Planning vs progress: renewable energy development across borders

With Reform UK winning 41% of all seats up for local election this summer and the drama around Ed Miliband’s alleged near-sacking in the recent cabinet reshuffle, renewable energy and the UK’s net zero goals are increasingly featuring at the centre of policy debates. Residents across the country are concerned with the speed and scale at which the Secretary of State for Energy Security and Net Zero proposes to deliver renewable energy assets, with a particular focus on the use of agricultural land for renewable development and the impacts of projects on local communities. 

But what does this debate look like in other contexts? Climate change is an issue affecting the whole world, yet individual countries have chosen to face the challenges ahead armed with vastly different strategies. The UK places an emphasis on public engagement over the lifetime of a renewable energy application, with very clear regulations around a developer’s responsibility to notify the relevant stakeholders and engage with local communities to develop a given project. The process relies on a strong bureaucracy, and depending on a project’s energy generation capacity, involves a variety of government bodies and local and national authorities. The receipt of feedback from residents living near a proposed site is also a crucial step in the English planning process, and national guidance on statutory consultation requires developers to respond to this feedback before an application can even be accepted for examination. 

While this approach aims to centre communities and emphasise responsible development of renewable energy assets, the extra hoops developers must jump through before a project is approved have played a part in the UK lagging “significantly behind the rest of the world” when it comes to investment in and delivery of clean energy. At the time of writing, statistics from Elexon show that “the UK ran on 100% low carbon energy for the first hour in its history this week.” This paints a stark contrast to California, which announced its own historic first this summer: the state’s power grid “has run on 100% clean energy for some part of the day nearly every day this year,” making it “the largest economy on the planet” to run on two-thirds clean power.

So what does California do differently? 

For starters, developers have a choice between submitting their application to the local authority or to the California State Energy Resources and Conservation Commission (CEC) on projects exceeding 50MW of capacity. Both options require extensive assessments and scoping work to be completed prior to application submission, but where state-level guidance requires certain kinds of public engagement to be undertaken in regards to the project, local guidance does not. The website for Tulare County, one of the primary regions in which solar developments are located in California, reads like a travel brochure targeted towards renewable developers, boasting of the “advantages” to growing a renewable energy company in the County and boldly advertising incentives for business investment in the area. The idea is that renewable energy brings jobs and general economic growth to an otherwise deprived region, and is therefore an important factor in improving the livelihoods of local communities.

Developers choosing to submit their application to the CEC face far more technical requirements around public engagement specifically, as per the California Public Resources Code section 25545. However, public engagement only occurs “once an application is deemed complete,” compared with the informal and statutory consultations that are always held prior to an application’s submission in the UK. Notably, however, all public engagement activities must be organised and led by a representative from the CEC. The developers themselves do not play a role in this process, and focus their efforts wholly on project specifics, site surveys and adherence to state and local guidance. 

Meaningful public engagement ‘the UK-way’ is not a priority for the state of California when it comes to renewable energy development. However, this does not mean that developers can build without regard for local communities. 
According to section 25545.9 of the California Public Resources Code, “The commission shall not certify a site and related facility under this chapter unless the commission finds that the construction or operation of the facility will have an overall net positive economic benefit to the local government that would have had permitting authority over the site and related facility. For purposes of this section, economic benefits may include, but are not limited to, any of the following: (a) Employment growth; (b) Housing development; (c) Infrastructure and environmental improvements; (d) Assistance to public schools and education; (e) Assistance to public safety agencies and departments; and (f) Property taxes and sales and use tax revenues.” 

It is also a requirement that the application be submitted to “all California Native American tribes that are culturally and traditionally associated with the geographic area of the proposed site and initiate consultation” in an effort to mitigate disproportionate impacts that may be felt by underserved communities.

Both contexts present clear benefits and drawbacks when it comes to the regulations that ultimately determine whether a given application for a renewable energy project is approved. The efficiency and legality of California’s system may offer developers a more streamlined path to approval, but it also raises questions about the depth of community involvement and long-term sustainability. In contrast, the UK’s slower, more consultative approach reflects a broader commitment to democratic planning and environmental stewardship - even if it comes at the cost of speed.

Ultimately, the path forward may lie in a hybrid approach: one that preserves the UK’s commitment to transparency and community input, while borrowing elements of efficiency and economic pragmatism from international counterparts. As the political landscape evolves domestically, the future of renewable energy in Britain will depend not just on policy, but on the willingness to learn from global successes - and failures.