SC(3) CR-Plan 5

Sustainability Committee

Inquiry into Carbon Reduction in Wales: Carbon Reduction via Planning

Response from Pembrokeshire Coast National Park Authority,

I refer to the above Sustainability Committee invitation to submitwritten evidence on the role of the planning system in carbon reduction.

The Pembrokeshire Coast National Park Authority would applaud the Committee for its structured programme of consultation, and it welcomes the opportunity to contribute its thoughts. The Authority would firstly wish to associate itself with the comments of both the WLGA and Planning Officers Society for Wales, but would wish to emphasise the few points below from its perspective.

It is a concern that the Committee has concluded from evidence to date that the land use planning system is a major barrier to progress towards meeting carbon reduction targets. We would see it, rather as an issue of leadership, commitment and empowerment from the top, with the planning system well placed to make a significant contribution to a comprehensive and integrated strategy towards addressing carbon reduction, and Local Planning Authorities eager to play their part. The key to success will be achieving awareness and commitment from the people of Wales and the development industry that serves them.

We would see the following as contributing to such a strategy.

• The need for a decisive national policy lead from WAG, as promised in the last consultation on planning for climate change, action on which has been slow (the original consultation commenced in 2006). This needs to dovetail with a translation of the "2011 Zero Carbon Aspiration" into practical targets with realistic milestones (the equivalent of the English 2016/2019 targets). A decision is also needed on the higher Code for Sustainable Homes levels, and in particular on redefining Level 6 in terms that are realistic and sensible in respect of energy generation.

• Work on our LDP , including modelling using the Three Dragons toolkit, etc, has highlighted the serious questions about scheme viability when factoring in achieving the higher levels of the Code as well as the significant contributions to affordable housing provision and S106 infrastructure charges that WAG expects the planning system to deliver. This is a particular issue in this national park, where the opportunities to provide significant affordable housing contributions through the planning system are limited (even with a 50% contribution from schemes of two or more dwellings). Further guidance is needed from WAG on the relative priorities to be afforded to affordable housing provision, higher design standards and infrastructure charges.

• The urgent need for public and building industry awareness-building on the principles, practices and benefits of sustainable building, something that WAG should lead on nationally, working in partnership with LPAs and others on local awareness programmes. This will be essential to achieving rapid progress on the ground.

• Within such a programme we consider that a strong case exists for the creation of a network of area energy advisory services for householders and businesses, building on the success of schemes such as that piloted here through a WAG Sustainable Development Fund project, REAS (Renewable Energy Advisory Service).

• That sustainability principles should underpin the structure and content of Design and Access Statements as a key vehicle for achieving high quality design.

• Before deciding to introduce further relaxations of planning control over renewable energy and other householder developments WAG should learn from the experience of the introduction of similar relaxations in England and give full weight to the benefits that the planning system bring to improving the quality of development. Where relaxations are introduced they should at least be subject to a "prior notification" arrangement similar to that already applying to certain agricultural and other developments. This would allow the LPA to ensure sensible siting and acceptable design standards.

On TAN8 we would ask for more guidance for LPAs on considering visual amenity, landscape character and biodiversity matters in appraising renewable energy proposals, as there is a widespread misperception within the industry and the public that the promotion of renewable energy should simply over-ride other planning considerations. The opportunity could also be taken to clarify further the extent of existing permitted development rights for the installation of solar panels, as it is often said to us by installers that the present wide range of interpretations taken by LPAs causes confusion to householders and the industry.

We would be happy to expand on any of these points.

Yours sincerely

Ifor Jones
Director of Conservation and Planning