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Wales Proposes Underground-First Electricity Lines

Wales consults on prioritising underground electricity lines for devolved schemes, with three proposed exception tests and a January 2027 deadline.

by | 23rd October 2026 21:35 | EnergyPlanning Policy

Wales has opened a consultation on an underground-first planning policy for new electricity lines operating between 11 and 132 kilovolts (kV) within devolved competence. The Welsh Government announced the proposal on 23rd October 2026. It wants underground cables to be the starting point, rather than steel lattice pylons.

The consultation runs until 15 January 2027. Ministers are proposing evidence-based exceptions where underground construction would cause greater environmental harm, be technically impracticable, or make a project financially unviable. Wooden poles could still provide an overhead alternative.

For planning applicants, network operators and landowners, the significance is potentially substantial. The policy would change how the route, technology and cost of electricity lines are justified in planning submissions. I would be careful not to mistake this consultation for a new legal ban: it does not apply to every power connection in Wales.

Which electricity lines would the proposal cover?

The proposed approach concerns new electricity lines between 11 and 132 kV associated with devolved onshore electricity generation projects in Wales. These are typically distribution network connections, rather than the highest-voltage transmission lines moving power over long distances.

That boundary matters. The consultation expressly excludes electricity generation projects themselves, energy storage facilities, transmission infrastructure above 132 kV, and other infrastructure within UK Government responsibility. It does not change the consenting route for those schemes simply because they happen to be in Wales.

The proposed policy would also not apply to electricity lines that fall within existing permitted development rights, or lines consented by the UK Government. Welsh Ministers say they would nevertheless expect UK decision-makers to consider relevant Welsh policy when determining projects in Wales. That expectation is not the same thing as Welsh Ministers acquiring decision-making power over a reserved project.

If you are assessing a particular connection, first establish the voltage, what generating project it serves, the relevant planning or infrastructure consenting route, and whether permitted development applies. The geographic location on its own does not settle the question.

Three proposed tests for overhead electricity lines

The consultation sets out three tests that applicants might need to meet before an overhead alternative is accepted. The environmental test would ask whether burying the cable would actually cause more harm than running it overhead. That could matter where excavation or access works threaten sensitive habitats, landscape features or heritage assets.

The technical test would concern physical feasibility or unacceptable engineering risk. The consultation gives geology and geography as examples, rather than creating a fixed list of qualifying sites. The economic test would require evidence that undergrounding makes the relevant project financially unviable.

These are proposed tests, not adopted thresholds. There is no published rule that a certain percentage cost increase automatically qualifies, and no guarantee that an overhead route would succeed merely because a developer prefers its price. I would expect a credible application to explain its alternatives, quantify its assumptions and make clear why a less intrusive option has been ruled out.

One useful question for a consultation response is how the economic test should handle network costs that are ultimately borne by bill payers. Underground installation may reduce visual impact and some exposure to severe weather, yet bring extra construction disturbance, repair difficulties and expense. The Welsh Government acknowledges that tension rather than presenting undergrounding as cost-free.

What would happen to poles and pylons?

The preferred hierarchy would consider underground electricity lines first, wooden poles next, and other less intrusive infrastructure only where justified. Large steel lattice pylons would no longer be supported for new lines within the defined devolved scope.

That is not a proposal to dismantle existing pylons or prohibit every overhead cable throughout Wales. In particular, household-scale distribution equipment, existing networks and schemes authorised through another legal route need to be assessed against the wording of the eventual policy, not a generalised headline.

For rural projects, route selection could become just as important as the appearance of the supports. The consultation envisages explaining how a route fits strategically planned electricity networks and whether it can be aligned with existing or planned infrastructure to reduce cumulative impacts on communities and landscapes.

How would the policy become effective?

Current Planning Policy Wales, at paragraph 5.7.9, already expresses a preference for underground electricity lines where possible, while balancing that against costs which might undermine an otherwise acceptable project. The new proposal would put undergrounding more firmly at the top of an explicit decision-making hierarchy.

Welsh Ministers propose an Interim Ministerial Planning Policy Statement as the first step. The intention is to incorporate it into the next revision of Planning Policy Wales (PPW). They also propose an Infrastructure Policy Statement under section 127 of the Infrastructure (Wales) Act 2024 for significant infrastructure projects within the Welsh consenting regime.

Applications may currently require planning permission from a local planning authority or Welsh Ministers, or an Infrastructure Consent Order from Welsh Ministers under the 2024 Act. The consultation seeks a consistent policy direction across these routes, but any effect on a live application will depend on when and how the policy is adopted. No commencement date is confirmed in the documents issued on 23rd October.

Practical implications for applicants and landowners

Anyone designing electricity lines for a renewable energy development should pay close attention to the evidence needed at the earliest route-selection stage. That means considering excavation methods, ground conditions, habitats, archaeological constraints, access for future maintenance and the relative effects of different overhead options.

The consultation specifically invites views on trenching, cable ploughing and horizontal directional drilling. Each method can affect the width and duration of works, soil management, drainage and access arrangements differently. It would be risky to treat ‘underground’ as a single uniform construction method.

Landowners may face different conversations about wayleaves, underground easements, reinstatement of agricultural land and continued access to cables. Those are practical consequences to examine, not automatic new requirements of the consultation. The policy proposal does not itself grant rights to excavate across someone else’s property.

The Welsh Government also wants applicants to show consistency with wider network planning. That links this consultation to the work of the National Energy System Operator on strategic spatial energy planning, and to Wales’s own energy strategy proposals. Those wider exercises do not remove the need to justify the particular location and technology of a connection.

Consultation deadline and what happens next

The Welsh Government consultation closes on 15 January 2027. The full consultation document asks 20 questions, including whether the three planning tests are proportionate, what overhead alternatives should be allowed and what evidence would demonstrate that undergrounding is unviable.

Network operators, renewable developers, planning practitioners, rural businesses and residents affected by proposed routes can all provide evidence. Responses are likely to be strongest when they deal with specific environmental, technical or cost consequences rather than treating overhead and underground construction as universally good or bad.

In a written statement on 23rd October, Cabinet Minister Adam Price said he would set out further steps in early 2027. Until the Welsh Government publishes a final policy, applications must still be assessed against the law and planning policy actually in force. The practical headline is clear: more demanding justification for overhead electricity lines is proposed, but the detailed rules remain open to challenge and refinement.

Sources: Welsh Government announcement, 23rd October 2026; ministerial statement, 23rd October 2026; and the complete primary consultation text.

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