Draft National Development Plan “lacks ambition and leaves gaps”

(Title Image: Welsh Government under Crown Copyright)

Environment Committee
Draft National Development Framework (pdf)
Published: 13th December 2019

The draft National Development Framework (NDF) will set out nationally-important spatial planning and infrastructure needs for Wales until 2040.

1. The draft National Development Framework lacks ambition and leaves some issues open to interpretation

The NDF is one of several planning strategy documents and several witnesses “expressed disappointment” that the NDF wasn’t ambitious enough and failed to set out any policy on certain types of land uses and general infrastructure. Some glaring omissions include plans for a national forest and biodiversity enhancement.

The NDF was said to be fine in a singular context of Wales as a place to live but was criticised for a lack of reference to external relationships; there was also an anticipated clash in the future between protection and exploitation of natural resources (i.e. the impact an expansion of renewable energy would have on the environment).

2. The division of Wales into three regions is described as “crude”

The draft NDF divides Wales into three broad regions – Mid & South-west Wales, South-East Wales and North Wales. Savills described these regions as “crude” and without a geographical context – though it was argued the regions were based on existing economic regions.

Ceredigion Council argued for Mid Wales to be considered separately so it’s not entangled with the Swansea City Deal (in light of provisional proposals for a Mid Wales growth deal).

Strategic Development Plans (SDP), developed on a regional basis, will lie between the draft PDF and local council-led Local Development Plans to deal with planning issues that are not nationally significant but cross more than one council boundary.

One only SDP currently in development is for the Cardiff Capital Region and isn’t expected to be finished before 2025. As the NDF is reliant on the SDPs to an extent, there were worries over how NDF objectives can be met until SDPs are finished.

There was also a notable absence when it comes to housing, with housebuilders arguing there was too much emphasis on affordability and academics saying the target of 114,000 new homes by 2038 might be an underestimate.

3. Decarbonisation has taken precedence over addressing the direct impact of climate change

There was broad support for including decarbonisation within the NDF, but this often came at the expense of dealing with the direct consequences of climate change, such as flooding (inland and coastal).

Some witnesses said there were gaps when it comes to delivering certain policies; RSPB Cymru used the example of improving biodiversity in the NDF, which lacked specific actions for nationally-important sites and didn’t include any obligations for developers to improve nature recovery.

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