SC(3) CR-Plan 1
Sustainability Committee
Inquiry into Carbon Reduction in Wales: Carbon Reduction via Planning
Response from The Campaign for National Parks
Submission to the National Assembly for Wales Sustainability Committee -
The role of the planning system in carbon reduction
The Campaign for National Parks (CNP) is the national charity which campaigns to protect and promote National Parks for the benefit and quiet enjoyment of all. We welcome the Committee’s inquiry into carbon reduction in Wales and have responded at an earlier stage (rural land use management), although not at all stages in which we have an interest - in particular transport and renewable energy. Therefore we are pleased to have the present opportunity to comment on these matters insofar as they relate to the planning system.
We do not propose to answer every question in detail. Instead we offer some general comments on the interface between planning and transport and planning renewable energy from a National Park perspective for the Committee’s consideration.
In summary, the points we wish to make are:
Planning and transport - as with all areas, but especially in protected areas such as National Parks, the coordination of planning and transport policy has a significant contribution to make in terms of reducing the need for residents and visitors to travel (by car in particular).
Planning and renewable energy - while renewable energy is central to a low-carbon energy future, its development should be pursued in conjunction with and not at the expense of other public policy objectives on the natural environment
We would urge the Committee to:
reinforce the message that joining up transport and planning policy and delivery should be a meaningful and sustained relationship between all relevant parties; and
call for TAN8 to give greater prominence to landscape considerations and encourage the development of specific local guidance on renewable energy
We have set out below some brief background on National Parks and National Park Authorities (NPAs) by way of context to the comments that follow.
Background - National Parks and NPAs
National Parks
Committee Members will be aware that Wales is home to three National Parks - the Brecon Beacons, Snowdonia and the Pembrokeshire Coast. Together these account for 20 percent of the total land area of Wales. They comprise some of the most stunning landscapes in the country and are geologically diverse, including rolling lowlands, forests, moorland, uplands, mountains and long stretches of coastline with associated coastal areas. They provide habitats for hundreds of species of flora and fauna and contain a rich cultural heritage, recorded by many important historic remains.
While the resident populations vary in number (Brecon Beacons 33,000; Snowdonia 26,000; Pembrokeshire Coast 22,500) and settlement patterns differ between the Parks, each can be broadly characterised as sparsely populated with a network of small towns, villages and hamlets, as well as more isolated single dwellings and farmhouses in some areas.
Renewable energy is becoming an increasingly important issue for National Parks, and there are various examples of community or small scale renewable energy projects that have been developed within them. For example, the Brecon Beacons has the first community-owned hydro-electric turbine in the UK, at Talybont on Usk1.
While each National Park has its own special qualities, among the most commonly cited are natural beauty, biodiversity, history, cultural heritage, remoteness, the opportunities they afford for outdoor recreation and enjoyment, and peace, tranquility and the feeling of escape from day-to-day noise and stress which is often associated with more urban, noisy and developed areas. These qualities make the National Parks popular as leisure destinations, and in addition to their small resident populations, the Parks together experience approximately 22 million visitor days annually.2
National Park purposes
National Parks in England and Wales have two statutory purposes: 3
i. To conserve and enhance the natural beauty, wildlife and cultural heritage of the National Parks; and
ii. To promote opportunities for the public understanding and enjoyment of the special qualities of the Parks.
A wide range of public bodies must take these purposes into consideration when making decisions that could affect the National Parks.4
NPAs’ role
NPAs are independent, statutory bodies funded by the Welsh Assembly Government to pursue National Park purposes. They are the sole planning authority for National Parks, with responsibility for preparing local development plans and determining planning applications. Each NPA is also responsible for drawing up a National Park Management Plan - for the Park rather than the NPA - setting out the strategic vision, priorities and policies that will be followed over a five year period.
Response
The planning system and transport
Planning and transport policy are clearly interlinked and both are relevant to National Park purposes - together they have the potential to help conserve and enhance these special areas, make them enjoyable places in which to live, and provide access to and around them for as many and wide a range of people who wish to enjoy them in sustainable ways. Equally, if not managed carefully, planning and transport policy can make living in or visiting the Parks a "high carbon” activity.
In particular, if developed without reference to each other planning and transport policy can be a contributing factor in residents having to travel long distances in order to access everyday services, and can promote over-reliance on the car for doing so. Failure to coordinate can also contribute to a lack of more sustainable transport options than the car for visitors to access recreational opportunities. In these ways, planning and transport policies which are not integrated or coordinated can contribute to a high volume of traffic within the Parks, which itself impacts directly and negatively on the physical environment, as well as indirectly by emitting high levels of carbon dioxide.
CNP believes that the overarching aim of transport provision in the Parks should be to develop and promote sustainable access in ways that protect and enhance the Parks’ natural beauty, cultural heritage and wildlife and, wherever possible, support social and economic well-being for all. In order to achieve this we believe that the following hierarchy of objectives should apply to transport policy within the Parks:
First, and most relevant to the Committee’s present area of inquiry, to reduce the need to travel as much as possible through integration with planning and land use policy;
Second, where travel is unavoidable to ensure that there is a range of convenient, reliable and attractive sustainable modes available to meet the needs of both residents and visitors in accessing everyday services and amenities, popular sites and recreational opportunities; and
Third, accepting that some travel by car will remain necessary in the immediate future, to ensure that it is managed in ways that minimise environmental harm and do not erode National Parks’ special qualities.
In relation to the first objective, NPAs can to an extent contribute directly to achieving this through their planning function, for example by making decisions that support the provision of local services, and by promoting the use of travel plans whenever relevant to any new development (however small) or land use within their area. However, NPAs do not have transport powers so must work with and seek to influence a wide range of other bodies with responsibilities in this area - at national, regional and local level - in order to bring together fully planning and transport policy within the Parks.
As a part of its inquiry the Committee has asked whether national policy, in the form of the new national transport strategy One Wales: Connecting the Nation,
gives sufficient emphasis to the relationship between transport and land use planning. Our response is that while both national and emerging regional policies do appear to recognise the importance of how the two areas interrelate, there is still room for improvement, in particular at regional level where transport policy is currently being developed by the four new regional transport consortia (RTCs).
As the Committee might be aware, RTCs have in recent months been developing regional transport plans (RTPs) for submission and approval by the Welsh Assembly Government. We believe that the RTPs are significant documents at both regional and local level as ultimately all local transport plans must be compatible with them. In contributing to the RTP development process, CNP welcomed general recognition of the relationship between transport and spatial planning and the need to make these work together to reduce the need to travel. However, while some RTCs have from the outset specifically recognised the National Parks and role of NPAs within their area, this has not universally been the case.
We understand that the deadline for producing RTPs has now been put back by six months to allow RTCs to look again at their plans in light of the need to make commitments to transport-related carbon reductions. It might be hoped that this opportunity will result in improvements to transport carbon reduction measures across the piece, including for present purposes stronger provision for the coming together of planning and transport policy at all levels, including National Parks. While only one part of the answer to reducing current levels of car use, traffic, carbon emissions and the resultant threats to Parks’ special qualities, we believe it is an important aspect which must not be neglected.
For our part, CNP will continue to engage with both transport and planning policy development in Wales as opportunities arise, seeking to ensure that the potential benefits of their integration are realised in National Parks. While we are aware that steps are now being taken by RTCs to work with NPAs where this was previously lacking, we would urge the Committee to reinforce the message that joining up transport and planning policy and delivery should be a meaningful and sustained relationship between all relevant parties, including NPAs, rather than a one-off event for the sake of publishing strategies.
The planning system and renewable energy
TAN8 and any associated regional or sub-regional deployment strategy must take into account an area’s landscape capacity as well as its renewable energy potential, and must recognise fully the sensitivity of any nationally designated landscapes and their settings.
We support the development of specific local guidance on renewable energy, for example the information sheet prepared by the Brecon Beacons National Park Authority for individuals considering installing small scale wind turbines on their property5. This can provide a very helpful steer to local communities when considering the location and design of installations. We call on the Committee to encourage the production of such guidance.
An over reliance on large-scale onshore wind should be avoided. This has the potential to overshadow other opportunities, whether for smaller scale wind energy or other technologies. There are significant planning and environmental issues that can reduce the overall potential for onshore wind, which need to be fully considered in any review of TAN8.
The development of onshore wind should be in locations that do not detract from areas with high quality landscape characteristics. Any wind energy development should be of a scale and design that is appropriate for that location and for its landscape setting.
Greater consideration should be given within TAN8 to protecting the landscape setting of nationally designated landscapes, as wind energy developments can have significant visual and amenity effects on them.
The role of National Parks needs to be recognised more explicitly within TAN8 - through appropriate renewable energy development these areas can make an important contribution towards meeting targets. However, we do not consider that Park-wide targets should be set, as the majority of development will be small-scale in order not to compromise the objectives of designation.
National Parks are seen by the Welsh Assembly Government as places where sustainable development is promoted and that can experiment with new approaches, providing exemplars of best practice for wider Wales6. Pursuing innovative renewable energy schemes and publicising these to visitors and residents could assist in increasing the energy literacy of the public and in raising public awareness more generally about the importance of renewable energy.
Campaign for National Parks
January 2009
1 Talybont on Usk Energy is dedicated to promoting the generation and use of sustainable energy, renewable energy and energy efficiency in the heart of the Brecon Beacons and beyond http://www.talybontenergy.co.uk
2 According to most recent data for each Park visitor days annually are: Brecon Beacons 4.2 million; Snowdonia 10.6 million; and Pembrokeshire Coast 7.2 million.
3 As set out in section 5 of the National Parks and Access to the Countryside Act1949, amended by section 61 of the Environment Act 1995.
4 Section 11A(2) of the 1949 Act as amended by section 62(2) of the Environment Act 1995.
5http://www.breconbeacons.org/content/communities/renewable-energy/planning-advice-and-information/wind-turbine-information-sheet
6 Policy Statement on the National Parks and National Park Authorities in Wales, March 2007.
