SC(3) CR-Plan 6
Sustainability Committee
Inquiry into Carbon Reduction in Wales: Carbon Reduction via Planning
Response from Ceredigion County Council
1. 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?
The role the LPA can play in progressing towards the achievement of carbon reduction is dependant on the legislation the Assembly produces. However, the LPA could independently rise to the challenge and encourage and promote low carbon building etc. For any effect to occur within the LPA the relevant Council will need to put sustainable development at the top of their agenda and recognise the difference this will mean to local development etc.
Actions that LPA can undertake should be based on encouraging development that is reducing its carbon footprint. This could be achieved via the following:
Production of guidance notes on the use of renewable energy and low carbon building, use of materials, siting etc. These should be sent out with every planning application form.
Encouraging the development of low carbon development in sustainable locations.
Using local advisory groups (e.g. energy charities) that specialise in providing unbiased information to the public in the use of renewable energy, low carbon building methods etc when applications are submitted for renewable energy or low carbon development. This encourages relationships between the LPA and specialist groups but also will allow the LPA to gain advice on a specialist area.
Encouraging Planning Officers to attend courses etc on the use of renewable energy, low carbon etc. Perhaps even support an Officer to develop this knowledge further so that the LPA acquires some specialist knowledge.
It is acknowledged that the Assembly are currently in negotiations with Central Government for the devolvement of The Building Regulations, thus would enable revisions / amendments to Building Regulations in Wales on energy efficiency, water efficiency, materials, pollution and possibly through the Building Control system the implementation and control of Site Waste Management Plans, this would aid the LPA in achieving appropriate targets of carbon reduction, and more importantly, ensure that proposals are actually implemented during the construction phase.
2. 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?
It is considered that the revised proposals are a good starting point however no indication has been given that the limits set will alter e.g. go up with time. Current proposals state that major development (10 or more dwellings) will be required to reach Level 3 of the Code however no information has been given on whether this level will alter in time so that the 2011 target will be met. Additionally the current proposals do not address the cumulative effect that single unit development will have. When added together this low level of development will have a very large impact.
The thresholds that have been put forward are established on urban areas and therefore many rural counties will not see development that falls within the stated thresholds. Consequently unless the LPA takes the initiative and produces a threshold that is suitable for the rate of development within their areas many areas of Wales will not have to meet the required targets. Therefore guidance should be produced specifically for these areas and how these Counties can reduce their carbon impact.
3. What changes to the planning system are needed to ensure that low carbon technologies are introduced more extensively into residential properties in Wales?
Adoption of the Code for Sustainable Homes with a progressive timetable that will eventually require all development to meet a level within the Code. This Level then should alter in time e.g. 2011 sees all development having to be Level 1 of the Code, development over a certain size to be meeting a higher Level, by 2013 all development to Level 3 etc.
GPDO altered allowing installation of micro-generation technologies to be permitted development.
A simple method of encouraging the implementation of low carbon technologies is ensuring that the legislation/ guidance produced is clear and that the wording is actually encouraging. For example, not saying that technologies will only be permitted if X, Y and Z are met.
4. What needs to be done to ensure better co-ordination between land-use planning and transport planning?
An initial starting point would be the clarification as to whether there are formal consultation procedures between regional transport bodies and local planning authorities, if not this should be made clear. Additionally if it does not already exist formal representation from land-use planners should occur on the regional transport bodies.
As the four transport consortia have now submitted their provisional RTPs to WAG, the opportunity exists for the Committee to scrutinise whether adequate engagement has occurred between the consortia and the local planning authorities (and National Park Authorities) on this issue so that it can recommend that any deficiencies be remedied before the RTPs are finalised.
There also needs to be adequate engagement between WAG and the local planning authorities and National Park Authorities in preparation of the National Transport Plan.
The advice contained in TAN18 as to the submission of Transport Assessments with Planning Applications needs critical scrutiny as it may be regarded as the least carbon-conscious in the UK.
Legislation within England, Scotland and Northern Ireland recommend/ require submission of a transport statement/ assessment form with all planning applications, whereas Wales leaves this to each LPA to decide; and, whilst the threshold levels/ criteria necessitating submission of more detailed transport assessment are approximately the same for Wales, Scotland and Northern Ireland, those of England are significantly more comprehensive.
5. Does the Welsh Assembly Government’s new transport strategy, One Wales: Connecting the Nation give sufficient emphasis to this issue?
The document recognises the difficult challenge that is presented in reducing greenhouse gas emissions whilst also meeting the demand for transport. However although some key actions have been identified within this document it is difficult to assess how these can be implemented in rural Counties.
6. What are your views on the current and proposed planning regimes for the consideration of large-scale energy projects in Wales?
Any decision concerning large scale renewable energy proposals in Wales should be made by a committee set in Wales.
7. What changes to Technical Advice Note 8 (Planning and Renewable Energy) would you wish to see?
It is considered that clarification would be in relation to Para 2.13 which states, 'Most areas outside SSAs should remain free of large wind power schemes.' The TAN then goes on to discuss the need to achieve a balance between wind power capacity and avoiding the spread of wind farms across the whole of a county (cumulative impact) and suggests that it may be acceptable to restrict 'almost all wind energy developments, larger than 5MW, to within SSAs and urban/industrial brownfield sites.'
It would be useful if the Assembly could indicate the types of circumstance which might allow an exception in favour of wind energy development rather than of restraint. If they cannot do so, perhaps the equivocation should be removed from the paragraph.
Additionally para 4.5 makes reference to Energy Advice Reports. With para 6.2 suggesting that planning authorities should be acquainted with, and have an understanding of the various forms of renewable energy technology currently available and should have access to experts when necessary. It would be useful if the Assembly could commission the ongoing formal collation of up to date industry/academic assessment of energy conservation and generation products efficiency, or formally identify and confirm the ability of a specific expert body with this information and supply a source reference in TAN 8 to the collated work/expert body. It is acknowledged that there are experts in the field, such as Energy Saving Trust - but it seems that their resources would not be such that they could readily fulfil this function on a day to day basis at present. If this source were to be developed it could then be quoted in Supplementary Planning Guidance or used as an expert source by LPAs and save considerable duplication of effort across LPAs. It would also remain responsive to the fast-moving market scene on renewable technology.
Para 5.2 suggests LPAs consider the local availability of renewable energy resources. The announcement of research into a Renewable Energy Resources Assessment toolkit with the WLGA is welcomed and the toolkit might be a useful additional appendix to TAN 8.
In respect of Wind Energy developments, TAN 8 should take a strategic view of access considerations, in respect of the capacity of the highway network to facilitate delivery of wind turbine parts to SSAs, identifying preferred routes and identifying pinch points which could then be the subject of RTP Policy for remedy/LDP safeguarding where necessary.
An update on Wales’ position on nuclear energy and the impact of the UK Planning Act 2008 on Wales in terms of competency vis a vis the Infrastructure Planning Comission would be useful.
It would also help if TAN8 contained a statement as to how it dovetails with the Climate Change Compendium proposed in the Climate Change MIPPS in 2008.
It is also considered that further information is required on micro-generation renewable energy technologies, especially if changes to the GPDO do not occur.
