On 16 May, RTPI Cymru submitted a response to the Welsh Government consultation on Hydrogen Policy. Read the response below.
We note the preferred hydrogen policy for Wales supports the development of emerging hydrogen infrastructure & applications. As part of the preferred policy, Welsh Government will encourage the targeted production and use of hydrogen where it contributes to decarbonisation, it meets the requirements of the UK Low Carbon Hydrogen Standard and developers can provide evidence of contributing to a just-transition for those communities and industries affected by the deployment of hydrogen. We also note that the responsibility for demonstrating that hydrogen is the right choice, that it contributes to long-term decarbonisation, and builds a stronger, greener economy, would rest with the developer.
Given the prolonged period of cuts within the public sector we have seen Local Planning Authority (LPA) services diminished across the whole of Wales. This has impacted on staff numbers, skills, and delivery, leading to the stretching of planning officer capacity and a decrease in specialist skills in key areas. These wider, associated issues are fundamental to the operation and delivery of the planning service and the effective implementation of policy and plans.
It is vital that consideration is given at this early stage to the upskilling of LPAs on hydrogen related development, to ensure they can determine applications and hold meaningful discussions with stakeholders in a timely and effective manner. For example, while calculations on emissions, including the UK Low Carbon Hydrogen Standard do accompany some energy proposals currently, we believe there is a need for further training in this area for LPAs. This will mean evidence can be fully scrutinised by decision makers and public sector planners feel equipped to assess this information. Alternatively, given the likely sporadic nature of such applications, lessons could be learned from the Scottish Government and Scottish National Planning Improvement Service approach to hydrogen. In Scotland, a centralised specialist hub was proposed to provide the expertise needed by planning authorities. Scottish Government has identified awareness of, and expertise in planning for hydrogen as low amongst Scottish planning authorities. Funding has been made available from Scottish Government net zero to pilot the hub concept through focusing on hydrogen. A new National Planning Improvement Hub | Improvement Service
Further guidance in the form of a Technical Advice Note (TAN) would also be welcomed. A TAN could outline how proposals are expected to evidence a ‘just transition’ along with how decision makers are expected to assess evidence.
We are aware there are hydrogen proposals emerging across Wales and thought needs to be given to how Welsh Government can address the planning guidance gap quickly and sufficiently, supporting planners in the decision-making process.
By introducing this policy through a Written Ministerial Statement (WMS), there is some risk that it could in conflict with the wording set out in Planning Policy Wales, despite being aligned on overarching principles. Careful consideration should be given to the wording of the WMS to ensure that policy conflicts are avoided during implementation. There is a need to be aware that whilst the policy will be a driver for industry and developers to explore new opportunities in Wales by providing policy support, it is likely that industry, developers and those submitting schemes are the most aware of the technical aspects of the production and associated issues. Therefore, there is a need for the wording of the WMS to target the public, Planning and Environment Decisions Wales (PEDW) and Local Planning Authorities as those who will have less experience of dealing with these technologies. For decision makers, there will need to be clarity in the short term, given the absence of any update to Planning Policy Wales or the introduction of a relevant TAN.
In accordance with the five ways of working, it is important that the WMS is drafted in liaison with industry experts, LPAs and other key bodies such as NRW and PEDW to avoid the unintended consequences that have been experienced in some other recent policy changes.
While hydrogen is not mentioned by the consultation. It is naturally occurring hydrogen from deposits. As far as we are aware, the exploration of these resources hasn’t begun in Wales and isn’t a current priority within the UK, however, there is potential for this to change quickly. There is a need for this form of hydrogen to be given consideration, along with others. It is vital that training and support for hydrogen is forward thinking in terms of the speed at which technology is developing.
