National Trust Wales Submission to the Environment and Sustainability Call for Evidence on the Planning (Wales) Bill

November 2014


As a charity rooted in the belief that places matter to people National Trust Wales sees land-use planning as a key tool in the creation of great places for people to live, work, play and visit.


An effective planning system guides good, necessary development to the right places, making an important contribution to prosperity and growth. It ensures that poorly designed developments and those in the wrong place don’t get built. It delivers the new homes, shops and services that community’s want, where they want them. And it protects the things that matter to us all; from much-loved open spaces, green fields and productive agricultural land to our historic city centres, towns and villages. National Trust Wales is a frequent participant in the planning system, and we recognise the importance of a fair and balanced decision-making process. We support a plan-led system as a means of providing certainty and confidence, and a way to deliver good development which meets long term needs.


We are grateful for the opportunity to respond to this call for evidence. We appreciate that the Planning (Wales) Bill which it addresses is the result of a lengthy Welsh Planning Review and we strongly support the evidence-based and consultative approach which has been taken by the Minister and his department.


While we welcome this Bill we also acknowledge that the Bill is the beginning not the end of a journey. Guidance which determines much of how the planning system will run will be developed over the next two years and we hope to remain engaged in this process.


In addition, one of the underpinning drivers behind Positive Planning is culture change within the planning system. We hope to support in this through our future representations to planning boards.


We only wish to make a short submission to the Committee covering the following areas;

1.    Loss of Design and Access Statements

2.    Resourcing of Local Authorities where applications are determined by the Minister

3.    Changes in regulations around applications to register town and village greens



1.    Loss of Design and Access Statements

We understand that the requirement for design and access statements will be removed by the Planning (Wales) Bill. While we accept this we do feel that some developments do need to give special consideration to design and access, especially those being developed in designated landscapes. We would like to encourage the inclusion of an alternative means for developers, where appropriate, to further consider the design and access features of their development.



2.    Resourcing of Local Authorities where applications are determined by the Minster

National Trust Wales has concerns around resourcing of Local Authorities in situations where applications are deferred to the Minister. In these cases Local Planning Authorities will be left to deal with the post-determination work (such as discharge of planning conditions) following an application for a DNS, which they would not be responsible for approving. This could cause resource issues for the authority, especially as they would not be in receipt of the planning fee for that application. We would suggest that a system through which the Minister’s office recompenses the Local Authority needs to be put in place.



3.    Changes in regulations around applications to register town and village greens

National Trust Wales is concerned that the provisions relating to Town and Village Greens will result in local people losing access to land that they rely on for exercise, leisure activities and general health and wellbeing. These areas are under incremental threat from development.


We are discussing how similar regulation has functioned in England and might subsequently support further changes to the Planning (Wales) Bill on this issue.



For more information please contact;

Emily Keenan

External Affairs Consultant