Respose by Coed Cadw (the Woodland Trust) to the Welsh Assembly Government Consultation on planning for climate change
March 2007
1. Introduction
1.1. The Woodland Trust (Coed Cadw) welcomes the opportunity to respond to this consultation. The comments that follow are delivered on behalf Wales’ leading woodland conservation charity. We achieve our purposes through a combination of acquiring woodland and sites for planting and through wider advocacy of the importance of protecting ancient woodland, enhancing its biodiversity, expanding woodland cover and increasing public enjoyment. We own over 1000 sites across the UK, including over 100 in Wales, covering a total of approximately 20,000 hectares (50,000 acres). We have 300,000 members and supporters across the UK.
1.2. Coed Cadw is an active member of Wales Environment Link, and we support the joint response to the consultation produced by WEL’s planning Working Group.
2. Key points
2.1. Coed Cadw enthusiastically welcomes the production of this consultation document. We recognise that climate change is not just greatest single threat to ancient woodland, but also one of the greatest threats to the future well-being of all life on earth. The Assembly was right to highlight climate change as an absolutely key issue in the Environmental Strategy last year. It is therefore absolutely right that that this consultation document should be issued, so as to help ensure that the planning system plays a significant role in action to achieve the necessary cuts in CO2 emissions.
2.2. Mounting evidence suggests that the time for action is running out. It is therefore vital that we act decisively and immediately to cut CO2 emissions.
2.3. To assist with the analysis of the consultation, we have responded to the specific questions asked rather than giving only general comments. Where a specific question does not fall within our charitable remit or area of expertise, however, we have not provided an answer.
Responses to specific questions
Q1 Do you agree with the Assembly Government’s overall approach to Planning for Climate Change
The Assembly has adopted some excellent policies on climate on climate change, most particularly in the Environment Strategy. But if these are to be delivered the Assembly has to provide strong and decisive leadership on the issue, in pursuit of its sustainable development duty. The problem that arises is where economic objectives are perceived to be in conflict with environmental policies. The Assembly needs to ensure that all of its own policies are assessed, and indeed reviewed, to ensure that it does not end up positively supporting policies which likely to lead to significant increases in CO2 emissions.
Micro-generation can certainly play an important role in reducing CO2 emissions, but it is only part of the answer. Coed Cadw would go further, in requiring new developments meet minimum standards in terms of insulation, the most efficient use of energy (ie combined heat and power where appropriate) and the incorporation of micro-generation whether this takes the form of photovoltaic cells on the roof, passive solar heating via windows, or the incorporation of wind generators. The top priority should be to reduce energy use as a result of any new development.
Q3 Do you consider that the MIPPS has sufficiently covered the gaps/weaknesses in Planning Policy Wales? If not please specify where the weaknesses remain and how could national policy tackle these?
Basic planning tools make a substantial difference to the contribution that development makes to CO2 emissions. They are well-established but their use in Wales has lagged behind elsewhere. WAG needs to set far stronger policy on these points in the MIPPS:
a. location of development – e.g. mandatory urban capacity studies and strengthening the sequential approach so that development is directed towards sustainable locations before consideration is given to development in less sustainable locations. (The planning system should still recognise, however, that some brown field sites are actually richer in biodiversity than intensively managed agricultural land. It should not always be assumed that such sites are always the most suitable for development.)
b. the mix of uses within an area – allocations that deliver a mix of uses both within themselves and that contribute to reducing the need to travel by creating a mix of uses within an area.
Q4 Do you consider the line between building regulations and planning remains clear even though the links should become stronger?
The Welsh Assembly Government should look to bring together planning, building regulations and the use of measures that require or promote performance above building regulations. e.g. the Code for Sustainable Homes.
Q5 Is the relationship between climate change adaptation and mitigation clear?
In our view, yes.
Q6 Do you agree with the revised objectives and principles in this chapter are appropriate? If not, why not?
Yes. The Stern Review makes a compelling case that has implications for all our land use planning decisions. It is right for the Assembly to make clear that these need be heeded whenever decisions are taken.
Q9 Do you consider this will be achievable? If not, why not? [caring for biodiversity]
Coed Cadw would support this aspiration in principle, noting however that it will require areas to be identified “as important for the ability of species to adapt and/or move to more suitable habitats”. This does pose the question as to how such will be identified, and which species will be taken into account.
Whilst endorsing the sentiments above, Coed Cadw suggests that the selection of any individual species in this context would be entirely arbitrary, and that the planning system would be better to identify geographical areas where there is a high proportion of semi-natural habitat, which is usually associated with a number of important species, particularly ancient semi-natural habitat such as ancient woodland. It is in these areas that all kinds of rare and endangered species have the best chance of surviving and adapting to climate change. In these areas, damage to semi-natural habitats should be avoided, and, where possible, development should incorporate the creation of further areas of semi-natural habitat.
Q12 Having regard to the compendium, do you consider that the proposed policy outlined in 12.9.1 can be implemented? If not, why not?
We believe that these proposals are both worthwhile and practical. We would suggest however that local authorities should be required to implement the standards on CO2 emissions included in new section 12.9 from a given adoption date, rather than simply needing to incorporate them into the development plans when these are update. Why build n unnecessary delay into the system?
Furthermore, it should be spelt out that the MIPPS is a major change of policy that over-rides existing UDP policies, such as those on density, and the presumption that existing permissions will be renewed. The consequences of the MIPPS should be the fundamental re-assessment of existing development plan allocations and unimplemented permissions that come up for consideration.
Coed Cadw (the Woodland Trust), Yr Hen Orsaf, Llanidloes, Powys SY18 6EB
www.coed-cadw.org.uk
www.woodland-trust.org.uk/campaigns
www.epolitix.com/forum/woodland-trust
For further information please contact:
Rory Francis on 01766 832563, email: roryfrancis@woodland-trust.org.uk
