SC(3) CR-Plan 3

Sustainability Committee

Inquiry into Carbon Reduction in Wales: Carbon Reduction via Planning

Response from Coed Cadw (The Woodland Trust)

1. 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?

Coed Cadw is strongly supportive of the commitment in the One Wales Agreement to: "aim to achieve annual carbon reduction-equivalent emissions reductions of 3% per year by 2011 in areas of devolved competence.” We recognise, however, that this aim represents a huge challenges as 2006 figures suggest that Wales is the only part of the UK were CO2 emissions are actually rising. In the view of Coed Cadw, the Assembly will only achieve this target is emphasis is put on all the following areas, in so far as they are under the influence of the land use planning system:

• Cutting greenhouse gas emissions and increasing energy efficiency

• Using renewable sources of energy which achieve genuine reductions in CO2 emissions

• Substituting products and materials that use less energy for those that require high amounts of energy to process such as concrete and aluminium

• Protecting carbon stores

• Sequestration of carbon (taking up of carbon from the atmosphere for example by trees)

• Compensating for residual carbon emissions through offsets carbon offsets e.g. through tree planting

We particularly draw attention to the importance of carbon based land management, managing the uptake and release of carbon dioxide from the land in order to reduce greenhouse gas pollution. Its objective is to conserve and enhance natural carbon sinks and minimise loss of carbon from carbon sources so as to store carbon for the long term, as well as generating renewable products such as wood, which substitute fossil fuel-based products or products whose processing needs large amounts of fossil fuels.

Woodland has the greatest role to play in carbon sequestration¹. The inclusion of paragraphs 5.2.8 and 5.2.9 in the Planning Policy Wales (2002) document (replicated at appendix A) should be of benefit in protecting existing ancient woodland habitat and the creation of new woodland habitat.

The Welsh Assembly Government’s Planning Policy Wales Companion Guide (2006) indicates the need for LPA’s to consider topic based policy on the protection of trees and woodland, however, there is no duty on Local Planning Authorities to include protection of woodland in their revised Local Development Plan documents, or to afford significant weight to the protection of woodlands when taking decisions on applications affecting woods and trees.

We would recommend that a greater duty be placed on Local Planning Authorities to apply Paragraphs 5.2.8 and 5.2.9 and that a system of audit be put in place to ensure that the protection of trees and woodland habitats, which are so vital to the reduction of carbon in Wales.

2. 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?

Local Planning Authorities in Wales need to ensure that they include a topic based policy in their Local Development Plan, in accordance with The Welsh Assembly Government’s Planning Policy Wales Companion Guide (2006), which affords the protection to trees and woodland envisaged by Paragraphs 5.2.8 and 5.2.9 of the Planning Policy Wales (2002) document. In selecting sites for allocation, LPA’s must ensure that such sites do not adversely affect Woodland.

3. 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?

Recommendation 7 is welcomed but the consultation of July 2008 does not seem to go far enough in realising the aims of Recommendation 7. Requiring Local Planning Authorities to include policies aimed specifically at Carbon Reduction in their LDP’s must be more comprehensive than requiring sustainable building standards and localised renewable energy sources. Local environmental factors must also be taken into account, if new development is to truly effect carbon reduction.

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

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

Through the process of environmental appraisal of Local Development Plans, Local Authorities and the National Assembly should ensure that new development, and community facilities, are located in so that they are easily accessible on foot, by bicycle and on public transport. Large scale developments in out-of-town locations create a future, long-term dependence on C02-intensive private car travel.

Greater access by public transport to rural leisure sites such as woods would greatly improve quality of life for those living in urban areas whilst decreasing the number of car visits to woodland. Where transport is planned for new developments, consideration should be given not only to transport links with town centres, retail and employment sites, but also with rural leisure sites such as woodlands and nature reserves.

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

Outcome 17 deals with biodiversity and emphasises the duty on Public Authorities as well as the Assembly Government to have regard to the purpose of conserving biodiversity, when exercising their functions. It should be noted that there are some habitats for which mitigation and compensatory measures are not possible. Ancient woodland cannot be recreated, and once lost, is irreplaceable.

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

Coed Cadw is very supportive of development of renewable energy, seeing it as essential if we are to meet the challenge of reducing our greenhouse gas emissions. We also believe that the features for which important wildlife sites, such as Natura 2000 sites, are designated, should be protected from significant damage due to development. Through the 'Planning Disaster’ Coalition, Coed Cadw voiced strong concern regarding the new procedure for large scale energy projects in Wales, suggesting instead that these applications should be determined by the Assembly though a more democratic process.

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

Annex A

Trees and woodland

5.2.8 Trees, woodlands and hedgerows are of great importance, both as wildlife habitats and in terms of their contribution to landscape character and beauty. Local planning authorities should seek to protect trees, groups of trees and areas of woodland where they have natural heritage value or contribute to the character or amenity of a particular locality. Ancient and semi-natural woodlands are irreplaceable habitats of high biodiversity value which should be protected from development that would result in significant damage.

5.2.9 Local planning authorities should, as appropriate, make full use of their powers to protect and plant trees to maintain and improve the appearance of the countryside and built up areas.

¹ Woodland Trust (2007) Position Statement, Trees and their role in carbon management for land and