National Assembly for Wales

Croeso. Welcome to the meeting of the Climate Change, Environment and Rural Affairs Committee. The meeting's bilingual, and simultaneous translation is available. If you need it, you can pick it up under 'English' on the options on languages. You should not have to mute or unmute yourself; that should be done automatically. If I drop out, Jenny Rathbone will take over. Are there any declarations of interest? 

Can I welcome Dr Roisin Willmott, director of Wales and Northern Ireland, Royal Town Planning Institute, and Dr Neil Harris, senior lecturer, School of Geography and Planning, Cardiff University? You're both very welcome. We'll move straight to questions. My first one is: how has the NDF wording been amended to strengthen integration with other key Welsh Government plans and strategies? Really, do you think it all fits together?

Shall I go first?

Yes, please.

Thank you. There has been some explicit changing of the wording, and I think it's good to recognise that certain strategies have come forward since the initial drafting of the consultation back last year. So, the revised transport strategy, for example—that is now under development, where it wasn't on the previous consultation. So, that has now been able to inform a revised version of the plan. I think the marine plan was a good example of where there has been integration, because that was being developed at the same time, and I think that's something to be aware of, with all of Government strategies and plans—that there's no perfect alignment in terms of time. That's virtually impossible, so there will be some plans that are ahead, some that are out of date and need to develop and inform. And as the process carries on, as there are future reviews of this plan, they can inform those reviews as well. But I think, for where it stands at the moment, there has definitely been good integration of the existing policies in terms of where they are now.

Thank you. Do you want to say anything, Neil, or—?

I very much agree with Roisin on this. This document is doing an awful lot of work in various areas, including with strategic development plans. And I think, for a document of its type, it knits together with the other strategies appropriately. I think it does its job.

Thank you very much. Joyce Watson. You're still on mute, Joyce. I'm not quite sure why, because I think it's meant—. You're now not. 

It's because I wasn't expected to be called until later.

Okay. That's fine. I'll carry on, then. The inclusion of policies that could be considered non-spatial in the NDF rather than in 'Planning Policy Wales'—is that an issue? Or as long as it's there, that's all that matters?

Sorry—I'm just getting to grips with the technology and the process. I think where they are non-spatial, perhaps they do have a spatial element. They're reinforcing what is said in 'Planning Policy Wales', so there's certainly no contradiction there. They set the spatial context and the spatial principles, if you like, rather than the more general planning policies with that. One of the criticisms in the original consultation was that perhaps rural issues weren't highlighted. So, now there are policies in there to emphasise the importance of rurality in Wales, which, of course, is very important, and with all of the other issues. So, it tries to give us a spatial complexity to those particular policies. So, it is appropriate, I think.

And Neil.

I had a good look at this suggestion that there might be things in here that aren't sufficiently spatial. There is policy 6 and 'town centre first', where I think that kind of statement has always been in something like 'Planning Policy Wales'. So, I think there are things in there that aren't sufficiently spatial. It's not always important—and I think there's a distinction, isn't there, that sometimes the policy might be in there because it is of particular national significance at the present time. So, I can see why some policies might be in there even if they didn't have a significant spatial element, if they were very clearly setting out what Welsh Government is going to do. So, I think it's a mixed evaluation, for me, on those. So, some very spatial, some could be into 'Planning Policy Wales'. The reason I suggest it might be looked at a bit more is because this is a document that has grown very significantly. With the monitoring framework, this is a document that now is really three times the length of the consultation document. So I think anywhere where we could end that would be useful. 

Thank you. Llyr.

So, would you say that it's trying to do too much now?

It's doing a lot of heavy work. I think it's setting out national trends. It's trying to set out a national strategy as part of 'Future Wales'. It does quite a lot, I think, for each of the regions, so each region is getting roughly 20 pages. If you take what's in there now for the regions, that's longer than the consultation document was in itself initially. So, it's doing a lot of work to fill the gap where strategic development plans are. I think it is trying to do a lot of different things.

There's a suggestion there, is there, that it's a bit top down, then. Should there not be greater scope for the regions themselves to cast some of that parameter?

As I was going through it, I was thinking it'll be local authorities working together. I suppose what would be really important as part of your evidence and scrutiny of it is to what extent 'Future Wales' or the NDF gives a sufficient steer to the SDPs without going too far so that then those that come together to formulate them don't feel a sense of ownership of them. And there's still a lot of uncertainty. I suppose we might even get to the review of 'Future Wales' before we have SDPs in place. So, I think, yes, 'Future Wales' is doing a lot of work to fill that gap of strategic development plans at the moment.

I see Roisin nodding. I presume that you agree.

Yes, I would agree, and I think it goes back to this point I made about the alignment of policies in terms of timing. So, we don't have any strategic development plans at the moment, and they will take at least four years, probably, getting all the evidence base and information together. Hopefully it'll be quicker than that, but we could be looking at four years. So, we would have that complete policy vacuum, and I think we have to think about this document as being a—I go back to it being a journey, really. So, if we look at Scotland, they're about to start their fourth, and each time it's improved and it's been able to work with different things, so I think we have to look at it in that stage as well. So, if SDPs come on, then it can become lighter in terms of those regional policies.

It's an important point, isn't it? Because if this informs or influences heavily the SDP, well, the SDP then obviously has a similar influence on local development plans, and it's very much top down and you don't really see a way for the local voice to bubble up as far up the chain as some of us, maybe, would like. But thank you for that; that's quite interesting.

Could I just then—? Given that we're talking about the SDP, it's been mentioned, hasn't it, this interaction between the growth deals. Because we're looking at particular footprints in terms of the regions as well, and we'll elaborate on that a little bit in a moment, maybe. But how do you see that interplay between the growth deals and the strategic development plans, then? Because clearly the SDPs will be driven by the Welsh Government's vision in terms of development, whereas the growth deals are largely driven by the UK Government agenda. 

That's a very valid point. I think in an ideal world the SDPs would have come forward first, and they would provide the strategic framework that was needed in that particular region. It would have provided the evidence of what was needed. And what's important as well is that the regions aren't in isolation from each other—it's how they integrate together, and that's a good part of this development plan, as well, that it can pull them together. That's why sometimes you need a top-down in that sense, but in time there will be an interplay between the two. The growth deals—when the funding and the programmes are under way, they do have to be taken account of, and can't be ignored, particularly when there's significant funding involved. But perhaps in time they could be flexed to meet what the evidence is showing that's brought forward by the strategic development plans.

Neil.

I think the key issue will be what it is for any planning document, which is all these different sectoral dimensions—protection of the environment, economic growth—and the balancing of them. So I think how they play out is a key part of what doing the SDP will be. So I suppose the SDP will just have to make the integration of all these different dimensions. So I think in terms of how they link to growth deals, it's a factor they'll take into account, but they'll have to take into account so many other factors, just as 'Future Wales' is having to integrate the various dimensions of Welsh Government strategies. 

Okay. One of the changes that the Government made, of course, was to move from a three-region model to a four-region model. Was that the right decision, do you think? Are there other regions or other footprints that you would prefer?

The RTPI certainly supports the four-region model. South-west and mid Wales was perhaps a bit too large and incongruous. In that sense, I think it falls more naturally into south-west Wales and mid Wales being separate. I think if you separate any of the regions down further, then what are you actually achieving? I think you need a certain spatial scale, and then economies of scale, and what we have to remember as well is that it will take a great deal of resource to put these together, not just for strategic development plans, but anything else that goes on. So, if you start making them much smaller, then you have to think about the resourcing, particularly in terms of team sizes, et cetera, and would it be better to just do joint local development plans in those senses where you feel there's a more natural environment between local authorities. 

I'll bring Neil in in a moment. I'm just interested, really, because obviously within—I represent north Wales—the north Wales region there's huge diversity, isn't there? You have the industrial presence along the east and then the rural hinterland and the western seaboard, and I'm thinking that somewhere like Gwynedd would have much more in common economically, socially, culturally as well, with Ceredigion than it would with Flintshire, for example. And also, of course, there's always this east-west axis in relation to Wales, and one understands why—it's a historic thing in terms of having an extractive economy—but surely in terms of a national development framework, yes, we need to see our place within the wider national and international context, but do you feel that there's enough done in strengthening the north-south outlook? Not necessarily physical links or only transport links, but certainly that sort of national entity in terms of north-south links. Because clearly many of us feel it's deficient. 

I'm not quite sure how to respond to that, actually. Certainly on the transport side, I could go into that, but I think, as you say, with Gwynedd and Ceredigion, certainly at the local development plan level there is an opportunity there to look towards each other's areas, and neighbouring local authorities do need to do that when they put together their local development plans. And strategic development plans will have to do that as well. So, north Wales will have to look to mid Wales as well in their development, and vice versa, of course. So, it is important to do that interrelationship. But, of course, Cardiff being where the governance centre, if you like, for Wales is based, then we do need to think about those links, about how Cardiff—well, Cardiff Bay—becomes inclusive to the whole of Wales and connected in that sense, definitely.  

If I may come in, firstly, on the question of moving to four regions, I think that aligns with, in terms of number, the project that we carried out as part of the preparation for the NDF. So, Cardiff University was engaged in a project, and it did recommend four regions. And that was one of their comments on the consultation—moving to four. The only difference between what we put together and what is evident in 'Future Wales' is what do you do with Ceredigion? Certainly, in our project, we put Ceredigion in with south-west, which just left Powys, effectively, as a region in its own right. So I suppose maybe just exploring whether Powys and Ceredigion as a mid Wales region makes sense, I think, is worth another look at. So, I think four is appropriate, based on—[Inaudible.]—whether they're the right four in terms of their boundaries needs to be explored. 

Can I come in here? Unless you dismember Powys, and there's a good argument for that in that places like Ystradgynlais and Brecon look towards Swansea and Cardiff, whereas places in Montgomeryshire look towards north Wales, then really you are fitting into what is the mid Wales development group. And I think it really is important that everything we do fits into these new regions and not, as we've had too often in Wales in the past—and you may disagree with me—where we have one for police, one for fire, one for education, one for social services, one for the planning of disasters, and each one has a different group of local authorities joined together. Do you agree with me that what we actually want is some sort of regional footprint that works for everything?

Absolutely, I would agree with that. It makes it much more efficient in that sense. 

Because health is another one, isn't it? If Ceredigion goes with Powys, then obviously there'll be two health boards in one region, but there we are. Okay. Thank you, Chair. 

Sorry, can I ask you—and I know health isn't one of your areas of expertise—do you see any reason why Ceredigion cannot go in with Powys as a health board, and then we would have a south-west Wales health board covering Pembrokeshire, Carmarthenshire, Neath Port Talbot and Swansea?

I suppose there is some logic to that, but I don't know what the needs are of the health service at all, I'm afraid, so I couldn't comment on that. 

Thank you. Thank you, Llyr. On to you, Janet. You're still on mute, Janet. I'm not sure why. 

Sorry about that. I'm okay to go now on climate change, yes?

Yes.

Okay. The RTPI's paper submitted as written evidence has urged the Welsh Government to be bolder in its approach to integrating responses to climate change into its policy frameworks. Can you both explain whether you feel the NDF has been updated appropriately to take into account the challenges presented by climate change, and outline any core areas remaining of concern where you feel the Welsh Government should have been more ambitious?

Shall I go first, since it was the RTPI's evidence that you commented on? First, I think that climate change was in the original consultation document but it perhaps wasn't explicit. But now it is very much front and centre. It is quite explicitly in the introduction and running through the document as well now. So, it is quite clear that climate action is required to be taken through the development plan. 

For me, I suppose I'm looking more, rather than just references, at actual thematic and fundamental principles that are going to be adopted, if you like. 

Yes. Well, certainly, in terms of the energy generation, that is the presumption—that it would be on carbon-reduced energy generation. There is one area that perhaps could be strengthened, and that's on the coastal planning side of issues, and we can see the fantastic view behind you now, so, it might be pertinent. But, should there be more on coastal planning? That is definitely something that is required in local development plans, but perhaps with this longer term, the 20-year focus with this development plan, and looking beyond that as well, coastal planning is very important for Wales. 

Well, that was going to be my lead-on question, really, because the RTPI's evidence paper also suggested that the plan could go further to address the issue of coastal adaptation in the future. In acknowledging that, do you accept this issue might be beyond the scope of this plan, as you say, and the NDF could be pivotal to setting the agenda in the area? And, again, if you could both briefly explain to the committee how you think the NDF can address climate change resilience through the process of coastal adaptation.

I suppose it's looking at where you put your growth zones. That is one of the issues that Wales really faces—that our main population centres in the north and the south are based on the coastal flood plains. So, that really needs to be looked at and planned for, with sea level rises or even just storm activity as well. So, that is something that needs to be built in. Is that the right place for growth? Probably, but there is one anomaly in the document, just in terms of the visualisation from the plan. So, if you look at the south-east Wales growth plan, it puts both Cardiff and Newport as at-risk flood areas. So, from the scale of that diagram, it does indicate that you shouldn't do any development in Cardiff and Newport, and perhaps it needs a little bit more explanation on that side, because, otherwise, it just looks like a blanket ban on any form of development in those areas. So, it does need to be fleshed out more, I think. 

Is it fair to say, because of the lack of grid capacity, though, the NDF could have been more ambitious, had we had sufficient grid capacity?

Grid capacity is definitely an issue, and that has to come—. If we're talking about where you have your windfarms and how you connect them, that is an issue. And, of course, undergrounding is a potential solution to that, but, of course, there's an additional cost to that, and would the National Grid—and I believe you're speaking to them later—be willing to take that forward in areas outside national parks, for example? So, that would come down to an issue of cost on that. 

And talking about national parks, do you feel that there could be more scope, again, more ambition within the national development framework to see more land designated as national parks?

I think you'd have to look at what the criteria are for national parks and whether other areas warrant that within Wales. Or is it better to focus on the parks that we have at the moment, assuming that they all remain to meet the criteria? And I wouldn't suggest that there are any that don't meet that. You have the areas of outstanding natural beauty as well, which, perhaps, with not quite the status of national parks, are still valuable protection. I think if you have much more coverage, then you really start to restrict Wales, and it's better to think about how you can do positive development and manage that development in a positive way. 

You'll be aware, even though it's not quite in my constituency, of Snowdon and lots of concerns there, and that policy 12 should include an additional priority to support—. We have real problems with cars, transport, lack of public transport accessibility, for people to access. What measures do you think the NDF should have included within policy 12 that would reduce car dependency and facilitate greener modes of access to and around the most popular visitor destinations in designated landscapes, which, quite frankly, are experiencing chronic road congestion? From a planning perspective, could you both explain how you feel that the NDF could actually bring about some change here?

I'm conscious I'm hogging the field—

Yes, it would be nice to hear from you, Neil [Laughter.]

Yes—while my connection holds out, that is. I didn't have a chance to come in on the climate change challenge question initially, and I just think that, actually, what you've got here, compared to some other parts of the UK, is that you've got something that really puts climate change and decarbonisation resilience right at the heart of your NDF. So, I think it's doing a good job on that front.

I think the integrated sustainability appraisal does flag up—and, again, it's done its work of flagging up—what are some of the remaining challenges. And I suppose the flooding dimension is one of those to explore further, and the other was, obviously, Cardiff Airport, as one of the international gateways and what that might mean in relation to climate change targets and carbon targets et cetera. So, I think that would be my response to that earlier question.

On the other questions, I suppose I feel that, as a national development framework, this is probably doing about as much as it can do to set the framework—SDPs and LDPs do that more kind of local contextualisation. As I say, I think this is a document that has grown substantially and I think it might need to be pared back for clarity of what it's focusing on, which is setting out those national issues and then leaving the space for the strategic development plans and the local development plans to give a more localised contextualisation, such as what might happen in the national parks et cetera.

So, yes, I'm arguing for staying at a strategic level in this document rather than seeing it grow and grow further. The fact that it is a development plan means that it has become more classically development-plan-like in the sense of the local authority development plan. So, I think it just needs to stay at that strategic level, for me, and it's kind of going a little bit detailed.

May I just come back on that, Mr Chairman? I know from previous experience, when there are problems that arise in LDPs, quite often then there's reference to the spatial plan and then the national development framework and, so, people, quite often—. This document we're all discussing now does actually influence greatly how things are delivered at local level, so I suppose I would tend to think that I prefer to see more clarity in there. That's just more of an observation than anything.

And then I've got a final question to you on COVID recovery. I've raised this before, but, very briefly, can I ask if you both feel that the NDF has a sufficient focus on post-COVID-19 recovery, and whether you consider this to be as green as it could be, given the present evolving? Because we're not out of COVID yet. So, again, I am very concerned about this particular framework and that it has to evolve, as we evolve, as we go through COVID. So, considering rural infrastructure, how best do you think the Welsh Government can include economic regeneration and recovery in their plans, especially for our areas like north Wales?

Who's going to go?

Yes, I think the best thing this document can do is pursue resilience, I suppose. If it puts resilience at the heart of the document, we can focus on how it might deal with things post COVID. But whatever it might have to deal with—

Sorry to interrupt and I do apologise—

So, I think what I feel you've got is a document—[Inaudible.] Sorry, I couldn't hear that—my connection is breaking a little.

I was just going to say that you say what this document could do, and my question is: is it doing it?

Did you hear that, Neil?

Yes. What I think this document does is that, in some places, it makes a commitment in terms of what the Welsh Government will do, and that's why, when some of the policies I said earlier weren't spatial, there is a commitment to engaging in land assembly. So, there are certain commitments to what Welsh Government will do. Because what I think is very different around this document is its development plan status. It's been much more clearly articulated as policies than its predecessor Wales spatial plan, for example, and it sets that framework. I mean, it doesn't do anything, in the same way that a local development plan doesn't really do anything; it's the actions that follow from that and that setting of priorities and so on. So, I think if you're looking for the document to do something, it doesn't; the Welsh Government will do something framed by what it sets out to do in its priorities in this document. 

Thank you. Can we move on to Jenny?

Thank you. We've dotted around a little bit, so I just want to just finalise the issue around climate change. Obviously, there's no room for timidity on climate change, so I welcome Roisin's remark that we have to be bolder in our approach. Now, obviously there's a lot in there on energy policy and there's some on flooding, which I'll come back to in a minute, but have we really captured everything that relates to climate change? Because it isn't just about those two things; it's obviously about how we use the land, our resilience in terms of food, given that some of the places we get food from at the moment may cease to be areas that are habitable. Does it sufficiently capture the full challenge of climate change without going into too much detail?

Yes, I think it is very strong in that sense. I mean, biodiversity is the other area, of course, which is very important for climate change, and that is very strong in the document. And of course, you have the area statements, et cetera, which will provide evidence to support that in the form of those and SDPs and local development plans because, of course, biodiversity and environmental management needs to be done at all different scales as well, whether it be a local nature reserve up to larger scale things like the proposal for a national forest, for example.

One thing we were pleased with in the revision was the acknowledgment of the agricultural land, so the Vale of Glamorgan area, which is good, strong agricultural land, that that is acknowledged within the plan as well. I think it's very difficult to go into much more detail on topics like agriculture because, really, it starts to get more difficult to understand in planning terms. Land use is often used in terms of land management things, rather than how, perhaps, a town planner would use the words 'land use'. We feel it's much stronger on that, but, of course, we can always do more for climate action, and that will need to be done through actions as well and making sure that we've got the alignment with the other Welsh Government policies.

But is it tough enough in the sense of setting the framework for the work to be done by the regions on their SDPs, in the sense that no change isn't an option rather than going into the detail? Do you think the framework it's setting is clear enough to say, 'We have got to deliver on these things'?

I would suggest so.

Okay. You're nodding, Neil. Is there anything you wanted to add here?

Yes. I think—. [Inaudible.] Yes, the framework's a positive one. I think Jenny's question around what other aspects of sustainability might it deal with, I suppose there's some dealing with questions of water in the document, so it does address some aspects of that. The raising, Jenny, of your point around food is interesting, because, I suppose, as a town and country planning document, then I think Roisin's right in that the planning system deals very strangely with the question of agriculture and food and issues like that, almost not necessarily seeing it as a central issue sometimes. So, I think I will probably go back and look at the document and see whether it does take into account various dimensions of things like water and food supply, et cetera, in sufficient depth.

Okay. Thank you for that. I agree, water is a really crucial issue and thank you for reminding us about that. Just going back to the issue around flood warning areas; perhaps I can declare an interest: both my house and my office will be under water unless we change our ways. Does it mean, Roisin, that when we're discussing growth zones, we should simply say, 'There will be no more developments on flood plains, end of story'? Because clearly, otherwise, we're just having to clear up the mess we create for ourselves. You're muted, Roisin.

Sorry, I was waiting for the little box to come up. So, I think we need to be careful about that, because obviously, if we stop developing in places like Cardiff and Newport, Swansea, then we have to go into the rural areas, and is that appropriate? So, there are difficult balances in that sense. I think what we need to do is be more selective. I would recommend certainly not building on new flood plains or a flood plain that isn't developed on now, and not encroaching on that. We also have to think what's happening upstream as well, so thinking about what's happening up in valley areas and upland areas, and that's where biodiversity plans can come in as well. So, appropriate planting can help retain water to stop flooding downstream. So, it's not just about where you develop, it's also about what happens upstream as well. So, all of that needs to be thought about together, and the national development—well, all the development frameworks need to think about that, so the national plan, the regional plans and the local development plans, of course, are very important on that factor as well.

You made an important point in your paper about the maps. Obviously, pictures tell a thousand words, but you say that it would be useful to have a link to be able to see the maps in more granular detail, and certainly that's something that I'm sure people living, say, in Cardiff or Newport would want to see, exactly where these flood plains are—well, where those flood warning areas are—but equally, that is a useful tool for developers when deciding where they want to pitch to develop x or y. It's a great idea, but I just wondered if that granular detail really exists as opposed to somebody who's put in a map. It would be lovely to think it does exist, but that's, I suppose, what neither of us can answer.

Can I just add one more point? Creating flood plains; it's been done in some areas and not others. If we can create flood plains up river, it stops the floods occurring lower down.

That's an important point, Mike, but I think it doesn't apply to coastal areas, like Cardiff and Newport, where we're not going to be able to do very much about the ocean rising. We're simply going to have to mitigate it. I mean, I assume that is correct, Roisin or Neil.

But you can also—sorry, I don't want to interrupt your dialogue here—but you can also create areas on the coast to flood, rather than the areas where you've got housing and people. Sorry, Roisin.

Is that a practical proposition, either of you?

I know it's been used in parts of eastern England, for example, but I'm not sure about the appropriateness of it in Wales, as in whether the coast lends itself to that. I'm not sure. I don't know whether Neil had any thoughts on that.

Certainly, to come in on some of the things that have been discussed, certainly to get down to some degree of granularity of areas at risk of flooding, yes, that data is used in planning decisions. The question about whether or not to build at all in areas at risk of flooding, that policy has some degree of clarity to it, but it's not the kind of policy that really works effectively in a planning system, especially when we get down to individual decisions, because we have so many things we have to balance and compromise when making an individual planning decision. Policies like not building at all in areas of flood risk would be a very extreme and severe form of policy, so it would be a very bold thing to do. But I can't see that kind of policy working within a planning system where the balancing of so many different considerations is taken into account in individual cases. So, yes, I'm not sure that kind of policy would necessarily work in how the planning system currently operates.

Okay. Clearly, one has to plan for existing populations for, say, a new school or something like that, but you could envisage, could you not, that you'd say that you can't do any major development on existing flood plains, say, a new housing development or major capital infrastructure? It would be foolish, wouldn't it, to put anything like that on an existing flood plain?

'Planning Policy Wales' does have very strong policies on that side, and there are mechanisms as well for Welsh Government to call in any housing developments—I think it's over 10, I might be incorrect on that threshold, 10 homes—if the local authority is minded to approve it and it's on a flood plain. So, there are mechanisms already in place with that. And it's about managing whole areas as well, and what impact that particular development would have downstream, if you like, on other areas. Would it displace the flooding to other areas, existing housing areas as well? But it's also the safety of people. It's thinking about their property and the trauma that people go through if they're flooded, but also for themselves, and how they could escape if there was a flooding angle as well. So, we need to think about those factors as well in development.

Okay. Just moving on to the point you made about the whole of the Vale of Glamorgan included within a national growth area, which, clearly—obviously, I'm not sure that anybody is envisaging building on the whole of the Vale of Glamorgan, and, obviously, it completely conflicts with the need for resilience of food networks and other things that need to be localised. So, how do you think the NDF needs to approach that, so it's clear that we want some growth areas, but, clearly, there need to be some places protected for both recreation and agriculture?

I think, certainly in some ways, it's the presentation of the document, and it's trying to stay at a strategic level and not put too many lines on maps, and, of course, as planners, once you've got a line on the map, it goes there. So, it's trying to take—. It's almost like the spatial plan idea of 'Roughly around this area we expect this'. And, of course, you've got Cardiff and Cardiff Airport as well—potential economic growth areas. You've got St Athan airfield, which is a large brownfield site, which could offer good development opportunities—economic development opportunities, et cetera. But, I suppose it's just the presentation in the plan where it says 'growth area' across the Vale of Glamorgan. But it has been acknowledged since that original consultation draft about the agricultural quality of the land there as well. So, I think it's just for users of the document, they need to understand that perhaps they're illustrative maps, in those senses.

Okay. So, basically, people will need to refer to the SDPs and the LDPs in due course for that level of granularity.

Yes, that's a good way of putting it. Yes.

Fine. Okay, thank you. In terms of the point you made about the role of road transport, and, obviously, there's a huge central part of Wales that hasn't got any effective rail network at the moment—the A470 is the obvious north-south alternative. Do you think that there needs to be a little bit more on where road transport is the most practical option? I mean, it would be lovely to see a north-south Wales rail network, but it's not without its challenges.

Yes, absolutely, I'd agree that we need to be careful about road transport, obviously, as it has huge drawbacks, particularly in the climate change discussions and debates. But, I think, when it comes to the links across Wales, then the A470 does play an important role in that, and perhaps needs to be acknowledged until we can get a north-south railway line up through the heart of Wales in that sense. And that partly reinforces the question that Llyr said before about how you strengthen the unity within Wales from that perspective as well, so that's part of it. The A470 is part of our heritage, isn't it? It's part of our being.

Yes, if I could come in to add, I think in relation to—I suppose you need to step back and think to what extent other transport improvements within certain parts of Wales would have greater sustainability outcomes than focusing on that north-south link. So, I suppose it's to look at what level of movement there is and what demand there is to move north-south, and to see whether, actually, in sustainability terms it might be far more advantageous to be investing in, for example, improving the sustainability of people's movement around the region within south-east Wales and continuing to do that rather than focusing on a north-south link. So, I just think, what's the sustainability advantage of investing in that over, maybe, movements within other areas of Wales?

Well, I think that's a very fair point. I just wanted to move on, now, to raise the issue of the national forest policy. Clearly, there's a role for trees to provide more resilience in food supplies, and that could be one of the driving forces around the national forest. But I think what's envisaged is not a national forest in one blob, like the New Forest, but a presumption that we will create a lot more trees for the benefit of the whole of Wales. That's why there's nothing on the map that says, 'National forest here', but would you expect to see more information about the places where you think the national forest should be laid down in the next 20 years? 

Yes, certainly. I think this goes back to the point I made about the alignment of policies in terms of timescale—that this is, obviously, relatively new and being thought through, so there probably isn't much more detail that can be put in. I think you explain it very well about it being about growing more trees rather than a blob, a single area, of trees. So, I suppose in that sense, the development plan does have the policy in there that there will be wider planting of trees across Wales.

There could be the possibility, like you have for the areas that have been marked out or demarcated for windfarm areas—you could potentially find where the best places are, which would be suited the best and where they are needed the most, going back to that flooding issue. Are there areas where it would provide the most benefit to built-up areas of Wales, for example, if you had a forest here or a woodland there?

Okay, so it's something you think we, perhaps, ought to press for in the next iteration: these designated areas, with clear guidance as to why they're the designated areas.

Yes, for the future iterations—yes. 

Before I call you, Neil, we're into the last quarter of an hour, so we're going to have to move on—

Okay, sorry.

—to Neil Hamilton and Joyce, shortly. But, Neil, can you come in—Neil Harris—and answer the question?

Yes, just on the question of the national forest, I had two thoughts to follow on from what Roisin was outlining. When we saw the consultation version, the idea of a national forest was floated, and one of my observations on it was that there is nothing about where, in the NDF, that will start to come to fruition. So, I suppose two comments follow from that: one is that I suspect it would be possible to do something that, maybe, mapped existing forest coverage and where you wanted to complement and supplement that. So, where would be the strategic areas? You don't need to outline it in detail, but where in Wales would we be expecting to make significant contributions towards this national forest?

The second comment comes from, I suppose—this is a development plan, now, and I'm just trying to think what difference that makes to what we might be doing with this national-level document. So, for example, in preparing a local development plan, if something is just an idea, but there is nothing that you can start to put to fruition in that, then you might come up to an inspector looking at a local development plan, and they might say, 'Well, this is premature, there's nothing of substance here to go into the plan. It is, at the minute, simply an ambition and therefore what can go into the plan that gives substance to that?' It's just a point triggered by Roisin saying 'at the next iteration'. I think that was Jenny's comment. I don't know if you mean the 'next iteration' as in going through this Senedd now, or in five years' time might it be realistic to then start putting some flesh on the bones of what this ambition to have a national forest would be in this development plan?

Okay, thank you. Neil Hamilton.

Those were the two comments to follow on from that.

Thank you. Neil Hamilton. You're live, Neil.

Oh, right. Okay, sorry. I'd just like to follow up some points that are in the RTPI's written evidence to us, but the other Neil can come in on this as well. One thing that you say is that we need to clarify the relationship between the national development framework and the strategic development plans, to avoid conflict and confusion in the decision-making process. I wonder if you could flesh that out a bit. You also point out that there's nothing in the NDF at the minute that says it has to be regarded as the highest tier of development plan for developments of national significance, and you also say, quoting them, that the Welsh Government

'will use regional energy planning to identify opportunities for all types of renewable projects'.

Where do you see in this area in particular, renewables and low-carbon energy development, the scope for confusion in the role of SDPs and the NDF? As you pointed out earlier on, we haven't got any SDPs as yet, so perhaps the process of developing this has been upside down; it would be better if we'd started the other way around, but we are where we are. So, where do you think there is scope for confusion and how do we clarify it?

Well, I suppose at the moment there wouldn't be any confusion because, as you say, there aren't any SDPs. It's just when the SDPs are in place, we just need to be clear where the priorities are, so that, for example, the areas that are outlined for renewable onshore wind—they need to be incorporated within SDPs as well, and which is the hierarchy? At the moment, we only have local development plans and, of course, national planning policy, which isn't a development plan in itself, but if a local development plan, for example, is out of date or silent on a particular policy area, 'Planning Policy Wales' takes precedence as well. So, what would be that relationship? And I think it is something to be worked out, or that will be flushed out, when the different tiers of plans are in place. Some of it will be timing, because as plans are developed and then they're being used for a number of years, they will start to—the policies might become out of date. There is a rolling process for reviewing them, of course.

Yes. This is a sort of evolutionary process, in a way, I suppose. At this stage we're just setting some general principles, but in devising the SDPs in due course, they will be devised in the light of the overall guidance that the NDF provides.

Yes.

Neil.

I think there's an interesting point of principle as well. One of my earlier comments was that I think, as a national development framework, this is venturing into SDP territory, with a 20-page statement for each of the regions of Wales. That's quite some detail compared to how earlier versions of the Wales spatial plan, for example, sketched out priorities to look at. For me, with a planning, decision-making hat on, the NDF or 'Future Wales', when it is adopted or approved, will have development plan status, and it will have within it statements and material for the regions. So, what you've got is almost like the front part of an SDP, almost, in a national document that will have development plan status. So, it will be interesting to see how this document is used in decision making in relation to its regional elements—in decision making in local authorities, for example. So, it'd be interesting to get the perspective of local authority decision makers about how they would use this document as a development plan, which is a very different status to what Wales's spatial plan has had. So, again, there's another cautionary note to think, 'Is the NDF going too far into SDP territory?' So, a question about whether it's doing enough or too much on the regional element I think is an area to investigate and explore a bit further.

Thank you very much for that. I'd like to move on to the question of minerals extraction and the policy framework for that. Again, policy 19 sets out that SDPs should provide the framework for mineral extraction and the circular economy and waste treatment and disposal. RTPI, in its evidence to us, says they would argue that longer term planning and guidance are required in relation to minerals and waste, and that should be more prominent in the NDF. Would you like to expand a bit on that?

Yes. Well, at the moment, because of the lack of SDPs, we certainly feel that it could fill that gap at the moment. So that's the idea, and just having that longer term view of mineral and waste plans at a national scale across Wales.

Dr Harris, have you got a view on that?

No, other than to note that things like minerals and waste are those areas of planning activity that have not been neglected, but have been far more difficult to deal with when you have local development plans for very localised areas. So, the SDPs and, potentially, part of the NDF—it's a sector and an area where I think the strategic oversight of those areas—minerals and waste—is, in planning terms, particularly important and it's got something to offer to those sectors, I think.

Thank you. My video keeps going off, so it's not—

[Inaudible.]—Neil, the important bit.

That's not me, it's just happening automatically. It's not that I'm losing interest in what I'm seeing and hearing, but there we are.

And lastly I'd like to explore a bit more what you say about policy 25, regional growth areas, in relation to Brecon and the border. As you say, it's referred to in the document, but there's no explanation of what is considered to be the border. The national park goes all the way up to Hay-on-Wye and probably goes up for about two thirds of the border of Breconshire, at any rate, and about half of Breconshire itself is within the area of the national park. So, development in those areas is going to be much more limited and restricted than it might be elsewhere. And given that we've therefore got a border between England and Wales, and we're talking about here as well, to what extent do you think there is some doubt about what is included within this area of Brecon and the border?

I think there are two issues here. One is what kind of development would go on. Of course, places like Brecon and Hay are very important to Wales, and we mustn't forget them as well, and they will have needs and they play important roles within Wales as well. And there is that interaction across the border with links, but perhaps not from this morning for the moment. So, there is that, 'What kind of regional growth is perceived there?' But the other thought is why is it only there that the border is mentioned? The border isn't mentioned anywhere else in terms of growth terms. So, if we think back at north-east Wales, for example, the cross-border operations there are very important strategically. I mean, I expect the strategic development plans will pick that up, but in terms of the national development framework, I know that there are lots of interactions across that part of the border, for example.

And in north-east Wales, the border is completely imperceptible in urban areas, whereas further down you've got rivers and so on, which are natural barriers and it's more obvious. But that's a fair point, actually, that we don't get mentions of the border elsewhere, and it will be interesting to see how that is dealt with as we do have SDPs. 

We've also got Offa's dyke, but I'll treat that as a comment, Neil, and go straight on to Joyce Watson.

Not all of Offa's dyke is in Wales, of course. [Laughter.]

Joyce.

I want to ask a little bit around the views in RenewableUK Cymru's written evidence that the NDF should include policies relating to all types of DNS, not just renewable energy generation projects—any views you have.

I haven't seen the full detail of their comment, but I went and had a browse in relation to this question around those developments of national significance that are at pre-application stage, et cetera, and the very, very clear majority of them are all energy related. I think there are two or three that might be transport or water related, and those tend to be port-related developments that fall within developments of national significance. So, I think 90 per cent to 95 per cent of developments of national significance that are captured as defined as DNS are energy related. So, I suppose if you're looking for a document that does focus on what is most important nationally and in practical terms, then it is energy-related development that dominates DNS. There may be other aspects around port-related development that are picked up in the national development framework, but I think, if you're covering 90 per cent to 95 per cent of DNSs as being renewable energy, then it suggests that it's an appropriate area of focus for me.

Okay. Thank you.

Yes, I'd echo Neil's comments on that. Welsh Government have put a statement in to say that's the justification for that as well.

Okay, fine.

Thank you very much. Can I say to you it was very helpful, not least because I agreed with almost everything you've said? [Laughter.] But a lot of what you said will come out in our final report, so thank you very much. You'll get a copy of the transcript. Check it. I always do, because I have a tendency to move my head around, and, if you do that, sometimes they miss the odd word. So, be careful of that. But thank you very much, and we're very grateful to you for giving evidence. Thank you.

Can we now go into a short break and come back at 2.55 p.m.? Yes.

Good afternoon again, everybody. Can I welcome Hedd Roberts, who is head of customer solutions, electricity transmission at National Grid? And if I can perhaps ask the first question. The ability of the National Grid to support large-scale renewable energy development: what I've been told—you can tell me if I'm wrong—is that there are places where there used to be generation, such as Carmarthen bay, such as parts of the Vale of Glamorgan, where you're quite happy to have it, and other areas where there's no tradition of large-scale transmission, where you're not. Is what I've been told correct? How able are you to support large-scale renewables?

Good afternoon, everybody, and thank you for the question, Chair. If you will just permit me a moment of just explanation, I'm here today representing National Grid's electricity transmission business. We own and operate the high-voltage transmission system in Wales and England. That's the electricity superhighway, if you like, that connects sources of generation to distribution networks, which are then connected to homes and businesses. In Wales—and this comes to your question, Chair, I think—our electricity network at the moment in Wales, we have a network in north Wales, and we have a network in south Wales, but we don't currently have any transmission network in mid Wales. That's currently serviced by the distribution networks, so that's Western Power Distribution and Scottish Power Energy Networks. I do just need to distinguish between the role of the transmission owner that I work for and the National Grid electricity system operator. They utilise our infrastructure and the infrastructure of the two Scottish transmission companies to balance demand and supply of electricity on a minute-by-minute basis, and they're a legally separate entity of National Grid. So, whilst I'm obviously happy to take all questions this afternoon, if there are any that require a system operator perspective, then I'll make sure that colleagues from the system operator follow up subsequently with the committee.

In answer to the question, I guess it is easier to accommodate new sources of generation where we have existing infrastructure, so that's in both north Wales and south Wales. That's not to say we're not prepared to connect new sources of generation wherever that is seeking connection, but obviously we're acutely aware that network infrastructure has an impact on the communities in which it's housed, and there is, as always, a balance to be struck there between the need to decarbonise and to connect new sources of renewable generation, but also a balance with the cost and also the impact on communities. I think what is really, really important here is—. Where we're looking at infrastructure where there is no infrastructure currently, it is really important that we are able to be as strategic and as co-ordinated as possible. Hopefully, that's clear.

Jenny.

Thank you. You rightly point out in your paper—thank you very much for it—that we are increasingly going to be using electricity to both heat our homes and power our vehicles. Obviously, to do that, within our climate change objectives, we're going to have to massively increase the amount of green energy we are generating. Could you just tell us a bit more about how you envisage us developing the charging networks we're going to have to supply if people are going to shift to electric vehicles, which could happen much quicker than we think? Because it seems to me that there's no point in moving to electric vehicles if we just power these vehicles by the same old dirty energy that we generate. So, if you could say a little bit more on that front, that would be great.

I will try. Thank you for the question. I guess what we're seeing is that, as sectors converge and seek to decarbonise, electrification becomes more essential to, as you mentioned, how we move around, how we heat our homes, how we power industry. And grid infrastructure, therefore, is arguably becoming more essential to our way of life and our future well-being. And, clearly, transmission networks such as the one I work for and distribution networks will play an essential role in supporting charging infrastructure, as you mentioned, for electric vehicles, but also connecting the renewable resources so that they can be charged in as carbon neutral a way as possible.

And, of course, electric vehicles will be charged in many different locations. So, that's both at home and at work, or at ultra-rapid EV charging points along the strategic road network, and all of those things will rely on grid infrastructure. We at National Grid have been working on a solution to try and support the uptake of EVs across the UK, actually, because we see that range anxiety still presents a significant barrier to this. And continuity and consistency across all parts of the UK will really increase consumer confidence in adopting EVs and ensure that it's a universal roll-out and nobody's left behind. 

We're really encouraged by the fact that the UK and the Welsh Governments have recognised the need to intervene here, and we're obviously actively supporting the work that Arup are leading on behalf of the Welsh Government ahead of their transport decarbonisation strategy publication.  

So, to drive from north to south Wales, the most useful route is to go up the A470, which is obviously passing through a huge desert in terms of the grid networks. So, how would we power those—how would you envisage us powering those electric charging vehicles? Is that to be done exclusively by locally generated renewable energy? But where would that then leave us if there was a particularly cold snap or other adverse circumstances?

Yes, and I think the answer here is network infrastructure. Now, whether that is more distribution network infrastructure—. As I mentioned in my intro there, there's already distribution network infrastructure in mid Wales; we don't currently have any transmission infrastructure. But I think the premise of your question is correct. Having an energy network to support charging I think is hugely beneficial. The reliability of our network is 99.9999 per cent, and, as we become more reliant on electricity as we go forward, I think having the network infrastructure in place to provide that reliability will be really important to people's future well-being across Wales. 

Okay, but doesn't it require you to change the way in which you operate, because, at the moment, the renewable energy operator generates electricity and then they have to send it back to the National Grid before it can be distributed to users? Hasn't that got to change, in line with what they do in Germany?

I think that from the point of view of smaller renewable developments and—. Are you talking about micro-grid—

Yes. 

Yes, so, in terms of those sorts of things, as a transmission network operator, clearly, we're used to connecting generally large sources of renewable energy to start with. So, we have done some work more recently to come up with some novel ways of connecting smaller projects to our network, but again that's still 50 MW, that's still large by comparative standards. I think that, clearly, the opportunity here is for some more strategic thinking about network infrastructure in the middle of Wales in particular, and I think that's really important, because there are, clearly, a variety of needs here. It's not just connection of more renewable resources; it's also decarbonisation of heat and transport, as you mention. And what we would be concerned about, I think, is that we end up with a project-by-project, piecemeal development of the grid, which could end up being potentially more expensive and ultimately more disruptive than a more strategic solution. And we've been really encouraging Welsh Government to really lead a conversation here, with all of the necessary stakeholders involved, a really transparent discussion about what the real options here in mid Wales are and what they could bring. 

Okay. Thank you. 

Thank you very much. Moving on to Janet. 

Thank you. Policy 11 on national connectivity includes the commitment to invest in improvements to the strategic road network, including the creation of a network of rapid charging points for electric vehicles. With 990 charging points around Wales, of which only 60 can rapidly charge in under an hour, access remains an obstacle to our large-scale transition to cleaner modes of transport. What changes to the grid need to occur to supplement an increase in rapid charging points, and can you clarify what steps would need to be taken to introduce vehicle-to-grid technology that assists the network at times of peak demand?

Certainly. So, I'll take the first of those questions, and I'll have a go at the second, but it might be something that my system operator colleagues could provide more insight on, actually.

So, if we take the first question of what's required, the work that we have done is to look, obviously, at areas where, largely, with the exception of going through the middle of Wales, the transmission network in the UK does sort of map reasonably well to the strategic road network, and, therefore, it's possible to provide transmission connections or distribution connections at various points on the strategic road network. So, I think we did some work that showed that if you did 50, then the majority of car journeys would be covered—something like 90 per cent of car journeys would be covered. And what's required there is some new infrastructure that steps down transmission voltages to connect to charging infrastructure, such as things that can charge cars, or step down from distribution. So, it's new infrastructure, but it's not a huge amount of infrastructure.

When we get into mid Wales, which was, I think, also the subject of the previous question and the reference to the A470, of course, the issue there is that we don't currently have any transmission infrastructure. So, you'd be looking at connections from distribution networks. Now, I think you could still power rapid charging from a distribution network. I think that where it gets more difficult is where you start to look at ultra-rapid charging and, when you get to that, it's probably helpful to have a stronger grid, and that probably needs some transmission involvement. And, again, I think what's important here is that we develop that in a strategic way; that we're not going kind of piecemeal, development by development. I think my concern there would be that we'd end up with something sub-optimal. 

Your question about vehicle-to-grid technology is about what's required to enable that. As I say, I think it's best if I ask my system operator colleagues to follow up with you on that, but I know that they have been running some trials with some electric vehicle technologies that have the software on board that allows them to communicate with the grid. And, really, as long as we can trial that technology and make sure the system operator can use that information in ways that's helpful, then that's really all that's required. It's just additional software in the cars themselves. 

Thank you very much. You may have to come back to me on the next one, then. Policy 12 on regional connectivity includes the stipulation that active travel must be an essential part of all new developments. It says that planning authorities should ensure that a minimum of 10 per cent of car parking spaces will have electric vehicle charging points in new non-residential developments. In order to surpass this commitment, I wonder if you would outline your thoughts on proposals to convert publicly available lamp posts into electric car charging points, and, again, what impact would that have on the grid? 

So, I'm kind of going a little bit outside my sphere here, I think—

Sorry.

No, of course. So, essentially, I think that is a question that would be better answered by one of the distribution companies that operate in Wales, so either Scottish Power Energy Networks in the north or Western Power Distribution in the south. So, whilst we connect large sources of generation and transport that and connect it to the distribution companies, it's really them that are distributing that to homes and business. I really think they'd give you a better answer to that question.

Okay, we'll follow that up. Thank you very much. And, then, on barriers to capacity, as it stands, do you think the NDF is likely to be effective in supporting enhancement of grid resilience and capacity, because a recent report by the Welsh Government stated that the limited deployment of batteries in Wales to assist with renewable energy generation is partially due to a constraint on the National Grid transmission network in south Wales? This constraint, apparently, will be in place until 2026. Can you outline what conversations you've had with the Welsh Government about the batteries sector and whether you think that this current arrangement is contributing to stalling moves to further generate clean energy via renewable sources?

So, if we take the battery issue, my understanding, which I should confirm with my system operator colleagues, is that that restriction has been recently removed. So, the concern with the transmission network in south Wales was that whilst there was the capacity for the connection of more renewable energy, there was a restriction on the connection of new, traditional sources of generation, which run at times of system peak—so, when it's really cold and dark in the winter. That is the way that the system is planned to ensure that it's secure for those cold winter evenings, and, under those conditions—so, high demand and low wind—there was a restriction such that if you connected new batteries in Wales, you wouldn't be able to export from those batteries at times of winter peak when it's dark and cold because of everything else in south Wales that was operating at that time. Now, I think that restriction has been recently removed, so I don't think that's in place at the moment, but I think the sensible thing for me to do is just to confirm that with my system operator colleagues and ask them to write to the committee to confirm.

Thank you very much. I've got a final question, Chair.

We're going to have to move on because we've only got another 15 minutes or so left.

Just a quick one?

No, sorry, Janet. I'm being unkind, but we're going to have to move on. Joyce Watson.

Good afternoon. I want to explore the capacity and the ability for you, the National Grid, to cope with and assist with the marine development plan in terms of renewables in Wales. 

Yes, sure. So, I guess the first thing to say is that, as the National Grid, we're technology agnostic and committed to working with stakeholders to connect all types of renewable resources to the grid, and do that in a way that has least cost for consumers and least disruption for communities. I think the important thing to stress here is the importance of effective integration of marine and terrestrial planning to the delivery of electricity connection projects, including interconnectors to other countries and perhaps offshore windfarms, because, of course, it's no good having lots of offshore windfarms if we don't have a way of transmitting that energy onshore to the places where it can be used. I think it's also really important that the terrestrial plans make provision for the infrastructure to support the marine developments, obviously, and I think that's particularly important. One point that is particularly important is the need to protect potential cable landfall sites—the sites where cables from interconnectors or offshore windfarms come ashore—because my understanding is that suitable sites for that are limited at the moment. 

Okay, thank you.

And just to further explore it—. I don't know whether you've looked at the marine energy plan in Wales, or whether you haven't, I don't know, because you didn't give us a paper, so we don't know. Are you satisfied at the moment, as things stand—if you've done it, or you can come back to us—that those two parts that you've just described, looking at the terrestrial and the sea, both fit together? Or do you want to come back and give us a note on it?

I think my point is that it is crucial that they fit together. If we get a disjoint there, then I think we'll have a problem. I'd be very, very happy to come back with something more specific, if that would be helpful.

Okay, thank you.

Moving on to Neil Hamilton. We can now hear you.

Good afternoon. You've just said that you're technology agnostics and that you will provide the infrastructure for whatever those who make the ultimate energy policy decide upon. But we all know that there are massive current barriers to increasing grid resilience and capacity in different parts of Wales. Obviously, we've spent a lot of this afternoon pointing out that there is currently no transmission network over a huge area of mid Wales. So, what do you think can be done to remove these barriers? What needs to be done? What isn't in this national development framework that ought to be in there from your perspective on this issue?

I think the first thing I'd stress is the need for co-ordination. I hope I'm not boring the committee by mentioning that, but I think that it's really important that we get co-ordination, such that we're developing the infrastructure in a way that meets all future needs, minimises disruption and minimises cost. I think that is really, really important, and, as I've mentioned, we've been encouraging Welsh Government to—. We think Welsh Government could lead a debate here with the relevant stakeholders, and have that really transparent and really explore what the long-term options are, and get everybody's feedback on that. We think that would be really, really helpful.

Of course, on the issue of new infrastructure in areas like mid Wales that we have kept talking about, obviously we're acutely aware that rural communities have expressed significant concerns about the impact of developments of infrastructure, and it's obviously critical to strike the right balance here between the need to connect the growth of renewable in Wales with the cost to consumers and the meaningful and lasting impacts that there would be on local communities and upon the environment. Under our current licence and regulatory obligations, development of new overhead lines is really seen as the primary option for connections, with undergrounding of assets considered in designated areas such as areas of outstanding natural beauty, and that's of course due to the cost of burying cables being significantly higher than the cost of erecting pylons.

As the committee is aware, these costs are passed on to bill payers, and our regulator Ofgem is understandably keen to ensure that we get the most economic solutions. However, I would say that the commitment to net zero is, clearly, a drive, is clearly going to need significant infrastructure development throughout the UK, and I would say that now is a really good time for Governments and regulators to consider how best to deliver that infrastructure. We're really keen to work with all stakeholders to explore the art of the possible here, and whether that be through engineering or non-engineering solutions. And I've mentioned that I think the Welsh Government have an opportunity here to really lead a national debate. 

Now, that is exactly what isn't happening. I know you don't want to be drawn into the policy framework within which this is set, but given that we're going to, as Jenny has pointed out, need a massive increase in the number of connection points for electric cars and so on in the future, we'll need the transmission network that's capable of driving that. We don't, as yet, have a marine development plan to integrate with the offshore wind source of energy into this NDF land-based planning network. As you already say, there is massive opposition, or even noisy opposition, from people who are living in areas that may not be AONBs, but nevertheless are wonderful countryside, and there's going to have to be a choice between one or the other, in my view, given the energy needs of the future if we move as fast as we're currently doing in the direction of electric-powered transport.

So, inevitably, you're going to have to provide the Government with these options and the relevant costs. As you say, the cost of undergrounding is vastly greater than having terrestrial lines for transmission. So, what discussions are you currently having with the Welsh Government to point out these pretty obvious points, but that you can also give them the cost framework within which they're going to have make these unpalatable choices?

Well, we're really happy to work in partnership with the Welsh Government on this development and help wherever we can, really. We really commend the Welsh Government for setting out a strategic framework in the NDF—I think that's really helpful. What we would also like to see, though, is them really leading this debate, as I mentioned, because I think that could really, really help us to move forward.

Thank you. We must move on to Llyr Gruffydd.

I'm so sorry, I had a problem with the translation there. Could you just repeat the question for me? I'm so sorry.

Yes.

That is absolutely, I think, what's required in Wales. So, just for the benefit of everybody on the committee, the issue in eastern England—the thing, I think, that we've all learned, as we've gone forward, is that the regime overall really incentivised point-by-point development of the grid, so an additional cable for every individual project that came along. And what's become clear is, whilst that may not be the most cost-effective way forward, it's certainly not the way to minimise the impact on the communities of the east coast. And so we really welcome the action that the UK Government have taken in doing this offshore review, because I think that is a real opportunity to do the strategic plan that I've talked about here this afternoon, that I think is required in Wales. Of course, in Wales, the advantage is we haven't already started connecting projects point by point. That adds an additional layer of complexity on the east coast, as we move from point-to-point connections to something more joined up and strategic, and I think that's why now would be great timing for the Welsh Government to lead that discussion on something more strategic.

So, is that not something that we lose because of the disjointed approach to marine planning and terrestrial planning? I mean, should that not be in the NDF?

I mean, where it appears, others are probably better qualified than me to comment. From my point of view, we'd really like to see that happening, because I think that has the potential to reduce the cost of renewable integration and improved resilience, and also to minimise the impact on communities.

Thank you, Chair.

Thank you very much. Can I thank you very much, Hedd, for coming along and giving your evidence today? It's been very helpful on our journey along the NDF in Wales, so thank you very much. You'll get a copy of the transcript. I'll say to you what I say to everybody: check it—if you're anything like me and you move your head around, sometimes the odd word gets missed. Thank you very much.

It's been really enjoyable. Thank you very much, everybody.

Can we aim to start back at 3.30 p.m.? Yes.

We should now be live. Can I welcome Rhys Wyn Jones, director of RenewableUK Cymru, and Eleri Davies, head of consents UK, onshore wind of RWE Renewables? Welcome. Croeso to both of you. If I can ask the first question: can Mr Jones expand on RenewableUK's written evidence that its members are extremely concerned about constraints on the grid connecting new large-scale renewable energy projects and how these are considered?

Good afternoon. Can you hear me?

Yes.

Okay, great. Well, first of all, just to say 'thank you very much' for the opportunity to speak with the committee this afternoon. We're very grateful for that. Indeed, we're very grateful for the continuing engagement that we've had with Welsh Government and with Welsh Government officials throughout the course of the development of 'Future Wales' through its two iterations. So, we welcome that and we're very grateful for that.

In terms of the concerns that we express regarding the grid, I think it's basically such a long-standing problem that has put significant constraints on the potential for development of renewable energy projects at scale, with a number of developers, a number of RenewableUK Cymru members, expressing their concerns. The appetite to develop projects is getting more pent up. I suppose there's more interest with the climate emergency, the net-zero commitments that Welsh Government and other Governments around the world, indeed, have made, not to mention the falling costs of renewable energy, and also the availability of revenue support, again, in the case of onshore wind, which potentially makes projects a lot more economically viable, save for the issue that, in some cases in Wales, the projects aren't able to come forward, for a variety of reasons, but one of the major ones is the cost of grid connection and the complexity of grid connection that make what might be viable projects cost-prohibitive.

So, I think the reason that there is such a level of concern is exactly that. It's twofold. One is it's such a long-standing problem, and I think the fear is that we end up back in the situation that we had in 2011, when there was a potential solution, and I'm talking now in terms of mid Wales, that didn't materialise. It was very, very sensitive politically, and the timing was dreadful, and at the time, with a bit more foresight and maybe if we knew then what we know now in terms of climate emergency and the need to move to net zero, we might not be having the conversation that we're having now. So, I think the view of members is that they absolutely want to work in partnership with the key stakeholders to make this happen, but we can't afford for grid capacity issues to again stall development. According to RenewableUK modelling, there's a substantial discrepancy, if you look ahead—this is, again, in relation to onshore wind—for the decade ahead, between the low case and the optimum case for the potential cumulative contribution that onshore wind could make. I think one of the key drivers behind the optimum or the low-case scenarios materialising would be the availability of grid. So, it's front and centre of our concerns, albeit we do appreciate that the 'Future Wales' document is not exclusively there to deal with consenting grid—it's there to deal with other matters. But it is part and parcel of the planning issues that 'Future Wales' deals with, and indeed does touch on.

Neil Hamilton's got further questions on the grid. Neil. It must be unmuted.

Sorry about that. I should have got used to it by now, shouldn't I? The question that is immediately prompted by your opening salvo there, which of course describes exactly what the current situation is, is: what more should be done by Welsh Government towards improving grid resilience and capacity in Wales? We've got this ridiculous situation at the minute where wind turbines are being erected in places like Bryn Blaen near Llangurig, where they can't connect to the grid, and probably the same is true of Hendy as well, near Llandrindod. And at the minute there is no infrastructure in mid Wales—nothing between Pembroke and Trawsfynydd, for example—and here we've got grandiose commitments made by Government, but we haven't got the infrastructure whereby they can fulfil the commitments that they've made. So, given that there's supposedly a climate emergency, there seems to me an even bigger emergency in terms of policy development, and if they make policy commitments that are going to come to fruition in 10 years' time, say, not 15 years' time, then we really need to get on with setting out what the transmission and distribution network those commitments require looks like. There's got to be, obviously, a national debate on this, and this national development framework has got a hole in the middle of it in this respect. So, what do you think the Welsh Government should do in order to fill that void?

Eleri, do you want to go first?

Yes, I can go first. So, thank you for that. As you say, it's not just that projects haven't been able to connect already, it's also all that untapped onshore wind potential in mid Wales that's currently not being progressed, largely because of a lack of existing grid capacity. Where we are getting offered grid connection agreements, the connection dates are well into the 2030s, which is a long way away, especially when you're looking at a 2050 net-zero target. So, due to delays caused by planning—the planning process is lengthy, unfortunately, but it is what it is, and also Ofgem's funding approval process takes time—we need to start thinking about the 2020s now. We need to think about what we will need in 2030, 2040, to get to net zero, and the other thing to note is that demand for grid will increase regardless of renewables, notably to meet the significantly increased demand that we need to get heat and transport decarbonised. So, it's all very well declaring a climate emergency and committing to net zero—I think the Welsh Government needs to put some sort of plan in place, a national plan, to map out that journey from now to 2050, and a key part of that plan will be to look at the grid, and that's gas and electricity grid.

I do agree that the NDF maybe isn't the place for all of this. The NDF deals with the consenting element of grid, but there's a larger strategic issue there as well. We know from the mid Wales experience that grid is a very emotive issue, and, as National Grid suggested in the previous evidence session, we need to collaborate, and the Welsh Government needs to lead that national conversation to improve the understanding about grid within communities. Because it's not just a lack of grid now—it's also because new grid will be required to decarbonise Wales in the future, and for those people to charge their electric vehicles and use their heat pumps.

We urgently require a coherent and costed plan for the upgrading of the grid infrastructure. Usefully, I think, in 'Future Wales', from a 'Future Wales' perspective, in terms of what we're discussing today, it's really good that there's a recognition of the grid infrastructure under policy 17 now. That's definitely a step in the right direction, but I think we also need a policy presumption in favour of new and upgraded grid infrastructure, and the weight that's being afforded to net-zero targets for renewable energy generating station projects also needs to apply to the grid. And, yes, ultimately, I think it is just a case of everyone working together—Welsh Government working with UK Government, Western Power, SP Energy Networks, National Grid and Ofgem, just to prioritise work on facilitating the anticipatory grid upgrades that we will need for our onshore and offshore projects in the future. 

Okay. Do you want to add anything? 

Do you want me to come in on that as well?

It's up to you if you want to add anything, or if you just say, 'I agree with Eleri', we'll move on.

Eleri has articulated it very clearly. There are just two other things I'd mention very quickly. I completely endorse the need for working on a collaborative basis. I think there is a—. I have absolutely no doubt the Welsh Government completely understands the issues around grid; I think there's a slight nuance in terms of taking more active leadership in terms of making that case in conjunction with the industry and other stakeholders for that to happen. And I do understand also the difficulty in trying to project what actual demand will be. Now we know, if we're going to electrify vast swathes of society, we're going to need a hell of a lot more power to do that. But we're trying to say, 'Well, exactly how much do we need?', and there are a couple of ongoing pieces of work being done by the likes of Natural Resources Wales and Arup for onshore, and the offshore renewable energy catapult for offshore, to try and quantify that, and, indeed, by local energy planning as well to quantify it. So, that work is important and, in some ways, it feels like a transgressive act to suggest that we just need to get on now, because if we don't start now then we will really hamstring ourselves throughout the decade and the decades to come, and we'll miss out on the development and we'll miss out on the economic opportunities as well that this will afford. 

Okay. Thank you. On to Llyr Gruffydd. 

If we alternate between who responds first, it will probably work quicker, if that's okay with Eleri and you. 

Yes, that's absolutely fine; I just wanted to be sure. 

I think—. Yes, potentially, it does help in that there might inevitably be a clustering of projects owing to the available resource and conditions locally, which would make some areas more suitable than others, for obvious reasons, for development. But, as the Member has just identified, the drawback with the pre-assessed areas was the fact that the theoretical availability, a developable project at scale, just didn't seem to be something that our members felt was significant, once you'd applied the usual criteria that one might apply. So, in that regard, we didn't feel that they merited retention. However, we did very much welcome first of all the engagement that we had during the iterative process, and the end results that we now have, whereby the traffic-light approach that we did have has been dispensed with, and also a criteria-based policy that is a lot clearer than in the first iteration, which gives developers a certain amount of clarity and confidence that they can bring projects forward.  

From an industry perspective as well, I think we've discussed at length what the problem with the pre-assessed areas is, and now they've got this policy presumption, where they're capable of accommodating development in an acceptable way, but only in a landscape perspective, which ignores the multitude of other considerations that feed into finding these sites, so things like noise and shadow flicker, access, wind speed et cetera, and we've quoted before the 5 per cent figure.

And going back to your question about grid, as a developer, and probably like a lot of other developers out there, we have a mix of projects that are inside a pre-assessed area and others that are outside, and obviously the policy—policy 17 and 18—allows for both, but with a bit more support, I suppose, for the areas within. But it doesn't really change our approach as a developer. We will progress projects within and projects outside in the same way. But, coming back to the grid, it doesn't really help with planning for strategic grid infrastructure if a lot of your projects are going to be coming forward outside of those areas. So, I think, again, it comes back to that collaboration with industry, and obviously there is a point where you go public with your projects. There are some projects out there that might not be in the public domain yet, but there is plenty of information there on where projects could come forward. If everyone works together and industry shares those plans when they can, then, that, I think, will be more important to developing that strategic grid than the lines on this map. 

Thank you very much. I just want to explore how we're going to move forward at pace on this, because Eleri's already said the planning process is painfully slow. How do you think the NDF is likely to interact with SDPs in terms of getting moving on this one? 

On this point, I'm slightly concerned by some wording in the supporting text to policies 17 and 18. So, I think it's on page 99 that it states:

'The Welsh Government will use regional energy planning to identify opportunities for all types of renewable projects.'

And that suggests, to me, that they're going to ask local authorities to come together and put more lines on maps, or, as the experience usually is in these cases, not put any lines on maps and say that none of their area is suitable for renewables. I just personally don't think this is appropriate for the NDF or 'Future Wales', as it's now going to be called, which is the main policy against which developments of national significance will be determined. So, those 10 MW plus projects should not be subject to some further tweaking at the regional and local levels.

I think if Welsh Government are going to advocate that approach, they should make sure that that's limited to sub-DNS-scale projects—so, the community-scale projects below 10 MW. My concern is that, despite the requirement to be in conformity with 'Future Wales', because it's allowing local authorities to look into this in more detail, that, obviously, delays things. There's a process for adopting these SDPs and these LDPs. It also runs the risk that the ambitions of 'Future Wales', especially for onshore wind, will be diluted and, potentially, undermined by these lower-tier plans, and that has been absolutely our experience with the Welsh Government's renewable energy toolkit, which the local planning authorities across Wales have used to make sure that there are no suitable areas for onshore wind, and very few for solar as well. So, I think they're my key concerns with the regional planning. I think, for onshore wind above 10 MW or renewables above 10 MW, 'Future Wales' addresses that. Just let's not water it down with lower-tier plans.

Okay. So you think that that just needs belt-and-brace clarity.

Yes, I think so.

Okay. Rhys. 

I don't have any other comments to add to that. I think Eleri's captured it perfectly well. I don't have anything to add to what Eleri said, actually.

Okay. So, you both think that 'Future Wales' is clear enough that we must develop much more renewable energy if we're going to meet our target of 70 per cent renewable by 2030, which isn't very far off, in terms of contracting and all the rest of it. Are you satisfied that 'Future Wales' really ties down SDPs and LDPs to deliver on this, given that we all need to decarbonise everything we do?

Yes, I think the case for renewable energy is clear. And because projects of the scale the company I work for is working on—the over-10 MW projects—have been taken out of that local planning system and given to the Welsh Ministers to approve directly, I think we just want to work with 'Future Wales' now. We don't want any meddling further down, because that will, inevitably, cause delays and more risk to projects.

Nevertheless, if we want people to lend their landscape to generating wind energy, we want those local communities to also benefit properly from that, so that needs to be tied into LDPs and SDPs, does it not?

Well, actually, in terms of local ownership and community benefit, they're not material planning considerations—so, a legal or policy test for what can be taken into consideration. But, absolutely, we've worked with the Welsh Government on their local ownership policy as an industry, and we're progressing schemes, for example Alwen Forest up in Denbighshire and Conwy, where we've gone into partnership with Community Energy Wales to offer up to 15 per cent of that project as a shared ownership opportunity. So, we are working with Welsh Government to try and deliver those local benefits as well. But I think the other thing to note is it's not just planning policy that's going to get the projects away—it's probably more likely the grid cost, the grid connection dates and the available capacity. That's the key driver, I think.

Okay. Well, the main problem there is that National Grid seem to think it's somebody else's responsibility—namely the Welsh Government's—when they are the monopoly provider. So, that is a cause for considerable concern, and one that is not entirely in our hands.

I recognise that concern. However, I think there's been a distinct shift, which has probably been precipitated by the climate emergency and the net-zero target to which we are now legally bound, which has caused National Grid and certainly our members and other stakeholders to pause and think about how are we going to actually get this done. We need to collaborate first, to make the needs case, and we need to understand what the need is, and then we need to work out a coherent, costed plan for all of Wales from which Wales benefits, at the same time as Wales potentially being a net exporter of power, to enable us to deliver these targets as quickly as we can. And we obviously do not have much time. I don't think I would recognise the fact that National Grid thinks it's somebody else's problem. My view on that is that there's a definite appetite to collaborate, to work strategically and collegiately to move this issue of grid, which has been a chronic issue for as long as I can remember, and to resolve it properly.

Well, it's good to know. Thank you.

Thank you. Joyce Watson.

I just want to ask about the interaction between the NDF and the marine plan that would permit renewables and the views that you have on whether that is adequate, whether it fits together and whether it meets needs. 

Thank you for that question. Well, the proof is going to be in the pudding, to an extent. I think there's definitely an acknowledgment within 'Future Wales' that the two need to coexist. I don't think it's the case that there's a plan for the land and a plan for the sea and never the twain shall meet, but obviously, a lot of how this works depends on what actually happens. 'Future Wales' and the marine plan work together to provide a framework for the management of change around the coast; that's what it says in 'Future Wales', so we have to take that at face value. It goes on to say that co-ordination between marine and terrestrial planning is important to sustain and facilitate the development of port, harbour and marina businesses and associated enterprises et cetera. So, it's clearly something that's being borne in mind.

Thinking of grid once again, there is a clear overlap as offshore wind assets and other marine energy assets need to land somewhere, and I know that National Grid is actually consulting on that at the moment. But I think as well as the integration of 'Future Wales' in the marine plan, there's probably some more consideration around the potential introduction of statutory timescales for consenting marine licence applications, because in Wales you need a marine licence application and you also need a development consent order when you're doing large-scale offshore renewables.

Having such a statutory timescale for marine licensing applications could have the effect of making Welsh projects more competitive by reducing consenting timescales, and, of course, all of these things are taking place in a very, very competitive environment, so if projects don't go forward in Wales and we want to have the benefit, they might go forward somewhere else. So, anything that we can do to facilitate that would be welcome. But coming back to the question, time will tell, but I do, at least, have comfort in the fact that 'Future Wales' recognises that there's an interaction between the two environments. 

I'd echo Rhys's comments there. The key thing for us is that there is that explicit support for the onshore infrastructure. In terms of the marine licence, if Welsh Government need some assistance with what could work better, then my offshore colleagues working on the Awel y Môr scheme in north Wales would be more than happy to help with that.

Okay. Thank you. Moving on to Janet Finch-Saunders.

Thank you, and good afternoon. In written evidence, RWE state that they were pleased to find the inclusion of a paragraph on co-ordination between marine and terrestrial planning, and a specific reference to energy generation. Could you both outline your thoughts on whether that paragraph does enough to co-ordinate between the two plans? And I wonder whether, in conversations that you may have had with the Welsh Government, you have received any commitment that marine renewables will be a central part of any green recovery. 

In terms of the policy, 'Future Wales' is a land-use plan and then there are separate plans for marine. The thing that's complicated in Wales, as you know, is the devolution of powers. The large-scale offshore windfarms—350 MW plus—are determined in Westminster, so there's separate policy that comes out of the department over there, which does complicate matters. But in terms of what 'Future Wales' can do to actually join the marine and the onshore elements, then I think it goes as far as it needs to, because there will be infrastructure onshore that needs to be consented, and it might be consented at local authority level, it might be Welsh Ministers level, or it might be in Westminster. So, this plan I think probably does what it needs to do in terms of making that link. In terms of discussions with the Welsh Government, I understand that they are fully supportive of marine renewables as well as the onshore element. So apart from that, I don't think I have anything to add.

I can certainly echo the fact that, as far as I'm aware, the Welsh Government is hugely committed to marine renewables in all their guises. There's a lot of work ongoing to support the development of marine technologies down in south-west Wales. We've recently seen the application for lease for Wales's first potential floating offshore wind project, which is really, really encouraging, and I know Welsh Government has been actively investigating ways in which the supply chain can really benefit from development of these emerging technologies around the Welsh coastline, as well as established technologies, of course. I think the continued challenge for technologies that are more emergent is obviously the availability of an incremental revenue support framework, which is something that the UK Government provides, which enables them to make that journey along the cost curve towards achieving proper commercialisation, and, in the much longer run, cost competitiveness with other more established technologies. So, I do think there's a role for all marine renewable energy, and it is reassuring to see a lot of attention on those emerging technologies, as well as the established technologies as well.

Thank you. Can I ask you both to expand on your written contributions, which highlight that the basis for cumulative impact was only mentioned in the context of landscape and visual impact, and not in other topics such as nature conservation, cultural heritage and transport? Particularly with regard to nature conservation, your written evidence did raise concerns that it will have a different threshold from all other criteria. Can you explain how you think the criterion of no acceptable adverse impact would be consistent with other criteria and whether you think this change would still give enough protection to our wildlife and, indeed, our biodiversity?

Shall I take that question, Rhys, as a planner?

Be my guest.

Just as an overarching point, the points I'm making here are technicalities. They're not fundamental issues, but I think they do need to be addressed in the final version of 'Future Wales'. I make the point as a planner who has to grapple with policy wording on a very regular basis, and I would maybe suggest that the policy planners in the Welsh Government discuss the wording in detail with their decisions branch, who are also involved with applying policy in practice quite regularly.

I'll take them in the order I put them in my response, if that's okay. So I'll start with the 'no unacceptable adverse impact' criterion, against criterion 3. So, as currently worded—'no adverse impact'—that policy could preclude any renewable energy development, and it should be amended just to be consistent with planning practice and the remainder of the policy as well. And the failure to include the word 'unacceptable' means that the policy test doesn't have any scope in there for the decision maker to take a balanced view of the adverse and beneficial impacts of the project.

So, if you think about it, every form of development, so a housing estate on a field or a new road or a renewable energy project, they all involve some form of development, which will involve, usually, removing habitats or moving them around or whatever. So, if the policy is to refuse everything that has an adverse impact, however small, because there's no sort of threshold here, it's just no adverse impact, no projects would get consented, and I just don't think that is the intention of this policy. But, as currently worded, that's how it could be interpreted. So, that's my point on an acceptable adverse impact.

The point on cumulative—usually, in environmental impact—

You can say—let me interrupt—you can say that a lot better than me. [Laughter.]

I have to say it quite a lot in my world. So, in terms of the environmental impact assessment process, which we have to go through for all of our projects—a very rigorous assessment of the impacts of our projects on the natural environment, including nature conservation interests—what we have to do is assess the project on an individual basis, and then we also have to assess it on a cumulative basis. That means taking into consideration the impacts of our projects alongside the impacts of another project. So, for example, if you had a local highway and you had two windfarms being constructed at the same time, the cumulative impact is the impact of both on that local highway network if they were being built at the same time. Again, this is a technicality; it's usually addressed in planning policy and local development plans, et cetera, by having a catch-all cumulative criterion right at the end, which just says, 'You shall assess x, y and z and then the cumulative impact of all of the above.' So, that's how it's dealt with usually, but it's just unusual that in this document it only refers to cumulative in the context of landscape and visual, but it also applies to noise and cultural heritage, nature conservation, et cetera.

Thank you.

Thank you. I think it was very interesting what you said about cumulative, because—nothing to do with this—but two areas that we deal with, one that we deal with as a committee, and one we don't. One is the opening of chicken farms—large-scale chicken farms—and the other is the development of houses in multiple occupation, and the cumulative effect is not taken into account in planning law whatsoever, and each case is—I think the term is in planning—'dealt with on its merit'. 

I think maybe because all of the windfarm projects that we deal with have to go through that environmental impact assessment process, where cumulative is written into the legislation, that might be where it's come from, but it's what we do, and we assess cumulative for all topics, not just landscape and visual.

Okay, thank you. Many of us wish that that was in all planning. Moving on to Joyce.

Sorry, Chair. Can you move on and come back to me? I've got a problem with connection just at the moment from where I was reading, so I'm trying to reconnect that.

I'll go on to Jenny, and come back to you.

Thank you. I just wanted to ask you about your comment, Eleri, that there's insufficient detail, or it's unclear how the safeguarding of locations for the national forest will work in practice and interact with development proposals. I wonder if you could just tell us what it is that's absent that you're worried about, given that you already are developing windfarms in forests.

So, firstly, to note that I totally agree that planting more trees is absolutely part of that nature-based solution to achieving net zero. In principle, I fully support that element of the plan. But, as currently drafted, there's no way of knowing what form that national forest will take—will it be one large forest; lots of multiple smaller forests—how suitable land will be selected, and where it will be located. On top of that, it's not clear how the safeguarding of these locations for the national forest will work in practice, and how this allocation will interact with development proposals. So, our experience shows from Brechfa Forest West and Clocaenog that it's perfectly possible to have onshore windfarms and renewable projects co-existing with forestry, and they co-exist quite comfortably. So, I think it's not necessarily an objection to the policy, it's just until more detail becomes available, we just don't know whether the national forest policy will be a block on renewables or an initiative that can co-exist alongside renewables. Obviously, we would prefer the latter. We just need more detail, I think.

Okay. We can agree on that. I definitely don't think it's going to be one blob on the map; it's going to have a much more strategic approach to trees in all their wonder. Clearly, more work needs to be done on that, but do you need to have that at this stage?

I don't think we need to have it at this stage. I guess the concern might be that all the blobs are in the best places for windfarms, so it's just a case of being kept informed, maybe, as those plans are worked up.

Okay, thank you. Rhys, you don't have any concerns on that front.

No, we didn't make any specific comments, so nothing further to add to Eleri's comments there. Thank you.

Back to you, Joyce.

Thank you. My iPad crashed just as I was about to try to read from it. Anyway, I want to ask a little about the habitats regulations assessment. Eleri, you've made comments about it, and you said it should be amended to align with the current legislation and technical advice note 5, which is about nature conservation and planning. Would you like to expand on why you've made that statement?

Firstly, I'm going to caveat this with 'I'm not a lawyer', but I have discussed this with our internal counsel, who has raised these points. I'll just run through these briefly, but again I think it's a point for policy planners to pick up with decision-branch planners at the Welsh Government, just to make sure that they've got the wording correct, really, because it is important.

Basically, the language being proposed for the habitats regulations assessment is imprecise. 'Future Wales' refers to assessments being required when a project 'has the potential to impact', so that's the potential to impact on a protected site, and then it suggests that no adverse effect on designated site features is a reason for refusal. These two are very nuanced, but they are legally incorrect. So, the wording in both the habitats directive and regulation 105 of the habitats regulations, which are both referred to in 'Future Wales' in that section on habitats regulations, what they say is that for HRA screening the legal test is a real risk that it is 

'likely to have a significant effect'.

So, the threshold is very low. Assessments are required if there's going to be a likely significant effect on a nature conservation interest, but it's not as low as what's being proposed in 'Future Wales'. And then, for HRA decision making, the legal test is no adverse impact on site integrity. That means that, much like the policy wording on the 'unacceptable' point I raised earlier, there can be some adverse impact on a specific feature or habitat, even if it is a priority one, provided, for example, that such an impact is very small and temporary in nature, and the feature was capable of reasonable and quick recoverability in conjunction with other considerations such as conservation objectives. So, they're technicalities rather than fundamental issues, and I assume that the legislation would override the plan in any case, but I still think it's important to get the wording right in that plan.

Okay, I thank you for that, and they've sounded like technicalities when you were reading them out to me, but they could be serious technicalities in some cases, so we will probe the Minister—or our lawyers, before we probe the Minister—on seeing where those differences might lie. In my view, from what you've just read out, and what I've read that you've sent to us, they could have quite serious—how can I put it—adverse reactions, depending which side of the reading you happen to be on. You've been down this road before, I've been down this road before, so we need some clarity.

Thank you.

Finally, from me, what do you think of the proposals for monitoring and reviewing? Obviously, after they've been monitored and reviewed, some things are going to change. Are you happy with the direction that we may be going in?

Broadly, yes. To reiterate, Renewable UK Cymru welcomes this document—the scope and the ambition are great. And we also, again to reiterate, appreciate the extensive engagement that's taken place. We welcome the fact that it's an evolving plan; it's going to need to be, because things are moving so fast. So, it could be that 'Future Wales' benefits from being reviewed more regularly than every five years, although I appreciate that that is a resource-intensive exercise. And also, any monitoring of the progress of the plan is only, really, as good as the engagement that the Welsh Government succeeds in encouraging with it. And certainly, in terms of plan development, the engagement levels, I think, have been excellent, so that augurs well.

Further to that, I know that our members' values and the things that we spend a lot of time talking about are really closely aligned to the desired outcomes in 'Future Wales'. And it might come as a surprise to Members that I've probably spent more time, in the last six months, talking with my members about how our projects can offer the maximum achievable benefit to Wales than I have, necessarily, just talking about—[Inaudible.]—megawatts or decarbonisation, or anything like that. 

I think the thing that is a big concern, which is something that we've already talked about, is that the challenges that our members have with some of what's in the 'Future Wales' document are very, very, very long-standing issues. You know, we can't wait five years to find out whether or not the plan is delivering what it said it would do, or whether or not places are necessarily better, which is, of course, an extremely subjective judgment.

Members have got tens of millions of pounds of investment decisions in the offing, potentially, and what they need, at a time when certainty is a commodity that's in very short supply, is certainty. But, I think, when you bring it right back to what this document is designed to do as a planning framework, I think it's good, my members are going to work with it and they will do everything that they can to make it a success, but we need to move at pace on sorting out the grid.

Eleri.

Yes. In terms of the review process, I appreciate that there will be a lot of evidence to be taken into consideration and indicators and stuff. The one thing that surprised me was the seven questions set in 'Future Wales' at page 59. I just find them a bit vague, really. Theoretically, you could answer 'yes' to all of the questions, having actually done very little in reality. So, taking examples from my line of work, 'Has Future Wales supported decarbonisation?' is one of those questions, and I think you could argue that one renewable energy project or a district heating system could be classed as supporting decarbonisation. But that's not much progress in five years, is it? So, I think the Welsh Government route map to 2050 needs to set some more, kind of, 'target' targets, as it were, so something concrete that you can measure progress against. And then, rather than simply, 'Has Future Wales supported the delivery of renewable energy?' why not link that back to the targets from 2017? So, the 70 per cent of electricity consumption from renewable energy and the 1 GW of locally owned. I don't quite understand why those questions are so vague and why they're not being linked to something that we can measure against.

I was looking at the 'Energy Generation in Wales' report for 2019 that came out last month. It's quite interesting to see the renewable energy capacity installation rates coming down from 2015 and it would really be quite nice to look, in five years, and see that it's coming back up again, and anything that 'Future Wales' can do to assist that would be welcomed, really. I appreciate that there are a multitude of reasons why that's happened, but I think anything that Welsh Government can do to kick start that consenting process is definitely a step in the right direction.

Anything to add? No. Can I ask you a question basically around RWE? We've talked about looking at development in mid Wales, how about further developments around urban areas? I know that you've done a lot around Swansea—in fact, I've visited the site just outside Pontarddulais—but we've got lots of mountains, I can guarantee we'll have lots of wind, so what about developing more in urban areas? And, if you do that, there's an opportunity not to have to go through the National Grid but have local generation with that, outside your—

Well, we will happily look across Wales for opportunities to develop onshore wind projects. But, as I mentioned previously, there are a lot of considerations that go into finding a site and, in urban areas, the key issue, or the key constraint, as it were, would be residential dwellings. So, you need a separation from those residential dwellings to protect their amenity: noise, residential visual amenity and shadow flicker. So, that's the reason why we can't go too close to urban areas, but we do consider projects in all locations.

Sorry. Can I just be boring and talk about my area? You've got Mynydd Gelliwastad, which goes all the way, eventually, over to Ammanford; it's the equivalent of what you've got at Pontarddulais, where you've got a site and somebody else has got a site the other side. But there's nothing on Mynydd Gelliwastad; there are quite a lot of these mountains between Carmarthenshire and Swansea. There are also mountains dotted around, quite a lot, or hills, and my colleague Huw Irranca-Davies will tell you about the number of mountains they've got up in the Llynfi et cetera. You've got valleys; you've got to have mountains. I'm just really trying to tease out what progress you're making, therefore. Are you still looking at some of these where you've got people who need electricity close to where you've got an opportunity, and these are well away from where people are living?

Yes. We are certainly looking at opportunities in south Wales and north Wales, and, as you say, the mid Wales stuff is a little bit further behind because of the grid issues. But we absolutely look at everything. It's not something that I'm working on directly at the moment, but I can ask my colleagues in the site-finding team to give you some information on why those projects—. And it's not just RWE either; there are other developers out there who might be—. We might think a site has got potential but it's already been signed up to another developer. So, absolutely, we look at everything that's suitable and we have to take a view, and we have to factor in all those issues to decide whether it's a project that has potential before we take it forward.

Will you write to us on that?

Yes, I can. I'll make a note of that. Is it just the Swansea area you're interested in or just generally?

In and near Wales. I talk about Swansea because I know about Swansea, but I'm sure that—. I know about the Llynfi valley and I know the Afan valley. Every time you've got a valley, you've got a mountain, by definition, and the use of these mountains—. You've done quite a lot; you've got that very big site on the Bridgend county and Rhondda Cynon Taf border. You've got a huge site there, haven't you?

That's Vattenfall's site—Pen y Cymoedd. That's the biggest onshore wind site in Wales, yes.

But that's not an abnormal place in Wales to have valleys with hills above them.

Yes, and, absolutely, those sites are usually closer to the grid network as well. But, often, there is very limited capacity, even on the south Wales and north Wales grid; it's not just an issue in mid Wales. I've got an example from a recent project that we applied for a grid connection on, and it took us three rounds of applications to actually get a grid connection agreement that we could sign up to, and that was because we were in a queue with other developers ahead of us, getting that capacity ahead of us. So, there's a lot of competition in the area, and probably across Wales as well, for that capacity. And, as you say, there is that capacity in south Wales that is closer to the populations, but, yes, sometimes it's not enough for what we're trying to connect.

I may be wrong—and if I am, please tell me—but I think it's easier to get connection where there used to be power stations, be that Tir John in Swansea or Carmarthen Bay, or the recently decommissioned coal-fired one in the Vale of Glamorgan. Am I right in that?

Yes, I guess it depends. That's probably a question for the National Grid or the distribution network operators. You'd think that once somebody decommissions, that grid capacity then becomes available, and often I think it does, but sometimes it's decommissioned and taken down, or the developer doesn't want to lose that grid capacity because they want to do something else with the site at a later date. So, logically it makes sense, and I think that probably is the case in many areas, yes.

Well, I can tell you Tir John's available, because it's returning to a waste-disposal site.

Okay, can I thank you both very much? Sorry to hog the last five minutes or so just talking about Swansea, but I think that that's an example of this. If somebody was sitting here from Aberafan or Neath or other parts of industrial south Wales, they'd be saying exactly the same thing, but they'd be highlighting their own areas. So, I thank you both very much. I found it very helpful and I'm sure the committee has as well. You'll get a transcript. I would urge you to check it, though I don't think you'll have the problem that I do, because I tend to move around when I'm talking and sometimes it doesn't catch some of the words because I've projected my voice in the wrong direction. So, thank you very much, and we're very grateful for your giving your evidence. Thank you.

Thanks for the opportunity.

Thank you. Diolch yn fawr.

Before we go into private session, I move we note the following papers: correspondence from the Chair to the Minister for Environment, Energy and Rural Affairs on the Welsh Government's draft budget; correspondence from the Chair of the Legislation, Justice and Constitution Committee to the Llywydd and Chair of Business Committee—scrutiny of COVID-19 regulations; correspondence from the Minister for Environment, Energy and Rural Affairs on the Agriculture (Model Clauses for Fixed Equipment) (Wales) Regulations 2019 following correspondence from the Tenant Farmers Association; and correspondence from the Chair of the Petitions Committee on air quality. Can I move that we accept those?

And can I move a motion under Standing Order 17.42(vi) and (ix) to resolve to exclude the public from the remainder of the meeting?