Responding to the Welsh Government NDF consultation: Some Key Points

Responding to the Welsh Government NDF consultation: Some Key Points

THE CONSULTATION ON WELSH GOVERNMENT’S DRAFT NDF CLOSES ON 1st NOVEMBER.

Please see ‘NDF WIND & SOLAR PLANS FOR WALES’ page for an explanation of the draft National Development Framework and its role in Welsh planning, some key concerns about the proposals and links to consultation and evidence documents.

It has proved immensely time-consuming and difficult to first track down and then trawl through the myriad of documents in various locations on the Welsh Government website, and  few of us have the time to do this.  The bullet points below are intended to be a useful and time-saving resource in responding to the Welsh Government (WG) draft National Development Framework (dNDF) consultation. At the bottom of the page is a link to a pdf setting out more detailed considerations.

  • Consultation inadequate
    The dNDF webpage does not link to key ARUP evidence documents, which explain the priority areas (PAs).
    The dNDF is urban centric, and very general except for tightly prescriptive renewable energy (RE).
    ARUP evidence documents contain numerous errors, are poorly set out, demonstrate ignorance of Wales.
  • Lack of Democracy especially for rural communities
    The NDF and regional strategic development plans will override Local Development Plans and remove local decision-making.
    The dNDF proposes large prescribed RE ‘priority areas’ (PAs) across 1/5 of Wales, together with a permissive RE policy – with WG making all decisions for >10MW.
    Rural Wales’ needs ignored.
    RE policy is tailored to the needs of developers.
  • The dNDF sets 20-year policy without providing justification
    There is no discussion of contextual evidence or quantification of cost or consequences.
    Other technologies, including off-shore, target capacity/power generation, reducing demand, are not discussed.
  • Devastating Landscape changes within and beyond Priority Areas & impacts on tourism and well-being
    WG states that landscape change is accepted as inevitable within PAs.
    There is no evidence regarding cumulative impacts.
    There will be visual blight over most of Wales, including parts of National Parks.
    Impacts on tourism and rural amenity are ignored.
    Devastating impact on landscape and on the well-being and livelihoods of rural communities
  • Biodiversity will be severely hit
    Reversing biodiversity decline is every bit as important as reducing greenhouse gas emissions.
    The dNDF will accelerate biodiversity loss.
    The proposed policy 8 is too general for any practical protection in face of unsuitable development.
    Some European protected sites and many Sites of Special Scientific Interest are within PAs.
    Connectivity and priority habitats/species at grave risk.
    We have no confidence in NRW’s ability to protect either designated sites or locally important sites within PAs.
  • Priority Areas are chosen for maximum size, minimum environmental protection
    Permissive methodology for the identification of PAs – poor justification for ‘refined’ PAs which are based on consideration of “fixed constraints” which exclude key environmental protections, relegated to a category “variable constraints”, of less importance in defining PAs.
    Several criteria maps are inaccurate.
  • Unsound Policy clashes
    The ARUP methodology ignores practical technological constraints (wind speed, grid availability, access, populations etc.) and key environmental constraints which inform the AECOM methodology incorporated in Planning Policy Wales and Local Development Plans.
    Areas of Wales are now covered by 3 conflicting RE policy designations: TAN 8 Strategic Search Areas, LDP Local Search Areas and now PAs.
  • Reckless Unfinished Policy which should have failed Habitats Regulation Assessment and Integrated Sustainability Assessment
    Key environmental issues are left for “design guidance”.
    Eleven critical issues which are the subject of existing legislation (EIA, Environment Act, WBFGA etc.) including “protecting and enhancing ecosystems and biodiversity” and “cumulative impact” are not addressed.
  • No Confidence in Fair Implementation
    The recent Hendy Windfarm decision, ignoring Welsh Government’s own Planning Inspector’s findings, demonstrates that WG does not consider it has an obligation to carefully weigh landscape, environmental and social impacts against RE policy.

For more detailed maps of individual ‘Priority Areas’ see Powys and Other Counties. Please advise us of particular problems with Priority Areas near you.

If you would like more detail, please download More detailed considerations pdf here.

We are advised that  Question 15 of the response form should be used for responses which do not fit elsewhere, and that these responses will receive full consideration. If you prefer, you can submit a response by letter without using the form.