We have responded to the Welsh government’s consultation on its National Development Framework (NDF) and raised concerns about the impact on the landscape and tourism, and the missed opportunities for protecting open space.
The NDF is a new development plan which will set the direction for development in Wales from 2020 to 2040. It contains 26 planning policies concerning development in Wales, 15 apply throughout Wales and 11 deal with planning for three designated regions.
The society supports the policies on green infrastructure and the approach to maintaining and enhancing ecological networks.
But the NDF adds a whole new layer of strategic policy in respect of planning, and all the work done by local planning authorities to deliver local development plans with hard-won protections and community engagement will be undermined.
Says Nicola Hodgson, one of our case officers: ‘The NDF as drafted would have a serious impact on the rights of local communities and their ability to participate in proposals for development.’
The society disagrees with the classification of all renewable energy projects over 10 MW as ‘developments of national significance’. This designation means that local planning authorities and local people will have no say in proposed projects for large swathes of land included in the priority areas for development
It remains unclear how the 11 proposed outcomes in the document can be delivered and there appear to be inconsistencies within the document. The presumption for development does not appear compatible with the seven goals in the Well-Being of Future Generations (Wales) Act 2015 nor the objectives of the Environment Act. The NDF envisages landscape change without proper recognition of the importance of landscape to communities for health and well-being or the impact on tourism and public access.
Nicola continues: ‘There is a missed opportunity: the document should require developers to dedicate land in any development for permanent public benefit, including registering land as a town or village green (under section 15 (8) of the Commons Act 2006), dedicating land for public access (under section 16 of the Countryside and Rights of Way Act 2000) and creating public rights of way.
‘We would welcome more robust protection of open space as such land is vulnerable to disposal and development and policy guidance is not sufficient to protect it.’
The society urges that a new statutory designation for the protection of open spaces should be introduced to allow local people to nominate areas that are important to them. For instance, in England it is still possible to protect open space as a ‘local green space’ under paragraph 100 of the National Planning Framework 2018.