulted from the earliest stages of Local Plan production to allow for effective and timely engagement with Development Plan Documents to aid in the effective production of the Local Plan where NGET assets and proposals of the Local Plan may interact. In relation to this, we would draw your attention to the guidance provided at the beginning of this letter under ‘About National Grid Electricity Transmission (NGET)’ which clarifies the relationship between various companies operating under the National Grid title but which are separate from one another. In view of this, NGET requires direct engagement.
Where Development Plan Documents do not suitably consider NGET assets within the area, there is a risk that those assets will unduly impact on the effectiveness of Local Plan proposals; in particular on the ability for allocations to come forward where NGET assets interact. Importantly, the presence of NGET assets within a proposed allocation does not preclude it from development; we only ask that such interactions are appropriately recognised and responded to. To this end, we kindly request the following email is included within the Council’s consultation database:
NG Planning ngplanning@fishergerman.co.uk
New Infrastructure
Demand for electricity is expected to rise significantly as the way we power homes, businesses and transport evolves. As the UK transitions towards net zero, fossil fuels will be replaced by increasing volumes of low-carbon electricity, including from offshore wind and other renewable sources.
The UK Government has committed to achieving net zero emissions by 2050, requiring a balanced approach to greenhouse gas emissions and removals. Decarbonising the energy system is central to meeting this national objective.
National Grid Electricity Transmission (NGET) is delivering a range of infrastructure projects across England and Wales to support this energy transition and ensure that the transmission network can accommodate the rapid growth in low-carbon generation.
The way NGET generates electricity in the UK is changing rapidly, and NGET are transitioning to cheaper, cleaner and more secure forms of renewable energy. NGET need to make changes to the network of overhead lines, pylons, cables and other infrastructure that transports electricity around the country, so that everyone has access to clean electricity from these new renewable sources. These changes include a need to increase the capability of the electricity transmission system between the North and the Midlands, and between the Midlands and the South. It is also needed to facilitate the connection of proposed new offshore wind, and subsea connections between England and Scotland, and between the UK and other countries across the North Sea. Taking this context into account, In planning for the area the Council should:
•
Safeguard all existing NGET transmission assets, including overhead lines, underground cables and substations.
•
Support future reinforcement and expansion, including works required for the Great Grid Upgrade and other strategic national infrastructure projects.
•
Ensure development proposals located near transmission assets demonstrate that they will not compromise safety, operability, maintenance access, asset replacement, or future network expansion.
•
Safeguard existing and potential access routes required for the delivery and removal of Abnormal Indivisible Loads (AILs) associated with the construction, replacement and maintenance of transmission-scale equipment, including large transformers at strategic substations.
•
Resist development or highway alterations that would prejudice, constrain or render impracticable AIL access, unless suitable mitigation or alternative agreed routes can be secured.
•
Encourage early engagement with NGET to identify and resolve any potential impacts at the earliest possible stage of the planning process.
Protecting existing assets and enabling future network development will ensure that the Council contributes effectively to national decarbonisation targets while supporting local growth, resilience and energy security.
Further Advice
NGET is happy to provide advice and guidance to the Council concerning their networks. Please see attached information outlining further guidance on development close to National Grid assets.
If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us.
To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, NGET wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets. Please remember to consult NGET on any Development Plan Document (DPD) or site-specific proposals that could affect our assets.
Attachments:
- GNLP Scoping Consultation NGET Response (2.78 MB)
