Comment

Renewable energy technologies and Future Wales

Turley and Eversheds Sutherland welcome the publication of Future Wales: The National Plan 2040 and Edition 11 of Planning Policy Wales. The documents recognise renewable energy as a priority matter of national importance and, in our view, provide a positive policy context to enable Wales to meet its climate change ambitions.

The framework provided by the documents is timely given the wider commitments to renewable energy for Wales echoed elsewhere in the last few weeks. Labour’s election manifesto pledges an ‘energy revolution’ for Wales. The UK Government Budget and the Welsh Government Final Budget 2021-22 also include commitments to support the delivery of renewable energy projects and programmes across Wales.

Future Wales – A positive policy framework for renewable and low carbon energy

Proactive response to industry

Welsh Government has responded positively to feedback during consultation from the renewables industry. Importantly, the traffic light approach to the assessment of new onshore wind proposals, evident in the August 2019 draft of Future Wales, has been replaced by an approach which will enable individual projects to be considered on their merits, whilst still guiding developers towards “Pre-Assessed Areas” designated as being most suitable. This is a positive step toward delivering development and will help Wales to achieve its targets.

A positive policy framework

Policy 17 (Renewable and Low Carbon Energy and Associated Infrastructure) of Future Wales confirms:

• Strong support for the principle of developing renewable and low carbon energy from all technologies and at all scales to meet future energy needs in Wales.
• Decision makers must give significant weight to the need to meet Wales’ international commitments and national targets to combat the climate change emergency. 
• Protection of National Parks and Areas of Outstanding Natural Beauty, together with a general requirement to demonstrate no unacceptable adverse impact on the environment. 
• A commitment to transition to a multi-vector grid network and reduce barriers to the implementation of new grid infrastructure. 
• A presumption in favour of large scale wind energy development in the Pre-Assessed Areas for Wind Energy, subject to the criteria in Policy 18.

We welcome the criteria based Policy 18 (Renewable and Low Carbon Energy Developments of National Significance), which provides a clear decision‑making framework for renewable and low carbon energy technologies.

Future Wales – Practice must follow policy

Consistent development plan policy

Future Wales confirms Welsh Government will support regional and local energy planning to identify opportunities for all types of renewable projects.

This support is guided for the first time by the certainty of a national level development plan policy with clear and concise criteria. A policy that can, and must, be applied anywhere in the whole of Wales.

This clarity can be harnessed to ensure the positive delivery of renewable energy and low carbon development across Wales, where the criteria can be met.

Welsh Government, regional and local authorities can use Future Wales to guide collaboration with stakeholders across industry to deliver new development in this manner.

Effective implementation

The following next steps are essential to delivery on the positive national policy framework:

• Decision making – emphasise effective decision making using the policies of Future Wales to deliver development in the right location. 
• Policy layers – avoid additional complexity, different criteria and/or overwhelming evidence base stages when applied at the regional and local level examinations. 
• Resources – decision makers to work with industry during the decision making process to deliver high quality sustainable development that satisfies the criteria and not overburden the process at the wrong times. 
• Collaboration – all stakeholders (including local communities) to proactively work together through project feasibility and planning to produce appropriate evidence on the merits of a proposal against the criteria.

We urge policy makers to call time on any further policy layers. To deliver renewable energy projects, Wales does not need additional policies at the regional or local level. It doesn’t need a raft of evidence base documents debated at multiple examinations.

We would like to see the focus placed on decision makers working with industry to use the new national policy to guide delivery and deliver the ambitious renewable energy targets set by Welsh Government.

Further guidance

Any further guidance and research prepared to inform the development of onshore wind must avoid over-complicating the position with further policies and regulation.

Conclusion

Does Future Wales facilitate the delivery of development required to realise Wales’ renewable energy potential? Is it the positive planning framework for transformational change needed to deliver political aspirations in the move to Net Zero? We think so.

Welsh Government has instilled a positive stance for facilitating the delivery of renewable energy development across Wales. This timely policy move is welcomed by industry. Let’s not move the goal posts. No additional policy layers are required!

Future Wales provides concise development plan policies that are applicable to every development proposal anywhere in Wales. This can guide quality and evidence based renewable development schemes across the country. The policies are capable of delivering consistent assessment of such proposals and efficient, positive decision making. It will act as a framework for timely collaboration, including with local communities.

Following these steps would set Wales apart. It would provide a positive policy context and planning framework to support the industry in delivering Wales’ renewable ambitions.  It can facilitate the consistent application of the presumption in favour of sustainable development. This will help deliver the sustainable, pragmatic and political goal of Wales as a world leader in renewable energy.

For more information please contact Owen Francis, Rhianon Jones or Paul Maile

22 March 2021