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Jonathan Standen, planning director at Lichfields, says that one of the issues with decarbonisation is that planning is often treated as a later-stage task.
On most hospital estates, the main challenge is not the case for decarbonisation, but the space and timing needed to make it happen. Low-carbon plant must be fitted into busy sites where ambulance routes, clinical buildings, neighbouring homes and older utilities are already competing for room, and the work must be planned around hospitals that cannot simply pause while upgrades are installed. For NHS trusts receiving Phase 4 Public Sector Decarbonisation Scheme funding, this is where the grant award becomes a delivery test.
The scheme has awarded £816.6 million across 245 heat decarbonisation and energy efficiency projects, with NHS bodies receiving £408.1 million across 41 grants. For trusts, that funding can support heat pumps, solar PV, low-carbon heating systems and related upgrades, but it does not remove the need to resolve the planning route, the location of new plant, construction access and any impact on patients, neighbours and hospital operations.
The estate challenge
NHS England’s latest Greener NHS progress report shows the size of the estate challenge. The NHS Carbon Footprint stood at 4.7 MtCO2e in 2024/25, with estates the largest source of the emissions the service directly controls. Buildings energy, waste, water and refrigerants account for 3.1 MtCO2e, while direct emissions must fall by a further 1.8 MtCO2e by 2032 if the NHS is to stay on course.
Those reductions have to be delivered across an estate that is already costly to run and difficult to maintain. The latest Estates Returns Information Collection records 11.3 billion kWh of energy use across the NHS estate in 2024/25, alongside £14 billion in estate running costs and a £15.9 billion backlog maintenance bill. The King’s Fund has also highlighted £3.5 billion of higher-risk backlog, where failure could cause major disruption or have a catastrophic impact on patient services.
For trusts, carbon reduction cannot be separated from maintenance, energy resilience or clinical continuity. A boiler room, roof or plant compound may already be tied into backlog works, fire safety improvements, clinical reconfiguration, ambulance access or future expansion plans, so decarbonisation has to be planned around the way each hospital operates.
Funded schemes can become harder to deliver when the planning route is assumed rather than tested. A heat pump compound, new plant area or solar installation may look straightforward in design terms, but consent will depend on where it’s located, how visible it is, whether it affects neighbours and how the work can be carried out around clinical operations.
The same piece of equipment can raise very different planning issues from one site to another. A plant compound beside an existing service yard may be relatively straightforward; one closer to homes, wards, patient entrances or heritage assets will need closer assessment of noise, appearance, servicing and construction access.
Solar PV can follow the same pattern, with roof form, visibility, glare, heritage and building condition all affecting how simple the consent route really is.
The problem comes when these questions are asked after the scheme has already been determined by technical design, procurement assumptions and funding deadlines. By then, the location may have been chosen, equipment specified and costs tested, leaving less room to deal with a planning issue without affecting the layout, phasing or programme. Policy support for lower-carbon healthcare infrastructure is important, but it does not remove the need to address amenity, access, construction impacts and the day-to-day operation of the estate.
Early planning work is not an extra layer of process; it is a way of avoiding late changes. It allows the team to review the planning history, identify constraints, agree the consent route, speak to the local planning authority and build any surveys or technical assessments into the timetable before the scheme narrows.
Can deliver
At Wansbeck General Hospital in Ashington, Lichfields is seeking consent for a scheme that would use warm water from historic coal workings linked to the former Woodhorn Colliery. It is an unusual proposal, but the planning task is still a familiar one – how the equipment sits on the site, what it means for amenity and noise, how construction is managed and how the work is carried out around a hospital that remains in use.
There is already evidence of what these schemes can deliver once they get through that process. At North Tyneside Hospital, a £22 million carbon reduction scheme completed in 2021 included large-scale heat pumps, boiler upgrades and a 975kW solar PV installation. It is estimated to have reduced CO2 emissions by 75%, saving around 3,470 tonnes of CO2 a year and about £500,000 in annual energy costs.
Those are the outcomes trusts will want from the next round of funded work. The risk is that good schemes lose time between award and installation because planning has been treated as a later-stage task. Bringing it into the programme early gives trusts a better chance of avoiding late changes, protecting funding and getting low-carbon infrastructure into use while hospitals continue to operate.
