National Assembly for Wales

Bore da. Good morning. Can I welcome Members to this scrutiny session? Are there interests Members wish to declare? No.

We're moving on to the national development framework: evidence session 1. Thanks to Dr Willmott and Dr Harris for coming along to answer our questions today. Do you wish to make any introductory comments, or are you happy to go straight to questions?

Happy to go straight to questions. 

Yes.

Do you think the balance between the content of the draft NDF and 'Planning Policy Wales' is right? If not, what should we do?

I mentioned in my written summary that I think the overall balances are roughly appropriate. I think we've got a fairly concise national development framework and 60, 70 pages where 'Planning Policy Wales' is actually showing its middle age, if you like, in getting a little bit of heft behind it in terms of its size. In that sense, the balance between the two is appropriate. I think the issue that needs to be explored a little bit further is the extent to which there are statements in the NDF that don't really have any added value beyond what would be in 'Planning Policy Wales'. So, the NDF states that it's a spatial plan, so you're looking for those spatial references, you're looking for that greater level of detail of what goes where, how much et cetera at a national level, whereas 'Planning Policy Wales' is a broader set of statements of policy, and what I see in the NDF are some things that remain at the level of broader statements of policy, rather than having that more developed element that I would expect to see in an NDF-style document. That's broadly my view on that.

Yes, the Royal Town Planning Institute would endorse that as well, and just say that, going forward, having had lots of discussions with people that are responding to the consultation as well, I think for practitioners there will be a need for understanding the role of the NDF compared to 'Planning Policy Wales'. We don't want to repeat what's in 'Planning Policy Wales' in the NDF, so I think that's something that we need to watch out for.

Thank you. Neil.

Good morning. Dr Willmott, can I ask you first of all whether you could expand on the comment in your paper that

'an opportunity to push boundaries in the longer term planning for Wales and in taking action against climate change has not been fully grasped'?

Yes, certainly. This is about—. We very much support all the zero-carbon aspirations and words that are in the NDF; we just feel that we, as a nation, need to go further, really, on this and do whatever we can to address this. So, issues around grid, for example, and decarbonising so we can access decarbonisation measures. So, if you think about issues like cars becoming more electric, then we need more generation. So, we really need to look at decarbonising the grid and taking all of those forward. So, we need to do everything we can. There are very strong policies in the NDF about that in terms of energy generation, but then in terms of climate change, we need to look beyond that as well, and that's the important thing that we're making in terms of biodiversity and looking at strengthening Wales's biodiverse nature as well. It's not just about decarbonisation, although that is a very important part of it.

Also, I think an important part in the NDF is about the transport elements as well, not just the electric cars, but looking at how we plan developments so that people can use public transport infrastructure more and more, so where housing developments are and how you access employment and leisure facilities and education facilities as well. So, it's looking at a broader aspect of that.

And I suppose that comes back to my first comment about the links with 'Planning Policy Wales'—that we need to look at them together to make sure that we do get that read-across and the strength for the issues that we need to address with climate change. And I think we always look at climate change, in zero carbon, in terms of mitigation of climate change, but we also need to look at the adaptation, so linking in with the marine plan, shoreline management and flooding policies as well.

Well, as you probably know, I'm not a fan of the Government's aim to decarbonise and zero carbon, but we're not here to argue that today, but just to take it as read that that's the Government policy. I'm still not quite clear, in concrete terms, exactly how this document is lacking in—as regards the national grid, for example, obviously, the Welsh Government doesn't control that, and feed-in into the national grid is restricted, and that creates also sorts of problems in the generation of power. We've got windfarms that are generating electricity that just disappears—it can't feed into the grid, because they can't get a connection. So, in what specific ways do you think that the framework doesn't supply the necessary ingredients of achieving what the Government's policy is in this respect?

It's looking at that wider aspect. So, I put in the zero carbon and we supported that in looking at how we can strengthen that, but it's about the biodiversity elements as well, because you can do a lot in carbon capture with bogland, for example. There are other experts that can talk about biodiversity, but that is a really important element as well. And I think there's a big role here with Natural Resources Wales and the area statements; they will play a big role in that, and it's very important that we bring those forward as early as we can.

So, we're waiting for other bits of the jigsaw to be created before we can see the whole picture. That's the point you're making, is it?

Yes.

I suppose as a follow-on to that, what the NDF might be is the plan for the jigsaw, if you like, so even if there are things that are beyond the immediate control of Welsh Government, there may be things that we want to flag up and identify for a range of organisations and say, 'This is our vision, this is what we want to do, this is the Wales we want to see in 20 years' time, and these are the missing parts.' So, even if we can't do something about it, we can flag up to other organisations through the NDF that these need resolving if we're going to deliver the Wales that we want.

And have you got specific examples that you'd like to see included?

I don't have any specific examples myself, but they're the kinds of things that I think, 'Well, you know, are there gaps in the network? Are there issues of—? You've got the energy potential, but have you got the lack of connection to the grid and the distribution of that?' So, I don't have specific examples, but they're the kinds of things that I think the NDF would be doing. So, even though it's beyond the Welsh Government's powers, still highlight it as a particular issue that needs people to come together and work on.

Okay. Well, can I ask you also—? Both of you, in fact, comment in your written evidence that the spatial strategy map focuses on what already exists rather than presenting a vision for the future. I suppose you've touched on this in your remarks this morning so far. What would you prefer to see in the map, compared with the one that is part of the framework document?

When you look at the strategy map, you think it's quite schematic; it's not unusual for documents at this level to take some schematic way of illustrating what its vision is. But, for me, it just felt very static in what it was identifying, showing the national parks, areas where growth is planned to go, which is roughly where it's been et cetera. So, I was expecting something that maybe—. To follow on from the previous point, where are the gaps in the network? And because it's taken that very almost abstract and schematic way of dealing with things, it's not then illustrating where things are going. So, you could take that map and think, 'Well, Wales, in 20 years' time may be very similar', but it just doesn't have that dynamism: what do you read off that map that isn't already there? So, if there is nothing, really, to illustrate, then fair enough. But I think just that kind of shape—. If this is a document that's going to shape where things go—it does identify areas where growth will be concentrated, but nevertheless, I'm just looking for something a little bit more detailed in that strategy map. So, it may be illustrating that in a different way.

And there are tensions, aren't there, between the importance of development of small towns and the development of existing areas of high density of population? And the way the map is constructed yokes together areas that are quite distinct and there's nothing much in common. I daresay we'll come to these in other questions later, but, Dr Willmott, do you agree with everything that's been said by—?

Yes, certainly. One specific example I'd give is in terms of transport connectivity as well within Wales. Obviously it's important to look at—we don't want to be just within Wales and just looking internally, but the links with England and the seaport links as well are important. We don't want to lose sight of that. But within Wales, really we're talking about the—I'm talking rail specifically, because that's what we need to look at rather than new roads, although some roads can improve efficiencies—but we're really talking about the railway infrastructure that we have. Can we look at being more visionary about connecting the nation? I was in north Wales for the last couple of days; it's a long journey and it really, whether you go by car or—

From south Wales?

From south Wales to north Wales—the connectivity across the nation is quite difficult, really. So, could we have a vision to improve that in any way?

Jenny Rathbone.

Can I just go back to Dr Harris's remarks? Would you expect to see a somewhat different framing of the question, which is—we declared a climate emergency back in April, and therefore some people would argue you need to start from there? So, what are the strategies we need to put in place to ensure that we become carbon neutral by 2030? And that would be an alternative way of looking at things, rather than describing what we already have with some tinkering around the edges.

I suppose underpinning it, because when I looked at the document, I thought, 'What is the base strategy of this document?' And it is to concentrate growth in urban areas, and that's a fairly straightforward planning policy response to things. So, I think the underpinning idea of moving to carbon neutrality is there, in the sense of that's where the priorities for growth will be. So, in a way, there's much more emphasis on an urban Wales. That's what I think—you know, the concentration of growth there.

What I was looking for in—. Some of what's in there, for example, in terms of renewable energy, is very clear; there's a very strong steer on renewable energy. But that's the kind of thing that you think, 'Well, could you develop something very similar for other policy areas?' The spatial targeting of things—where the real strategic investments are going to be in public transport infrastructure—and to map those and illustrate that network that you want to see beyond what's already there.

There's nothing there about food miles, as far as I recall, which is one of the reasons why we have all these lorries going up and down, because we don't have local economies. They're hugely dependent on organisations outside of Wales.

I suppose, as with any issue that's raised, I have some sympathy for the Welsh Government team that's writing the document on what it is that goes into a national development framework. We have produced a fairly concise document. I suppose the challenge will be to resist saying, 'It doesn't say something about this, it doesn't say something about that', and just to really say, 'What are the priorities that a national development framework can do.'

Would you not expect it to at least flag that up as an issue? Food security, food miles, you know, these are—

Yes, food security is an issue. Where does our food come from? What are we reliant on? What is the food potential of Wales and of its different parts as well?

Okay.

Joyce Watson.

Good morning, both. Dr Harris, you've already started talking about the fact that you expected more mapping of how the different challenges and opportunities identified in the draft NDF affect different parts of Wales. So, do you want to give some examples?

Yes. The section of the document that prompted that comment and that response is section 2 of the NDF and, as somebody had said before, the NDF says it is a spatial plan. And then we have section 2, which is challenges and opportunities, so it talks about an ageing society—a relevant policy issue—it talks about inequalities, and there's a lot of emphasis in the overarching aims of the NDF, drawing from Welsh Government objectives of addressing inequalities. So, we look at that section, for example, and think, 'Well, are these, then, spatial challenges? Are particular parts of Wales more impacted upon by an ageing society?' We could start to think about those inequalities. Well, some inequalities are between places, so we could start thinking about mapping educational attainment, mapping house quality, access to services, health, life expectancy—all these are the kinds of things that underpin that section, so all the issues are flagged and raised, but none of it is mapped in any way. So, we've got no sense of where in Wales are these particular issues of ageing, poverty, access to services, transport accessibility—where are they particularly acute. So, that's what I was wanting that section to be. It's a spatial plan, and yet it takes place entirely out in all those issues that section 2 really starts to talk about. So, that was my disappointment. That's what my wish would be—to see what does Wales look like when you map and you explore how these particular issues, important as they are, affect the different parts of Wales.

Okay.

Could I add to that?

Yes, certainly.

It's an initiative the RTPI was working on a few years ago. We did it in England with Manchester university and we did a project with Cardiff University as well about a map for Wales, and it's about having that evidence base, and not just relevant for the NDF, but for all Government policy, about having that spatial interpretation of what is happening on the ground and how that then should influence Government policy, like educational attainment, like particular health issues and the ageing population—so, looking at that and then changes over time. That would also then help monitor Government policy. So, not just planning policy; we're talking about education policy, health policy, et cetera, as well. So, that would be a really important resource for Welsh Government, in that sense, and everyone in Wales, really.

Thank you very much. Andrew Davies.

Thank you, Chair. I suppose if you were a viewer looking in today and you're hearing 'NDFs' and 'SDPs', you're wondering what you're listening about, to be honest with you, but I'm going to encourage more use of those words now. [Laughter.] I'd like to know how can the NDF work if the strategic development plans aren't in place. What's your view on that? Do you believe that the level of direction with the SDPs—I sound as if I'm talking about political parties here—is the right direction for the overall benefit of the NDF? That's to both of you, that is.

I'm happy to—

You carry on.

I put into my written statement—about a quarter of this document is setting the scene and setting the framework for strategic development plans. So, it is a document that is quite dependent on those SDPs coming forward. So, for example, the reference to establishment of green belts in particular parts of Wales is set out as a requirement, then the SDPs you would be expecting to articulate and refine where that is, and then that might then be refined even further in local development plans. So, there are certain policies in here that are dependent on that plan hierarchy and to cascade through it, so, you'd expect then, 'Okay, well, that's the green belt expectations set in the NDF for south-east Wales.' The SDP for south-east Wales would then say, 'Well, it's roughly here,' and then you might get refinement of its boundaries in a local development plan. So, there is a dependency on that hierarchy of plans working.

The SDP is the bit in the middle. It's interesting to explore, I think, to what extent would a national development framework, in the absence of an SDP, still provide some context and set up the issues that a local development plan could take forward, because those local development plans will be coming forward and being prepared, and some completed, prior to an SDP being in place.

So, it is a hierarchy, and it depends on that. Having said that, the NDF is a development plan document, and it will come to bear on all planning decisions that are made. So, every single planning decision has a relationship to the development plan—sometimes a very clear one, sometimes not—so, the NDF will still have relevance to all that decision making, even if it's in the absence of an SDP. But the way I see it is it has been set up very much as a document that tries to drive SDPs and sets up some fairly clear expectations that they will exist, that that's the way that regional working will take place, and, on some particular topic areas, does give a very strong steer to an expectation that an SDP will include something. So, it is quite dependent, for some of those strategic planning issues, on the SDPs coming forward.

Yes, completely agree with that. We would argue that you only need SDPs in those parts of Wales that have complex boundary movements, if you like, between the local area, so, between the local planning authority areas. So, south-east Wales is a classic for that. So, there are complex movements—people live, work, et cetera across boundaries. So, we feel that the SDP would provide a very important role there, and that is lacking at the moment. We've needed that for a long time, so it's really important that that comes forward, and it's very good to hear that plans are starting to happen to bring that forward. But do you need one in Ceredigion, Powys, parts of rural Wales? Possibly not, because the complexity isn't quite there. So, a local development plan, maybe a joint local development plan, might work in certain areas rather than a full-blown SDP. So, we don't agree that there should be an SDP everywhere in Wales, because they do take a lot of resource as well, and what value would they add in certain parts? Maybe the original idea was perhaps the north Wales A55 corridor, perhaps, maybe around Swansea bay. But some of those could be overcome with joint LDPs as well.

Just on that evidence, you said that certain parts of Wales would most probably get away with not having an SDP. Am I right in understanding that, under what's proposed, they have to have an SDP, otherwise it can be imposed on them? So, it's not a case of it's a pragmatic solution. As I understand it—and I'll happily be corrected—even if it's not appropriate, they have to an SDP to work in unison with the national development framework.

Not in the legislation. The legislation doesn't require an SDP everywhere. It does say in the NDF that—. There is a one line—sorry, I haven't brought my copy with me, but there is one line to say, 'We expect SDPs' in each of those. But, really, is that relevant? Would an SDP for the west and mid Wales region really add anything, for the amount of effort that goes into that? Because we have to remember as well that, at the lower level, when you have an SDP, it's proposed that you would have what they call an 'LDP lite', whether you like that term. So, you'd have less information in the LDP because you'd have the SDP there.

I suppose it's how you interpret that word 'expect', isn't it? Because, at the centre, they could say, 'Right, you haven't put it in place'—albeit it's expressed as an expectation—'Therefore, we're going to impose certain parts of this on you'.

Can I be helpful? Can I be helpful here, Andrew? Under 'Policy 16' it says:

'The Welsh Government requires Strategic Development Plans to come forward in each of the three regions'.

So, the word 'requires' is there.

So, 'requires' rather than—

But Roisin is absolutely right. The legislation simply says a local authority, with part of another local authority at least, can then bring forward an SDP. So, what we've got here is a consultation version of the document that sets out an expectation that's not evident in law. So, it is a change in sentiment from what was established in the legislation to what is now set out here. It also suggests that other forms of regional working are not what is expected to deliver the NDF.

You could also interpret that very sentence as 'within those regions'. So, you could have one for south-east Wales, you could have one for Swansea bay, which would be one coming forward within west Wales and mid Wales, and then the A55 corridor, which fulfils the north Wales region as well. So, you could interpret it as it doesn't cover the whole region, anyway.

I think you're absolutely right on that. Jenny Rathbone.

Yes. Extremely helpful comments, I think, because, having been involved in the Planning (Wales) Act 2015, I think one of the problems we have is that we're just not able to get our policy intentions to stick. The developers are constantly getting round them, so, hopefully, with this new NDF and the other plans that will flow from it, we will have something that is clear that we will do this and we won't do that. So, I just wanted to explore a bit further how much of the interrelationship between the NDF and local development plans or SDPs where they're required is down to turf wars between different parts of our governance or simply just a lack of joined-up thinking.

Oh, that's a challenging question. I wouldn't like to use the words 'turf war'. Perhaps there might be different perspectives, different viewpoints.

Well, yes. That's another way of putting it.

I mean, there will be—. You will look at things through different lenses anyway, if you're looking at it from a national level or you're looking at it from a local level as well. You'll see things in different granularity because you need to, because that's the level of governance. So, that might bring you to a different interpretation. I think, in terms of where you started from then, in terms of getting what we want from these national policies, it comes down much more to about the detail of what happened during decision making. So, it's more about the viability arguments and interpretation of that policy, and how it actually gets interpreted on that. So, I think that's much more about briefing and training—we've argued in the past for statutory training for councillors, for example, that sit on planning committees, so that they really understand it and it's ongoing; it's not just when they first start on the committee, it is ongoing—but also of officers, and having the ability to be able to argue with developers about the viability, and understanding what the policy expectations are. 

And an important part of that is having well-resourced planning services, because, if you're up against it in terms of time, and you're just trying to get things through and you're being harangued on the phone because you're not moving things forward, but you have such a workload because there aren't as many people—. That's just one aspect of it, but that is an important element for getting those policies right as well on the ground. 

Okay. So, how then do we have a planning system that actually—. We need an NDF surely that is not so big that nobody ever reads it, apart from a few good people like yourselves, but that really does set out a strategic plan for the next 20 or 50 years, and then an expectation that the local plans won't contradict that. Is that possible in planning law?

I think it's more about the local development—. The national development framework will look at the big, national issues. And, really, it does give some guidance in there where it says—I haven't got a specific example in mind, but, 'At the national level, we want to see this, and, in local development plans, we'll need to take the more detail of this forward.' So, there are examples of that side of it. But it's 'Planning Policy Wales' that's actually really important in terms of writing the detailed policies at the local development plan level, and getting that detail right about the aspirations and where national policy is taking it forward.

The NDF needs to read across to 'Planning Policy Wales' as well, but looking at what needs to be done at a national scale—so, your big transport routes, the big energy, those kinds of issues, rather than 'Where is the small housing?' and—

No, I absolutely understand we're not about fine-tuning what goes on in each village. But it's really about how we make the NDF stick once we've decided what needs to be in it, rather than local council X decides they want to do something completely different, which is in contradiction with it. Clearly, the Minister has the power to call it in, and say, 'This is in contradiction' but at a lower level—. That's fine with large plans, but, if you have constant erosion of the NDF, with small developments that then lead to something else, these things have a sort of, 'Oh, but we allowed it there, so, therefore, we must be able to allow it here.' 

The NDF, its main—well, one of its principal roles as a development plan will be the plan for making decisions on developments of national significance. So, they are set out in the legislation. So, the NDF will be the decision-making plan, if you like, for taking those big decisions. The other important aspect is—and, of course, that's by Welsh Ministers—the planning inspectorate, so, appeals; so, making sure that that comes through in any decisions that they make. So, they have a big role. It comes further down the line, perhaps, but they do have a big role in terms of enforcing that and influencing that, and during local development plan hearings, et cetera. 

Well, that's one of the biggest problems we have, that planning inspectors constantly overturn decisions that are not in line with the planning Act. 

So, that comes down to training and influencing the inspectors, which is an area that needs to be—

So, that's the—. Welsh Government have got to get a grip on that. 

Yes. 

Okay. Thank you. 

Can I briefly add to that? 

Yes. 

Thinking about—. There is emphasis throughout the document on the NDF being read in conjunction with 'Planning Policy Wales'. The two very powerful things the Planning (Wales) Act 2015, as you said, gives is a status to the NDF that 'Planning Policy Wales' doesn't have, and there's a number of practical implications arising from that. So, local authorities, when preparing a local development plan, have to take into account the policies in 'Planning Policy Wales'. Now, we have LDPs and SDPs being in general conformity with the national development framework. So, there's a strong—. What you've got, as set by the Act, is a stronger steer on that. So, the decisions at local level will be made in accordance with all three elements of that plan hierarchy. So, you have PPW and NDF working together, and the NDF gives stronger legislative teeth in terms of decision-making rules on that. So, decisions at a local level will have to be made in accordance with the development plan, and that development plan has traditionally just been the local development plan. Now it will be three documents bearing down on that.

Okay. So, you're arguing in your document that the work on SDPs is only just starting. Is that a lack of co-ordination or somebody being laggards or—? Because Roisin is saying, 'Well, the one in south-east Wales is coming along.'

Well, starting.

Starting. Well, they've been meeting for some while now—the Cardiff region board. You'd expect this to have become an important part of their work.

[Inaudible.]—Jenny?

I'm sorry?

Is that a comment or a question?

Well, I think it's a question to Dr Harris. I mean, maybe you're in agreement. I thought you were arguing slightly differently to Roisin.

I suppose what we have is we have the working out now in practice of what was designed in the Planning (Wales) Act of a three-tiered development system. We have one of those tiers well established—the local development plans. The national development framework is coming forward. You've got that bit in the middle—the SDPs, and they're very different. Because when you asked the question of Roisin about politics, it struck me that what is distinctive is that you've got a Welsh Government leading on the NDF, you've got local authorities leading on their LDPs. Who is it that produces the SDP? Well, it's a collaborative endeavour, and so the politics of it is very different as well. So, how that will come forward, because I guess it's going to be more of a consensus, compromise and negotiated outcome between local authorities, which is not the same as producing your own local development plan—

Okay—

Sorry.

Sorry—I thought you'd finished. I was just going to say 'thank you'. Andrew.

Can I just ask very briefly: you just gave us a taste of the pyramid there that has been developed or is being developed—? Just a simple question: will local decision making be weakened or strengthened by this architecture that's being put in place? Because, for most people, that's the key question, isn't it? From the way you describe it to me, it sounds as if it's going to be very much a top-down approach, and, actually, rather than strengthen local decision making, this whole system will weaken local decision making.

I suppose you need to think very carefully how you respond to that. I don't think it weakens local decision making. It certainly gives more status to the policies and intent of Welsh Government when making those local decisions.

So, it will weaken it.

Well, it doesn't necessarily mean it's weaker, in my view—

But the decisions are coming from the centre—

But we've always had—. As I said, we've got 160-page 'Planning Policy Wales' document, which gets serious traction in decision making, whether that be locally or when those decisions are made at appeal. But what we have and what was the intent behind the planning Act was to strengthen the status of what it is that Welsh Government produces, when making those local decisions, which was one of the disadvantages, seemingly, of the Wales spatial plan—a predecessor to the NDF, sort of—which was that there was a requirement to produce it, but it had no particular status in decision making. So, that was the fix in the planning Act—to enhance the status of that tier of documents. So, whether that seemed to weaken local decision making or whether it just said that, actually, stronger consideration of what it is that are the Welsh Government's priorities as expressed in the NDF when making planning decisions at local level—that's probably how I'd see it.

If I may add in that I don't see it as weakening the local level. Actually, we feel that it's missing at the national level in terms of a development plan—having that national spatial development plan—since the Wales spatial plan's demise, or whatever. We need that and that is missing in Wales.

Okay, thank you. I'm going to move on to talk about the three-regions model. I know that Dr Harris has said that

'the risk is that the regions do not make sense…for planning and development purposes.'

Are you sure it's only a risk? I don't see Machynlleth having a lot in common with Morriston, and I certainly don't see the people in Welshpool looking to Port Talbot as part of their local region. You have previously argued for something that I fully agree with—the four-region model. We've already got the Swansea city region set up there, which works quite well, with people settled into it. Tacking on Powys and Ceredigion, which have already got their mid Wales growth region—I see that as not particularly advantageous. Would you agree?

Yes, I have two comments to make in response to this. Certainly, yes, we did a piece of work. I and colleagues were looking at all sorts of different aspects of how Wales works, its functionality, its policy context, and you can carve regions as you wish to. Our proposal was for four, and I think four still makes sense, so I think nothing has happened to make me change our view about what we produce for Welsh Government, which was to recommend four regions in an NDF.

The second point is my disappointment that what has come forward are three regions that are just picked out of economic development areas. To come back to the point about declaring climate emergency, thinking about the whole range of issues that are in this document—strategic green infrastructure, ecological networks, travel to work areas, all those types of things—and then we collapse to three regions that are defined for economic purposes. So, that's my disappointment. What does that then signal about the role and the underpinning of the NDF, if we've got this great opportunity to think about how the different parts of Wales work in all of the sectors, themes and issues that impact upon the different parts of Wales, and yet we've prioritised a particular formation of a region? And, as you say, I have sympathy—when we've looked functionally at how different parts of Wales connect, then we've got one of the regions that just doesn't seem to speak to the regional geographies of Wales.

I think we could debate all day, couldn't we, three or four regions? They've picked three; I think, kind of, move on. But I suppose the question is Powys and Ceredigion—are they a region in themselves? Geographically, they're large, but do they warrant being a region? What does that mean? So, we're happy to move on with three, but we know that there is evidence for four. But I don't think it's a reason for weakening the NDF in that sense. We don't feel strongly about it, but we can see arguments for there being four regions.

Thank you very much. Before I call Andrew Davies in, can I welcome a delegation from the Parliament of Maldives, who've come in to see us in action? No pressure, Andrew. [Laughter.]

Welcome. I just want to touch on the housing numbers. In our briefing last week, officials highlighted how they've settled on this 8,300 mystical figure. I'm just trying to work out—they did say it was led by science, and it wasn't a figure they'd plucked out of thin air, but what are your views on the way that the housing numbers are created, and obviously set in stone, basically, in the document? Because speaking from a political point of view, I'm a regional Member, I have three local authorities—I declare an interest as a member of one of those local authorities—I know locally what a vexed issue this is, that these figures seem to materialise and then they're told they've got to develop their local development plans around them. So, I'd be interested to know what your thoughts are on the number of 8,300, and in particular they've raised the number of social housing to nearly 50 per cent in their equation, looking at the numbers.

Housing numbers—it's always a challenge. I think it's wrong to have the number specifically in the NDF, because numbers change. This is a 20-year plan with five-year reviews. Over that five-year period, numbers will change. Life changes, if you like. So, estimates and assumptions of people's movement, birth rates, death rates—everything changes. Sometimes, Government policy can influence that as well. So, I think it's important to have—and I understand that there may be a move to move the numbers outside the NDF so it's more of a living document. So, that might overcome that issue. There is a move to a new calculation method. I think it's referred to as the Scotland model, because it's work that the Scottish Executive have—

I think that's the model they've used. If I understood the answer I received from officials last week, that's the model they used to arrive at this figure of 8,300.

I'm afraid I'm not expert enough to go into the detail of the Scotland model, but it can be more reactive. I think local planning authorities are—it's not a change in the fact that the numbers change as they're developing their local development plans. We live in that system now when population projections change continually. I think it's about how that's handled for LDPs as well. If you're at the date of submission and a new figure comes out, how do you deal with that? That's a process issue, I think, about how that's dealt with, in that sense.

Did you want to say anything on that, Dr Harris?

Yes, I just think that this is a constantly moving ballpark figure. Again, going back to that plan hierarchy—

You see, I didn't get the impression from officials that it was a moving feast—this was the figure and this is what they're working to. I agree with you—it is a moving feast, as such. Populations go up and down, people move around and we know we've got a deficit in housing numbers. Does this number merely put us in a place where, going forward, we will build enough, but we won't make up the deficit? All of those things need to be taken into account. My line of questioning is trying to elicit from you some observations that would say that it does need to be a constant—[Inaudible.]—and I think I'm getting that.

Going back to that issue of the plan hierarchy, if you've got an NDF, it might set out some broad figure that, two or three years down the line, we've got an SDP and a different set of household projections going there and different demographic data, then when we get to an LDP—. When you get to the LDP, which is when you start designating sites, that's the pinch point in things—that's when everything becomes very real on the ground, and that's when you're going to have to churn all of this data. So, you might say, 'Well, actually, yes, there's a figure in the NDF, but we've got plenty of evidence that in the two or three years since the NDF was published that we do this.'

The question does raise for me a wider issue around the expectations in relation to the evidence base that you see and the transparency of it for an NDF. The NDF is a development plan document, or will be, having the same status as the local development plan. For me, that's set up a lot of my expectations around what it is that this document is and how it will be prepared. Now, it's not the same process of preparing as an LDP—the local development plan—but it's the status of it. The equal status in law of those two documents does set up a series of expectations.

So, the evidence base—. If you're scrutinising an LDP, you've got an inspector really going through it with a fine-toothed comb. What does the evidence base—? How transparent is it? Can I see where this information has come from? That's not quite there in as robust a way, for me, as I expect it to be there, and as inspectors expect it to be there, for a local development plan. So, it leads to these kinds of questions of, 'Well, how has it been arrived at et cetera, and what is it? Is it a target? Is it a statement of intent? Is it some broad statement about where we are now?' It comes back to that point of where we're going to be in 20 years' time.

One small supplementary, if I may: you introduced the words, 'Is it a target?' More importantly, local authorities look at it as an obligation, so would you interpret it as being an obligation for the authorities to meet that target or—?

I suppose everything will depend on what stage you are at in the preparation of your LDP. If you've adopted one recently and you've got a very clear evidence base for meeting local housing needs et cetera, then you'd maybe take this into account, but, as I say, on the process of plan preparation and that kind of cascade or hierarchy, I would suggest that whenever you are preparing a plan, at local level or SDP level, all of this data is going to have moved on quite significantly. We've done some work that shows that, actually, the basis on which this data is calculated is quite spiky, because what we're doing is, often, projecting past trends to come up with future figures, so it's very variable based on those trends.

When you're preparing at a local development plan level, there are so many factors to take into account that you take into account that and say, 'Well, if that's what the statement is in the NDF target or obligation, or however it's interpreted, we've got our evidence here—we start there, maybe, but then we move rapidly on to look at a range of other factors, which might mean that's now well out of date or that there are local factors that we need to take into account that lead us to depart from that.'

Thank you. Jenny Rathbone.

Speaking of housing, you argue, Dr Harris, that we ought to have a map of where public sector landholdings are. I can see that that would be very useful for all of us, but I can also see it being very useful to developers who then instantly snatch up land around it that they think will become more valuable as a result of seeing all this information. I mean, is that a worry or can they get hold of this if they do the work anyway?

I hadn't extended it into a worry. The point I was making was that, if you've got the idea that you're trying to encourage more sustainable patterns and more sustainable urban form, you're trying to address climate change, you're trying to ensure good accessibility and non-car-based mobility and you want—. And then you say, actually, 'We've got land somewhere'—but where is it? Is it in a place that is going to support this objective of a more urban-focused development? So, that's what I was wanting here: you've got your objective on the one hand and then you say, 'We're going to use our landholdings'. The first question I want to know as a spatial planner is, 'Where is that land? Is it located in places that are going to help me deliver that policy objective?' Now, the broader question is: will the house builders start to speculate around that? Well, I suppose what we want to know— the first question is: is that publicly-owned land that might help to deliver more affordable housing in the right places? And I don't know that from this document. So, I'm already starting to raise questions about how well will that ownership of public land support the housing and other development agenda that's in the NDF.

Okay, but you can see the dilemma: the minute we publish metro lines, the developers buy up all the land around the new stations. 

The same thing happened with motorway junctions. Joyce Watson.

I'm going to ask you for some views on wind and solar, but, before that, I just want to keep on this land ownership theme, because you've talked about it in terms of housing development, but, of course, underpinning everything, we've got the Well-being of Future Generations (Wales) Act 2015 and we've got large-scale landholdings that are currently mostly farmed or land-managed. So, could we not also look at tracking some of those? Would it not be useful in terms of the wider thinking, which is the climate change, the food production that Jenny's talked about, and delivering—? Because you said there was a lack of big policy ideas that should be underpinned, then, within the national development plan. So, could that not fit with that? Because I find it—. I've asked around and not an awful lot of local authority councillors have any idea of the farm holdings of their authority.

Yes. I think I'd go back to the start—I want to know where this land is, and I want to know what purposes it might serve. That might be housing. That was the first example that came to mind. You've got an agenda of delivering a significant proportion of new housing as affordable housing, 47 per cent. That's high, and using publicly-owned land to try and help deliver it, great, but where is it? And, if it's not in a location where it's suitable for housing, what other things might it be useful for? And some of those things that you raise may well be—. So, how can we use that to help deliver other aspects of the NDF? So, other aspects of the NDF about developing ecological networks, about—. I floated the idea of a national forest. Okay, well, again: do we own the land in the right places to help deliver those kinds of things? And the first base thing is: where's that land? You've said it's important; where is it? That's what I want to know.

Okay. Thank you. I'm going on now to views on appropriateness of the wind and solar energy priority areas—probably one of the most contentious things I've ever had to deal with in mid Wales. So, what are your views on the evidence base behind those priority areas?

The detail that we've been fed by people who are experts in this area is that there are potentially some faults with the evidence in terms of buffer zones around settlements. So, there's an accepted buffer zone. So, actually, most of the priority areas may not be able to be developed in practical perspectives. So, that is something to look at. I believe you're having an evidence session with people who are more expert in this area than myself on the specifics of that. I suppose we have these priority areas because of the technical advice note 8 situation, and that has worked relatively well in terms of you know where there are no-go zones, national parks, areas of outstanding natural beauty, for example. So, we have that kind of, if you like, culture established already within Wales, so this is taking it further, but whether we need to look at it in a slightly more granular way—. For example, one argument is that perhaps we use a criteria-based approach, which might look at things, which would certainly cut out things like the national parks and AONBs but be able to get around this issue about the buffer zones—so, providing more detail within the priority areas.

Okay. But there are things that could be done, of course, within national parks and AONBs beyond wind turbines, because I know that's what most people will be thinking of, so we might as well put it on the table. But they are considerable landholdings and they could be considered for delivering other aspects of renewable energy. So, do you think, in those terms, that there's a potential missed opportunity?

Certainly, because of that culture of TAN 8, or that principle that we thought we've already got from TAN 8, windfarms are the—have come forward. I suppose because we're looking at the national level—so, what are the national schemes, what are the big schemes—that is why there's so much on the windfarms and, of course, solar farms have come on as well. There is obviously the potential for other renewable energy. Is it at the scale that we need it at the NDF? There is mention of it. There are obviously many policies within 'Planning Policy Wales'. Are they more—? So, for example, hydro schemes, I don't think we're looking at any huge hydro schemes in Wales—I might be wrong—but mainly more smaller ones, so are they more at the local level? There's certainly national policy in place for the smaller renewable energy schemes, but, yes, we certainly need to look at those.

Okay. I suppose the next obvious question is the one that arose just after I was elected, I think: what are the challenges in translating the areas that we've got mapped out, of course, into the actual developments on the ground?

Well, I have pointed to one potential issue that's been raised with us. So, that is one aspect. Obviously, communities are very important in all of this, and you've made reference to that already. There is a general—. For many communities, they don't like the big windfarms, but I have been to communities in Wales that are directly affected by big windfarms, and they're quite happy with them. They get some benefits from them, but, apart from that, after the construction phase, they aren't overly affected by them and are quite happy to live alongside them. So, there are—. Sometimes it's the fear of development, which is perfectly understandable. So, I think we need to work with communities in terms of understanding the impact of that, because what are the alternatives? Living next to a big coal-fired power station. I'd rather live next to a windfarm than one of those. But there are—we do have to understand community issues as well.

Absolutely.

Just very quickly, a follow-on point: TAN 8 was always unusual. Something that was in technical advice, which is subservient to your planning policy, now seems to have found its proper home in a national development framework. And it was one of those areas of the NDF where I thought, given what is stated upfront about the policy objectives, then this is actually grappling with the real thing, the real challenging question, at a national level, of what it is that you locate where at a strategic level.

Okay. Can I call on Neil Hamilton? And then Llyr wants to come in as well, unless you've got another point you want to make, Joyce.

Yes. The national grid is the obvious one. That was one. How are you going to connect all this to the national grid since a lot of it is located in the mid Wales region, where the grid's about to fall over anyway, so we've been told by other experts? How is that, in your opinion, outlined in the national development framework and then 'Planning Policy Wales' in terms of trying to deliver that?

I suppose the only response I can give to that is one I highlighted earlier—that I expect this map to show the pinchpoints. I want that spatial representation of where it is in Wales. That is, there are bottlenecks in terms of us delivering what it is we want to. If they are connections to the grid, then let's see that mapped out as to where they are, so that we can start understanding where they are, how that might impact on other policy areas, and start to address them.

Okay. Thank you. Neil Hamilton.

I'd like to take you up on what you just said about taking communities with us, and how it's the fear of development, rather than the actuality once it's occurred that people—

Sometimes.

Sometimes, yes. Because I haven't found a single community as yet—I represent the same area as Joyce, Mid and West Wales—that is happy to live next to a windfarm that has actually been constructed. They accept it as an established fact, in a kind of resigned way—'There's nothing we can do about it.' But I was at a meeting near Builth just a few days ago, which was convened by the local county councillor, but with all the community councils as well, and they're massively concerned about the implications of this plan for rural areas and, in particular, being tacked on to Swansea and Port Talbot, with which they feel they've no affinity geographically or in work patterns, transport or anything, and that their interests as a rural community are not going to be properly protected by the kind of map that has been produced, the three-region model, and, secondly, that where these wind developments are going to take place is going to be in their areas, not in the urban areas. I was in Scotland last weekend, driving from Glasgow down to Carlisle, and I was amazed, actually, at the landscape, because I hadn't been on that road for quite a long time, and it was absolutely afforested with windmills. Tourism, of course, is an important earner in mid Wales, particularly, and the landscape implications of this are very significant. So, people are worried at different levels about this, and there are conflicting policies here that have to be reconciled somehow.

And that will—that should be done at the detail of a specific proposal. I think this—. This is an indicative map. I've pointed to that there may be issues in terms of the specific areas. But it is at the detail of a specific proposal, when that comes forward, that these very issues are considered—are there particular landscapes? But we do need to find a way of producing our energy that is decarbonised, and how can we take that forward? I suppose the other aspect, which the NDF can't tackle wholly, is we all need to reduce what energy we do use in the first place, and then we need less as well. We can talk about having electric cars, which, hopefully, would come from a renewable source, but, actually, if we all reduce the amount that we drive in the first place, then we'd need to produce less electricity to drive those cars as well, and that is something that's in the NDF and in national policy, about having more walking and cycling, and living our lives, wherever possible, where you can rely on that a lot more. So, we will need to make that shift across as well, so—.

I think it needs a lot more than policies on walking to achieve any significant difference—I think this is all fantasy land, actually—in terms of the volumes that are required. The National Farmers Union put out a press release last week, for example, to say that, to reach the Government's objectives, you'd have to afforest an area the equivalent of 1,400 farms in Wales. I don't know how many farms there are, but that's a very significant proportion.

It's Carmarthenshire.

Is it?

It's the size of Carmarthenshire.

Yes. So, we have to be absolutely clear that what we're doing here—. And the national development plan needs to present the facts about what the implications are, for people to be brought along with the Government and not just find out— that it's a nasty shock, that this is what was planned all along and it wasn't made clear to them.

I think that's very much more a comment than a question, Neil. Llyr—

It's part and parcel of the way the framework document is constructed. I'm not suggesting that we conduct the debate on the implications of climate change, but just that people need to be told that, 'If you want this, then you're going to get that'.

Llyr.

Thank you, yes. Just a few things on the spatial approach versus a criteria-based approach, because I think we passed that very quickly without probing that enough. The message is coming back from the sector, clearly, that the designated areas that are in the NDF as it is now—it's not going to work. I mean, they suggest that only around 10 per cent of those areas are able to be developed. So, Dr Harris mentioned that it's here to give effect to delivering policy. Well, that isn't going to deliver the policy, is it, if that's the case? And the fact that we have this spatial culture emanating from TAN 8 doesn't necessarily mean that TAN 8 was any good, to be honest. So, do you have anything further to say about the criteria-based approach, as opposed to the spatial approach, particularly given the scale of the climate emergency that we're facing and the need for nowhere to be off the table, really, but clearly within specific criteria?

I suppose we are talking about the preparation of a spatial plan. So, I'm a big fan that the spatial plan should have spatial content, because if it's going to add any value beyond criteria that might already be established in 'Planning Policy Wales'—. So, I go back to—. I think this is—. If you have a decarbonisation agenda, then you need something more robust. And the role of this NDF is to try and add a spatial dimension, so in principle, yes. Whether we've got the areas right, what the capacity is of those areas and if the capacity's not in them, where else is it going to come from, or what alternative forms of renewable energy are we going to attract? So, I think just going for a criteria-based approach would be a retrograde step in what is claiming to be a spatial plan. This is one of the most spatial bits of this spatial plan, so it would be a shame if it wasn't—.

It is, yes, but they need to work, as you say. They need to be viable.

It's on to you and decarbonisation.

Right. Well, I think we covered the narrowness of the decarbonisation focus earlier, didn't we, and the need to be more aware of issues around flooding and coastal erosion et cetera? The other omission, I feel, from this, is an appropriate focus on rural growth, which tends to be represented in north Wales, clearly, and the urban north-east is there for that sort of growth element and then the narrative is very much supporting the other communities to get on, or at least that's my fear. So, do you share that concern, to start with?

I certainly share it, and, as I say, I was trying to digest these 70 pages and think, 'What is that kind of fundamental—where are things going? What's the kind of core strategy here?' Urban focused growth and rural communities will sustain themselves with an appropriate amount of development. So, yes, to answer the question, I'd share the view that it's not stasis for rural communities, but it's sustaining, it's kind of low level, it's kind of ticking over, if you like. But it is quite difficult for an NDF to say something about rural areas with any kind of spatial specificity; you'd be relying on those other scales—the local development plan or place plans to be picking up on maybe some of the issues that are probably more pressing for rural communities. But the general painting of things is something I think is a reading I took from the plan as well.

Although, it's been pointed out to us that the national planning framework in Ireland sets specific objectives for the renewal of Ireland's rural fabric. So, you could be more explicit in that respect, couldn't you, here, albeit at a broader—?

Yet you might find statements of similar form in 'Planning Policy Wales' that are sufficient. Coming back to that idea that PPW and the national development framework are to be read together, the same kind of level, one has a slightly different status to the other, but nevertheless, you might find what you're looking for in relation to those statements in 'Planning Policy Wales', but there's nothing more to add to that through an NDF. Does that make sense?

Yes. Is there something, therefore, around the need to maybe designate—? You know, we have the three areas, would it not be better to have one that is the rural hinterland—I know that that would be huge—but we've been pursuing as a party, the Arfor concept, down the western seaboard, and that you have Anglesey, Gwynedd, Ceredigion, Carmarthenshire, and there's an arc there. You know, you have universities, you need to join up the dots in terms of transport links. Would that kind of approach maybe allow a greater focus on those rural issues, instead of having urban and rural in the same melting pot and then urban always wins, usually, I find?

Yes, I suspect—. I mean, you can think about other European examples—I'm going back a little while now—but some of them kind of do create these kinds of concepts. So, not just thinking, 'Well, here we have a nation. Okay, let's carve up some regions', they might flag and identify, 'Okay, well, networking of coastal communities in a particular area', so, like you say, a coastal arc or something that is an idea that then gets people thinking about working together or facing similar kinds of issues, even if they're not necessarily in the same region. So, you could designate something—well, 'designate' is too strong a word, but you could illustrate in that spatial strategy areas where collaboration and a common idea of working together could be shown spatially.

So, you could do both. Could you do both? You could have the designated regions but then you could overlay that with the thematics, or does that just make it too complicated?

No-one wants an overly complicated document, do they, especially if you want the public to engage with it? I suppose it comes back to my comment that a lot of it is about articulating things for regions. The national map is, as I say, static—what's there at the minute. So, you could have something that doesn't overlay regions that still nevertheless identifies—. The other issue that's not cropped up yet in the questioning is the whole issue of language, so you think, 'Well, actually, do you want to show y fro Gymraeg in some kind of map?'—all sorts of extra things, spatial things, ways of thinking about different parts of Wales that you can illustrate. As I say, western coastal communities, y fro Gymraeg and various other things. I suppose areas that have a strong connection with England—you could show a similar kind of concept there. So, there are different ways of doing it, certainly.

Okay, thank you.

Thank you. Moving on to Jenny Rathbone.

Thank you very much. Just looking at the extent of the robustness of the plan for transport links, Dr Willmott, you're pretty critical of the schematic map on page 25, but there is obviously a map on page 2, which just gives you the basics of the main roads, the rail and the other transport links. It doesn't give you the active travel links. But I just wondered what you'd want to see there in a replacement for this, I agree, quite complicated map. I appreciate that one of the things you highlight, which I'm sure we'd all agree with, is the poor connections between north and south Wales. Superficially, looking at it, it looks as if you should run a railway line between Swansea and Colwyn Bay. Is this the sort of thing you'd be wanting to see?

Yes. The map itself, I understand, is schematic and it's quite useful in that sense. I think it's more the vision and the words and the policy behind particularly transport infrastructure—we'd like to see more progression with that, which, perhaps, is one of the weaker elements within the NDF—having more integration with what's happening with, particularly, rail. There's active travel, obviously, but a lot of that happens at the local level and there is work coming under the Active Travel (Wales) Act 2013 on that. But there might be national routes on that. These might be separate maps as well. I think one of the problems we have—. We'll always have these—we've already talked about housing projections, when one plan is produced and then another one. So, the Wales transport strategy—that needs to come forward, and they need to work together as well. That's only just about to be reviewed, so you'd hope on the next iteration of the NDF we'd have a more up-to-date Wales transport strategy and so it would be stronger on that side of it. But that's my criticism—that we're being visionary enough in terms of our transport infrastructure, and we have to think as well about our railway lines. Certainly, south Wales and the north Wales coast and parts of west Wales are very vulnerable to coastal erosion and storms et cetera, so we need to think about that infrastructure as well.

Undoubtedly. From my perspective—is the document clear enough that we will simply not allow large-scale housing developments on areas that don't have good public transport links, because that seems to me a fundamental of any NDF.

It certainly says in here that 'Planning Policy Wales' is very strong on that, and that's where 'Planning Policy Wales' would be the main document for that.

It hasn't stopped rather a lot of unfortunate developments in the Cardiff area.

But the current 'Planning Policy Wales', which is much stronger, only came in in December, and probably those consents were under way. So, yes—.

Okay. So, you think that does close that loophole. 

I wouldn't say it closes it, but it certainly reduces it. I'd like to think it closes it.

Okay. So, looking at the map on page 25, I don't quite understand these black dumbbells.

Which are the dumbbells? Oh, those. Connectivity.

Okay, all right. So, you'd like to see a clearer strategy of how we're going to make better connections between north and south Wales.

And west Wales. Within Wales as well.

And west Wales. 

I think we have relatively good, strong links on the south Wales corridor into England and the north-east Wales corridor into England as well, but certainly within Wales, we need to strengthen that.

Equally, if we don't know where the national forest is going to be, then we can't ensure that the transport links for tourism are in place, to ensure that people aren't arriving in cars in their droves.

Yes, absolutely.

Can I come back with two very quick points? The NDF talks about locating development in towns and cities with good public transport links. What is that? What kind of frequency of service? Is it somewhere that's got a rail service? Is it somewhere with a high-frequency bus service? The metro work is taking place, so which locations of it—? And we can identify these things. We can give a good signal about where these things are going to go.

The issue of the national forest has been raised. I suppose, if I was an inspector looking at a local development plan and someone said we were going to have some sort of strategic, city-wide park, I'd say, 'Well, where's it going to go, then?' And if he answer that question, I'd say that's premature. That's an idea. Where? Because then you can start to answer questions, such as what impact on travel is that going to have et cetera? How does it relate to landholdings that we've got to help deliver a national forest? So, yes, it's another example of how I just want this to be a bit more pinned down. There are sayings like, 'We will identify—', but the NDF is what does identify these things, not expressing an intention to identify them.

Okay, thank you. 

Thank you. Joyce Watson. 

I want to ask, because Dr Willmott, in my opinion you quite rightly said that there's a lack of addressing the issue of how the land-based planning system interacts with the coast and, thereby, the marine, so do you want to further expand on that?

Yes. I think it would be good to have more within the NDF about the coastal areas and what I've referred to about the transport vulnerability on the coastal areas. It might be going into too much detail, perhaps to look at specific coastal vulnerabilities et cetera, and that might be more for the strategic development plans or local development plans. There are certainly policies within PPW to look at the coastal side, but there's very little reference about the marine plan, and if we're talking about big infrastructure in the marine side, if you're talking about energy, then it needs to come on land somewhere. So, looking at that, perhaps, might be helpful as well. So, having just more interrelation. We've got a large coastline, so where does that feature within this?

But also, would there not be an expectation—? When we're talking about the top line and climate change, there's a vulnerability that exists, not just for the rail, which you're absolutely right to identify—and, by the way, it's not devolved, most of it, so there's a complication there—but there's another vulnerability about people who already live along the coast and the protection that they might need. So, it's multifaceted.

Yes. We've had it raised with us, actually, about north Wales, the growth zone. And if you think about the towns on the north Wales coast—Llandudno, Rhyl—they're all very vulnerable to coastal flooding as well. So, is that a steer that we need to look at—what coastal management we put in there as well.

I just wanted to add that the distinction between the predecessor Wales spatial plan and the NDF is there's a much tighter focus as a land use planning document, which probably reduces the opportunity to make connections compared to the Wales spatial plan with the marine environment. So, I think the remit is a tighter land use planning focus. So, with the coastal community, fine, but that broader connection to the marine environment is almost, not off-limits, but inhibited by the land use focus of this document compared to what the Wales spatial plan's potential was. 

Thank you. Llyr Gruffydd.

But should we not have one marine and terrestrial plan? Should it not be one document for both? 

It would be huge, I think. 

Well, it's—

That's not an objection.

Yes, because I can hear some people from the environmental non-governmental organisations saying that it very much should be that. 

Important to have read across between the two; I think that's important. 

It could be 'volume 1: land', 'volume 2: marine'. Neil Hamilton. 

Yes. I'd like to explore the cross-border implications of the NDF as well, and I wonder whether you think that it does deal appropriately with the obvious ones—we've talked about the grid already—and, obviously, there are land use and planning implications, because north-east Wales moves seamlessly into the Liverpool region, and, now that the tolls have gone from the Severn bridge, obviously there's a danger that south-east Wales is going to become a dormitory for Bristol, which is not the objective that we would wish for it. We want to revitalise the south-east of Wales as a vibrant area in its own right, and not just as a place for commuters to sleep in. So, do you think that these issues are properly addressed in the NDF?   

I suppose its main response to those specific issues, particularly the dormitory town—and that has a huge influence on house prices, so people that are resident in Monmouthshire area would be vulnerable to people who can travel to the Bristol area and earn higher wages, so you get that inequality, potentially—. The main response from the NDF is a green belt. It doesn't set out which exact fields; it gives a broad area in both north-east and south-east Wales in response to that. Is that the right role? There's a huge debate about green belts, particularly in England. Are they appropriate? Are they the right places? Are they too stagnant as well? So, actually, you can have—parts of the green belt biodiversely aren't very strong, whereas you can have brownfield areas, which there is a presumption for, that can be very strong in terms of biodiversity. So, are they the right places to build on or not build on? It's a huge debate that goes on and on.

So, should we have them in these parts of Wales? We do have green wedges in Wales as well, but there are other policies, and actually Scotland is looking at or has a range of different policies that it looks at. So, is that a better way of looking at how we manage that housing development? We can't stop people coming across—we wouldn't want to—but there is—

I do it regularly. [Laughter.] 

We do need to manage that area as well for populations that serve within Wales. So, I think green belts are a big question. They do inhibit flexibility within development, so—. 

Although it's been suggested that one of the reasons they're proposing the green belt in north-east Wales is because there's another green belt the other side of the border, which is pushing development into Wales, and so we need that kind of buffer. 

Yes, absolutely. Yes.

So, whether that's the right reason to have it or not is questionable, I suppose. 

And, actually, when the NDF was being drafted, I believe there was one proposed on the other side in the greater Bristol area, but I believe that that may have gone; there's an issue with the plan there overall, so—. But there's a potential for one the other side. Yes, absolutely. 

Thank you. We've gone three minutes over. We've got one question left, so, if we can just ask the question and answer it very quickly, we'll only be five minutes over. Jenny Rathbone. 

Okay. Well, I just wanted to pick up on the previous question about the cross-border issues. Should we have done an impact assessment before we removed the tolls? We all rushed like lemmings into removing the tolls on the Bristol bridge, but nobody looked at the consequences. 

A big decision like that does need to be looked at in terms of consequences, potentially, but it's not a land use issue, so—. Well, it has implications for land use, absolutely, yes. 

Okay. Just picking up on the interesting idea—. Dr Harris, you said that we need to have a monitoring framework. This committee could obviously become that monitoring framework, or its successor body. How often do you think it should be monitored?  

The suggestion of there being—. I thought that you get to the end of it—. Because this is a development plan document, again, it's framing everything, I think, about what it is and what should be in it, but it's a development plan document prepared by Government—a national Government, rather than a local, so, allowing for some differences—. But you would always, with a development plan document, say, 'Okay, well, how are you going to know if this is successful?' And, while there are some outcomes, very few of them relate to the old SMART—you know, specific, measurable, realistic. So, how do you know that this is a success? And I thought, well, you could create your own monitoring framework, or you could think, 'To what extent is it helping to deliver and helping to contribute towards the indicators in the well-being of future generations Act, et cetera?' But I was just expecting this kind of document to say, 'Okay, well how do we know it's going to be a success?' How often—you know, that question of how often we will look at it. So, an LDP is subject to an annual monitoring report, and there are various bits of data. So, maybe you don't want that for a national development framework, but something that is just added on at the end—. So, I got to the end and thought, 'Okay, well, how are you going to implement and monitor this, then?' And, then, it just doesn't do anything about that. 

It could be done outside the document, but, as a planner, I would probably expect something. If I was doing any document at any other level in this three-tier hierarchy, I'd be saying, 'Okay, well, how are you going to monitor it? How are you going to know when it's not quite working, that the policies are leading to counterproductive responses perhaps, et cetera?' That monitoring could be about how it's impacting on LDPs, it could be looking at decisions of particular significance, where they're being located, et cetera. There's just some work to be done about how we monitor that. 

The Minister does point out that it will be reviewed every five years. So, clearly, in the run-up to that review, we need to know which are the bits we need to fix. 

We have gone substantially over time.

Okay.

And we've got another set of witnesses coming. If we hadn't got another set of witnesses coming, I'd carry on for a lot longer, because you've said an awful lot that I've found very interesting and informative, and thank you very much for coming along. It's been very, very helpful. Unfortunately, we've got to stop at this stage, but thank you both very much. It's been very helpful. 

Thank you.

Thank you very much. 

Can we be back here at 11 o'clock, so we only kick off the next session five minutes late?

Bore da—good morning. Can I welcome our three witnesses this morning, who are Victoria Robinson, vice chair Planning Officers Society Wales and operational manager for planning and building control, Vale of Glamorgan; Tracy Nettleton, member of the Planning Officers Society Wales and Brecon Beacons National Park Authority; and Cath Ranson, planning policy manager at Ceredigion County Council? Can I welcome all three of you here? If you're ready, can I start with some questions?

What is your overall impression of the national development framework? We've listened to other people earlier today who were talking about things like it isn't ambitious enough and that not enough of its policies are mapped out spatially. Frankly, they were fairly critical of it in terms of its clarity. Do you have any views on it?

I think I would say that we'd support—the three national park authorities would support the principle, but, yes, it's a bit lacking in detail. And I think, from a national parks point of view, it's a missed opportunity. National parks are a national resource and nationally significant and they seem to be a bit of an afterthought. I'm sure we'll come on to talk about SDPs later, but I would like to say something about that later. So, from our point of view, it's a bit of a missed opportunity.

I've gathered views from the south-east region of the country, and obviously also had a look at what other regions have had to say so far about this, in representing the whole of the Planning Officers Society, which covers the whole of Wales. So, our overall feeling I think fundamentally is we welcome the idea of a national development plan—it's a good thing to have this in replacement of the Wales spatial plan, to have something that's much more up to date that we can build on; that's a good thing for SDPs and LDPs.

We feel in parts it doesn't go far enough, and in other parts it goes way too far, and we've got overall concerns around the evidence base that's been used to inform it. I guess we're coming from a position of, when we write local development plans, there's an awful lot of evidence that informs that, and we feel that some of the policies and proposals in here actually are quite firm and assertive, and, actually, if they are implemented in the form they're in at the moment, there isn't very much evidence supporting those.

So, for example, the policies around growth being within town and city centres is an absolutely laudable ambition, and we'd all look to be building where there is existing infrastructure, transport and so on, but the availability of those sites is limited. The ability of town and city centre or urban sites to deliver the kind of growth that we're going to need to meet housing need, for example—we've got concerns about the deliverability of the plan, and that's largely based on there being insufficient evidence to support those polices and proposals.

Thank you. And—.

From the perspective of Ceredigion in particular, but also the Growing Mid Wales partnership, strong concerns that the area is lumped in with south-west Wales and isn't a region in its own right. We've had discussions around the idea of the separate SDP for south-west Wales picking up on the Swansea city deal and an alternative way forwards for mid Wales, which is more likely to be a joint local development plan than a strategic development plan, purely because of the scale of growth that's envisaged. Very strong concerns that, as the map shows it, there's a big white space in the middle of Wales, with nothing going on. And our economic development officer commented on the first public session on the NDF that, if he showed that to an intending developer—if he showed that map—they'd be more likely to go to north or south Wales and not to come to mid, and some of the things that mid has are there because of the quality of the location and we need to build on those.

I was going to come on to that later, but, as we've come to it now, I'll carry on. Because I actually agree with you that lumping Ceredigion and Powys in with south-west Wales makes no logical sense whatsoever—there's no community of interest. Do the other people on the panel have a view on the three regions structure, or are you in favour of four or more?

I don't have a view myself—or the three national parks rather—other than we think the national parks should be outwith an SDP region, given that national legislation—UK legislation—is to not have major development in national parks, which is at odds then with the purpose of an SDP. It would then—. Potentially, with three areas—this is the only part where we do have a view, particularly in the Brecon Beacons—you could potentially have two SDPs partially covering a national park in the south-east and south-west, and possibly with Powys and Ceredigion, so we'd end up with three SDPs, three LDP lites and an LDP full for the mid, so it’s just fragmenting that when it should be just recognised as a whole, in and of itself, with an LDP in line with the NDF.

I think within the region south-west and mid as a whole, there's a view that it would almost be impossible for a local planning authority to split itself down the middle and have part of the area within an SDP and part not. So, they'd have to do a full local development plan for the area that wasn't part of the SDP and an LDP lite for the area within, and that would be even more difficult than LDPs are at the moment.

In terms of the south-east region, I think that's already got quite a clear regional framework. We've had discussions about the SDP boundary and whether or not that should or shouldn't include the Brecon Beacons national park, and we've come to the same conclusion, that we don't think the Brecon Beacons national park should be part of the SDP, for the reasons that Tracy's just alluded to, and I'd support their comments.

Okay, thank you very much. If I move on then, to Andrew Davies.

Thank you, Chair. I declare an interest, because Victoria is the operational manager for the authority I'm a member of. I just want to put a question in relation to 'Planning Policy Wales' and then the NDF and the policies that 'Planning Policy Wales' had vis-à-vis the NDF. Do you think that, as devised, they are compatible or do you think there need to be some improvements or some read across to tighten them up so that they do work better together? That's to all three, that is.

Our view was that I think there needs to be a better link, particularly in terms of the place-making aspirations of PPW. It's not clear how that translates into the NDF. And, again, just to echo Victoria's point, it's the evidence really—we need to see the evidence behind the NDF to see how it can relate better to PPW and vice versa and then to our own LDPs later on. 

Can I just ask you, Tracy, because I think that's the third time that you've said 'the evidence' and you need to see more evidence, on two different lines of questioning. Is there a real concern for you that the evidence that's underpinning this NDF is not robust enough and, actually, potentially, the NDF could fall down because the evidence just hasn't been good enough?

'Yes', in a nutshell. I would. Victoria summed it up. When we put together LDPs, we have to produce the evidence base in public, and it is scrutinised through peer review—

Can I just add that it has to be done in advance of formulating policy, rather than to justify the policy afterwards?

And it's all scrutinised. When we get in front of an independent inspector, it's all scrutinised and it's peer reviewed and it's questioned from house builders, from interest groups. So, we'd like to see the same scrutiny of the evidence base and what led to what's being proposed in the NDF having that, let's say, level of scrutiny.

And those comments—it would be fair to say that you would be supportive of those comments.

Yes.

Yes. 

Thank you.

It's also worth adding that there almost should have been a leaflet alongside the consultation draft that said what Welsh Government proposed to do to update 'Planning Policy Wales' to take into account the NDF when it's published. So, for example, there's talk of, in terms of renewable energy, revising PPW 10 and doing things to TAN 8, but you would only find that out if you'd been to one of the public sessions; you wouldn't find it out from the written information with the consultation.

Any other comments on PPW and the NDF, or—?

Yes. I would echo what Tracy said. I agree with what she said. There are particular proposals in the NDF that aren't supported by the evidence. In terms of PPW, for example, the NDF appears, on the face of it, to completely rule out the idea of any new settlements in Wales for the next 20 years, and PPW sets out, for the first time in this edition of PPW, the exceptional circumstances where a new settlement might be appropriate. And I think, as the Planning Officers Society generally, without any firm views on where those new settlements might be in Wales, we do feel that to rule them out is inappropriate. It comes back to my point about urban capacity, the focus on existing urban centres. And, without evidence to demonstrate that you can deliver growth in all the existing settlements, it's shortsighted to completely exclude the principle of new settlements in Wales, where, actually, that might be the most sustainable option for delivering growth and affordable housing to the level that it's needed.

Can I, just for my simple mind and maybe other people who might be watching this—what is a new settlement defined as? Is a new settlement defined as where one doesn't exist at the moment, or a significant increase in the existing settlement that may be disproportionate to what's already there? I am unclear on what the actual—. But you're planning officers, so is there a clear definition that says, 'A new settlement is where—'?

I don't think there is a definition anywhere clearly to say what a new settlement is. And I think probably when we think of new towns that have been developed over the last century, in the main, they probably did start off as a very small cluster of homes and village and have just grown into something totally different, but that doesn't preclude—for example, we've had proposals put forward where there's no settlement existing, but there's say, rail infrastructure, or a lot of brownfield land, so industrial sites. Proposals have come forward to that extent, or proposals have come forward, completely green fields, the middle of nowhere, but, again, with transport connections, possibly.

Now, I'm not saying, 'Oh, there's an ideal spot there for a new settlement', I'm absolutely not. What I'm saying is an SDP is the place to look at that information and decide whether or not that is the appropriate strategy for growth, depending on what your growth aspirations are for that area. And, unfortunately, the text in the NDF refers to—it basically seems to preclude that, by saying that you need to focus on existing settlements.

Okay. Thank you.

Llyr wants to come in here.

Yes. I am just interested in this sort of tension between 'Planning Policy Wales' and the NDF—and there are seeming inconsistencies, or they sort of undermine each other. And it just reminded me of some evidence we've had from RSPB as well in relation to sites of special scientific interest. I think I'm right in saying that the NDF requires minimising adverse impacts on protecting nature conservation sites and species, not avoiding them. Whereas the presumption in 'Planning Policy Wales' is that damaging developments should not be permitted. So, clearly, there's an issue there, isn't there, in that there's an emerging inconsistency. But, at the end of the day, I presume the NDF trumps everything.

Well, I think it would do. If it goes through as it's intended to go through, it will be part of the development plan, whereas PPW is guidance. So, the NDF—. Which is why we're concerned about seeing the evidence and it being properly scrutinised—

Yes, to justify this change in policy.

—to justify. Exactly. Then you'd have to update PPW. And I think Planning Officers Society Wales, but certainly the three national parks, very much like PPW's emphasis on the well-being of future generations, the way it's structured, the emphasis on place making and the involvement of communities. That doesn't come through with the NDF, which it should, because PPW was produced first, so it should follow. But there seems to be that disconnect, and obviously I would say that there needs to be that exclusion of damage to biodiversity rather than just avoidance.

But it's an example of quite a significant policy change that goes under the radar.

Yes, exactly.

But that should be covered within the NDF by habitats regulations assessment. If they're proposing anything that would cause damage it would need to be demonstrated it was—that there would not be overriding public concerns, and there was no other location that something could go to. So, there are very, very stringent tests at the moment.

Okay, thank you. Joyce.

I want to look at, now, whether—we've heard you say about evidence, so whether the draft NDF takes account of strategies, key strategies, and I'll give you some examples, like the Wales national marine plan, which is currently in development, and the Wales transport strategy, which is currently in development, the economic action plan, for example, or the Wales infrastructure investment plan.

It's probably worth me going first on the Wales national marine plan. I think there's a nervousness that the NDF is a land-based plan, but, from our perspective, there's insufficient co-relationship between the two, so how do you deal with the coastal issues that arise? The landfall for marine activities, how you deal with those things, doesn't seem to have been picked up on, and it needs a bit more emphasis. But I think to some extent it's actually, playing fair to Welsh Government, trying to take account of documents that are emerging.

It's very, very difficult to align the evidence and align the working so that you can bring the two together, but it's absolutely essential that we do need what happens in our ports, what happens to—if you like, edging into climate change, what happens with our coastal zone and the shoreline management plans, the coastal protection plans. We seem to be more and more frequently having instances of storm conditions where we lose a significant piece of infrastructure not just for a couple of days but for months on end, and, if you look around Wales, we regularly lose the Blaenau Ffestiniog line; we had the storms in 2013, we've had storms that have taken roads out, or rail, and they're not just flooding them for the immediacy, they're causing significant damage to the foundations of those infrastructure examples. So, there are very much things that need to be dealt with around coastal margins, and particularly picking up again on wildlife. What we're very proud of in Ceredigion in terms of the growth of tourism associated with marine wildlife has been exponential in the last few years, and it's that increasing awareness of what we've actually got.

Do you want to pick up on—?

I would say—I think it's largely trying to be consistent with those other frameworks and documents and it won't necessarily contradict them. I'm sure there are examples where there are contradictions, but I think it is a very high-level plan, and you'd expect it to be that, and you're not going to have the same level of detail that you'd expect in an SDP or even a local development plan in that regard, but I think we're a bit disappointed and surprised that there's not more in there, particularly in relation to transport. So, there's a of policy framework around development and growth being supported by infrastructure, in particular transport infrastructure, but transport infrastructure isn't shown spatially very clearly on the various plans that have been put forward. I think the metro symbol is just an 'M' in the middle of south-east Wales, and really that's a missed opportunity to focus in on the opportunities that the metro enhancements are going to deliver. And they're known quantities, to a certain extent, so why not put them in there and demonstrate, certainly for the next five or 10 years, so you can see what's going to be happening in that regard.

A clear message that's come through from lots of people that I've spoken to in this part of the world is the concern about the M4, the congestion around the Brynglas tunnels and the Newport area, and that that's really not tackled in the document and it's not really acknowledged properly. Therefore, that's a bit of a conflict, really, when you look at the level of growth that's expected in the Newport area.

On road congestion, I take it you only took one part of the M4, because we have serious road congestion between Pontarddulais and Port Talbot.

Yes.

I don't have any comments on that. Thank you.

I think one of our concerns is that the NDF feels like a constraining plan, rather than an enabling plan. And a bit like the Wales spatial plan before it, we don't know some of the economies we're going to have and some of the technologies we're going to have by 2040. We need to have a structure to the NDF that enables future reviews to take things on board, just so that somebody with an emerging new technology doesn't look at Wales and think, 'I can't go there', but looks at Wales and thinks, 'Yes, there's an opportunity for me here.'

Yes, I think you're absolutely right. Before I bring Jenny in, as a young child, in the late 1960s, I had a book that gave me all of these predictions of what's going to happen in the next 40 years: we were all to be travelling by hovercraft and the internet didn't exist. [Laughter.] Jenny Rathbone.

Do you accept the core proposition in this draft, that housing development should only take place where there are good public transport links?

Generally, but one of the concerns is that, when young families have young children, there's a strong reliance on relatives and if you are moving young people in particular away from their homes areas, then you break—

I wasn't suggesting you do that; I'm just saying that new developments should only be in areas where there are already—

But the corollary to that is that we need better public transport links.

Well, we can all agree on that. That's the whole point.

Yes.

I think we would definitely be—. As good planners, which we are, it is about sustainable development. You put development where the most services are. Of course, in a very rural area, that's creates tensions because people don't want to see their communities dying and yet, as we know, there's closure of rural schools and a lack of public transport. So, they want some development, particularly affordable housing, to keep young people there, but then that goes against the principles of sustainable development and focusing it where there should be all the facilities. So, in our planning world, in the Brecon Beacons, that is always a tension that we're struggling with.

Okay, well, obviously—. I think one of my colleagues is going to talk to you about that so I'll—.

Neil Hamilton.

I'd like to explore with you how far you think the development framework can be effective without strategic development plans in place, given that this is going to be an overarching document by which everything else below it is going to be governed. We've got local development plans, strategic development plans, and they all have to fit into one another. So, what's your view on the importance of strategic development plans in this context?

The aspiration behind the 2015 Act was very much that there would be three strategic development plans in those three parts of Wales where rapid and significant growth was expected. And at that stage, there was no expectation of all-Wales coverage. And it sort of yo-yoed around, 'We need all-Wales coverage. We need reorganisation. We need—'. So, if we're trying to—

Reorganisation of local government, you mean, or—

Yes, but if we're trying to manage risk in taking local development plans forwards, some of those things we've got little control over. So, we sort of note them as a risk and move on. I think that the push is to try and—. One of the things that the NDF needs to do is to work with the infrastructure plan and the infrastructure Bill to identify what's needed to help make Wales thrive into the future, and that doesn't necessarily—. I think, yes, there's a need for SDPs in those areas where rapid growth is expected, to work out what and where, how much and how you share it around. But for the areas where we're not expecting massive growth, and, as Tracy said, for the national parks, it doesn't make sense to have strategic development plans where that scale of growth isn't anticipated. It's an extra tier, it's an extra cost, and it's not needed, but I wouldn't argue with the fact that it is needed on the A55 corridor, in south-east Wales and in the Swansea city deal.

That takes us back to the way in which the map of the regions is constructed, and the inevitable tension that is always there in any planning overarching framework between urban areas and rural areas—I mean real rural areas as opposed to commuter belt areas. You do need to keep your focus on what you might call the empty bits that are going to need a completely different kind of approach from areas like south-east Wales, for example, or north-east Wales, where presumably there is going to be an increasing density of population and so on to a greater extent than there will be in mid Wales. So, do you think that the level of direction for SDPs in the draft NDF is appropriate?

Shall I come in from a south-east Wales perspective, because there's a strong commitment in our region to proceed with an SDP? We've already had, I think, eight now of the 10 local authorities that have agreed to the report to proceed with an SDP, so we're hoping to be able to put a proposal to Welsh Government soon to get on with an SDP in this part of the world, and for all the very good reasons. It's a relatively small geographic area. We've got very similar pressures centred around Cardiff and Newport and the Heads of the Valleys areas, and there's a lot of synergy between the areas in this part of the world that it makes sense to do an SDP. And in that sense, having the national development framework is useful because it means having that upper tier that you can look to. The trouble is we don't necessarily agree with everything that's in it.

So, for example, the green belt has been a key issue for the region, and we feel it's totally inappropriate to predetermine that location for a green belt. Certainly, it's an issue that needs exploring with evidence and with analysis as to the most appropriate place, if any, to have a green belt in the region. We don't think the NDF should go as far as it has in that regard. But the overall framework around where to focus growth, public transport links—those are things that we would naturally be doing and aligning with the NDF.

In terms of your question around how useful is this in the absence of SDPs, which are going to take some time to come forward, it's going to have limited weight until those documents start—not limited weight, because it has the weight it has as a development plan, but in terms of its application in development management decisions, it's at such a high level that there's not going to be that many things coming forward that comply with current LDPs and the current planning policy framework that would contradict what's in here, frankly.

There are one or two policies that I have an issue with—things like saying that public facilities have to be in town and city centres; I don't think that's an appropriate policy. I agree with them being in locations where they're sustainable and accessible, but town and city centres is a pretty limited location. But that aside, I think the NDF will be there as a useful framework for the future development plans that follow. Let's hope that the final version of it really does address the concerns that we've raised, and provides that useful framework for us.

Because this is a kind of broad-brush document, and it doesn't inevitably have the level of detail at a local level for you to draw worthwhile conclusions. Obviously, the challenges for an area like south-east Wales are very, very different from mid Wales. Preventing urban sprawl would be one of the issues, and we don't want to have our own version of Tokyo-Osaka—one long 100-mile urbanised area, which merges imperceptibly into another. So, I can see that, in those circumstances, this is where a strategic development plan would be absolutely vital, because it would flesh out the overall conclusions that we'll have in the NDF.

I would agree with both Victoria and Cath. For an area where you want to influence growth, and you need linkages between transport, between health, between schools, education—it's proper planning at the regional level that you have those groups, and then the LDPs come out from a local level. But forgive me if I'm repeating myself, but I am—for the national park, the local development plan is the appropriate vehicle to deal with planning issues in a national park, from the NDF down, rather than an SDP.

Well, that's a discrete unit that already exists, whereas everything outside it is not.

Exactly.

Can Joyce Watson come in on this?

I just want to ask, because I cover both your areas, Tracy and Cath, and much more than that. But I also was a Pembrokeshire county councillor before, and there was a unitary development plan with the Pembrokeshire Coast National Park and Pembrokeshire authority. I don't think—it doesn't apply maybe so much to you. That's happened in Brecon; in fact, Ceredigion struggled with their LDP anyway. Is that not a way forward, because I keep hearing you saying that the national park is this unique area, which it is in some functions, but it isn't so unique in other functions, because people have to live, breathe and work there. So, I'm going to challenge your statement, because that's what we're here to do, to test what you're saying. So, you don't want to be part of anything except the local development plan. I'm not sure, but I think you've still got your own planing authority, because I know there were moves to merge those. Would it not be perhaps—? If you're going to put your statement forward and give it some weight and value, would you consider, then, joint development plans as the way forward? Do you think that that would be a solution?

No, I don't. It may have worked for the Pembrokeshire coast because it's relatively small and in one county, but Snowdonia is two counties and the Brecon Beacons is seven. So, we couldn't—it would be nonsensical to do seven joint LDPs. It's a national designation, albeit, of course, people work there, they have to make a living there, they go to school there, and I think it has to be viewed as a whole, bearing in mind the fact that the Carmarthenshire part of the national park is very different from the Monmouthshire part of the national park, which is very different from the Powys part of the national park and the Heads of the Valleys. And the only way you can really deal with those differences in a cohesive way is through—only as far as planning is concerned; obviously, there are many other issues that cover the national park—a local development plan for that area.

I think there are moves afoot, talking about the other issues you were talking about. The mega catchment project with Welsh Water and Natural Resources Wales, which is seeking to look at the area as being a major water resources for the urban communities in the south of the country. So, there is a recognition that other things, other than planning, that the mid Wales areas sort of feed into. But I think from planning's point of view, in a national park, it should be the local planning authority—it should remain the LPA delivering the local development plan to bring all those issues together.

Okay, thank you. Back to Neil Hamilton.

I'd like to move on to a different subject now and that's the question of the cross-border implications of the framework. Given that we have a much more porous border than Scotland, for example, and Scotland is insulated by the borders whereas our borders merge into the conurbation up in north-east Wales, and with the abolition of tolls on the Severn bridge, there's obviously a danger that south-east Wales is going to become a dormitory for Bristol, and the extent to which Severnside and Deeside and Merseyside, both in Wales and in England, can develop as a kind of sub-region in themselves, although they're not connected administratively or politically. So, to what extent do you think the national development framework document deals effectively with the implications of what I've just described?

It's not my specialist area, I must admit. I'm not in a council that's close to the border, but I think Monmouthshire in particular in this part of the world are trying to grapple with those issues and it's having a significant impact on things like house prices in Monmouthshire, and beyond—in Newport, I'm sure. 

And then there's a ricochet effect from that, of course.

There's a ricochet effect—

I understand that Barry now has felt the ripples of this.

Yes. There's going to be a ricochet effect. We've already got a severe shortage of affordable housing, for example, in this part of the world and that we're trying to address through the planning system. I think our concern is, at the moment, that the NDF isn't tackling those kinds of issues enough—that the ambitions around housing growth are not necessarily going to address those concerns. It flags all the issues around affordable housing. It talks about the high demand—I think it's 47 per cent—in this region, but in terms of the delivery, that's where we feel the plan is lacking and is something that we, as local planning authorities, have been grappling with and have been considering through regional working and would hope to address through the SDP with policies and proposals. We don't feel the NDF has done that yet, and we think that by prejudging things like the green belt and the growth area, excluding almost all of Monmouthshire—it's just almost ignoring those issues rather than actually acknowledging them and leaving it to the SDP to say that these are issues that the SDP's going to need to tackle, to think about, to look at the evidence base and to consider things like green belts to allow growth in the most appropriate locations and so on.

And the impression that, increasingly, one gets, as we explore this is that this is a cartoon approach to the problem, in effect, in as much as you need to devise the framework on information that comes from the bottom upwards rather than something that is imposed on the framework, which then might not meet the facts as they are on the ground. That's the impression I'm getting in questioning and answers from our witnesses.

And you're getting a lot of nodding as well.

Yes, quite.

I think I'd agree with Victoria. Obviously, our area of concern would be the Monmouthshire side of the national park and we do liase, obviously, regularly, with colleagues in Monmouthshire and the pressure that that might bring, as you've said, but also that the hole is mid Wales and the NDF—there are issues about the drain over the border to Herefordshire, further up and then, obviously, we know about the A55 corridor and the drain to Liverpool and Manchester, but there's that mid bit around Shrewsbury and Birmingham that just seems to have been ignored.

Thank you very much.

Thank you. Jenny Rathbone.

I want to turn to housing now. We have the overarching objective that housing should only develop where there are appropriate sustainable transport links. So, I want to explore why you think that some of the proposals don't do that. For example, the idea of having a 47 per cent target for affordable housing. I think, for example, Victoria, you suggest that this has to include the role of the private sector, the volume house builders. Where's the evidence that they have actually delivered on affordable housing?

At the moment, they are the primary deliverer of affordable housing in Wales and have been for some time, because they're the major builder of houses.

That's different, isn't it? That is different—that is the problem in Cardiff. They have just reneged constantly on that obligation, and if we can't make this proposal stick in Cardiff, then it's much more difficult to make it stick in areas where there's less appetite for development.

Yes. And, you know, I'm fully supportive of all initiatives that look at delivering more affordable housing in the areas where it's needed, and there are lots of councils that are building their own council housing to try and do that, and that's really welcomed, and Welsh Government support for those initiatives is great. Similarly, lots of really good work is being done by registered social landlords, lots of really good exciting schemes, the innovative housing fund—all of those kind of projects are really welcomed and are starting to move in the right direction, I would say, in terms of delivery.

From a Vale of Glamorgan perspective, the majority of our housing that's being delivered is by the plcs, and they're delivering an average of 30 per cent affordable housing. Viability is much better in the Vale of Glamorgan than in lots of parts of Wales, and, certainly, I'm not suggesting that that's a reflection of the whole of Wales, because it's not. My concern is, though, that the way the NDF is written it's so focused on the public sector delivery of affordable housing that it's almost pushing out the plcs, and I've heard many of their representatives object to the rhetoric that's coming out through the NDF and the message that they're feeling, that they're being pushed out of Wales.

I've got many scars from battles from dealing with major house builders and trying to deliver for our communities, both affordable housing and every other type of community infrastructure. But nevertheless, they do deliver to a certain extent, and I don't think it's right to push them out of Wales. I think they still have a role to deliver housing where it's needed.

Yes, but it has to be of the right type. At the moment, they're building to very old standards and not raising their game to meet climate change. I've no objection in principle to volume house builders, it's just they've got to up their game to meet our requirements for carbon neutral housing, otherwise we're going to be retrofitting all this new housing.

I think it would help us, because—and it's probably the same with the Vale and possibly Ceredigion—when we were first writing our LDPs and determining planning applications, there was a commitment from Welsh Government about the code for sustainable homes, and that was withdrawn. So, we don't have the teeth to demand developers to provide that, because there was a backlash from the industry at the time about costs.

I think, to be fair, I'm no fan of volume house builders necessarily, but through the planning system was the only way until fairly recently that affordable housing could be provided. Fortunately now, local authorities are able to build their own, so we could see that. But I think what it means is that we have to be careful of an over-reliance on one element delivering. I think it has to be at a number of levels; we shouldn't just rely on the planning system if we're going to achieve the target of 47 per cent. That worries us, I think, across Wales as planners, that we won't be able to achieve it, and that's what's happened with LDPs, hasn't it? With the number of general housing we have to provide in our affordable housing targets, there's an over-reliance on the private developers to provide the affordable housing, and they would change viability, the market changed, so we couldn't reach it. So, it seems to be going the other way with a reliance on the public sector, which might be as it should be, but if we over-rely on that, then there may be issues there, and we can't meet it forever—

Okay, and this is the opportunity to probe why that might be problematic. So, Victoria, you've said that you don't think that there's a significant amount of council-owned land available for development, particularly in town-centre locations. I wonder if you could elaborate on that. How do you know that, given that there is the absence of a map of where all of this publicly owned land is?

That's kind of the point, really: that assumption has been made without having done any of that research to see what land is available. I can only speak from a Vale of Glamorgan perspective in terms of the detail, because I know it because I'm heavily involved in that side of things. Our housing team have an excellent housing strategy to deliver on council housing schemes, but it is a finite resource. I understand Cardiff have got a much larger programme, so presumably they have got land. And there's always the ability for councils to procure land for building council housing, but it's a very new phenomenon for us. I think other places, I understand, like Flintshire and, possibly, Conwy, have been doing more of this stuff for a couple of years and have probably got bigger build programmes, but I still understand that you're only talking about, perhaps, 50 units a year—this sort of thing—when I think the ask is something like 8,000 homes a year.

So, the capacity is not there at the moment. I'm not saying it couldn't be in 10 years' time, but a lot of work has to be done to push in that direction. At the moment, in the Vale of Glamorgan, it's a very small team delivering on council housing. The registered social landlords—again, their build programme is relatively small. All I can say is that that's my detailed knowledge in the Vale, but when I talk to colleagues in the region and across Wales, which I do regularly, I'm hearing exactly the same messages from them. The availability of public land—lots of sites have already been sold off.

Well, clearly, we need to put a stop to that, otherwise we're buying at premium prices.

Absolutely.

So, that will make the problem less difficult, won't it? If we retain public land to build new homes that are affordable, won't that be a useful contribution to—?

It absolutely will. What I'm saying is that it may be a little bit too late, in terms of the overall delivery. The fact is that I don't think anyone really knows, because the work hasn't been done to properly demonstrate that there are masses and masses of land in appropriate locations to be able to deliver this agenda. That work needs to be done.

Okay. So, could you just talk about this concept of town cramming versus the importance of creating green belts to stop Cardiff sprawling into Caerphilly and Barry?

Again, for me, that's a role for the SDP and for joint local development plans. On those issues, you identify how much growth you need and you look at where you might be able to accommodate that growth in a sustainable way. The very first place you will look is existing urban centres and existing communities.

The issue around town cramming comes up a lot. I deal with planning every day and I go to planning committee every month. Every planning application that we deal with that's in an existing settlement, the surrounding community, by and large, aren't particularly happy about it. They cite issues with school places, with doctors' surgeries, with existing congestion and so on and so forth. Those are real issues that people feel. We attempt to tackle them, and we attempt to increase school places through use of section 106 and so on and so forth, but it is a tension that's there and that you have to try and plan and manage.

But isn't that a failure of past planning policies, which have allowed volume house builders to build huge numbers of housing without insisting that, if they're going to do that, they need to build the doctors' surgeries and the schools to go with that significant development?

Yes, and that is what we do on a daily basis.

Well, we sometimes do that, but there are lots of good examples in Cardiff where we haven't done that—that's what has caused the problem. So, how can this NDF ensure that we're looking at this holistically over the next 20 years and that we are factoring in the concept that if we're going to build x number of houses, then that will obviously have a consequence for other public services, and that these volume house builders can't just dump all of these houses and walk away?

So, when we write a local development plan that's exactly what we do. We work out, 'Okay, you've got 10,000 houses and that generates x amount of pupils, and they're likely to go to these schools and that's going to generate a need for a new school here, here, here, here, and all the other infrastructure requirements—I'm picking on schools, but the same would apply to transport, community facilities, and so on. And, at a local development plan level, you do that work, and that work is robustly scrutinised by your communities, by the development industry, by the inspector.

But it hasn't stuck—well, up until now, so—. We've got countless examples of where that failure to have that holistic planning is what has caused all these people to resist further development.

To some extent, the first round of LDPs emerged into a failed market, and it's not the plan itself that failed, it's the fact that property prices have crashed, the value that you could get out of the development changed. For example, when I was in Pembrokeshire, we did a viability study for the LDP. We offered, to the inspector, when we submitted the plan, that we would do—if he was prepared to accept it, we would revisit that, because it was two years old. And it necessitated us taking a completely different tack on the policy, because the viability had plummeted in those two years.

Well, that doesn't explain the failure of planning policy in a place like Cardiff.

But that's—. But the point is, if you haven't got viability within a development, the expectations of the planning system for school places, for doctors' surgeries, for—. We've now got sprinkler systems, sustainable drainage systems—they're all placing extra costs on developments, and, for some developments, you may be able to get economies of scale, but, for others, you can't.

But surely, within a development, the balancing amount is the value of the land. If the cost of building goes up, then the value of the land goes down. That's a balancing issue, isn't it? So, you can do whatever you like. And dare I say that if, in the Vale of Glamorgan, somebody down in Cowbridge said, 'You can build 1,000 houses here', you'd have no shortage of builders wanting to come and build them.

Yes.

It does vary, and we've been fairly successful in getting 106 contributions. But viability is always an issue, and our priority is always to deliver enhancements to the site and affordable housing. And, ideally, we would like an education contribution, we would like a contribution to the health centre, we would like contribution to a play area, but they all add a cost. So, we all, as Victoria said, bear the scars of negotiating with housebuilders. And so, because our priority is the affordable housing, we want 30 per cent in some areas, 20 per cent in others. Well, if they're going to provide that, then they have no more viability in the scheme to provide the education contribution, the play area contribution, and that is the series of negotiations with planning.

That's what they argue. Unfortunately, the evidence is—. With Persimmon paying millions of pounds in bonuses, that doesn't really stand up as a viable argument.

I would—. I see where you're coming from. In our experience, we have a process to go through, which involves then going through a toolkit to assess viability. And then in the event that we still disagree—the developer and the planning authority—we use the district valuation service. So, there is a process and, unfortunately, at the end of that process, sometimes we can't get those contributions.

Okay, but—

Jenny, we're going to have to move on. Andrew and then Joyce.

Just very briefly on the housing numbers in the NDF—I'm a regional Member, I represent three local authority areas; I've already declared my interest in the Vale. One thing that I always find when local development plans come forward is that whatever region—whether it's in Cardiff or whether it's RCT or the Vale, people are fixated on numbers, they are. The Vale, for example, has this 10,000 figure, Cardiff was anything between 45,000 and 55,000 units. Here we have a figure of 8,300. We know we're starting behind the curve in that over recent years we just have not been building enough houses. We can argue whether that's social housing, private housing—it's across the board, basically.

As planners, what confidence have you got that that figure of 8,300 is a figure that is (a) achievable and (b) will start to move us in the right direction to increase the housing stock that we require? Because, as I said, from my point of view as an elected Member, constituents can get their head into numbers, they can understand numbers. The rest of this is, with the greatest respect, to constituents and to myself, most probably, slightly double Dutch, because I'm not a planner, I'm not, then. And when you look at the south-east region, where there's a big green belt, a lot of those numbers are going to—selfishly looking at this—come into my region of South Wales Central, they are, then.

Can I just say that, when it comes to the expression 'affordable housing', that's one of the things that scares local people? And the only way of getting around that is by talking of new housing to meet young adults or maybe older adults wanting to downsize, but actually talking to people as if it may be your young adults or your elderly parents, or it may be your neighbours. But when you talk about affordable housing in the round, they panic and think of it as being not their community, but invading neighbouring communities, and not necessarily of their social standing or whatever. It's very, very difficult to take that mindset and shift it into, 'This is about providing homes so that your extended family can live locally.'

Okay. Thank you.

[Inaudible.]

Sorry, I do go back—I'm just trying to test the robustness of the figure, because it's a central plank of, obviously, this document.

No-one spoke, so I wasn't quite sure—. Go ahead.

We'd like to know where that came from, what's the evidence behind that. I think the Planning Officers Society Wales have done some research about the numbers of housing requirements in the LDPs that are current, and the difference is quite marked to the 8,000 in the NDF. So, what's happened—we know that we're not delivering against those aspirational figures in our LDP, because they were aspirational by the Welsh Government—

Are you able to give us that difference off the top of your head, or—

I was looking for the piece of paper—

Can I just say that we had a meeting yesterday with two Welsh Government officials, as mid and south-west heads of planning or stand-ins? There are two lots of population and household figures that have been delayed and are coming out, and they've indicated that they will be taking the emerging figures into account in between the consultation draft and the submission to the National Assembly for scrutiny.

That's helpful to know, and thank you for that. Can I have that figure, if you've got it, please, where you said there's a difference between this 8,300 and the figure that, as an organisation, you have looked at, worked the evidence and come up with a number?

So, it's—. What it's based on, what Tracy was alluding to, is the existing local development plans. Now, in this part of the world, all of those are currently being—well, not all of them, seven out of the 10 are being reviewed, and so the housing figures now need to be completely up to date. Some of them are five, six, seven, eight years old, if not more, and, at the moment—don't quote the exact figures, okay, but I think it's more like 10,000 rather than 8,000. We're not meeting that; we're closer to around the 6,000, I think.

So, there's a whole host of reasons why those existing plans are not delivering those kinds of numbers. Those plans under review, they are looking at ways in which to address that issue, but the issue of housing need is still there, and these estimates are taking on a whole host of things, largely births and deaths, and those are pretty constant and pretty known, and then it's the migration factor that is unknown, and there are all sorts of factors that affect that, economic development being a key one.

I think there was a feeling that perhaps the potential of the impact of economic development was overplayed last time round and hasn't possibly come to fruition. However, there are factors now like city deal proposals that mean that those economic development factors are far more likely to come to fruition, things like the bridge tolls opening up in this part of the world—they are going to be drivers for change, and so I think, at the moment, our feeling is that this basis is too simplistic to just assume based on almost birth/death scenarios and maintaining the status quo, rather than being—. At local development examination, you consider all the other factors that are going to affect migration, and that's why you come up with your housing figures. You will always have the development industry in the one half of the room telling you that you haven't gone far enough, and you will always have the local communities and environmental groups saying you've gone too far. Those things are—it really is a sort of tug of war, but I have to keep emphasising it's based on evidence, and it's a whole package of information that informs those kinds of decisions.

This, quite rightly, I think, is at a higher level, but it's almost unhelpful to have those figures in here at this stage because they change regularly and because they almost set the bar, and then actually, when the likes of us come up behind trying to do strategic development plans and local development plans, where we're looking more robustly at the evidence and the figures and the influences, this is going to be used to beat us with, to say, 'This is what the NDF tells you'—

That's a real issue, when 1,700 houses have to be raised before you even start. I'm sorry, I don't want to—

We really do need to move on, Andrew.

That does need to be tested, that does, being so far out at the start.

Okay. That's for us to do another time. Joyce Watson.

I am going to move on. I'm going to ask if you have any views on the appropriateness of wind and solar energy priority areas. Do you have any views on the evidence base behind those? Do you have any views on the challenges in translating those areas into actual developments on the ground? Do you have any views on the inclusion of policies on district heat networks? And if you have no views at all, it doesn't matter.

I don't have any views on the wind and solar energy priority areas.

That's fine, so we'll move along.

If I just could say about the district heat network, I think Brecon has been identified, but I don't know where, again, that's come from, and what it actually means, who's going to be responsible for that district heat network. And I think it would be remiss of me if I didn't say the problem is then, whatever you do, you need the right connections to the grid, and we don't have it in rural Wales; it's just not there. That's why micro-hydro hasn't done so well, apart from the removal of the tariffs, obviously. But, you know, things like that—so, that needs to be thought about. So, we just wonder where—. We're not saying it's a bad idea; we'd just like to understand it a bit better. But I'm sure my colleagues might have views on windfarms.

Yes. For Ceredigion, we have no capacity for the grid to take any more renewable. 

Does it have to be on the grid, though?

That's the message we're getting, because of grid connectivity. So, that's, if you like, an example of where the NDF and the infrastructure work need to be joined up. The network providers are constrained by legislation so they can only respond to a firm request. So, if, for example, they have got the potential for three separate windfarms that would all require connectivity, and one comes in and the other two haven't, they can't plan for the wider connectivity.

Isn't this what the NDF is about, though—trying to direct some change in those things so that they're more deliverable?

It hasn't gone that extra step. It's identified that there are issues with connectivity, but it hasn't—. And I think, again, the current legislation prevents what needs to be done to address it. But as well as that there's the whole raft of potential technologies around hydrogen, battery storage, and things that would rely on renewable energy being co-located with significant water supply, and we need a flexible enough NDF to be able to build on that. So, it may well not be connectivity in the way that we've had it in the past. It may be a new form of transfer of that electricity, or bringing the added value of the end users to where that's produced to grow the economy.

But, in the light of that, just going back to district heating, would you, given the current problems with the grid—in 20 years' time we won't be having that discussion, I'm sure—not expect to see some sort of obligation for new developments to incorporate district heating so that we're not having the grid problem, because the heating will be used locally?

I think—. I mean, where the scale's appropriate. We've got a district heating network in Aberystwyth that takes in the Welsh Government building, Ceredigion's new building, the neighbouring school—there's discussion around whether it could be expanded to include some of the university estate. We've had another proposition for co-location of district heating with the extra-care home in Tregaron and with the housing provision alongside, and that has just fallen through on just the complexity and the need to draw a line on certainty of what will be provided in the contract. But a huge amount of work has gone into that, so there are some very disappointed people who've worked very, very hard to try and make it happen, and it's not. 

But, given that our objective is to eliminate carbon emissions by 2030, shouldn't district heating be the norm, given that the technology is going to be swiftly moving on and that this is the framework that we're trying to set for the next 20 years? Shouldn't district heating be the norm, unless there are exceptional circumstances?

Yes, but, if you like, to some extent, it's fitting that into the viability issues and how you can make this happen if it's not absolutely compulsory. And, if it is absolutely compulsory, would that put a stop on a particular development because there's not enough money in it to make it happen? The one in Aberystwyth—

In other countries, they've had district heating systems for years and years. 

Yes. Yes.

I think, hopefully, public bodies can take the lead on this. I know Powys County Council are exploring it with one of their schools in Talgarth, from an anaerobic digester, getting the heat from there to help to heat the school, and there's a housing development alongside it. But they're taking the lead and I think it almost has to be that first, really, while developers find that it's worth their while to do it, because there are benefits to it.

I can see that, but surely the planning policy has to make it the norm so that all south-facing roofs would have solar panels on them, or—

Or we need more focus on the really good examples that are out there, and we need to communicate that better to potential developers. But one of the issues is that it doesn't save money on the development, it saves money on the operating costs. But done right—. The Joseph Rowntree Foundation has developed—I'd guess you'd call it an urban extension—within a mile of York city centre, where they've got a district heat network, they've got swales, but they've got a district heat network that, if you like, is the driver within a building that's a community-use building. So, it starts to get the community working together, living together, just actually thinking up ways in which they can collectively be more sustainable. 

Can I suggest, because there are some things that we haven't talked about, except for that the Chair happened to mention it—? So, if we talk about the appropriateness of—we're talking about heat networks now, but it could be anything else. So, this is a policy, a headline policy, that's coming out of here and we've asked you for some of your views on what might prevent it and what might be difficult, but nobody's mentioned land at all. You've got landholdings, you've got landholdings, you've got landholdings, and yet nobody's mentioned it. Because the cost of land can be prohibitive, but also if, as delivery arms, delivery agents, you look at that first of all as an enabler to delivery, you've taken out one obstacle because you're not paying for it; you've already got it, it's yours in trust by the local taxpayer. And I haven't heard anybody mention it, and I'm a little bit surprised not to have heard any mention whatsoever, yet, of landholdings and how they might be more joined up in the thinking, whatever the thinking is, in terms of trying to deliver something at the NDF. So, do you do any of that thinking? Because—. I'm just asking.

As a part of the local development plan, we do an open call for sites, which I'm sure you will all be aware of. It's usually the point at which the community gets very, very nervous about what's coming forward. But, alongside that, we will also be doing that trawl internally: what do we own? What might you be thinking of using it for? And if it isn't already within an allocation or you need to make sure that that comes forward so it can be treated on an even keel with what comes forward from the public—