Welsh infrastructure applications now have a clearer checklist for the extra evidence needed when a single infrastructure consent order is intended to carry other statutory consents with it. Planning and Environment Decisions Wales updated its submission guidance on 13th October 2026, and the current page sends applicants directly to Appendix 2 of the application form.
The change applies to large projects in Wales using the significant infrastructure project regime. It does not create a new consent or widen the projects that qualify. Instead, it tells applicants where to find the supporting information expected when their draft order seeks to treat another consent as granted.
That distinction matters because Welsh infrastructure applications can be delayed or returned if they are incomplete. I would treat the new cross-reference as a practical validation warning: asking an infrastructure consent order to absorb a separate approval does not remove the evidence normally needed to justify that approval.
What changed for Welsh infrastructure applications?
The official submission guidance was first published in December 2025. The official page records a 13th October update. Its current wording addresses consents listed in Schedule 3 to the Infrastructure Consent (Miscellaneous Provisions) (Wales) Regulations 2025.
The current wording points applicants to “APPENDIX 2: ADDITIONAL REQUIREMENTS FOR DEEMED CONSENTS” in the official application form.
This makes Welsh infrastructure applications easier to assemble because the evidence checklist is now signposted directly from the guidance. The 12-page application form sets out the checklist across pages 10 to 12 and identifies the evidence which may accompany each type of deemed consent.
The Welsh guidance gives a blunt reason to take the list seriously: “We will only accept applications that are complete and valid.” It adds that missing documents can delay the process or cause an application to be returned.
What is a deemed consent?
A significant infrastructure project can require more than planning approval. Depending on the proposal, separate statutory regimes may control work affecting watercourses, protected species, trees, highways, marine areas, common land or pollution.
The Infrastructure (Wales) Act 2024 allows an infrastructure consent order to include provision treating certain listed consents as granted. In plain English, a project may be able to bring several approval routes into one order rather than secure every consent separately after the main decision.
That is potentially valuable, but it is not an evidence shortcut. Welsh infrastructure applications seeking a deemed consent must identify which consent is being requested and show where the requirements that would normally be dealt with separately are addressed in the draft order and supporting documents.
The statement can sit within the explanatory memorandum. That memorandum must explain the need for the project, identify the statutory powers relied upon and give reasons for every power or provision requested in the draft infrastructure consent order.
Which consents does Appendix 2 cover?
The Appendix 2 checklist is broad. It starts with the general statement identifying each consent to be deemed and then adds subject-specific evidence. The current form covers:
- Deemed marine licences
- Licences affecting seals or badgers
- Archaeological licences for protected wrecks
- Licences to remove deer
- Land drainage consents
- Water discharge and watercourse consents
- Environmental permits
- Greenhouse gas emissions permits
- Rights of way and definitive map orders
- Traffic regulation orders
- Tree works affecting protected trees or conservation areas
- Highway stopping-up and diversion orders
- Consents involving common land
The exact evidence varies. A land drainage consent needs a grid reference, description of the works and a method statement covering installation and maintenance. A water discharge proposal needs plans, discharge and monitoring points, expected volumes and rates, timing, destination and pollution controls.
For tree works, Welsh infrastructure applications are directed to include an arboricultural impact assessment. A traffic regulation order requires the relevant highway authority’s application form. A stopping-up or diversion request needs the Welsh Government form, a bilingual proposed order plan and signposting within the explanatory memorandum.
A deemed marine licence has its own bundle. The draft licence must appear as a schedule to the draft order, the explanatory memorandum must deal with its requirements, and the applicant must provide a statement recording the current understanding with Natural Resources Wales alongside the pre-application advice received.
The checklist does not guarantee a consent
Appendix 2 uses the phrase “may be required” for the subject-specific supporting documents. That means the list should be applied to the facts of the project and the consent sought, not treated as an automatic demand for every item in every case.
Equally, ticking a box does not establish that the evidence is adequate or that the consent should be deemed. The draft order, explanatory memorandum, technical material and consultation record still need to work together. Welsh infrastructure applications remain subject to validation and then examination on their merits.
The governing Schedule 3 identifies the consents that can be deemed. The application form does a different job: it translates that legal list into evidence prompts. Both need to be checked, because the form cannot enlarge the statutory power and the legislation does not supply the project-specific technical case.
Why the timing matters
A valid significant infrastructure project application must normally be submitted within 18 months of Planning and Environment Decisions Wales accepting the applicant’s notification, unless an extension is agreed under the regulations. If an application is found invalid after that period has expired, the applicant may need to restart notification and pre-application work.
That makes document planning more than an administrative exercise. For Welsh infrastructure applications involving several deemed consents, late discovery of a missing ecology method statement, highway form, bilingual order plan or drainage specification could affect the whole submission programme.
The current guidance also tells applicants to send an electronic copy to Planning and Environment Decisions Wales at the same time as each relevant planning authority. Natural Resources Wales must also receive the material where development lies within the Welsh marine area.
Once an application is accepted, the documents are published on the Welsh planning casework portal and one or more Planning Inspectors are appointed to examine it. The Welsh Ministers then make the decision under the infrastructure consenting regime.
A sensible document-control approach
I would begin by mapping every provision requested in the draft order against Schedule 3, Appendix 2, the explanatory memorandum and the submission-document schedule. Each row should identify the legal power, the responsible technical lead, the evidence, the latest consultation response and the exact draft-order provision.
For Welsh infrastructure applications, that exercise helps expose gaps while there is still time to speak to the relevant authority or regulator. It also reduces the risk of a technical report answering one consent regime while the explanatory memorandum describes another.
The October update is modest in drafting terms, but useful in practice. It gives project teams a definite place to find the additional deemed-consent requirements.
The key point is simple. Welsh infrastructure applications can combine important approvals within one infrastructure consent order, but integration does not mean omission. The new cross-reference makes the supporting-evidence trail clearer before a project reaches validation.
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