Our response to the Net Zero 2035 Challenge Group’s Report “How can Wales meet energy needs whilst phasing out fossil fuels by 2035?”
In September 2024, the Wales Net Zero 2035 Challenge Group released a comprehensive series of seven reports. Commissioned through the 2021 Cooperation Agreement between Welsh Government and Plaid Cymru, these reports offer a forward-thinking blueprint for accelerating Wales’s pathway to net zero, with a clear set of actionable steps for how to get there. Among them, the report addresses the question, “How can Wales meet energy needs whilst phasing out fossil fuels by 2035?”.
In this response, we aim to offer our perspective on the report’s recommendations. Marine Energy Wales’ goal is to support a just, inclusive, and effective transition to net zero, one that fully embraces Wales’s rich marine energy potential.
As the representative body for Wales’s offshore renewable energy sector, we actively engaged with the Net Zero 2035 Challenge Group’s open call for evidence. Our submission highlighted the considerable potential of marine renewables, however this evidence was not reflected in the final report.
Reflections on the Report’s Recommendations
The Challenge Group’s approach is rooted in the Well-being of Future Generations Act. By focusing on clearly defined, actionable pathways rather than ambitious targets, their work sets a new benchmark for pragmatic climate leadership.
We appreciate the time, effort, and commitment of the report’s authors, many of whose recommendations align with Wales’s broader goals and there are numerous valuable points within the report that we fully endorse. We particularly support many of the system-wide recommendations, aimed at reducing bottlenecks and barriers to the deployment of renewable energy.
- One notable proposal is the establishment of a dedicated renewable energy team by 2025, composed of planning, development, and specialist technical advisors. As an independent, arm’s length body of Welsh Government, such a team would be well-positioned to provide impartial advice and tackle barriers to renewable energy deployment. However, while the formation of this team would be an important step, it is crucial that the political will exists to act on their recommendations and follow through on key decisions.
- Marine Energy Wales has long advocated for the introduction of mandatory statutory consenting timescales for planning applications, so we also astrongly support the report’s call to implement these by 2026. The absence of statutory timescales currently poses a significant risk to the commercial viability of offshore renewable energy projects, and this measure would be instrumental in reducing uncertainty and mitigating development risks. However, the report neglects to make calls for increasing funding for Natural Resources Wales, so that the environmental regulator’s human resources match their growing caseload of work to be able to deliver against such timescales.
- Reforming grid access is another critical component of the transition to net zero, and we welcome the report’s recommendations in this area. Proposals to bring forward connection dates and encourage National Grid to pilot a regional energy strategy for Wales are crucial steps. While the Welsh Government already plays an important role in UK-wide transmission reform discussions, we agree that it should take a more assertive role in shaping decisions that will benefit Wales.
- We urge caution regarding the recommendation to devolve The Crown Estate by 2030. While the intention—to reinvest profits and rents in Wales for the benefit of its people—is commendable, we believe there are risks associated with this move that could slow the net zero transition and reduce economic opportunities in the short to medium term. Our discussions with The Crown Estate Scotland have revealed that their devolution process led to a significant period of internal restructuring, delaying external delivery. Given that Wales lacks an equivalent pre-existing team and office, the risks of disruption are even higher. To mitigate these risks, capacity-building efforts must precede any devolution, and lessons should be drawn from the Scottish experience to ensure a smooth transition that supports renewable energy development in Wales.
- Additionally, we caution against an over-reliance on established renewable technologies like onshore wind, fixed offshore wind, and solar. While these technologies are crucial for meeting the 2035 targets, focusing too heavily on them risks sidelining emerging technologies like marine renewables, which will be vital to delivering a resilient and cost-effective energy system beyond 2035.
Tidal stream and floating offshore wind must remain central to a diverse and resilient renewable energy mix in Wales, and we feel a significant body of evidence has been overlooked within these reports – evidence we believe is critical to achieving the ambitious targets laid out. Specifically, we feel the report does not fully account for the transformative role that tidal stream and floating offshore wind technologies can play in delivering a net-zero Wales by 2035.
How can tidal stream help Wales meet energy needs whilst phasing out fossil fuels by 2035?
Ynys Môn (Isle of Anglesey) is at the heart of Wales’s tidal stream energy ambitions. The Morlais project, led by the social enterprise Menter Môn, represents a 240 MW demonstration zone off the coast of South Stack. This initiative aims not only to harness the island’s abundant tidal currents for clean power generation but also to create meaningful economic opportunities for local communities.
Morlais is already well-advanced, with the necessary marine licence granted by Natural Resources Wales, a secured grid connection, and a fully constructed landfall substation. The project’s preparatory works have generated significant economic benefits for the region, and the site is now poised for turbine deployment in the coming years.
What makes Morlais particularly compelling is its open-platform approach, accommodating multiple turbine developers who are ready to demonstrate and commercialise their technologies. With tidal stream now eligible for the UK Government’s Contracts for Difference (CfD) scheme—bolstered by a dedicated funding ringfence—there is a clear and established route to market. In CfD Allocation Rounds 4, 5, and 6 (spanning 2022 to 2024), the Morlais zone secured contracts for 5.62 MW, 22.4 MW, and 10 MW respectively. This cumulative pipeline of 38.02 MW is scheduled to be operational by 2029.
Looking forward, there are six remaining CfD rounds due to take place to allow additional project to be delivered before 2035, each of these providing further opportunities for growth. Assuming similar success in future rounds to the average annual allocation thus far, Morlais could deliver 114 MW by 2035 or potentially more, should the funding ringfence increase in response to industry calls from bodies like Marine Energy Wales and the Marine Energy Council.
While it may be challenging for entirely new sites to progress through all phases of seabed leasing, consenting, and build-out by 2035, there are additional opportunities nearby. Minesto’s Holyhead Deep project, an adjacent site to Morlais, already holds an agreement for lease and an agreed grid connection. If this site continues its progress along the development pathway, it could deliver anywhere up to 80 MW of additional capacity by 2035.
Taken together, these two projects—Morlais and Holyhead Deep—position tidal stream to contribute between 100 MW and 200 MW of renewable electricity to Wales’s energy mix by 2035. This contribution will play a key role in Wales’s transition away from fossil fuels while generating both environmental and economic benefits for the region.
How can floating offshore wind help Wales meet energy needs whilst phasing out fossil fuels by 2035?
The Celtic Sea is set to become a key area for floating offshore wind development in the UK. According to The Crown Estate’s analysis, the region holds potential for up to 12 GW of capacity, with between 4 and 10 GW expected to be leased by 2030, and operational between 2035 and 2040. While these larger commercial-scale projects fall outside the timeframe considered by this report, the contribution of several smaller projects already in development has been overlooked.
To prepare for the larger commercial projects, The Crown Estate has awarded leases for five smaller floating offshore wind projects in the Celtic Sea. These “Test & Demonstration” projects are crucial pathfinders, helping to build the necessary supply chain and infrastructure in advance of the larger pipeline. Of these five, three are located within Welsh waters, positioning Wales at the forefront of this emerging technology.
The Erebus project, a 100 MW development led by Blue Gem Wind—a joint venture between Simply Blue Group and Total Energies—has already received all required environmental permits and is eligible to bid for Contracts for Difference (CfD). This places the project in a strong position to become operational within five years of securing a CfD award.
In addition to Erebus, two other 100 MW projects, Llŷr 1 and Llŷr 2, are being developed by Floventis Energy, a joint venture between Cierco and SBM Offshore. These projects are currently navigating the marine licensing process, and once approved, will also be eligible to compete for CfD contracts, making their delivery by 2035 a realistic prospect.
Altogether, these projects—Erebus, Llŷr 1, and Llŷr 2—could contribute 300 MW of floating offshore wind capacity to the Welsh grid by 2035. This is a significant addition to Wales’s renewable energy portfolio, particularly when combined with the potential contributions from tidal stream energy.
By not fully accounting for the contributions of both tidal stream and floating offshore wind, we believe up to 0.5 GW of capacity that these technologies can provide toward Wales’s net zero targets by 2035 has been overlooked. This omission underestimates the role that emerging marine renewables can play in delivering clean, reliable energy while supporting the decarbonisation of Wales’s electricity grid. By stating that these technologies will not be delivered by 2035, the report risks undermining continued efforts to build a supportive policy and investment climate to help enable their successful delivery.
Conclusion
In summary, while we believe the Wales Net Zero 2035 Challenge Group report has overlooked the vital contributions that tidal stream and floating offshore wind can make to Wales’s renewable energy future, we commend the report’s authors for their ambitious work. The proposals to address systemic barriers and accelerate deployment are forward-thinking steps but require additional development to ensure they deliver their intended outcomes. We recognise that compiling such comprehensive recommendations is a complex task, and we understand that omissions can happen.
Marine Energy Wales remains committed to supporting Wales in its net zero journey and welcomes the opportunity for continued dialogue with the Welsh Government and other stakeholders. We are eager to collaborate on further refining the pathways to net zero, ensuring that all forms of renewable energy—especially emerging marine technologies—are fully considered and leveraged as part of a diverse, resilient, and sustainable energy mix for Wales.