Sustainability Committee

Inquiry into Carbon Reduction in Wales: Carbon Reduction via Planning

Response from The Environmental Network for Pembrokeshire (TENP)

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Introduction.

1. TENP is an organisation of organisations active in Pembrokeshire all of which have a common theme of working towards a sustainable environment. Our approved policies are set out in Appendix 1.

2. Whilst TENP generally welcomes the proposals set out in the Paper, it makes the following observations -

Page 1 Para 1 of the Report. TENP is not certain that the Planning System is a barrier per se to meeting carbon reduction targets. Inconsistencies in policy drafting and implementation and delays in determining applications are inherent faults of the current system and should be rectified (requiring sufficient staff of an appropriate calibre) in any event not just in relation to the effective delivery of Carbon reduction policies.

TENP does accept however that there is a distinct failure by Planning Authorities to prepare strategies which work towards delivering low carbon / carbon neutral policies and in this sense there is a failure at a local level to reflect an urgent need to meet international concerns regarding the environment. The evolving LDPs should at least incorporate such options - the framework for which is the responsibility of WAG. In this regard the advice to LPAs could be based on that available from the UK Sustainability Development Commission.

Page 1 Q1. Guidance issued to Planning Authorities in Wales should emphasise the need for spatial patterns that

favour public transport corridors
encourage safe routes for walking and cycling

both of which will reduce the need for individual transport by car and hence contribute to the reduction of carbon emissions.

Local Planning Authorities also need to reflect regional transportation strategies (eg SWWITCH) to ensure that local patterns of investment complement existing and proposed investments in rail and road, trains and buses.

It is also essential that the ability to build additional properties in the open countryside and in small villages with limited services and a minimal public transport system is severely restricted as there is an implied dependence on private transport for all household needs and activities - not compatible with carbon reduction policies.

Page 1 Recommendation 1. TENP would question whether there is

a sufficient legislative base within the BR and the Planning system to ensure compliance with Recommendation 1.
appropriate training for Planning Officers and Members on the Planning Committees on negotiations with applicants and, if necessary, at appeal.

It is important in this regard that the differences between the Land Use Planning System and the Building Regulation System are recognised in the Paper and that the different responsibilities for implementation are not confused. Building Regulations involve consistent standards throughout Wales whereas Planning Authorities display a variety of policies within their UDP's and LDPs together with variations in the enthusiasm by which they apply and monitor their own policies. It is of course essential that land use patterns and building construction standards and techniques all contribute to carbon reduction.

TENP would support the preparation of a single Recommendation 1 rather than separate recommendations 1 and 2 with perhaps examples given rather than 'local decentralised sources' (plain English!). An overall target would avoid the sub-division of sites by the developer as a way to avoid the implied higher costs associated with larger schemes.

TENP would also wish to see specific references to the opportunities for LPAs to invoke S106 Agreements / compulsory powers that are likely to be needed to mitigate the environmental / climate change implications of many development proposals. It is important of course that there are national standards set in this regard to ensure that individual LPAs do not exercise discretion and avoid the hard options of zero / low carbon economies.

TENP would of course be pleased to discuss local planning policies with the appropriate organisations at any time, not just at times required by decree..

Page 1 Recommendation 7 - Agreed by TENP.

Page 2 inset point 1. Hopefully the increased standards suggested will apply not only to new build but include conversions and extensions.

Page 2 inset point 3 - what are strategic sites - how are they defined (by the developer and the Planning Authority)? Is this a Recommendation that is equally capable of clear application by the applicant and the Planning Authority?

Page 2 Recommendation 8 Agreed by TENP but with the proviso that the technologies which are given consent provide real long term savings and do not diminish the overall quality of the development - especially if the development is of an 'infill' nature in sensitive locations.

Page 2 Recommendation 7 requires a revised wording to form a positive statement ie " … to ensure that proposals for development are in locations which can easily be served by public transport".

Page 3 Q1. TENP welcomes the drive towards 'making the connections' and reducing the number of strategies thereby ensuring that the different disciplines combine to prepare policies and programmes that are mutually supportive. Regular meetings between transport planners and land use planners is one way of ensuring compatibility of policies and investment programmes.

Page 3 Q3. In TENP's view the supply and best use of energy is a crucial element of strategic infrastructure planning in the UK and in view of the nature of the Wales / England border (including the estuarial aspects) ie the mutual dependency and integrated infrastructure system, the separation of responsibilities between two governments for projects of a strategic / cross-boundary importance would not be in the best interests of the UK as a whole. On this basis the current division circa 50mgw / 1mgw is about right.

Certainly there are often unreasonable delays associated with the current Planning / Appeals regime especially where controversial projects of regional / national importance are concerned. TENP, whilst supporting a strict control of such applications and the associated evaluation processes, would wish to ensure that sufficient time is given for all arguments to be prepared and examined in the public arena under which ever system is adopted.

Note - the absence of reference points in the Paper, eg not numbering the questions, makes formulating responses more difficult.