SC(3) CR-Plan 19

Sustainability Committee

Inquiry into Carbon Reduction in Wales: Carbon Reduction via Planning

Response from RICS Wales

3 February 2009

Mr Mick Bates AM
Chair
Sustainability Committee
Cardiff Bay
Cardiff
CF99 1NA

Dear Mick,

Re: Sustainability Committee Inquiry into Carbon Reduction in Wales: The Role of the Planning System Carbon Reduction

Thank you for the opportunity to respond to this consultation.

RICS Wales is the principal body representing professionals employed in the land, property and construction sector and represents some 4000 members. As part of our Royal Charter we have a commitment to provide advice to the Government of the day and in doing so we have an obligation to bear in mind the public interest as well as the interest of members. As an organization we are fully committed to the urgency and importance of a low carbon property sector.

It is noted that the committee has already accumulated evidence that the land use planning process has emerged as a major barrier to progress. Planning has a vital and catalytic role to play but it is probably unfair to lay excessive blame on the planning system. The consultation work emerging from the Assembly leaves stakeholders in no doubt that the Assembly and the Minister in particular attach the highest importance to climate change. However, the subject is a massive challenge to the Government, regions and local authorities.

The planning system is a major player in the battle against climate change where it has an impact on the built environment, transport, spatial planning and the economy. At least one of our contributors has already made the point that sustainable development is not only applicable to climate change but also to social and economic development. Sustainability must be joined up both in implementation and the associated bodies and organizations.

Half of UK carbon emissions come from buildings and as a result the property sector is now a focus of policy. The Government 'Review of Land use Planning’ concluded that the planning system needed to be improved and recommended further wide ranging reforms to improve the way that the planning system supports economic prosperity whilst maintaining or enhancing delivery of other objectives. Since 2007 at a time when the property market has experienced dramatic change the planning system has been under intense scrutiny.

What particular actions do you think the Welsh Assembly Government should be taking to ensure that the land use planning system in Wales encourages greater progress towards the achievement of carbon reduction targets?

There is currently a plethora of consultation, new legislation, good practice, a number of separate bodies all pursuing energy savings objectives and all producing their own research and activity. In Wales this includes the Carbon Commission for Wales which oversees a number of sub-committees. This is a good thing in itself but it can only be a high level authority i.e. national or devolved government can set the over arching strategy and targets which need to be clear and consistent. The Planning system is arguably the one  process through which change is processed and the role of the planning authorities has to be a controlling and positive one. Perhaps, most importantly, it has to be an informed one.

If the Assembly is to secure enduring progress against UK emission targets the terminology needs to be clear. There needs to be more understanding of how carbon emissions are calculated and the implications of reduction. The process is still shrouded in scientific jargon which detracts from its importance. In terms of measurement there should be common measurements aligned with targets within the UK and the world. In its report 'A Green Profession’ published by the RICS in June 2007, concerns were expressed about the lack of common standards and benchmarking.

Applicants for planning permission should consider how well their proposals for development contribute to the Government ambitions of a low carbon economy and how well adapted they are for the expected effect of climate change. To some extent this has been met by the Update to TAN 12: Design whereby the Assembly Government sees Design Statements as a useful tool for ensuring that the sustainability implications of new developments are expressly outlined within planning proposals.

The Planning White Paper (now Act) has emphasized the fundamental importance of planning in delivering sustainable development in a changing global context. It is central to the delivery of new homes. It supports the business development necessary to create jobs and prosperity and enables the delivery of the infrastructure which provides access to essential transport, energy and water and underpins sustainable communities. Crucially the Act introduces National Policy Statements furthering the concept of Spatial Planning.

Spatial strategy has a vital role to play in delivering patterns of urban growth and sustainable rural development that help to produce maximum use of sustainable transport and reduces the need to travel. The Assembly has promoted the Wales Spatial Plan ’People, Places, Futures’. A particular strength of the Wales Spatial Plan is its attempt to provide a coherent all-Wales spatial framework to all Government policy and activity. Its main feature is the introduction of a number of key settlements as a focus for future development. The document is an on-going project and still demands more work to be recognized as a blue print for future planning in Wales and to ensure that emission reduction and adaptation are a key focus in the overall strategy for each region.

It is increasingly recognized that Planning has a particularly important role in shaping and helping to deliver the energy platform for more sustainable communities. More local renewable and local  low carbon sources of energy will be key to delivering the government target for reducing carbon. The use of sustainable standards and the incorporation of local renewable and low carbon energy sources in new developments will be helpful. However, the renewables industry is still developing and much work remains in finding innovative solutions and raising skills levels in the professions and the construction industry.

The Planning system has a role in creating an attractive environment for innovation and for the private sector to bring forward investment for renewable and low carbon technology and supporting infrastructure. The research capacity in our Universities has much potential to offer innovative solutions and the Further Education colleges can offer much needed vocational skills training in energy efficient construction methods such as insulation installation, solar thermal systems etc.

The Assembly is progressing its efforts to devolve the Building Regulations to Wales which will give more control of adaptations and alteration to property in line with best practice in sustainable construction. This will be a key factor, particularly in dealing with the existing building stock.

What particular actions do you think the Local Planning Authorities in Wales should be taking to ensure that the land use planning system in Wales encourages greater progress towards the achievement of carbon reduction targets?

The Assembly and local planning authorities have a number of key planning objectives which include securing enduring progress against UK emission targets. Targets need to be clearly understood at a local, regional and national level.

Within the framework set by the Assembly the local authorities are on the front line in promoting carbon reduction. Local Development Plans in the course of preparation are an ideal opportunity to reinforce carbon change policy and targets.

The Local authority should:

Promote the highest standard of resource and energy efficiency in new development.

Require land use patterns consistent with reduced travel

Vigorously promote small and large scale renewable projects

Restrict development which has a negative impact on carbon emissions

The London Borough of Merton has been quoted as an authority which demonstrates best practice and local authorities should be encouraged to share good practice with other planning authorities both within and outside Wales.

What are your views on the Assembly Government’s revised proposals for planning for climate change? In particular, do they go far enough in implementing the previous recommendations of the Committee?

The recognition that development proposals should mitigate the effects of climate change by reducing carbon emissions associated with their design, construction and use and include features that provide effective adaptation is to be commended. The aim that residential development should reach Code level 3 of the Sustainable Building Code and all new non-residential buildings should attain BREEAM excellent are positive steps. The 'One Wales’ document has made climate change a top priority and the minister responsible is tackling the issue with a commendable zeal and sought to involve as many stakeholders as possible.

What changes to the planning system are needed to ensure that low carbon technologies are introduced more extensively into residential properties in Wales?

This area is crucial and more so in Wales which has a large stock of older houses and a number of deprived areas containing large numbers of vulnerable low income families particularly in the old industrial areas and the major towns. Planners are constrained in influencing the existing stock unless development requires consent. Wales has already declared its aspiration to deliver carbon zero homes by 2011 and for all new homes to achieve code level 3.

RICS Wales believes that making peoples homes energy efficient should be at the forefront of the battle against climate change and moves towards a low carbon society. There has tended to be a concentration on new development but this forms only a tiny proportion of the total housing stock and the majority of the housing stock will be standing in 2050.

Proposals to extend the permitted development rights for domestic micro generation should be implemented. There is also a need to consider relaxation of planning for community renewable and distributed energy renewable energy schemes (not just for domestic microgeneration) and a need to encourage existing housing stock to link into decentralized  energy generation. All local planning authorities should be required to issue guidance for communities wishing to use renewable energy and should promote this.

RICS Wales supports the Welsh House Quality Standard (WHQS) which has an ambitious target to retrofit the social housing stock. This will entail not only modernizing homes with new kitchens and bathrooms but making them more energy efficient via insulation, new boilers, draught proofing and solar installations. This work will be heavily reliant on a skilled workforce. Refurbishment regulations could be one of the trigger points which ensures energy efficient work is incorporated into the work. Exemplars of homes which have been refurbished and introduced energy efficient standards will be a practical and welcome addition in the promotion of carbon reduction.

This concept could be developed into action areas or zones which widen scope for bulk buying and incorporating low carbon features. Installation of smart meters has particular potential here. However, if such measures are to be advanced it will need training to ensure that planners have the necessary skills to assess and advise on low carbon features. There is a need for training of planners to help them better understand the requirements for renewables and the bigger picture of the contribution that can be made to climate change and energy efficiency.

The introduction of energy performance certificates into the residential sector is currently limited and compulsory only when sales and letting take place but with some improvement to their design they will assist in making occupiers aware of the value in making houses energy efficient

What needs to be done to ensure better co-ordination between land-use planning and transport planning?

Devising effective policies to generate a meaningful reduction is challenging. Transport carbon emissions can be reduced by addressing the spatial relationship between the use of land and infrastructure and developing the built environment to encourage walking, cycling and use of public transport. RICS Wales supports the encouragement of a modal shift to public transport, cycling, walking and using the planning system to reduce the need to travel, particularly in private vehicles.

Does the Welsh Assembly Government’s new transport strategy, One Wales; Connecting the Nation, give sufficient emphasis to this issue?

Whilst supporting carbon reduction it is important that the policy is not centred on urban populations. Rural areas have different issues and fewer alternatives to the use of private transport.

The Wales Transport Strategy 'One Wales: Connecting the Nation’ recognises that much of Wales is rural in nature, and that tourism is vital to the economy of Wales. A balance needs to be struck. A blanket restriction on new development that is not served by public transport may hinder growth in the economy unnecessarily. For rural development, careful consideration should be given to public transport use especially for larger developments, but smaller developments should not necessarily be rejected because public transport options may not be available.

What are your views on the current and proposed planning regimes for the consideration of large-scale projects in Wales?

RICS Wales is generally supportive of proposals to stream-line the planning system. Most concern is in respect of the extensive powers to be granted to the Infrastructure Commissioners who will comprise a single consent regime for projects of national significance such as power stations, reservoirs and airports. RICS Wales views with concern that Welsh policies could be overridden by Westminster. It is proposed that decisions on onshore energy projects of over 50 megawatts (and offshore over 100 megawatts) will pass from the Secretary of State to the proposed Infrastructure Planning Commission.

Such major projects will be rare but it seems inappropriate that a non-elected, independent Commission should be given what appear to be powers of supremacy over the Assembly to decide issues of national significance to Wales. Such a measure will undermine Assembly sustainable development obligations if another body has the powers to sanction proposals which may not be consistent with Assembly policies?

What changes to Technical Advice Note 8 (Planning and Renewable Energy) would you wish to see?

TAN 8 encourages local planning authorities to embrace community owned renewables. However, plans for a speedier process for larger scale installations will mean developers are less inclined to want to work with smaller scale, cumbersome schemes. There is a need to consider relaxation of planning for community renewables and distributed renewable energy schemes.

A better balance between the role of strategic renewable sites and medium sized and domestic microgeneration sites projects is sought. This should include more incentives to encourage energy conservation at a domestic level and more investment in the development and use of other renewables. Any revision should take account of the research and good practice undertaken since 2005.

Finally, there needs overall to be a holistic approach to climate change. RICS Wales supports the Assembly in its efforts to tackle carbon emissions and will support its considerable on-going work.

The outcome of this consultation will be followed with interest. Please do not hesitate to contact me if you have any queries in respect of these remarks.

Yours sincerely

John C. Harper FRICS
Policy Officer
T + 44 (0) 29 2022 4414
F + 44 (0) 29 2022 4416
jharper@rics.org