Powering up the DCO application process on the UK’s strategic transmission infrastructure

Upgrading the UK’s electricity grid network to get clean power to homes and businesses is a national priority. A streamlined yet robust Development Consent Order (DCO) process will be critical to accelerating project delivery, but the sheer scale presents an unprecedented technical challenge. To meet it, our sector will need to consider both processes and people, write AECOM’s David Ritchie and Steven Whyte.

National Grid has embarked on The Great Grid Upgrade (GGU) – a massive grid modernisation programme that will entail building five times the amount of electricity infrastructure constructed over the past 30 years in just the next seven. 

The GGU is likely to include several developments that will be classed as Nationally Significant Infrastructure Projects (NSIPs). These projects will require the submission of Development Consent Order (DCO) applications to the Secretary of State for Energy Security and Net Zero, which seek permission to construct and operate them.  

DCO applications are required for those large-scale energy, transport, water and waste projects throughout England and Wales that meet the criteria set out in the Planning Act 2008.  

This regime was introduced to streamline the decision-making process for major infrastructure projects, which is beneficial where projects cross several local authorities but also because the DCO can include compulsory acquisition powers.  

Where are DCO applications being used to gain consent for power grid network upgrades?

The UK’s expanding network of subsea electricity superhighways are increasingly seeking consent via the DCO process where they meet the criteria set out in the Planning Act 2008 or where the Secretary of State directs that this is the consenting route that they should follow.  

For instance, we are advising on consenting for the Sea Link project, which will link Suffolk and Kent via a subsea high-voltage cable. This has included successfully seeking a ‘Section 35’ direction from the Secretary of State for the project to be treated as if it were a NSIP. The project is now therefore following the DCO consenting process. 

DCO applications are also used for terrestrial routes and substation developments – projects which are critical to delivering clean energy generated offshore or via subsea interconnectors to customers across the country.  

By way of example, consent for a new high-voltage overhead line from Grimsby to Walpole is being sought via the DCO process, which we are supporting on behalf of National Grid.  

How complex is a DCO application?

Regulatory compliance is complex, from a technical and environmental perspective as well as stakeholder engagement.  

For example, the A428 Black Cat to Caxton Gibbet improvements scheme in Bedfordshire and Cambridgeshire – a linear scheme brought forward by National Highways which is comparable to the GGU – required a DCO application which included 258 documents with approximately 20,000 pages in total.  (The A428 Black Cat project is dwarfed by the GGU, which is likely to require upwards of five separate DCOs, clearly illustrating the scale of the task at hand.) 

The process must be as rigorous as possible to navigate all regulatory and stakeholder challenges, address and mitigate potential risks and enable organisations to submit applications that are consistent across all documents and as robust as possible. Broadly speaking, the DCO process is similar across sectors, although there are always project-specific risks and nuances to consider. 

The working environment is often highly pressured as the teams manage the complex process, the volume of work as well as the submission deadlines. 

Five people-centric ways to power up the DCO process  

In the following part of this article, we outline five fundamental ways that the DCO process can be streamlined and optimised while keeping staff wellbeing and stakeholder engagement front and centre.  

These recommendations are borne out of our multi-sector DCO experience as well as more than 15 consented successful DCOs on behalf of energy clients within the U.K. 

Some of them have been industry firsts and therefore technically challenging, such as the DCO for the first Carbon Capture Usage and Storage (CCUS) scheme linked to a gas-fired power station at Keadby 3, which has already received the green light for development. 

For ease, we use our award-winning work on the A428 Black Cat scheme mentioned above as our primary example. 

1/Foster collaboration 

DCO applications are a team effort, involving many professionals from numerous organisations and disciplines including the client as well as designers, planners, stakeholder engagement specialists, environmental experts and more. This calls for an integrated and collaborative approach at the earliest opportunity, driven by strong leadership.  

Exceptionally strong collaboration between key stakeholders and teams was central to success on the A428 Black Cat scheme. Even with multiple stakeholders, including five host authorities, the DCO was accepted early. 

Key features of collaborative working included collaboration days and workshops on various topic-specific areas relating to the project timeline such as DCO examination preparation, efficiencies, and lessons learnt. Towards the final stages, co-located staff were able to conduct cross-discipline meetings and reviews to expedite the process.   

2/Pay attention to behaviours and wellbeing 

A DCO application requires professionals and people who don’t normally meet, yet who are mutually dependent, to work, share, help and support each other – often in highly-pressured situations. 

There is great value therefore in proactively investing time and resources in coaching teams to build relationships based on trust and respect, which is what happened on the A428 in partnership with fellow delivery partners and National Highways. 

Wellbeing workshops, events and activities were also held across the integrated teams to help them rise to the challenges of the DCO process.  

3/Bring contractors to the table early 

Early engagement with contractors during the consenting process helps to bring any potential delivery issues to the fore, strengthening the DCOs and accelerating construction when the infrastructure is approved.  

This is best practice on major linear infrastructure projects – such as the A428, where contractor Skanska was brought in to review the design from pre-application through to examination stages. This diversity of experience and thought enables a design that can be delivered. 

4/Adopt programme management methodologies 

As we have discussed before, DCO applications can be sought for projects that meet the criteria set out in the Planning Act 2008. An organisation (such as National Highways) may have several DCOs running concurrently. 

However, the GGU differs in that it is a wider programme comprising upwards of five DCOs, which will be managed by just one or two private sector organisations in partnership with National Grid.  

We believe that a disciplined, systematic approach using programme management methodologies will be needed to deliver each DCO application in a coordinated way.  

As no direct parallels exist in relation to DCOs, industry will need to bring experience from the design and delivery of large-scale linear infrastructure schemes across the world to the GGU, where programme management methods are being applied to obtain benefits for clients otherwise not attainable if project elements were managed separately.  

(See the project case study below to find out how programme management methods are being used to scale up the undergrounding of overground power lines in San Diego, California.) 

5/Use the latest stakeholder engagement tools and techniques  

It is inevitable that the national grid upgrade, with the prospect of pylons striding across the countryside, will be controversial in many communities. As Nick Winser, Electricity Networks Commissioner, points out in his recent report: “Affected individuals and communities are confronted with infrastructure proposals that are difficult to understand and may bring detriment to their lives.” 

The consenting process rightly gives ample opportunity for people and organisations to air their views, but also for the government and National Grid to educate and explain to people the aims of the broader programme as well as its local impact.  

It is critical, therefore, that public engagement must be meaningful, transparent, collaborative and conducted at the right time. A rich emotionally intelligent approach to public engagement can lead to stronger levels of success when used with the right tools.

Advances in technology are now enabling a far richer engagement experience that combines face-to-face meetings with virtual activities to bring the project to life.  

On the A428 Black Cat, we used augmented reality, traffic management animation, video flythroughs, and virtual consultations (a first for National Highways). We also used a Minecraft model and partnered with Mumsnet to reach as wide an audience as possible, which resulted in a ten per cent shift in the proportion of under 45s taking part compared to previous consultations.  

A critical collective challenge

Robust DCO submissions will be key to accelerating the deployment of the strategic transmission infrastructure needed to smooth the UK’s transition to a low-carbon economy. 

We believe that people, teams and tools are the building blocks to good DCO outcomes. If the UK is to succeed in modernising the grid at the pace required, those building blocks will need to sit on the strongest foundations possible – and that will depend on government, consultants and client working closely together united by a sense of urgency and common purpose.

With thanks to contributors Naomi Kretschmer, Bill Gregory and Phil Wayles.

Want to read more? In her recent blog post, Eloise John, who leads the energy business for AECOM in the UK and Ireland discusses the current imperfect planning system, which is adding extra layers of complexity to the engineering challenge on the Great Grid Upgrade.