New underground-first policy for 11-132 kV electricity lines in Wales

The Welsh Government is committed to ensure we have clean, secure and affordable electricity to power our homes, businesses and transport now and for future generations. We need to increase the amount of low carbon energy generated in Wales, replacing fossil fuels with an electricity system that is resilient and supports our ambitions for decarbonisation, economic prosperity, energy security and community wellbeing. We need to do this whilst appropriately balancing environmental, community and economic interests.

The electricity grid is a critical enabler of the Welsh Government's ambitions. As Wales transitions to a low-carbon future, investment in electricity network infrastructure will be essential to meet growing demand for electricity, to connect new sources of renewable energy generation, strengthen the resilience of the grid for the changing climate, and support sustainable growth across all parts of Wales. 

To deliver the Welsh Government's commitment to an undergrounding-first approach for new electricity circuits, ending the use of large steel lattice pylons for such circuits, the Welsh Government is developing a new planning policy approach for devolved electricity circuits in Wales. This consultation seeks views on the detailed design, implementation and operation of that policy and relates to electricity circuits (lines and cables) operating at voltages between 11 kilovolt (kV) and 132kV that are associated with devolved electricity generation projects onshore. 

This consultation does not consider the development or consenting of electricity generation projects, energy storage facilities, transmission infrastructure above 132kV, or other associated energy infrastructure. Decisions on these are the responsibility of the UK Government.

The electricity network

The electricity network in Great Britain is a coordinated system that moves electricity around the country. The network is split into: 

• The transmission network, which typically moves high-voltage (usually 400kV) electricity across long distances in Great Britain into high voltage substations nearer to consumers. This network is sometimes referred to as the ‘motorway’ of our grid system. 
• The distribution network, which, in Wales, moves electricity at 132kV and below from high voltage substations into lower voltage networks and substations, and then into homes and businesses. This network is likened to the ‘A and B roads’ of the grid system.

Electricity network circuits are made up of overhead lines mounted on wooden poles or pylons, underground cables, subsea cables, and substations that enable connections and contain control, balancing and monitoring equipment.

Some useful resources for further insight into the infrastructure components for the grid network can be found on the following websites:

• The National Energy System Operator – Energy 101
• National Grid – energy explained

The electricity network was developed to connect a relatively small number of large power stations to homes and businesses. As the energy system changes, new and reinforced network infrastructure is required to connect energy generation in different locations, often in more rural and coastal areas where renewable energy resources are greatest. Investment in the network is needed to improve resilience to the impacts of a changing climate, including more frequent extreme weather events, and to ensure a secure and reliable supply of electricity. 

At the same time, the transition to a low-carbon economy is expected to significantly increase demand for electricity through the electrification of transport, heating and industry. Expanding and strengthening the electricity network is therefore essential to enable decarbonisation, support economic growth and maintain a resilient energy system for Wales.

Work to develop and upgrade the electricity network comes with costs. These costs are ultimately met through utility bills. Electricity network charging is regulated by the Office of Gas and Electricity Markets (Ofgem), which has a role under the Electricity Act 1989 to ensure network development provides the best value to bill payers (through reviewing the business plans of network operators and approving payments to them for work carried out), and in protecting consumers from unnecessarily high bills (through price controls and the energy price cap). Paying for network repairs, reinforcement and expansion is complex. Further information can be found here:

• Energy Networks Association – Energy Networks Explained
• Nesta – What’s in an Energy Bill
• Ofgem – About us, Ofgem – What we Regulate
• National Energy System Operator – Electricity Transmission Network Explainer
• National Energy System Operator – Electricity markets explained

Legislative framework for electricity circuits with a nominal voltage up to 132kV

To operate and install devolved onshore electricity circuits in Wales, Network Operators require the following:

• A licence to supply electricity, issued by Ofgem, acting on behalf of the Gas and Electricity Market Authority as “the Authority” under section 6 the Electricity Act 1989, and either
• Planning permission from the local planning authority or Welsh Ministers under the Town and Country Planning Act 1990, or 
• An Infrastructure Consent Order from the Welsh Ministers under the Infrastructure (Wales) Act 2024.

When determining an application to install a devolved onshore electricity circuit in Wales, decisions makers must have regard to Future Wales: The National Plan and Planning Policy Wales, and in respect of an Infrastructure Consent Order, decisions must be made in accordance with any Infrastructure Policy Statement published under section 127 of the Infrastructure (Wales) Act 2024. 

Developing new policy for 11-132kV electricity circuits

A report by the Independent Advisory Group (IAG) on the Future Electricity Grid for Wales emphasised that electricity network infrastructure can have significant effects on landscapes, biodiversity, cultural heritage and communities, and that these effects should be carefully considered through planning policy and transparent decision-making. 

The Welsh Government wants to ensure that electricity infrastructure is delivered in a way that minimises adverse impacts and secures the best long-term outcomes for the people of Wales. The Welsh Government is therefore seeking to introduce a new policy relating to electricity circuits that form part of the distribution network (132kV and below) in Wales and invites evidence to inform the development of the policy.

The current policy for devolved electricity circuits is set out in Planning Policy Wales (PPW). Section 5.7.9 states a preference for new electricity lines to be underground where possible, and that a balanced view must be taken against costs which could render otherwise acceptable projects unviable.

Why undergrounding?

Undergrounding electricity circuits can reduce the visual impact of electricity infrastructure, helping to protect landscapes and local amenity. Undergrounding makes the infrastructure less vulnerable to some types of severe weather and can reduce impacts on birds and other wildlife. However, undergrounding is generally considered more expensive to install and maintain and can create construction impacts during installation. Developing policy about whether electricity circuits should be underground or overhead therefore needs to balance environmental, social, technical and economic considerations.

The new Welsh Government is delivering on the following Plaid Cymru manifesto commitment:

“Immediately prohibit the use of large steel lattice pylons for new 11-132 kV lines in Wales, with a clear presumption in favour of undergrounding and overhead alternatives permitted only where installation is via low wooden poles or equivalent, less intrusive infrastructure”.

Through this consultation we are seeking views on the detailed design, implementation and operation of a new ‘undergrounding-first’ policy to deliver on this commitment, having regard to the need to balance environmental, social, technical and economic considerations. We intend for the new policy to be supported by clear planning tests setting out the expectation for undergrounding as the default and considering circumstances in which overhead lines might be acceptable in policy terms. 

We will expect all organisations developing network connections within the scope of this policy to consider each planning test thoroughly and provide evidence in support of applications to install a new devolved electricity circuit, to justify where an overhead line would be required. The new policy will replace the current policy. 

We present the proposed planning policy in the following thematic sections: 

1. Aspiration for a strategically planned electricity network
2. New planning tests
3. Policy hierarchy for devolved electricity circuit infrastructure 
4. Policy implementation

As noted in the introduction, the electricity grid in Great Britain is a coordinated system. The Welsh Government wishes to see greater transparency and a strategic approach to the development of future grid proposals, including those planned to support our energy needs in Wales. 

Responses to the IAG highlighted concerns that energy infrastructure is being developed without a clear strategic framework. As Great Britain moves towards a more coordinated approach to energy system planning, policy should reflect this shift. The Welsh Government adopted a planned approach to energy in Future Wales: The National Plan and has developed regional energy strategies and Local Area Energy Plans. The National Energy System Operator (NESO) is now developing the Strategic Spatial Energy Plan and Regional Energy Strategic Plans, which will guide future energy and network development across Great Britain.

The Welsh Government considers that a strategically planned network is necessary so that new infrastructure minimises overall energy system costs, and wider negative impacts on Wales. 

When submitting applications, the Welsh Government expects network operators to demonstrate how their electricity circuit proposals align with the strategic planning of the electricity network across Great Britain, including Wales. We intend to set out our expectations in guidance to support the new proposed policy. Through the guidance we will also set out our expectation for applications to evidence how route selection has taken account of opportunities to align with existing or planned infrastructure where appropriate, helping to minimise additional environmental and community impacts while supporting the delivery of Wales’s future energy system. This information will enable decision makers to understand how proposals contribute towards a coordinated and efficient future network for Wales. 

Questions

Question 1: 

The Welsh Government proposes to establish undergrounding as the default position for new 11-132kV electricity lines in Wales. Will the proposed policy approach be appropriate for delivering this objective? Please explain your answer.

Question 2: 

The resilience of the electricity network is important for ensuring secure and reliable electricity supply to society and for supporting adaptation to climate change. What are your views on the potential impacts of undergrounding electricity circuits on network resilience in Wales? Please consider both benefits and challenges when providing your answer.

Question 3: 

Do you support the aspiration for a strategically coordinated approach to network development, and ensuring new proposals deliver maximum possible value to communities and the Welsh energy system?

• What do you believe are the benefits?
• What do you believe are the drawbacks?

Question 4: 

Do you agree that integrating proposed infrastructure with existing proposals or plans is a priority? What could be the impacts from this?

Question 5: 

In your opinion, which body would be able to provide advice to network operators and decision makers on whether individual electricity circuit proposals align to strategic plans? 

In planning policy, planning tests can provide a transparent framework for assessing proposals against clearly defined criteria. They help ensure that planning and consenting decisions are evidence-based, consistent and proportionate, requiring applicants to demonstrate how proposals align with policy objectives while balancing environmental, social and other considerations. 

The IAG highlighted concerns that the practical application of existing grid policy is not always visible to communities or decision makers. To address this issue, the IAG recommended measures to improve transparency in how proposals are assessed, with clearer evidence and justification helping to demonstrate how environmental, technical, economic and strategic considerations have been balanced within decisions.

Planning tests can improve public confidence in decision-making by making it clear how impacts, and alternatives have been assessed.

Planning test proposals

The proposed planning tests are intended to support implementation of the undergrounding-first policy by identifying and evidencing the exceptional circumstances in which an overhead solution may be justified. The tests are:

• Environmental test: requiring evidence that undergrounding would cause more impact to the environment than an overhead line.
• Technical test: requiring evidence that undergrounding is not physically possible, for example, for reasons of geology or geography, or unacceptable engineering risk.
• Economic test: requiring evidence that undergrounding would make a project proposal financially unviable. 

Questions

Question 6: 

Do you agree that the proposed planning tests are appropriate, proportionate and workable mechanisms for implementing the undergrounding-first policy and ensuring transparency in decision-making?

Question 7: 

What other practical tests that can be supported by evidence could be considered when deciding whether there is a sufficient justification for permitting a new overhead electricity circuit as an exception? Please provide reasons, evidence, or examples to support your answer.

Question 8: 

The Welsh Government is responsible for planning policy in relation to 132kV electricity lines that are connected to a devolved generating station in Wales but is not responsible for setting electricity prices. How do you think a greater use of underground electricity circuits, instead of overhead circuits, could affect electricity costs for households and businesses in Wales? Please explain your answer and provide evidence where possible.

The proposed policy change will make clear that undergrounding should be considered as the first design choice for new electricity circuits up to a nominal voltage of 132kV. 

To support consistent and transparent decision making, we intend to introduce a policy hierarchy of infrastructure options to support the policy, with underground circuits considered first, followed by wooden poles and then other infrastructure solutions where these are demonstrated to be the most appropriate option and less intrusive. This policy hierarchy is intended to guide project design from the earliest stages, helping to minimise impacts while recognising that site-specific environmental, technical and economic factors may influence the final infrastructure solution.

Questions

Question 9: 

What are your views on a proposed hierarchy for electricity circuit options, with undergrounding as the first option and then other options to only be permitted by exception, having exhausted the previous hierarchy option(s)?

Question 10: 

Do you agree that, where overhead electricity circuits are permitted, they should only be supported by wooden poles, or equivalent infrastructure that minimises visual impacts (excluding steel lattice pylons)? If not, please explain your answer.

Question 11: 

Electricity circuits can be laid underground using a range of methods, including trenching, cable ploughing and horizontal directional drilling. What do you think are the main benefits, limitations and costs of the different methods used to lay electricity circuits underground? Please provide any evidence, examples or experience that support your answer.

Question 12: 

Placing electricity circuits underground can have both positive and negative effects on the environment. What do you think are the main environmental advantages and disadvantages of placing electricity circuits underground? Please explain your answer and provide any evidence or examples if possible.

Question 13: 

How important is the speed of installation of electricity circuits to you? Please explain why.

Question 14: 

Do you have any evidence, research, data or case studies about the use of wooden poles, or other less visually intrusive types of overhead line infrastructure? In particular, we would welcome information on:

• how suitable they are for different locations and purposes
• their effects on the environment and landscape
• impacts on local communities
• maintenance and operational requirements
• reliability and resilience
• costs

Please provide any relevant evidence, examples or links to published reports.

The Welsh Government intends to issue an Interim Ministerial Planning Policy Statement (IMPPS) in the first instance to implement the change in policy. The IMPPS would be incorporated into an update to PPW when it is next revised. The Welsh Ministers' powers under section 127 of the Infrastructure (Wales) Act (2024) would also be used to introduce an Infrastructure Policy Statement (IPS) that sets out the policy in respect of Significant Infrastructure Projects. Taking this approach would ensure the policy has effect in those decisions made both by Welsh Ministers and local planning authorities. The policy would not apply to electricity circuits that fall under permitted development rights or those consented by the UK Government. However, we would expect the UK Government to consider Welsh policies in respect of decisions it makes on projects in Wales.

Evidence gathered through this consultation will inform the final policy approach and an assessment of any potential impacts the policy might have, for example, on the environment or people of Wales, including impacts to the Welsh language. From an initial assessment of the impact the policy might have on higher density Welsh language populations, any impact is expected to be limited, as the policy applies only to those developing and deciding on new 132kV electricity circuits in Wales. However, we welcome your views on this and on our approach to implementing the policy to ensure it is a consideration in decision making.  

Questions

Question 15: 

To implement the policy and ensure it is a consideration in decision making, the Welsh Government intends to use the Welsh Ministers’ powers under the Infrastructure (Wales) Act 2024 to introduce an Infrastructure Policy Statement. PPW will also be updated when it is next revised. Do you agree with the proposed approach of using an Infrastructure Policy Statement and update to PPW to implement the new policy? If not, please explain your answer.

Question 16: 

Do you think the proposed policy for underground electricity circuits could have any positive or negative impacts on people with protected characteristics or on particular groups of people? Please explain your views and provide any evidence or examples where possible.

This could include impacts on people of different ages, disabilities, genders, gender identities, ethnicities, religions or beliefs, sexual orientations, people who are pregnant or on maternity leave, or people who are married or in a civil partnership.

Question 17: 

In your opinion what would be the impact of the new policy on the Welsh language, particularly in areas with high populations of Welsh language speakers? 

Question 18: 

What, in your opinion, would be the likely effects of the proposed policy changes and associated planning tests on the Welsh language?  We are particularly interested in any likely effects on opportunities to use the Welsh language and on not treating the Welsh language less favourably than English. 

• Do you think that there are opportunities to promote any positive effects?
• Do you think that there are opportunities to mitigate any adverse effects?  

Question 19: 

In your opinion, could the proposed policy changes and associated planning tests be formulated or changed to:

• have positive effects or more positive effects on using the Welsh language and on not treating the Welsh language less favourably than English; or 
• mitigate any negative effects on using the Welsh language and on not treating the Welsh language less favourably than English?

Question 20: 

We have asked some specific questions. If you have any other relevant evidence that you believe would assist the Welsh Government in developing future policy on electricity networks in Wales, please provide this.

Question 1: 

The Welsh Government proposes to establish undergrounding as the default position for new 11-132kV electricity lines in Wales. Will the proposed policy approach be appropriate for delivering this objective? Please explain your answer.

Question 2: 

The resilience of the electricity network is important for ensuring secure and reliable electricity supply to society and for supporting adaptation to climate change. What are your views on the potential impacts of undergrounding electricity circuits on network resilience in Wales? Please consider both benefits and challenges when providing your answer.

Question 3: 

Do you support the aspiration for a strategically coordinated approach to network development, and ensuring new proposals deliver maximum possible value to communities and the Welsh energy system?

• What do you believe are the benefits?
• What do you believe are the drawbacks?

Question 4: 

Do you agree that integrating proposed infrastructure with existing proposals or plans is a priority? What could be the impacts from this?

Question 5: 

In your opinion, which body would be able to provide advice to network operators and decision makers on whether individual electricity circuit proposals align to strategic plans? 

Question 6: 

Do you agree that the proposed planning tests are appropriate, proportionate and workable mechanisms for implementing the undergrounding-first policy and ensuring transparency in decision-making?

Question 7: 

What other practical tests which can be supported by evidence could be considered when deciding whether there is a sufficient justification for permitting a new overhead electricity circuit as an exception? Please provide reasons, evidence, or examples to support your answer.

Question 8: 

The Welsh Government is responsible for planning policy in relation to 132kV electricity lines that are connected to a devolved generating station in Wales but is not responsible for setting electricity prices. How do you think a greater use of underground electricity circuits, instead of overhead circuits, could affect electricity costs for households and businesses in Wales? Please explain your answer and provide evidence where possible.

Question 9: 

What are your views on a proposed hierarchy for electricity circuit options, with undergrounding as the first option and then other options to only be permitted by exception, having exhausted the previous hierarchy option(s)?

Question 10: 

Do you agree that, where overhead electricity circuits are permitted, they should only be supported by wooden poles or equivalent infrastructure that minimises visual impacts (excluding steel lattice pylons)? If not, please explain your answer.

Question 11: 

Electricity circuits can be laid underground using a range of methods, including trenching, cable ploughing and horizontal directional drilling. What do you think are the main benefits, limitations and costs of the different methods used to lay electricity circuits underground? Please provide any evidence, examples or experience that support your answer.

Question 12: 

Placing electricity circuits underground can have both positive and negative effects on the environment. What do you think are the main environmental advantages and disadvantages of placing electricity circuits underground? Please explain your answer and provide any evidence or examples if possible.

Question 13: 

How important is the speed of installation of electricity circuits to you? Please explain why.

Question 14: 

Do you have any evidence, research, data or case studies about the use of wooden poles, monopoles (wood or steel) or other less visually intrusive types of overhead line infrastructure? In particular, we would welcome information on:

• how suitable they are for different locations and purposes;
• their effects on the environment and landscape;
• impacts on local communities;
• maintenance and operational requirements;
• reliability and resilience; and
• costs.

Please provide any relevant evidence, examples or links to published reports.

Question 15: 

To implement the policy and ensure it is a consideration in decision making, the Welsh Government intends to use the Welsh Ministers’ powers under the Infrastructure (Wales) Act 2024 to introduce an Infrastructure Policy Statement. PPW will also be updated when it is next revised. Do you agree with the proposed approach of using an Infrastructure Policy Statement and update to PPW to implement the new policy? If not, please explain your answer.

Question 16: 

Do you think the proposed policy for underground electricity circuits could have any positive or negative impacts on people with protected characteristics or on particular groups of people? Please explain your views and provide any evidence or examples where possible.

This could include impacts on people of different ages, disabilities, genders, gender identities, ethnicities, religions or beliefs, sexual orientations, people who are pregnant or on maternity leave, or people who are married or in a civil partnership.

Question 17: 

In your opinion what would be the impact of the new policy on the Welsh language, particularly in areas with high populations of Welsh language speakers? 

Question 18: 

What, in your opinion, would be the likely effects of the proposed policy changes and associated planning tests on the Welsh language?  We are particularly interested in any likely effects on opportunities to use the Welsh language and on not treating the Welsh language less favourably than English. 

• Do you think that there are opportunities to promote any positive effects?
• Do you think that there are opportunities to mitigate any adverse effects?  

Question 19: 

In your opinion, could the proposed policy changes and associated planning tests be formulated or changed to:

• have positive effects or more positive effects on using the Welsh language and on not treating the Welsh language less favourably than English; or 
• mitigate any negative effects on using the Welsh language and on not treating the Welsh language less favourably than English?

Question 20: 

We have asked some specific questions. If you have any other relevant evidence that you believe would assist the Welsh Government in developing future policy on electricity networks in Wales, please provide this.

Submit your comments by 15 January 2027, in any of the following ways:

• complete our online form
• download, complete our response form and email: YmatebionYnni-EnergyResponses@gov.wales 
• download, complete our response form and post to:

Consultation on new underground-first policy for 11-132 kV electricity lines in Wales
Energy Division
Welsh Government
Cathays Park
Cardiff
CF10 3NQ

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