SC(3) CR-Plan 10
Sustainability Committee
Inquiry into Carbon Reduction in Wales: Carbon Reduction via Planning
Response from Neath Port Talbot County Borough Council
Mick Bates AM
Chair Sustainability Committee
Cardiff Bay
Cardiff
CF99 1NA
Dear Mr Bates
In response to your letter of the 5th December 2008, the Neath Port Talbot County Borough Council’s responses are as follows:
The town and country planning system offers a powerful means through Local development Plans and determining planning applications to address and deliver development that makes a real contribution to carbon reduction.
In response to your questions:
What particular actions do you think the WAG should be taking to ensure that the land use planning system in Wales encourages greater progress towards the achievement of carbon reduction targets?
Clear guidance that applies across Wales in MIPPS/ TAN and that authorities are expected to apply as national policy is needed. This would avoid differing approaches by authorities, while allowing local discretion in relation to local circumstances. This should address the effective implementation of Travel Plans and look to enforce monitoring and corrective action where necessary. Monitoring and reporting on delivery in sufficient detail that it is auditable in relation to individual developments should be a requirement of the LDP Annual Monitoring Reports (AMRs). This would help engagement with the local community.
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?
Policies should be included in UDP/ LDPs and Supplementary Planning Guidance prepared. Monitoring and reporting via the LDP AMRs (see above) would give an impetus.
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?
A significant amount of development is delivered in Wales through developments that fall below the proposed thresholds (5 dwellings). This raises the undesirable potential for small sites (the majority in rural areas?) not addressing carbon change adequately. It also encourages developers to subdivide developments to duck under the threshold. Following the principles underlying the Community Infrastructure Levy every dwelling and relevant development should make its fair contribution.
What changes do the planning system are needed to ensure that low carbon technologies are introduced more extensively into residential properties in Wales?
See answers above.
What needs to be done to ensure better co-ordination between land-use planning and transport planning?
Delivery of carbon reduction will be delivered (or not) at the local level through individual developments. The LDP and consideration of each application should be the focus, and in turn there should be an audit trail from Transport Strategies through LDPs to how individual applications are considered. There should be a consistent message across all documents/ guidance including the National Travel Plan and Regional Travel Plans.
Does the Welsh Assembly Government’s new transport strategy, One Wales: Connecting the Nation give sufficient emphasis to this issue?
The strategy needs to recognise that apart from major projects (but see below), much of the delivery will be through the town and country planning system.
What are your views on the current and proposed planning regimes for the consideration of large-scale energy projects in Wales?
Energy proposals should be considered as an integral part of delivering a sustainable future for Wales. Major energy proposals should be determined by the WAG and not as at present by DECC or as proposed though the Infrastructure Commission. If the Infrastructure Commission is to take decisions on major proposals in Wales, arrangements need to be put in place to ensure that Welsh policies are reflected in National Planning Statements.
What changes to Technical Advice Note 8 (Planning and Renewable Energy) would you wish to see?
There are a number of problems with the TAN that need to be addressed:
1. The Council does not agree with the principle of concentrating major wind farms within SSA’s. This needs to be reviewed. It is suggested that targets should be given at a local authority level. This would allow each local authority to take account of the contribution that the area is making to meeting renewable targets from all renewable sources rather than concentrating on wind energy in specific areas. In this way, the environmental cost of all forms of renewable energy should be considered and taken into account at a Local Authority level.
2. Notwithstanding point 1, the Arup Study that underpins the definition of SSA’s E and F has been demonstrated to be flawed in its assumptions, viz. that the areas are sparsely populated and have a flat plateau landform. This is not the case as both E and F are incised by heavily populated valleys. The review should reconsider the boundaries of E and F to ensure that the redefined SSA meets these fundamental criteria.
3. Annex D needs to be reviewed to make it clear that refinement of the SSA boundaries can include the removal from the SSA of the significant areas of land that are not suitable for wind farm development due to factors such as wind speed, nationally important constraints and steepness of land, and therefore to remove the reference to them being 'minor adjustments to the SSA boundaries’.
