|Andrew R.T. Davies AC|
|Jenny Rathbone AC|
|Joyce Watson AC|
|Llyr Gruffydd AC|
|Mike Hedges AC||Cadeirydd y Pwyllgor|
|Eleri Davies||Innogy Renewables UK|
|Innogy Renewables UK|
|James Byrne||Ymddiriedolaethau Natur Cymru|
|Wildlife Trusts Wales|
|Jerry Langford||Coed Cadw|
|Coed Cadw Woodland Trust|
|Mike Wilkinson||RSPB Cymru|
|Rhys Wyn Jones||Renewable UK Cymru|
|Renewable UK Cymru|
|Andrea Storer||Dirprwy Glerc|
|Graeme Purves||Cynghorwr Arbenigol|
|Marc Wyn Jones||Clerc|
|1. Cyflwyniad, ymddiheuriadau, dirprwyon a datgan buddiannau||1. Introductions, apologies, substitutions and declarations of interest|
|2. Fframwaith Datblygu Cenedlaethol Drafft 2020-2040 - sesiwn dystiolaeth 5 - Ynni||2. Draft National Development Framework 2020-2040 - evidence session 5 - Energy|
|3. Fframwaith Datblygu Cenedlaethol Drafft 2020-2040 - sesiwn dystiolaeth 6 - Bioamrywiaeth||3. Draft National Development Framework 2020-2040 - evidence session 6 - Biodiversity|
|4. Cynnig o dan Reol Sefydlog 17.42(vi) i benderfynu gwahardd y cyhoedd o weddill y cyfarfod||4. Motion under Standing Order 17.42 (vi) to resolve to exclude the public for the remainder of the meeting|
Cofnodir y trafodion yn yr iaith y llefarwyd hwy ynddi yn y pwyllgor. Yn ogystal, cynhwysir trawsgrifiad o’r cyfieithu ar y pryd. Lle mae cyfranwyr wedi darparu cywiriadau i’w tystiolaeth, nodir y rheini yn y trawsgrifiad.
The proceedings are reported in the language in which they were spoken in the committee. In addition, a transcription of the simultaneous interpretation is included. Where contributors have supplied corrections to their evidence, these are noted in the transcript.
Dechreuodd y cyfarfod am 09:01.
The meeting began at 09:01.
Bore da. Good morning, everybody. I welcome Members to the meeting. We've had apologies from Neil Hamilton and we're expecting Andrew Davies to be joining us later this morning. Have Members any interests to declare? I take that to be a 'no'.
Can I, first of all, welcome Will Ryan, director, planning, of Savills, Rhys Wyn Jones, head of RenewableUK Cymru, and Eleri Davies, head of consents UK, Innogy Renewables UK Ltd, to the meeting to help inform our consideration of the Welsh Government's draft national development framework. So, croeso—welcome. Are you okay for us to go straight to questions? And, if I can start: what are your views on the evidence we've received previously that the draft NDF is a missed opportunity in terms of decarbonisation and tackling climate change?
Do you want me to start?
Ah, right. Okay. Great. So, yes, in terms of our evidence, I think the UK Committee on Climate Change has said that, to achieve net zero you need a fourfold increase in renewable electricity deployment, and, in this context, business as usual is not enough and I think the NDF needs to probably be a bit more ambitious in its policies towards renewable energy. I think, in that context, the NDF itself has a lot of very positive words about renewables, and that's excellent. However, our concern as Innogy, as a company, is that the Arup report that underpins the priority areas identified in the NDF is fundamentally flawed, and that's where our concerns come from, that those areas identified are, on the whole, not the best areas for onshore wind deployment.
Yes. I'd echo Eleri's comments that the goalposts have shifted—that's clear. We need to move faster than we have done. I think the NDF does contain a lot of positive intent in terms of renewables, but, in light of the pace that we now need to move at, RenewableUK Cymru feels that the priority areas—and I'm not bearing in mind any particular targets for renewable energy at the moment, but just the design of those priority areas does not enable the industry to move at the sort of pace and scale that I think Welsh Government wants to move at, and it's lacking in that regard. And the solution, as we see it, would be the consideration of a criteria-based policy, instead of the priority areas that have been proposed.
From Savills' point of view, and, on a more general energy note, and decarbonisation of it, I think the NDF just doesn't quite bring through some of the policies and intentions of the 'A Low Carbon Wales' document that was issued in March of this year. There are some really good examples in there of policies—there are some case studies—that are really positive in driving forward the decarbonisation agenda, and I think the NDF doesn't quite know whether it's a land use document or a general strategic framework document in trying to drive that forward.
You've already pre-empted what I was going to ask in terms of saying that there's a fundamental flaw in the document with regard to their priority areas. Do you want to expand? 'Fundamentally flawed' is the language that's being used, but exactly what do you mean by 'fundamentally flawed'?
Yes, I'll do that. So, I think the first—one of the first—issues with it is it's tried to conflate solar and wind, and by doing that—. The constraints for solar and wind are very different. So, the constraints that an onshore wind developer would apply are very different to what solar would apply and, therefore, the areas that you identify as suitable for those two technologies are potentially very different. That's not to say there wouldn't be some areas that are suitable for both, but generally, as a starting point, they should have assessed onshore wind and solar separately.
And, because they've done it as a combined assessment, they've applied some inappropriate constraints to onshore wind that you wouldn't apply to solar and vice versa. So, for example, on onshore wind, Arup have included, as a variable constraint, woodland, open access and agricultural land classification 1 and 2, but there's absolutely no reason why onshore wind is not compatible with those land uses. We've got examples, as Innogy, as a company. Brechfa Forest West, Clocaenog and Mynydd y Gwair are all—well, two of them are on forestry land and three of them are on open access land. So, there's absolutely no reason why those uses aren't compatible. So, that's one of the reasons.
They've also, in the Arup assessment, failed—. From an onshore wind perspective, when you start to develop a windfarm, one of the first things you do is put a separation distance between properties and your site, and that's to mitigate potential impacts such as noise, shadow flicker and residential and visual amenity. Arup's study didn't do that, and, as soon as you apply that to the priority areas, it wipes 90 per cent of it out. That leaves you with about 10 per cent that is theoretically developable, but a lot of that is already taken up by existing windfarms, and actually the maximum available land is about 5 per cent of those priority areas. But, realistically, the level that will come forward is much lower, once you've been through an environmental impact assessment process.
And that comes on to the next issue with the Arup study, which is that they've applied a subjective high-level landscape and visual intervisibilty study, which has—it's quite a crude instrument at that high level. But they've applied it and ruled out certain areas that we, as an industry, think could potentially be suitable, and also ruled in areas that are actually unsuitable, because there are some areas within the priority areas that are European designated sites, such as special areas of conservation, which—we'd never promote a windfarm in that situation. So, yes, they're the highlights from the Arup report, which will come through in our evidence. Sorry, I've rambled on a bit, there. Sorry, your go.
Eleri, clearly, is a developer and has that level of detail and expertise. If I'm looking at the bigger, general picture and comparing the priority areas to the previous framework, where we had strategic search areas, I think it's fair to say that the industry has been quite insistent that it didn't want to go down the route of drawing lines on maps, because there were several shortcomings to that.
I think, if you look at the SSA framework, I think the target was around about 1.6 GW in total. Whereas, in fact, around 700 MW was delivered. So, it's fallen far, far short of what was hoped, and there are a number of reasons for that. And I think, of that 700 that was developed, around about 130 of that was outside the SSA areas, and another 40 per cent of that total amount delivered is Pen y Cymoedd. So, when you strip that out, that leaves very, very little progress, based on the lines-on-map approach. And we seem to be going down the same route again, albeit the priority areas do have things to commend them over the SSA regime, because it envisages the development of larger projects. But just the general principle of the lines-on-map approach is seen to have not worked previously, and I wouldn't want us to be going down that route again.
If I may just add to that, it's the absence of assessment of the grid infrastructure as well throughout the document. And I know it's a difficult subject and it's proven difficult in recent years in Wales, but clearly it's something that needs to be addressed if we are to decarbonise both on a macro and a micro scale. And the lead-in times of projects of that nature, of grid upgrades, are significant as well and take a considerable time period out of the NDF in terms of delivering decarbonised energy.
I've got other people who want to come in. Do you want to finish off this, Joyce, first?
Just picking up on what Eleri was saying, are there other areas you'd want to share with the Government or the committee that you think ought to be areas that we target? And, for Mr Rhys Jones—Wyn Jones; I beg your pardon—what are the criteria that we should then be using if we're going to chuck out the lines-on-maps approach?
From our point of view, I don't think we'd want to put any sites forward, because it doesn't really—[Inaudible.]—that in a long-term planning perspective. But Arup's study started with what we call fixed constraints; I think that is a good starting point. It gives you an indication of where the protected assets that you need to protect—you've got your national parks, your AONBs, your special areas of conservation, SSSIs, world heritage sites. All those items are easy to map, and basically a criteria-based approach would give a presumption in favour of anything outside of those fixed constraints, subject to a detailed environmental impact assessment and, obviously, a process of planning, and a balancing exercise by the decision maker, which, in the case of the developments of national significance projects, would be the Welsh Ministers. So, that's the kind of criteria-based policy that we are familiar with in other parts of the UK and it works.
So, would you like to see a map that was the reverse of what we've got, which is areas where it's not going to be possible to develop renewable energy, because they're SSIs or AONBs or they're so built on that it would be impossible?
I don't think it's necessary to map them. They're all available on Government websites. I don't think it's necessary to have a map that says, 'This is where the protected areas are', because, if you map them on a map of Wales, it actually covers a substantial area anyway, so they're all protected from development as it is. I don't see any need to do anything more than just list them as constraints that you wouldn't go to.
I think it's policy 10 that is the policy that lends the presumption in favour of landscape change, and I think one of the things that we'd suggest could be that that should also reference potential environmental benefits that large scale projects can deliver, such as contributing to resilient ecological habitats, restoring degraded peatlands, and restoring semi-natural grasslands. Just to give you a flavour of the specific criteria that we'd envisage, some of the things that would figure within a criteria based approach would be a demonstration that any particular proposal is acceptable in social, economic and environmental terms, and consider some of the following: landscape and visual impacts, biodiversity, ecological and nature conservation impacts, residential amenity, traffic and transport, historic environment and so on. We will publish a full list of the criteria that we think should be contained as part of our full response to the NDF consultation, and apologies that we haven't—our UK company hasn't—given you that in full for this committee session, but we will do that as soon as we're able to. Well, we've only got 24 hours—we will do that today. [Laughter.]
Yes, I'm interested in understanding why the Government is pursuing a spatial approach, given the underwhelming targets achieved in the strategic search areas and TAN 8. I mean, have they given you a rationale as to why they are sticking to that sort of spatial approach and not moving to a different kind of model?
To be honest, no they haven't. As an industry, and as RUK Cymru—both under Rhys's management and previously—when we've had meetings with Welsh Government officials and Arup, their advisers, we've consistently said throughout the process of drafting this NDF that our preference is for a criteria-based approach and, 'Please drop the maps, because they haven't delivered what you expected them to, and you might repeat those same mistakes.'
Unfortunately, the priority area maps are actually less suitable for wind than the SSAs in TAN 8, when you look at the hard constraints I was talking about. I haven't been given a reason as to why they are pursuing this, other than the fact that they are maybe calling it a spatial plan and they want to have something spatial in there.
With spaces on it, yes. [Laughter.] It is quite concerning, I think, that those who are charged with delivering this aren't at all happy with the proposed approach. Not that you should dictate in any way, but clearly the evidence that you've given in your paper outlining the fact that it's 10 per cent—or 5 per cent if you include areas that have already been developed—is quite concerning.
Call me a cynic, but I find it difficult to believe that a Government, in proposing something that they have deliberated long and hard over—albeit in draft form—are proposing something that has quite clearly received such a strong pushback from the sector, with evidence to underline that it isn't going to work. Are the Government serious about developing onshore wind, do you think? Or, is this just a wheeze and a way of maybe making sure that some of it doesn't happen?
My view on that is, were I to be designing a proposal whose intention was to bring forward the sorts of scale projects in wind and solar at a pace that we need to see, then this certainly wouldn't be that approach. I think that it undermines the rhetoric, and, in that regard, I don't think that it's a serious proposal as it stands.
That said, the industry has never said, and will never say, that it proposes carte blanche the development. It absolutely does not, and I think that's a really important point to make. What the industry wants to see is a framework whose ethos is supportive of development at scale, subject to the strict meeting of strictly defined criteria that are acceptable.
Okay, thank you. Well, it wouldn't be a session on renewable energy without reference to the grid, or lack of, and, clearly, that comes through in some of the evidence that we've received. I'm just interested, really, given the concerns about the lack of reference to grid issues in the draft NDF, in how you think the NDF should therefore try and address some of these grid issues. Maybe, Mr Ryan, you could start.
From my point of view, one of the issues that I have with the NDF is that perhaps it's not ambitious enough in terms of infrastructure development, generally. The only real tangible infrastructure development in the largest sense, in terms of DCO or DNS—developments of national significant—that's actually identified, I think, is Wylfa Newydd, which I know we will probably come on to a little bit later. I feel that, as part of this process, there really is an opportunity to be brave about what Wales wanted to deliver in terms of infrastructure, whether that's in terms of specific energy projects, tidal lagoons, et cetera, or whether that's in terms of grid and transport.
Again, it comes back to that point I made earlier about whether this is a spatial plan or a framework. On the basis that it will be reviewed every five years, I'm not expecting that infrastructure projects will be committed to through this document, but at least in terms of support in principle. I would put the grid amongst that. There has been lots of work done. There are outstanding decisions to be taken on the grid as well. For that to be reflected within the NDF itself would actually put it in a position where it can become a statutory document and a material consideration in terms of planning, going forward, over the next 20 years.
One of our issues as an industry is that the grid is constrained across Wales. There's no getting away from that, and that's in terms of the ability to connect into the grid, as well as, for industry or whatever, being able to connect in for high-energy users. And one of the issues with the grid is that it's not being looked at holistically, and especially with the electrification of heat and transport, that's only going to increase demand. So, it does need to be looked at across the board, really.
But I think one of the shortcomings of the NDF is that, given that the consenting powers for grid projects up to 132 kV were devolved to the Welsh Ministers earlier this year, there is no policy for dealing with those projects. So, this is meant to be the primary decision-making document for DNS projects, but it fails to consider a number of devolved projects. It's only really got policies on renewable energy. So, it totally ignores all the other DNS projects that could come forward in the planning period. And, as Will was saying, it can't just react to what it thinks might come forward in the next few years; it needs to look forward to 2040 and, based on that, it needs policies that can adapt to a changing situation.
Yes. You mentioned tidal lagoons and, clearly, one of the issues that's been raised in our deliberations is the fact that it is very much a terrestrial development framework, and you have a separate approach to marine planning. Is that a weakness? Because, clearly, if we're talking about grid, then we need to take offshore and marine energy into consideration as well.
I'm not sure whether it's a weakness. I understand the difficulties, but whether it's onshore or offshore, there will still need to be that grid capacity, as you say, and there will still need to be onshore connections. And, again, it's about whether we want to be positive and brave enough to identify these offshore. There's no real requirement in a development framework to be limited to actually what's on the land, I don't think. The opportunities are there, and in terms of delivering that overall message of development over the next 20 years, then, these sorts of schemes should be at least referenced within the document as to understanding the whole overall provision rather than really focusing on one or two very specific renewable areas.
Okay. There are grid issues, as well, of course, that are relevant to achieving localised distribution to decarbonised housing development, which, you know, the draft NDF is seeking to achieve. Can you tell us a bit about how that's going to be played out, then, if it isn't explicitly there?
Well, again, it's almost so localised that perhaps it's one that will emerge through the SDPs and the LDPs. Again, referring back to the 'A Low Carbon Wales' document, there's reference in there, I think, to the Bridgend local energy action plan, which has more specific and localised evidence in terms of energy use.
I think one of the things that perhaps we're getting away slightly from, as the focus of the energy, but even in terms of the local growth areas and national growth areas, is that perhaps there should be a switch towards, 'Where can we generate and distribute energy effectively, and how should those growth areas be influenced by that?', rather than, 'Here are some growth areas—try and get a connection', which, on the face of it, seems to be the approach.
I know, with Morriston Hospital, for example, they either have, or are in the process of putting, a solar farm opposite it, which only needs to link across to the hospital. Is there a way of avoiding having to put things into the grid and sending it long distances? Actually having renewable energies close to things like hospitals, universities, British steel, other major energy users, so that you're not actually needing to send it down the grid from point A and long distances, but actually sending it over relatively short distances to major users.
Absolutely, and there are plenty of examples, either via private wire, which is the transfer of electricity or combined heat and power sometimes, for example, via waste development, energy-from-waste facilities. I know Cardiff council are relooking at the potential supply of energy locally from the Viridor waste plant in Splott, and there are those opportunities. Again, I note that the district heating network issue is raised late. I think there's quite a lot more that can be done and developed around that that can bring forward that decarbonisation. And, again, much of that is referenced in the 'A Low Carbon Wales' document.
I'd add to what Will has said. I agree that there are opportunities for private wire connections to high-energy users. But, if you're looking at onshore wind, which is my business, windfarms tend to be in more remote locations, further away from users. So, yes, there probably are opportunities for using that to—. With hydrogen, if that technology develops then there might be opportunities for avoiding grid in that way, but, as things currently stand, we are looking at grid connections, and, obviously, that's something that we have to consider—whether there's capacity in an area and whether you need to bring additional capacity in.
Yes. I think there's a slightly adjacent point to that, which is that we'll probably start to see, or hopefully start to see, more of a prevalence of power purchase agreements starting to enter the market. I know that, for example, Aberystwyth University is part of a consortium of universities that has agreed to off-take power from an offshore windfarm in the North sea, from Statkraft, I believe. But I think there's also the point, just talking about grid in general and connectivity, around this idea that we need to start thinking about these anticipatory investments in grid at the small and medium scale that are going to help deliver decarbonisation with heat and transport as well. We can't just think simply in terms of the generation projects cluster and then the connectivity follows; we have to think about these things from the other side of the fence as well.
Given the inadequacies of the UK grid, which is not a devolved matter, would you therefore expect to see something in this framework that maps how we're going to get around this problem, either by having a Welsh grid or by having lots of local grids, which picks up on some of the initiatives that you've just highlighted? It seems to me that there's not a strategy here. There are lots of local initiatives, but what would you expect to see in this framework, which is for a 20-year period, given that we can't control the UK grid?
I don't see that it's possible to map where you'll need grid for the next 20 years in this particular document that's meant to be published next year, but I do think that it needs to consider a bit more how Wales will deal with grid and what the priorities are and what works for Wales. So, I think that that's a key point that needs to come out of the NDF. But, in terms of actually mapping or deciding where the grid infrastructure needs to go, I think it's a case of the Welsh Government working with other stakeholders—the National Grid, Scottish Power, Western Power Distribution, developers, and other stakeholders, so, local authorities, et cetera—to actually come up with some sort of plan about how this is going to be delivered in the context of decarbonisation. It's not just about where—. This document is looking at it solely from the perspective of where the windfarms will go—'That will create a critical mass, that's where we'll put the grid'. Whereas, a more holistic view of it, working collaboratively between all the stakeholders involved, I think that that could be done separately, but feed into this or into the National Infrastructure Commission for Wales's work. So, that's how I see it panning out.
At the moment, we have a highly centralised system where everything goes back to the grid and then goes back again with another monopoly company supplying it. It's not how it is in other countries. So, would you not expect an ambitious plan to also demonstrate a different way of approaching it, as they do in Germany—so, having lots of localised solutions that then avoid you wasting energy when it's being sent back to some central point?
I can't really comment.
I'm not really sure; that's not my pay grade. But, as Eleri said, I think we should look at all options, whether that's expansion of the National Grid, which, after all, is a very effective and efficient way of transporting electricity. If there are local, regional or nationwide, as in Wales-wide, opportunities, then, again, perhaps it's almost in tandem with the current NDF to review that for the first revision of the NDF that is proposed for five years' time.
Sorry, it's those sorts of timescales that, probably, we're looking at.
Would you expect to see more emphasis on the evolving battery-storage technology?
Absolutely, yes, and a number of other technologies. Rhys mentioned hydrogen. I think, really, again, the NDF has looked at how renewables have been delivered over the last 10 to 15 years and continued that, rather than the opportunities that are out there, in tandem with those current techniques, to look at how energy will be supplied, delivered and generated over the next 20 years.
I'm sure some people have switched on their tellies this morning and seen the hoovering up of the ocean beds, looking for the gems that will be used for battery storage. It's horrified me, I can tell you that for nothing. So, in light of seeing that, and hard decisions having to be made—and I'm talking the grid here—there seems to be a more urgent need, as far as I'm concerned, about how we produce that without doing the harm that's going to happen, and also, how we then transport it and store it, because there's a whole new avenue now that none of us had thought about that's going to, in my opinion, absolutely destroy the oceans. So, maybe you haven't seen it; I saw it last night. So, in light of that and all the things that we've heard this morning, is it your opinion that we can't move whole scale along, which is what it seems everybody wants us to do in Government, without doing something about the national grid? We've got, as Jenny has outlined, the possibilities of small scale and a different way of storing and transporting energy, which is fine where it works, but is it absolutely essential that we look at the national grid?
There's nothing to stop Wales asking for those powers. I'm six months into this role, so I'm being really naive, I suppose, but there's nothing to stop us asking for those further powers over the national grid. I've talked already about needing to see this in terms of, yes, distributed networks locally, demand-side response, as well as making anticipatory investments in the grid at a national level that help deliver decarbonisation.
I did see the report to which you refer regarding mining the sea bed for cobalt. I think, under all scenarios mapped out by the national grid, demand for power increases to a great extent, over the 2050 time frame, and part of that will be the requirement for more EVs on the road and the associated infrastructure around that. But I do have sympathy with the argument that says it's not just about electric vehicles, it's about taking vehicles of all sorts off the road, because if you read the UK climate change committee report, 9 per cent of what we're going to need to do to get to net zero is about consumer behaviour alterations as well. So, there are a huge amount of moving parts to this, and, unfortunately, the unsatisfactory answer is, 'Yes, we need to look at distributed systems locally, demand-side response, but, yes, we need to look at the sorts of anticipatory investments we need to make in the grid nationally as well, so that we can deliver net zero, so that we can meet the renewable energy targets that we've got.' There are no easy answers to this.
But bringing it all the way back to the NDF and thinking about the pace we need to move at, and the scale that we need to move at, the question is, 'Is it, as drafted, going to deliver what we need, certainly for solar and wind at scale?' My answer to that is, at the moment, 'no', and we have to use every tool in the toolbox to do this, and we should not look a gift horse in the mouth in terms of the cheapest, most readily deployable technology, which gives us that leg up towards the targets, which is onshore wind.
Thank you. Given the inadequacy of the grid, I wondered if either Innogy or Renewables UK Cymru members have considered using solar/wind power to develop hydrogen. So, if you like, processing the energy on site in order to then make it available.
Yes, Innogy are currently funding a Master's in looking at this specific issue on hydrogen and applying it as a case study to one of our operational windfarms. So, I don't have the results of that yet. It's literally in the last few weeks that that Master's student has been appointed. So, yes, it is being looked by Innogy as a company across Europe, but also we are looking at this specific study collaborating with Swansea University. So, there will be results of that, which I'm sure we can share with you in due course.
Okay. Just going back to the framework, should this be part of the mix? We're great at releasing raw materials; we're not so good at processing them before we export them.
Absolutely, and I think one of the shortcomings of the document is that it doesn't provide a strategy. In terms of decarbonisation of heat, the Welsh Government haven't decided yet, or it's not in this document, anyway, whether they want that to be through electrification or from repurposing the existing gas grid for hydrogen or green gases. So, I think that's a decision at the strategic level that will hopefully feed down into the NDF, because there will be spatial implications to whichever decision the Welsh Government goes down.
Okay, thank you for that useful information. Is there anything you wanted to add, Rhys?
I'd just echo that—it's a really important point. There isn't anything about the repurposing, potentially, of the gas networks to accommodate decarbonisation of heat, and I've read some studies saying that the gas network that we have could accommodate up to 30 per cent hydrogen without the requirement for a large-scale modification. So, is that a possibility? That is something that the document or the energy strategy at large needs to consider, because these are huge questions. If you remember the 1970s, there was a huge project to convert town gas to natural gas; in terms of decarbonising heat, what I assume we are looking at at some point over the next 20 years is something similar, because at some point someone's going to have to come into every house on every street in Wales and say, 'That gas boiler has to go. We're going to have a hybrid boiler.' It might be hydrogen, it might be something else, but it's about decarbonisation of heat in the end.
Okay, thank you. That's very useful. Can I just move on now to the policy on establishing a national forest, which is policy 9? In your view, is there sufficient detail on the areas that we might be developing in this national forest theme?
The very straight answer to that is 'no'.
I think the point that I'd like to make is that, no, there's not any detail, which may not necessarily be a bad thing in as much as my interpretation of the policy is that the forest will not be one single area of land, but will be distributed equitably or inequitably around Wales, which, generally speaking, seems an appropriate approach. The area—I think it's 2,000 hectares per year—is quite ambitious, but, as I said earlier, we like ambition. But I know there are concerns about its potential to conflict with some of the priority areas as identified at the moment, and perhaps Eleri can expand on those.
Sorry, could you just elaborate on why you think there'd be a conflict between a forest and other priorities?
Well, just in terms of the areas identified for renewable energy, I would generally associate—again, without any other information on the forest, there's potentially a conflict there.
Based on the document as it currently stands, there are some wind and solar areas, and as I've said right at the beginning, forestry and windfarms are not incompatible. You tend to do a keyhole of felling, and then put the turbine up and all the infrastructure. There are benefits: it improves the infrastructure for NRW for their management of the forestry et cetera. But there is one solar-only area in south Wales, near Pen y Cymoedd, which is actually on forestry. And this is, again, I think, a failing of the Arup report rather than anything else, but there is not a solar developer that will go out there and fell an entire forest for solar. It's too expensive and also, as Will was saying, it would potentially conflict with that national forest policy.
But renewable energy developments as well, we've got examples at Clocaenog and Brechfa Forest West of habitat management plans. So, peatland restoration and the restoration of semi-natural grasslands. And these can happen in tandem, because a lot of forestry has resulted in degraded peat and previous users have affected that land and, actually, I don't know as much about solar, but onshore wind offers those opportunities to improve that land, which is in line with other priorities of this NDF.
Okay. So, have you submitted evidence to the Government on how to develop this national forest, in line with all the other ambitions they have?
To be honest, I haven't submitted anything, because I don't—. The other thing with the national forest is: is it development? So, it's an initiative, but it's not development in the sense of needing planning permission. So, how the Welsh Government go about finding these locations and planting the trees is not something that we would have any comment on.
Okay, but given its strategic importance to capturing carbon, would you expect a bit more information on how we're going to achieve these 2,000 hectares a year of forestation?
As a planner, yes, I would expect a bit more in the document. It leaves it all to a later date, doesn't it?
Well, we can't do that. This is for 20 years, so it's got to be fit for purpose for the next 20 years.
From our point of view, we haven't specifically identified suitable areas or an approach. Again, I think the policy as it stands is well intentioned and is generally supported, but there's so little information there that it's difficult to pick up as to where that policy might head in real terms.
And I think that applies to policy 8, the strategic framework for biodiversity enhancement and ecosystem resilience. That's another policy that leaves the decisions to a later date. Developments could provide opportunities to assist with that, but they could also conflict with other priorities. So, it needs a more joined-up look, I think.
I'm just wondering what your views are on the Welsh Government's support for the north-west nuclear arc initiative, as a representative of north Wales.
Yes, I think that's definitely down to me. Well, again, referring back to the 'A Low Carbon Wales' document, there is clear support in there for that balance of renewable energy, nuclear and other, essentially decarbonised, energy provision. And in general terms, the Wylfa Newydd scheme is advanced in terms of the development consent order examination, and I'm sure you're all aware that a decision was delayed, put on hold, for a further five to six months or so, in the last couple of weeks. So, in general terms, I think we need to let that process play out and see where that's heading with regard not only to the decision-making process, but also, then, ultimately, in terms of funding and how that will come forward.
Frankly, even if everything falls into place in terms of decisions and funding and bringing that forward, that takes us, in terms of construction and actually being able to turn on the nuclear provision in Wylfa Newydd specifically, well into the second half of the development framework period. So, certainly in the short term, it's not an answer, but, again, it's probably right that it's recognised as potentially a solution to decarbonisation in the longer term.
Well, there's a whole debate to be had about whether there is a huge carbon footprint in terms of nuclear, but that's not for today, maybe. But what about the balance that's struck there? It is an appropriate balance that's being struck between nuclear and renewable energy? Because I always feel that the levels of funding being pumped into nuclear, if that was invested, or half of that was invested in renewables, then it would transform renewable energy, and I wouldn't be surprised if we weren't too far enough generating just as much.
I can't really talk about that funding mechanism here. I think, in terms of the NDF, it recognises that there's the potential for that balance. I don't think anywhere it describes, actually, what that balance might look like, and I think, again, I come back to the point that pending any decision on Wylfa Newydd either—. And, again, I mentioned decision making and construction, but also the funding and the price point, et cetera. The NDF probably at the moment recognises that it's a possibility and kind of parks it there.
I was going to make the point that, yes, I agree with Will; I'm not sure that the balance—. I don't think the policy actually balances which one is preferred. I'm actually not sure the policy really says explicitly what the Welsh Government's view on nuclear is, but I'm assuming it's supportive because they talk about all the benefits. What I'd like to see within the NDF is some kind of recognition of in-principle support for offshore wind and other non-devolved projects. So, Wylfa is not a devolved project; it sits with Westminster. I'd like to see the Welsh Government saying, 'And we support offshore wind as well'. We're developing a Gwynt y Môr extension project in north Wales, as a company. I'd like to see something in there saying that we support these non-devolved offshore projects as well.
Yes, I agree in terms of I can't see how the NDF currently is trying to balance these different energy-generating means, but does that not point to a broader issue here in that the Government hasn't actually quantified what the demand will be longer term in terms of energy? Therefore, that would allow it then to articulate more effectively where it believes that energy's going to come from over the period of the NDF and beyond, potentially. I presume you'd agree that that's a deficiency generally, and if that provision was there, then, clearly, it would help inform a much more meaningful NDF in terms of striking the right balance.
Absolutely. The target in here from 2017 is 70 per cent of electricity from renewables by 2030. That was before the declaration of a climate emergency, and it was—. There needs to be a recognition that we need to look forward not just to 2040, but 2050. The Welsh Government have committed to reducing emissions by 95 per cent, and also with ambition to be net zero. You have to ask whether the 2017 target for renewable energy is actually fit for purpose anymore and whether it needs to be reviewed.
Well, it's 70 per cent of what. We don't know, so how big is that 70 per cent?
Absolutely. I totally agree. There needs to be a strategy on how the country is going to be decarbonised, but also, once you've decided what the demand is at the end, how you reach that. There needs to be some sort of route-map for that.
Would you not expect something of that kind to inform an NDF, because otherwise we're just fumbling in the dark?
Again, I think it does—it draws from the 'A Low Carbon Wales' document, but perhaps doesn't explain within the NDF where it's come from. It's identified that there's a climate emergency, and it's called a decarbonisation of energy; it's the most extensively discussed point throughout the whole of the NDF, more so than housing or regional development, and certainly more, if I may say, than the economic growth of Wales. And therefore, again, it needs to be—I keep using this phrase—brave enough to say, 'Look, this is what we need to deliver—not want but need to deliver—and this is how we're going to do it over the next 20 years'.
I'll just make a comment to which you may wish to reply to or not. Really, it's the technological advances we're waiting for. There's no reason why cars couldn't be solar-powered using ultraviolet radiation coming from the sun, which we know is going to come all the time. It's these sorts of immediate technological advances that we're looking for. In 1870 somebody predicting the future said the streets of London would be impassable due to the amount of horse manure on the ground. So, I think we need some care. We are looking for technological advances, aren't we?
Two things there. I think, first of all, now, it's either horse manure as a resource and not waste or an obstruction, and I think the other point really is that, yes, we need to be looking at estimating where we're going to be. And I understand that's difficult in a framework, but also, in that, bringing through more the economic opportunities through growth. Also, there's no reference in the NDF really to that association of decarbonisation of energy with research and development, with universities, with economic development, as well. That really, again, perhaps comes back to that first question that it's a missed opportunity.
Yes. District heat networks—the document obviously talks about creating these in various locations. Does anyone on the panel have a view of the viability of these locations that are identified in the document, and what can Welsh Government do in its own capacity to stimulate this particular area?
I don't have any expertise on district heat networks, but—
What I would think is, rather than identifying areas where you want them, you just have a policy saying, 'We support them anywhere they're viable and feasible.' I don't see the need to put dots on maps, but that's just my sort of very high-level view based on the policy wording. I don't know enough about district heat networks to say whether they're in the right places. I don't know how the Welsh Government could—
So, the location-led approach that this document takes is not necessarily one that you'd support. It's more a case of saying, 'We recognise district heat networks in locations across Wales can make a difference. We shouldn't be area specific in defining where we'll say "yes" there but "no" somewhere else.' I think that's what I'm understanding you're saying.
I guess that comes from more of the understanding of the priority areas, which we've already discussed this morning, for onshore wind and solar. Do away with the maps.
Correct. And, from my point of view, the locations seem—. I don't think there's any evidence to suggest where those locations came from. There are a number of towns. So, for example, in the north Wales region, there's a policy about north-west Wales energy, as we've just discussed, but none of the towns in north-west Wales or cities are identified for district heat networks. So, for example, Bangor where there's—. A lot of these heat networks work best when there's a high density of quite often publicly owned buildings, through universities et cetera, and there are no towns identified in that region at all. So, I think, 'Do away with those maps.' They're to be encouraged. And, again, I'm sure that, with the industry, and there's the Association for Decentralised Energy, which can advise on how best to bring these forward, then, there is expertise out there to determine how best to bring them forward, associated with specific heat generation like waste incinerators, for example.
They're doing some very innovative things in Bridgend at the moment. I sat through a very interesting presentation back in July on what they were doing. I guess the message is, I agree, we don't necessarily need to put these locations on a map, but just to suggest that those who want to progress these projects go and look at projects such as those ongoing in Bridgend, learn from them, and then see what they can take away and implement themselves.
You mentioned heat from waste, and that is something that the document seems to be silent about. The other thing that there seems to be silence on is the role of hydroelectricity. Every historic town and village is built near water, for obvious reasons. Would you expect that to be outlined in the NDF?
I don't know. I guess the NDF—. I do think it should be referenced. I think it should be referenced as technology that might come forward. But I don't know how many projects there are that are over 10 MW hydro. But pumped hydro, those kinds of solutions, I do think they should be referenced in there somewhere.
Why do they have to be over 10 MW? I mean, I understand that that's what the framework needs to be concentrating on, but, in terms of overcoming some of the grid problems and the expensive liquid gas people are having to use for heating their homes in areas that aren't on the grid, surely, would you not expect some sort of focus on using alternative energy sources that are there in abundance in many of our communities?
Yes, I would agree. I think that it's quite focused on onshore wind and solar from a renewables perspective. It doesn't talk about the other options.
Yes, it should do—it should say more about it. I think, in the end, the difficult thing with this is—I do have sympathy—it's a slightly contradictory position to adopt, potentially, on our behalf as an industry, where we say, 'Okay, we need to use every tool in the toolbox if we're going to get to the targets and deliver net zero.' And that's true, but what this document goes part of the way to doing, but doesn't go, necessarily, as far as it should do, is actually make some bolder statements on what it actually is that we are going to pick. Because there will come a reckoning where you have to say, 'Okay, this is what we favour, this is what we're going to do. If not all our chips, we're going to put a lot of them in, and this is what we're going to do, because that's what we think will work, based on the evidence.' This is making a play around lots of different things, and it's more, maybe, in hope than in expectation, and I think there needs to be a little bit more commitment to certain specific ideas, or maybe a demonstration of a lack of commitment to certain specific ideas that aren’t favoured, and I think that's what's lacking from this.
Well, thank you very much for coming along this morning. It's been very informative and helpful. Again, we're very grateful. You'll get a transcript of it. I would advise you to check through it, because, if you're anything like me, when I'm talking to somebody, I tend to turn to face them, and when you do that, sometimes the microphone doesn't catch every word. So, please check it for that, and thank you very much for coming in.
The next panel's coming in in two minutes' time, and we're still quorate.
Gohiriwyd y cyfarfod rhwng 09:58 ac 10:01.
The meeting adjourned between 09:58 ac 10:01.
Can I welcome James Byrne, Living Landscapes manager, Wildlife Trusts Wales, Jerry Langford, public affairs manager, Woodland Trust, Mike Wilkinson, senior conservation planner, RSPB Cymru? And Anthony Geddes, national manager for Wales, Confor, is on his way but is having difficulty with the A4232, which other Members have had on their way in this morning. So, can I welcome you? If you're happy, we'll move straight to questions. And, if my voice will carry on, I'll start.
There's a policy on establishing a strategic framework for biodiversity enhancement and ecosystem resilience. Do you think the policy goes far enough?
I'll take that. First of all, we'd like to say we really welcome the policy. There are significant elements within the policy that are very—[Inaudible.] However, we think it could be more ambitious and it could do so much more. We like the—. Under the challenges and opportunities, it says—in the introductory sections, it says that:
'Climate change and the decline in biodiversity are global challenges and the biggest issues faced by our nation. Addressing these is our greatest responsibility when considering the legacy we will leave for future generations and as a consequence we have declared a climate emergency'.
And we completely agree with that. And the reason for that is because we have a mass extinction and we have a global climate crisis as well. That's been reflected in SoNaRR—the state of natural resources report—saying no ecosystems in Wales are resilient. It's been reflected in the various states of nature reports that we've put out, saying that there's been a 60 per cent decline in biodiversity. We know most of our designated sites in Wales are in unfavourable condition. The recent Intergovernmental Panel for Biodiversity and Ecosystem Services report that came out highlighted that, in the next few decades, 1 million species could be pushed to the edge of extinction or actually extinction, and other reports have shown within a few decades we could lose to extinction 40 per cent of the insect species on the planet.
These are really significant and really big, scary stuff, and that's why we're pleased to see outcome 10 and we're pleased to see policy 8, but we think it should go further. And one of the areas where I think it should go further is that, first of all, it uses some weak language like 'should', like 'should protect ecological networks', and we think it should actually say 'must protect ecological networks', and I also think it should explicitly state that Natura 2,000 sites, SSSIs, local wildlife sites, priority habitats and priority areas for species populations are sacrosanct. We cannot maintain and enhance biodiversity and the resilience of ecosystems, as it says in the Environment (Wales) Act 2016, section 6, if we are allowing development to impact the biodiversity hotspots in Wales biodiversity hotspots in Wales. Therefore, I don't think that it goes far enough. I think it's good, I think it's a good start, but I think it can be more ambitious.
I'd agree with everything that James has said. From an RSPB perspective, we'd say that the ambition is great. It's recognition, if you like, from the captain on the bridge, that we need to go to a completely different place, but it feels like the supertanker is going to take some time to turn around. What we see, I think, in the NDF here is the need to embed the ambitions more thoroughly across the NDF and also across the Welsh Government's other plans, such as investment strategies and low carbon delivery plans. So, the NDF needs to be seen as part of a picture about how the Welsh Government chooses to invest and take the nation forward.
I absolutely agree with James: nature recovery is about protecting and managing the best and improving the rest. What we see in the NDF is the beginnings of a really positive policy, policy 8, which has some really innovative thinking behind it. But it doesn't go far enough. We think that it needs to include—as James has said, really—a commitment that development must deliver net biodiversity benefit. The rationale there is that, over the years, development has contributed, along with other things, to an erosion of biodiversity. Therefore, if we're serious and want to realise that ambition of reversing biodiversity decline, Welsh Government needs to set out a clear role for what development is expected to do towards that. And that clear commitment to 'must deliver a net benefit', which is in 'Planning Policy Wales' but needs to be pulled up into this top-tier plan, is really important.
The other thing I'd say is, like James, we see the lack of a strategic policy around spatially defined biodiversity sites as a lack, and we see the absence of any reference to priority species and the action needed for priority species. The example that I'd use there is the curlew. We know from work that we could lose curlew—an iconic Welsh uplands species—over 20 years, which just happens to be the period of the NDF. So, that's the period where we need to make these changes.
Yes, I'd just add that it is very welcome to have an infrastructure plan that actually includes within it green space, green infrastructure issues, the biological environment. So, it's a great start. It's also very welcome to have it state that environmental and well-being objectives are a purpose of infrastructure projects—it's not just narrow economic objectives.
We certainly agree that a test of this plan or the policy is that they actually—. There is the opportunity now that infrastructure can help address biodiversity decline, rather than continue to be a driver of it. So, I think that that provides a very clear test for the success of the plan and the policy.
So, for example, in the Woodland Trust, we know that there are something like 70 active cases of ancient woodland threatened by development in Wales at the moment. So, our expectation is that there won't be any, and that that number will go down sharply. So, we do have a means of testing this. As I say, it's very welcome to have the remit of infrastructure planning widened to include these environmental safeguarding issues.
Thank you. Can I welcome Anthony Geddes, the national manager for Wales, Confor, following his battle with the A4232? [Laughter.] Thank you for coming along. You heard the first answer to the question, but you didn't hear the question itself.
I didn't hear the question, no, so if you could—
What the question is is your views on the policy of establishing a strategic framework for biodiversity enhancement and ecosystem resilience, and whether the policy goes far enough.
Certainly. In our response to this is that we very much welcome strategic green infrastructure, especially in and around urban areas. The possibility for urban forest is quite an exciting one—the expansion of that role. I would also say that, within Wales, there are approximately 140,000 hectares of broadleaf forestry owned privately. I think that the strategic green infrastructure statement doesn't go far enough in identifying our existing asset of woodland, both in the private and public sectors, to be a major potential landbank for biodiversity, and the support and improvement of that.
Yes. I just wanted to pick up on what Mike said about specific species, and the curlew as an example. Would you expect that level of specificity in the NDF? Or would that come elsewhere?
It would come elsewhere, but what I'd expect to see in the way that policy is constructed is recognition that the ecological network, which is the really great thing that's being promoted by that policy, takes account of the needs of priority species. So, for us, one of the issues is how do you translate that intent into timely and deliverable actions. And there are two things there. One is that it's very good, but it's very focused on habitats, and we're just really beating the drum for the need to think about the habitats that you'd need for species. So, we've done work, for example, on areas where landscape-scale delivery for curlew would have benefits. No, it definitely has to come in the detail.
There is another issue though, which is around the role of area statements in translating that policy into reality, and the policy relies on green infrastructure planning for its implementation and on the area statements process. We just feel there's a need perhaps to check whether those delivery mechanisms are adequately in place and will deliver on the implementation of that policy. Those are issues, I think, for the policy to signal, but it's an issue then for the implementation of the policy. How are we actually going to make sure this happens? Area statements are great, but they're an untested mechanism, they're not in place, but this NDF will go live in a year's time, perhaps, therefore there needs to be the delivery of that policy following on very rapidly. That's really what I'm trying to get at.
Yes, I'd agree with that, and obviously the IPBES report and the Minister have called for transformational change. And, when we're talking about species, we aren't talking about that the NDF has specific policies for curlew, but the environment Act—section 7 within the environment Act—requires NRW and others to create a list of priority habitats and priority species, and that is not within this policy. The policy also states enhancement of biodiversity and resilience through ecosystems, but it doesn't say protection of current assets—so, not building on a SSSI or et cetera. So, we think that's—. Having reference to section 6, habitats and species, is going to be important. Otherwise—. We wouldn't like to see Members of the Assembly species champions be lost and have no species left to champion because they've been pushed to extinction.
And we've put in a proposal for this—well, a bit of spatial planning. So, we suggested something like in a priority area for renewables there could be a statement of environmental master planning, which, when I was at the RSPB nine years ago, myself and my colleague Mike Webb and others created, called the statement of environmental master planning, processes where you looked to effectively use the community benefits scheme, the habitat management scheme, to actually put—instead of having a bit here and a bit there for species and habitats, actually aggregate that together and actually put it in strategic areas where it would have the most biodiversity benefit. So, we've suggested that.
Just an example of why we think this is important: at the minute—at least, a couple of years ago—there were 331 hectares lost within the Gwent Levels SSSIs, and this figure includes both land already developed, as well as allocations within the relevant local development plans yet to be developed. So, at the minute, we're still losing nationally important habitats and species to development. And that's why we think this highest tier national plan in Wales needs to be strengthened and include habitats and species, as listed in section 7, as there is a legal duty to protect in Wales.
Yes. Okay, thank you for that. I was going to ask about whether there's sufficient focus on green infrastructure. We've covered a lot of that, I think. But I'm just wondering whether you feel that the green infrastructure agenda is somewhat pigeonholed in policy 8 and doesn't really permeate throughout the document more.
If I could respond to that, I think it's great that the green infrastructure is there but, yes, it doesn't appear to be embedded—
—in many of the other policies. So, for example, in the regional policies, it barely gets a mention anywhere. So, what we would suggest is that, actually, as well as putting the intention in the NDF, there actually needs to be a bit more on a more rigorous, defined process for actually ensuring that that aspiration is delivered. So, Mike referred to this as, possibly, a biodiversity net benefit protocol, but I think it's essentially a process that starts by saying, first—I'm referring to what Andrew said—you assess and evaluate what you've already got, so all that existing woodland and your mature trees, for example, and your other habitats, and value that, because that's the most valuable component of green infrastructure. So, the next step is that there's a requirement to maintain and protect that, and then thirdly the create and enhance.
I think that that process needs to be set in a more formal way, and I'd further suggest that this is a situation where a target or a benchmark would be useful. This committee has previously recommended a 20 per cent tree cover target for all urban areas, and that would seem to be something we would greatly support. What that does, for example, is it gives immediate value to your existing tree cover and woodland. So, instead of the situation we have now, where developers see mature trees as an inconvenience and that's a cause of a lot of friction at community level, the target would give them a value and actually incentivise their retention. And that can be transferred to new infrastructure projects where you have the same or preferably a slightly greater target to ensure that new infrastructure developments, including housing, actually contribute to meeting that tree cover target.
It all depends on how the policy as a whole is going to be treated. If the policy 8 is there and it is to permeate the rest of the policies, then that's great, as long as there's that instruction that that's clear, of putting—
Exactly, yes, if that's the intention. Obviously, the flipside to that is policies can be siloed and can be just looked at individually.
So, for example, delivering affordable homes—within delivering affordable homes, there's no mention of green infrastructure, and we all know the huge benefit of green infrastructure to people's health and well-being, and especially for people in lower income communities, where it's been shown that there's a lack of green infrastructure and a lack of trees. And, therefore, the benefits to those areas would be far more significant if the green infrastructure was supplied, as we've called for previously—accessible green space and green infrastructure standards, as they have in England. Natural England has got 'Nature Nearby', called ANGSt.
I'd just like—. Sorry.
Just one last thing—another aspect of green infrastructure and having it in here, we can be really ambitious and ask for things that they've done in other countries, such as having a requirement, for example, for all commercial buildings to have solar panels or green roofs, which they have in France and other countries. So, we can be more ambitious with this, and require green walls, et cetera. I know businesses want to do that. I'm currently in negotiations with some of Wales's major businesses about putting green roofs and green walls onto their buildings.
I was going to say that I think there is a role for targets and I think that they could apply across a range of different biodiversity things. This policy is really a policy that's signposting. It's saying, 'Welsh Government and its partners are going to do something', and that's where we really get down to the implementation. So, it's all in the implementation, this policy, and really there needs to be a dialogue and a process about how to take forward those ideas. I think a gap in that policy and the NDF is, 'Well, what does this mean for Welsh Government's own consenting powers in relation to developments of national significance? What is the Welsh Government then going to expect DNS to deliver in the way of biodiversity enhancement?'. So, I think there's quite a big dialogue to be had, and we can't go any further today, I'm sure.
Thank you. Joyce Watson wants to come in first. I'll come back to you.
Thank you. First of all, I need to say that I'm a member of the west Wales wildlife trust, the Woodland Trust, and RSPB Cymru, so that's three of you sitting there. So, I want to make that clear.
That should be an example to all of you. [Laughter.]
But, having said that, coming back to the comments by James about green housing, we're sitting here at the moment and thinking how we manage the landscape that we will destroy, but what we can maintain. We're sitting here while it's absolutely pouring with rain, and you won't be surprised that I will talk about run-off from those creations. So, should there not be some sort of joining up here? When we're looking at the NDF, if we're saying, 'We're going to build whatever it is we're going to build', we should also look at capturing some of that run-off and then create a green space. Trees are obvious for soaking it up, but so are hollows, where you could create a pond and keep some of the species where that development is, and therefore also grow an interest in biodiversity directly within those communities.
I completely agree, and what isn't mentioned, or at least I haven't seen in here, is actually Welsh Government's standards or requirements on sustainable urban drainage systems—SuDS. And, obviously, the drafters of this policy probably didn't want to repeat every individual piece of Welsh Government policy, and assume that that will be read in 'Planning Policy Wales' and others. But it would be worth having that in section 8 and other sections.
With SuDS—and green roofs is a SuDS as well—there's a great opportunity to, actually, with new development, significantly reduce the capture rainfall. Green roofs don't take any additional land space and they have a significant impact on biodiversity. But also, the study has shown they actually can capture between 40 and 70 per cent of intensive rainfall, slow it down and then you can put it into either the drainage system or into the creation of new wetlands. I couldn't tell you the figure, but in Wales and in the UK we've lost a significant amount of wetlands—farm ponds, for example, and garden ponds, et cetera. So, yes, I think it's a really good opportunity to use the development system to actually put more SuDS, more green infrastructure, more green roofs and swales et cetera back into the landscape, and specifically have them for the multiple benefits, including increasing biodiversity.
Mike, you raised a point about targets, and we talk about green infrastructure, but I see in James's paper here that he touches on out-of-date data that the NDF is built on, and you talk about population objections. How confident are you all about the data that this plan is predicated on? Because when you talk about population data, which you highlight to us, James, there's a significant difference between what the projection is now of modest growth—0.61 per cent, as opposed to 4 per cent, which this plan is predicated on. So, if you're talking about green infrastructure, if you're talking about targets, if you ain't got the data right, the whole thing's going to be wrong in the first place anyway.
Well, what I'd say is this a draft NDF, and, when it's published, I think it needs to have reference to, and to be permeated with, the up-to-date data, and those are the recent projections from the Office for National Statistics.
In terms of updating, could I just sort of mention—? I think we're in a new political climate as well, where there's a heightened public and political awareness of both climate emergency and biodiversity emergency, and I don't get the feeling that that's really factored into this piece of policy work. As I say, one of the crucial tests of it is: is it contributing solutions to those two emergencies?
But could I just come back to the point of flood mitigation? Because, again, land management for flood mitigation is very much a spatial issue, and it's not mentioned in this document. I think there is an opportunity there. And we, at the moment, do have an issue with Natural Resources Wales's approach to flood mitigation, where they seem to consider the engineering solutions but are not considering the potential land management solutions. So, again, I think that's another example of where this document could contribute a lot more.
I was just going to say that it's evident, in reading the document, the way that it's been created, structured and written by individual specialisms and specialities. Also, coming back to Joyce's point, when we are looking at provision of our housing in Wales, we can actually start so much further back down the supply chain in ensuring that these houses are built from timber, ensuring that those woodlands, plantations and forests are designed and structured in a way to provide the biodiversity habitats, and, where possible, to provide spatial land management and flooding benefits. They're not one-trick ponies, and it really does feel, in here, that there's a lot of missed opportunity to connect those policy routes together and actually to engage the concept of low-energy, high-quality housing delivery with the additional benefits of maybe not so much the decarbonisation, because I think that's well linked, but those other spatial plans.
Very briefly, yes. I just want to pick up again on the point made about the inconsistency between the NDF and 'Planning Policy Wales' in terms of that development should enhance biodiversity, not that it must contribute to net biodiversity benefit, as 'Planning Policy Wales' articulates. I raised this with the Minister yesterday. She was denying that there is an inconsistency and that there is a change of policy. You wouldn't agree? Because, presumably, the NDF will trump 'Planning Policy Wales'. I mean, the NDF will dictate to strategic development plans or local development plans what they need to achieve, and, if it isn't as strong, then, clearly, there's an issue there.
Our interpretation of the way in which 'Planning Policy Wales' and the NDF are constructed and are read together, in our view, creates ambiguity and conflict. In our view, what's needed is actually revision of both the way the NDF is worded and revision of the way that 'Planning Policy Wales' is worded. If I take SSSIs as a specific example, there is a presumption in 'Planning Policy Wales' that you don't damage SSSIs. But in the NDF, there's a renewable energy policy, policy 10, which has a presumption in favour of renewable energy, and it only says that development should minimise adverse effects. That is in conflict, in relation to SSSIs, with 'Planning Policy Wales'. I've been reassured that that wasn't the intent of Welsh Government and I am absolutely happy to believe that, but it does need to be revised, in our view, in the way in which the final NDF is revised and reworded, and in the way in which 'Planning Policy Wales' needs to be reviewed, in our view, to remove what we consider to be at the best an ambiguity and at the worst a weakening.
I totally agree with Mike, but what I'd like to just add is that, as was mentioned before, our best sites are still getting damaged by development, and that's why we've called for the NDF to explicitly state that mature sites, SSSIs and others are sacrosanct and should not be developed on, because we cannot maintain and enhance biodiversity if we're continuing to lose it, and deliberately losing it. And we actually think that it would make things simpler, less time consuming and less expensive for Welsh Government, developers, members of the public, statutory and non-statutory stakeholders such as NRW and ourselves, because it would significantly reduce the potential call-in, significantly reduce the likelihood of a judicial review and it would significantly reduce the combat of development process, where a developer hires in a team of consultants and then their boffins argue with NRW boffins, et cetera, and you've got what's an 'acceptable' loss in biodiversity and what is an 'unacceptable' loss, and what is minimised and what is not minimised. So, effectively, it then becomes a subjective judgment by the authority, the appropriate authority. So, we think, if you actually take away that reason for that major conflict, then you actually make things a lot less time-consuming and a lot less expensive and a lot simpler and a lot easier, and, therefore, better planning.
The ambition for a national forest is there in policy 9. What sort of detail would you expect to get in a draft national development framework around where, how?
Jerry, do you want to dive in or—?
No. After you.
In terms of the national forest being part of the NDF, I would expect the concepts, the strategies and the structures to be well laid out within this document so it's explicit, and, actually, in the respect that the three main strategies of the national forest are laid out in the draft NDF in terms of habitat, timber creation and access to green spaces—. I'm sorry, I can't remember the exact wording of those three key strategies, but they are laid out quite clearly. What I think is lacking in section 9 is the steps that may be required to deliver on a national forest. There will be some contentious or some combative steps when in conversation with our colleagues, I suspect, about which habitats are appropriate for woodland creation, which habitats are not appropriate for species selection or importance, and I would like to see some more clear guidance on how the Welsh Government feels it can advise landowners of what it feels is appropriate for usage there.
Well, the first thing I'd say is how welcome it is to have the policy in there in the first place. I think it's a wonderful initiative and has huge potential. So, we're not particularly concerned about the lack of detail at this stage, because I think it's an opportunity to start a new conversation about what woodland and forestry can do—this idea that woodlands can provide an environment in which all sorts of things can happen, including housing and development, but it also combines people with green space, with wildlife. So, I think there's an opportunity for a whole new, exciting conversation there. What we think is crucial is that there is a lot of stakeholder and community involvement, so what we have suggested to Welsh Government is a substantial and extended stakeholder engagement exercise, which will create the opportunity for communities and landowners to come forward with proposals and build something that is truly Wales wide from the bottom up. So, I do think it's a very welcome initiative. I think, yes, there needs to be a clear process put in place, but certainly I would advise against rushing to close down on what it is too quickly.
I would certainly echo that last statement.
From RSPB, we'd certainly agree that it's a welcome policy; it's something that provides a useful and valuable initiative. It's all in the detail, so, from an RSPB perspective, there are opportunities here to improve biodiversity, to enhance biodiversity, but it's all down to getting the right tree in the right place, because other habitats store carbon as well. Our peat lands are an important resource in terms of storing carbon, and aspects of the elements of the policy and, indeed, policy 8 could give greater recognition, I think, to natural solutions, and not just forests, in delivering climate change mitigation.
The one thing I would say in terms of the implementation—I agree with Jerry, yes, it's a signposting policy, it's about how it's worked out. I think I would put on the table—we think there's a need for a bit of a data refresh on priority species, particularly the upland birds, which may be quite vulnerable to afforestation if the afforestation goes in the wrong place. So, that's something we'd like to see as part of the evidence base as the policy's taken forward and implemented.
If I could add, I think we should try and move away from seeing this as afforestation, because I think it can be so much more than that. I think that's why we need this new conversation about what a forest actually should be. I think it's a well-wooded landscape, essentially, and that could apply to urban areas as much as the uplands. So, I think we do need this opportunity to completely widen out that discussion and avoid the mistakes of the 1950s and 1970s, when we had this very centralised, imposed forest expansion that, effectively, destroyed public support for forestry for a generation. I think this an opportunity to go about it in a completely different way, to achieve something that is much more multi-objective and covers multiple sites.
The right tree in the right place. Does that include agroforestry, given that Brexit still towers over us as a possibility? A 'no deal' will mean there will be no fruit coming from abroad, so are we going to be—?
Obviously, we very much think so. In fact, we've done some calculations recently on how Wales could achieve the very ambitious woodland expansion targets that are recommended by the Committee on Climate Change. We think a third to a half of that can be achieved by agroforestry in its wider sense, so that is improving scattered tree cover on farms, hedgerow renewal, restoration and expansion, riparian protection strips, shelter belts, wood pasture, and that's before you get into the more technical agroforestry production systems. So, yes, I think there's huge potential there, but we do need a different approach to farm support to achieve that.
I'd agree. I think there's a potential for a whole range of different mechanisms. I think, going forward—the kind of process that Jerry talks about, I think the important thing to include in that conversation is a consideration of how all the different mechanisms relate to ecosystem resilience, because that ought to be a kind of golden thread, I think, running through the NDF and actions that flow from it.
I just want to be controversial, because we've got areas of outstanding natural beauty, we've got national parks, and they were designated as such in their current form at a given time and in a given place. So, if we're talking about trees and deforestation, if we went a bit further back than when those designations were put in, would it not be possible that there were many, many more trees on those landscapes—in fact, it is the case that there were many more trees and different species on those landscapes—so, is it not, whilst we're talking about—and I'm not talking about a forest in the national park writ large, but is it not the case that we need to think differently now that we have seen the consequence of sometimes designating and almost sterilising areas that perhaps would benefit from rethinking? And I'm particularly talking about trees.
I absolutely agree. I think landscapes evolve. In the uplands and the national parks, I don't think the way forward is lots of planting. The way forward is possibly modifying land management so you get a more natural colonisation and a more gradual increase in tree cover in that way. That is a reflection of a natural process, and I think will greatly enhance landscapes. There will be implications for some individual species, and I think that's where the challenge is. To achieve those climate committee targets does imply a significant change in the Welsh landscape—an increase of a third on existing tree cover. That will have impact, but we have 30 years to do it.
I would build on that and say I think within national parks there is actually a very significant opportunity for natural regeneration and some afforestation in appropriate areas. Even if you look at it on a single article, like water quality, where you're talking about planting riparian edges or you're putting buffer zones in and around reservoirs, if you look at the Brecon Beacons national park, the opportunities that Dŵr Cymru have looked to explore there in order to reduce their energy consumption for removing suspended particulate from water, which could be done by a natural product, which could be done by land management, by tree planting, improved grass management in those locations and riparian planting along rivers and streams—there's so much more opportunity to bring the national parks on board and also to look at greater opportunities. If you are keen to house people, the significant number of houses—140,000 homes delivered by 2038—it's not unreasonable to consider that those will have to be in rural, peri-urban and urban areas. And, if you're delivering housing in rural areas from products derived in those rural areas, then there will be a continued need for productive forests, of productive timber, productive habitat, productive enjoyment and leisure. And I think those actually should be welcomed by the national forest as an opportunity to sustain the communities that live in them.
The bottom-up approach sounds very exciting, as does the agri-forestry, but will it deliver the timber we need to build the homes of the future? Because, if we're going to create eco-housing, it's largely timber based at the moment, as I understand it.
There's a very good co-operative operating in north Wales, which I would recommend that everyone visits, called Elwy Working Woods, who actually do demonstrate how they can deliver this at a local scale. They manage local woods, including some that are in the public forest estate. They have their own saw mill; they build local houses. So, yes, I think it is possible to weave that in, and I think one of the requests of the NDF is: can it create a framework that can facilitate this sort of distributed infrastructure, rather than just focusing on single-site, big-ticket investments? I'm sure Anthony will say more, but forestry needs some infrastructure everywhere.
I think the key thing here is, when you're looking at what you want your forest to deliver, to remember that it won't deliver that without the appropriate management. And what we've seen with several afforestation projects that have been undertaken over the years is that management has not been supported. That lack of management has meant that the trees, the crops, have not come to fruition, have not done what we've expected, which has been through damage from invasive species.
I think every woodland has a role to play, whether it be fibre production for insulation or lignin, whether it be Sitka spruce for graded construction timber, but the key element that comes on that is that we can plant this, we can commit to this, but, unless we manage it, we are not going to get what we expect or what we need. And I think that's something that's missing in the understanding in this document, but I actually think it's also something that's missing in the understanding of the Welsh Government at the moment.
I think we've done a fair bit on your conclusions of the habitat regulations assessment within the NDF, and I think it's fair to say that we've already heard this morning that you conclude that it's too high level, and I know that that's been interwoven in all the things that have been said. Is there anything particular that you, at this stage, want to add to this inquiry this morning?
In relation to the habitat regulations?
My colleagues gave me the short straw on this one. So, yes, I think there are two big things for us coming out of the habitat regulations assessment. Twenty of the 33 policies have been taken through an assessment process. The assessment works by saying that, 'It's all right, there won't be an adverse effect, because here are the mitigation measures that we've come up with that apply to those 20 policies.' From our point of view, there's a need, really, to embed that mitigation into the NDF and to be really clear about what projects and lower tier plans are expected to do to take account of those mitigation measures.
The second thing is that some of the mitigation measures aren't that clear or precise or certain. One of the mitigation measures is, 'Policy 8 will help out because it's creating an ecological network, and that will benefit Natura 2000 sites', but there's nothing in policy 8 that actually says that that's the specific purpose of policy 8. So, there's a need—and I'm using that as an example—to draw the habitats regulations assessment more into the way in which the policies are constructed, so that the conclusions of the HRA really do carry weight and are embedded.
There are also parts of the HRA that we're quite concerned about, or just confused about, because parts of the habitats regulations assessment seems to suggest that more evidence is actually needed before you can conclude that there isn't an adverse effect. So, for example, the assessment of the port of Holyhead policy says something quite marked—it says, 'Unless we do more work, we can't actually say that there won't be an adverse effect on the marine environment as a result of the port development'. So, that's something that just really needs to be gone back on, because either that conclusion isn't robust, or the policy isn't robust. One or other needs to be changed.
The question it raises in our mind is, 'Should more evidence have been looked at in order to produce that assessment?', and that's the sort of question that we would throw back because, as written, it raises all sorts of questions about, 'Well, maybe we need more studies to decide whether there is an effect or not', and, in that case, the policy should be less definitive.
Yes. I'd say that it potentially is deficient, because the NDF says that the HRA needs to be a strong guide to lower tier plans and projects, because it sets out, as Mike said, the mitigation requirements. But, as a point of law, it's not a strong guide—it's not, 'To enable said developments to go ahead, it must—. Any developments that are impacted must undertake the mitigation measures.' So, I don't think being a strong guide gives that sufficient influence to the lower tier plans. It just says 'a strong guide'; it doesn't say, 'You must undertake the mitigation measures', and that is a legal requirement if you're going ahead, otherwise you're going to have to go through the policies—is there an adverse effect, is there an imperative reason for overriding public interest, and potentially, then, going to compensation measures?
And there is the alternatives test as well. I'd say for most developments, it might fail on an alternatives test. For example, a housing development—is there an alternative location to a housing development? Yes, there will be. That's what the local authorities undertake. So, I think the NDF needs to state that lower tier plans must undertake the mitigation measures within the HRA.
Right, I'm going on now to wind and solar energy priority areas and the evidence base that's behind them. And I'm going to ask the RSPB to expand on the written evidence that policy 10 has on developments within those priority areas and only requires—your words—'minimising adverse impacts on protected nature conservation sites and species, rather than avoiding them'.
This really comes back to the point I was making earlier, which is the tension or conflict between the way in which 'Planning Policy Wales' operates, where it gives a presumption that developments should not damage sites of special scientific interest, and the wording in this policy that simply says that, for nature conservation sites, developments must minimise adverse effects. So, there's a clear tension, really, there, and the question that raises is—. My reading would be that policy 10 trumps PPW, and therefore that, actually, has an effect on the protection of SSSIs. And not just SSSIs; it also has an effect on the protection or the safeguarding of supporting habitats for the Natura 2000 sites. Because the policy says Natura 2000 sites are excluded from this presumption, but it doesn’t actually say that the supporting habitat that is also necessary for the Natura sites is also excluded from that presumption.
I think the problem with the policy is that the priority areas have largely been derived on the basis of an assessment of landscape and visual impact. Therefore, the presumption should really only apply in relation to landscape and visual impact in those areas. It shouldn't apply in relation to the biodiversity and the ecosystem resilience, because that has not formed part of the selection process for those priority areas, in my view. And, indeed, Arup's reporting says specifically, 'We haven't looked at biodiversity and ecosystem resilience because that should be dealt with somewhere else.' So, the place where it needs to be dealt with is in the criteria set listed within policy 10, which says what the tests are that developments must go through. So, in our view, there's a need, really, to look closely at the criteria in policy 10, but also in policy 11, and also in the way in which the energy policies in PPW are framed, because, in our view, they just don't work coherently together—they don't run from the evidence, which, as I say, is namely around landscape and visual impact, and therefore they just really need revision and to be refreshed.
I would agree with that. It states that AONBs and national parks are exempt from priority areas, but SSSIs aren't, or even impacts on SSSIs are not. But it's worth noting that national parks and SSSIs are both national scale designations—one for, obviously, mainly landscape, and one for wildlife—but AONBs are not. There are no AONBs in Scotland. They're called something else—'national scenic areas' I believe. So, it's just worth pointing that out.
So, we think that you cannot have a damaging development on a SSSI—I believe they should be sacrosanct. You cannot maintain and enhance biodiversity if you're actually contributing to its decline by building on top of it. I appreciate for this policy it's renewable energy. We've got two global crises at the minute, which are potential global killers. We've got climate change and we've got the extinction of biodiversity on the planet. You cannot offset one crisis by impacting another, by exacerbating the other crisis. So, that's why we believe that, for this policy, the areas of high biodiversity value, including local wildlife sites or sites of importance for nature conservation, need to be included within the policy as no-go areas, because we cannot offset one crisis by exacerbating another.
It's sort of why I asked the question I asked earlier, as well. We're looking at areas through sometimes rose-tinted glasses, in my opinion—it's my opinion—in terms of the designations that were put at that time and in that place. It's sort of leading into this question. And there is, as you say, a real conflict that's going on here, in terms of what we're doing, where we do it, why we are doing it and what we're trying to achieve.
So, we've heard evidence this morning by the wind energy sector that said that just saying, 'You put wind here, it means you're going to get it', and that we need to start looking at priorities. That’s what they said, so we can hold them to it. By immediately saying that there are huge swathes of land where we cannot produce energy—wind energy specifically—are we not overlooking the fact that, sometimes, if what we really want to achieve is green energy, we have to also rethink where we have to put that green energy for the greater good, but also to give the opportunities for those two crises that you've just talked about to work together?
I think there may or may not be a case for that sort of thinking. The evidence base presented for this policy makes no reference to that sort of thinking, provides no evidence about whether there are designations within these areas that might be relaxed or not. We would resist that. We think that our most important sites are essential, really, to reversing biodiversity decline. We did some analysis. The area of SSSIs within the priority areas that have been defined accounts for, I think, something like four per cent of those areas. I can't believe that it's that critical to the priority areas that you couldn't safeguard SSSIs in that area. So, I'm not convinced by that argument, I'm afraid.
The other thing I would say, really, is that, at a strategic level, we should be making these choices about what kind of energy we go for, what kind of renewable energy, within some kind of strategic framework about, 'Well, what are the forms of renewable energy that are going to have the least impact on ecosystem resilience?'. One of the weaknesses in the policy in our view and the evidence base is the need to separate out solar and onshore wind. They're very different technologies. They have very different impacts on wildlife. Our research shows a much greater potential for developing onshore wind in harmony with nature—sorry, onshore solar in harmony with nature. We estimate the potential for, maybe, 160 to 170 GW of onshore solar, but only about a thirtieth of that for onshore wind. But what we lack, I think, is a strategic framework for actually building ecosystem resilience and thinking about biodiversity into Welsh Government's choices around a whole range of energy futures, both in the terrestrial planning sector and in the marine planning sector. But a starting point, I think, here, would actually be to separate out onshore solar and onshore wind because they are very, very different things.
May I make briefly just a much more general point? I think the safeguarding of biodiversity particularly and biodiversity recovery surely must be a strategic priority, and that applies inside priority areas and outside, and it applies to all of surviving biodiversity and not just protected areas. SSSIs, for example, do not work for woodland because only about 10 per cent of ancient woodland is scheduled. So, it is a much more general principle that needs to be established and written into documents like the NDF.
Like section 6 and section 7—habitats and species.
I think one of the difficulties with the priority areas is people may read them like the old technical advice note 8 areas, as areas of search, but they're not written as areas of search, and there needs to be much greater recognition that there are areas in these priority areas that are completely unsuitable because of biodiversity impacts for development, and that applies to priority species and to biodiversity sites. That, again, is one of the big changes that is needed, in our view, to the approach.
I mentioned in this that you could, if the priority areas are kept, create a statement of master planning principles for each priority area in order to align both and create the most bang for your buck in terms of biodiversity and wind resource as well.
Thank you. This session is meant to finish at 11 o'clock. Andrew Davies has got a very important question to ask, so—
I think it's roughly about £27 for a membership of the wildlife trust. Was that your question?
I was going to ask the question—. The NDF channels most development into areas that historically have had a lot of development. What is the risk to biodiversity in those areas that, obviously, have seen quite a derogation in their biodiversity by virtue of having a lot of development targeted at them? What are your views or observations on the current proposals that sit in the NDF?
I think it doesn't necessarily have to be a problem so long as the safeguarding process requirements are actually in place. So, for highly developed areas, again this is why we support the suggestion of a minimum tree cover target, or that sort of mechanism, because, again, evaluate what you have and make sure you safeguard that and then enhance.
So, I think it is possible to envisage a process that actually does retain and even enhance biodiversity, even in quite highly developed areas, and on the other hand, if you take development to less developed areas, there actually may be more challenges because there are greater constraints, because the habitats are more coherent and extensive.
So, to shorten the session, there's no fundamental problem with the proposition I just put to you, because there are mitigating measures that can be put in place. If everyone agrees with that, we can all finish at 11.02 a.m. [Laughter.]
With good green infrastructure planning. Key really is green infrastructure planning, protection of important biodiversity, to make cities more climate proofed and also provide access to nature for people. So, it's kind of a win, win, win.
But green infrastructure needs to be biodiverse green infrastructure. There's no point putting in what I call green concrete, which is just a hybrid tea plant, which is no good for wildlife. If you want to get the multiple benefits and reverse the decline in biodiversity, it needs to be biodiverse green infrastructure, and biodiverse green infrastructure and biodiversity in parks, et cetera. The greater the biodiversity, it's been shown that it actually has better impacts on people's mental health. So, the more biodiversity in a park, the better the green health. And the same has been shown, and it's in our green infrastructure report.
I would also say that you can add, and we'd like to see in this as well, accessible natural green space standards. I can reference the Natural England 'Nature Nearby' document, which highlights them. So, we'd like to see accessible natural green space standards, which includes creating new areas of appropriate green space. For example, just walking in here today, beside the Senedd, there's a patch of land that has got a big 'for sale' sign on, 'please develop here'. But at the minute it's a bit of brownfield land, very low on biodiversity, but that could be used as a temporary biodiversity site and actually create a biodiverse green space in there and a mini park until it's actually developed, and get wildflowers and bumble bees, which are in decline in the UK with several on the edge of extinction. So, you can get an urban green space and get everyone here to go out and sit in the natural green space and enjoy it and soak in the biodiversity and improve your mental health.
There's an easy first step, which a number of councils in Wales have taken, including Cardiff recently, and that's to commission what's called an i-Tree report, which is a comprehensive evaluation of their tree cover. And that's a crucial first step; it tells them what they've got and it tells them what it's doing for the city in terms of the value of the services provided. From there on you can build, rather than doing what Sheffield's done and destroyed their assets.
And there's also a role for building standards, in addition to the green infrastructure. There are opportunities to develop building standards so that you build opportunities for nest sites on new homes and for access for bats. So, it needs to be looked at holistically really to achieve those sorts of things.
One last comment from me before we finish. There's about 1 million households in Wales who have got gardens. If we all planted a tree it would make a big difference, wouldn't it?
Thank you very much for coming along. You've been very informative and, I've got to tell you, please check the transcript. If you're anything like me, when I'm talking to somebody, I turn to face them, and when you do that, you have a tendency sometimes for the microphone not to pick up everything you've said. So, you have to check it for accuracy. Thank you all very much for coming along. It's been very helpful.
bod y pwyllgor yn penderfynu gwahardd y cyhoedd o weddill y cyfarfod yn unol â Rheol Sefydlog 17.42(vi).
that the committee resolves to exclude the public from the remainder of the meeting in accordance with Standing Order 17.42(vi).
Cynigiwyd y cynnig.
Can I move a motion under Standing Order 17.42 to resolve to exclude the public from items 5 and 6 of today's meeting? And can we meet back here at quarter past?
Derbyniwyd y cynnig.
Daeth rhan gyhoeddus y cyfarfod i ben am 11:04.
The public part of the meeting ended at 11:04.