SC(3) CR-Plan 15
Sustainability Committee
Enquiry into Carbon Reduction in Wales: Carbon Reduction via Planning
Response from Friends of the Earth Cymru
Introduction
Friends of the Earth Cymru is dedicated to protecting the environment and promoting a sustainable future for Wales. We are one of the UK’s most influential environmental campaigning organisations and have 21 local groups working in communities all over Wales. We are part of a network of over 60 organisations across five continents who share knowledge and experience on climate change and its global affects on local communities.
We welcome this opportunity to contribute to this final part of the Committee’s inquiry into Carbon Reduction in Wales. The Planning System has an impact on a wide range of policy areas including housing, transport, energy and the economy. It therefore has a major contribution to make to carbon reductions in Wales.
Local Government is essential in delivering the carbon emissions cuts we need in order to properly tackle climate change. The UK Government has reaffirmed its commitment to the role of local government in addressing this problem:
'Local Government has a pivotal role in tackling climate change particularly through its community leadership role and the range of services it provides……Mitigating and adapting to climate change cannot be regarded as an optional extra for local government; it has been designated a core activity on which action is required.’ (Ref UK Government response to EAC 9th report)
Whilst we welcome the Assembly commitment to the development of renewable energy systems, it is frustrating that planning for large-scale energy projects in Wales continues to be a non-devolved competence.
Inquiry Questions
The Welsh Assembly Government should ensure the development of low carbon communities by implementing the following actions:
Set out a target of 40% carbon emission reductions from the local authority area by 2020
Revising Planning Policy Wales 2002 to ensure that climate change is the primary consideration in planning policy terms
Ensure a recycling rate of 70%, an increase in reuse of materials and an overall reduction of waste
A presumption against incineration for the treatment of residual waste
Retail policy reviewed to included impact assessment, to prioritise local traders, and to build diverse local economies
Sustainable economic policy based on the principles of local and low carbon
Revising the grid in Wales to help develop decentralised power and to share and store renewable energy inputs
Setting renewable energy targets for each local authority, both within the area and its own estate
Assessing the potential for biomass (wood waste/pellets) and percentage of possible energy use from sustainable sources within Wales to inform a new policy on the development of this area (forestry management, collection of wood waste, depots and suppliers, biomass boilers suppliers and distribution)
Local Planning Authorities and Local Authorities in general should be strongly encouraged to implement the following actions to achieve carbon reduction and help create low carbon communities:
Energy policies that require all new developments, and changes to existing developments to incorporate 10-20% on site renewable energy
Developments of over a certain size, either new or those being altered, should be required to incorporate a combined heat and power system (CHP)
Transport policies that require all new developments to provide cycle storage areas and safe walking and cycling access routes, together with an incorporated public transport link
Existing developments, including industrial sites, business parks and housing estates, should be connected to the town centre with safe designated walking and cycling routes
Hard standing in new or altered developments must be permeable and incorporate sustainable urban drainage systems
Pedestrianisation of at least 2 town centre streets to encourage walking and reduce traffic congestion
Sites should be set out in area action plans for the creation of wildlife habitats
Housing policy should require all new development to be zero carbon (as of now)
Housing developments should be planned so as to reduce car use, and be planned around shared central space incorporating community facilities, and provide both individual and shared recycling collection points
In addition to the policy proposals above, the following changes to the planning system would help in increasing low carbon technologies in residential properties:
Energy policies that require all new developments, and changes to existing developments to incorporate 30% on site renewable energy, or up to 70% if biomass CHP can be installed
Developments of over a certain size, either new or those being altered, should be required to incorporate a combined heat and power system
Create a free loan system for the installation of solar powered water heaters and biomass boilers & heating systems in order to retrofit existing homes
Create a local authority fund for retrofitting areas of deprivation, and set up local authority installation teams with attendant apprenticeships and training
For further information, see the Friends of the Earth commissioned report on low carbon housing 'Home Truths’ by Dr Brenda Boardman http://www.eci.ox.ac.uk/research/energy/hometruths.php
We are very disappointed in the Planning Act 2008 and believe that it removes a historic democratic decision-making process, and the local community’s right to be heard and consulted on major infrastructure projects in their area.
The Infrastructure Planning Commission (IPC) it establishes is an undemocratic body and unanswerable to the National Assembly for Wales. In a devolved era it is incredible that this body will have the final say on major decisions that will affect our future energy supply, and developments in our communities.
We campaigned for changes to the Bill including on right to be heard, consideration of climate change and devolving the power on generation stations over 50MW in Wales to the Welsh Assembly Government. The only concession won was that the National Policy Statements (which for energy will be prepared by the UK Department for Energy and Climate Change (DECC) and include Wales) has an obligation to consider climate change.
The Welsh Assembly Government and all parties in the National Assembly have called for this planning responsibility to be devolved and we strongly support this. We would urge the Committee and Government to continue pressure for this power to be devolved. The IPC’s decisions could undermine efforts by the National Assembly to build a low-carbon economy based on renewable energy in Wales.
In the meantime, the Welsh Assembly Government must have written assurances that they:
will be fully involved in the UK DECC’s preparation of the National Policy Statements on energy
will be consulted by developers in advance of any consent application located in Wales
will be consulted by the IPC in its consideration of any project in Wales
In light of the increasing seriousness of climate change, as shown by the Tyndall Centre report 'Revisiting Emission Scenarios in the Light of Post-2000 Emission Trends’ and acknowledged by Lord Stern in the New Scientist recently, Wales urgently needs to move to renewable energy. Whilst a mix of technologies is necessary, onshore wind is the most developed technology and quickest way of achieving high levels of renewable energy without investing in new technology or pilot projects which may take some years.
There should be more flexibility in the TAN8 mapping approach as there are a number of projects and sights which could be suitable for windfarm development outside the TAN8 map area.
Friends of the Earth Cymru, January 2009
References
'Reframing the climate change challenge in light of post-2000 emission trends’ by Kevin Anderson, Alice Bows at the Tyndall Centre for http://www.tyndall.ac.uk/publications/journal_papers/fulltext.pdf
'Home Truths: A Low-Carbon Strategy to Reduce UK Housing Emissions by 2050’ by Dr Brenda Boardman of the Environmental Change Institute at Oxford University. http://www.eci.ox.ac.uk/research/energy/hometruths.php
'Launch Green Economic Revolution now says Stern’ by Catherine Brahic in New Scientist 21st January 2009
http://www.newscientist.com/article/dn16433-launch-green-economic-revolution-now-says-stern.html
