Comment

Future Wales: The National Plan 2040 & the role of Strategic Development Plans

Following the publication in February of Future Wales: The National Plan 2040 and Edition 11 of Planning Policy Wales (2021), our Cardiff team will be providing their thoughts on the document’s key takeaways. First in the series, we consider the role of Strategic Development Plans in the Welsh plan making process.

We welcome the first publication of a national tier of the development plan in Wales. Future Wales is ambitious, concise and spatial in focus. It provides further clarity on the direction of travel adopted by Welsh Government and is the first major publication in the drive to create a ‘distinctively Welsh planning system’.

Whilst we support Future Wales’ ambition, we are not getting carried away!

National development plan

Future Wales is the national spatial strategy for Wales. It seeks to focus on solutions to issues and challenges at a national scale. The plan sets national objectives and promotes a broad spatial strategy to achieve them. It is ambitious in key sectors including housing and affordable housing growth, placemaking, well-being and quality of life, sustainability and renewable energy.

Future Wales is clear on one central thread: the document will not work in isolation. Welsh Government is seeking to empower plans at regional and local levels. These plans must identify the location of new infrastructure and development required to deliver national ambitions. They must be kept up to date and in conformity with Future Wales.

The ‘Model of Future Wales Influence’ on page 12 of the document shows how national, regional and local plans must work together.

Regional workload

Many of Future Wales’ ambitions are admirable. The structural question is how and when will these ambitions face meaningful scrutiny (in the same way as any other development plan document) or be delivered? The answer is delegated. Future Wales ‘empowers’ plans at the regional and local scale to identify schemes and projects that benefit communities and help achieve national ambitions. It unmistakably concentrates the pressure on regional and local plan making.

Strategic Development Plans (SDPs) will form the regional tier. Wales’ four regions (North; Mid Wales; South East; South West) must produce SDPs that embed placemaking as an overarching principle (Policy 19). They must co-ordinate and manage development across each region and ensure that wider than local matters are tackled collaboratively.

The plans must consider strategic regional matters for spatial strategies for future growth to settlement hierarchies, and sustainably manage natural and cultural assets. SDPs must set housing provision requirements, co-ordinate transport and green infrastructure, and the delivery of minerals extraction in appropriate locations.

Some outcomes are already imposed on SDPs. Future Wales identifies a broad area within the South East Wales growth area for an ill-defined ‘Green Belt – Area for Consideration’. A similar area is demarcated in North Wales. The SDPs must retrofit the evidence for this, be tested for robustness and stand up at examination (the scrutiny is likely to be significant).

Future Wales is clear that until the adoption of an SDP the area must be treated as Green Belt in planning terms. The planning policy context setting out the circumstances for limited development in these areas is set out in PPW11. This restrictive position will persist until the SPD and consistent LDPs are adopted – the timescales for which are significant.

We have areas of Wales subject to the highest protection from new development. Areas where the definition of appropriate development is severely limited. These areas are untested and unsubstantiated. The greatest challenge for the industry in the immediate term is the lack of clarity regarding the precise geographical extent of these areas. Greater clarity from Welsh Government is required to inform the interim planning position.

This awkward and untried position is challenging in planning terms. It is challenging from a decision making and deliverability perspective. The South East Wales Green Belt area is air brushed across a large swathe of the region, challenged with delivering the largest proportion of the ambitious growth targets in Wales. There is a clear juxtaposition in aims and ambitions with an indefinite period of uncertainty before it can be resolved.

Regional planning in its infancy

Action needed

We support the delivery of effective regional planning as an opportunity for Wales. Alongside the House Builders Federation (HBF), we confirmed this support in October 2019, setting out the key actions needed to make regional planning a success in Wales.

No confirmation has been given that any of the key actions have been realised. There is no certainty on approach and/or timescales for any of the SDPs proposed. There is a distinct absence of clear leadership on how this raft of work can be efficiently completed.

Collaborative action is quickly needed if the regional tier is to fulfil its potential in providing the evidenced strategic direction required to drive sustainable growth. This is the only way to cut across matters of greater than local importance, combat local politics, and provide a clear strategic policy framework and direction for decision makers.

The making of a successful SDP

In October 2019, alongside the HBF, we set out the following guidelines for the delivery of successful SDPs in Wales:

• Balancing detail with expediency – the scope must be realistic and deliverable.
• Clean slate approach evidence base – layering of up to date evidence including market input is vital to robust and informed regional growth strategies.  
• Consensus and strong governance – consensus and compromise is vital on key spatial decisions that aren’t undermined by competing political agendas.  
• Meaningful collaboration – meaningful two-way collaboration and engagement between the plan makers, development industry and local communities will be essential.  
• Realistic timescales for delivery – SDPs must be clear in scope, ambitious and prepared in a manner that avoids slippage, which will undermine confidence and decision making.

Policy vacuum

We are concerned at the potential time lag between the publication of Future Wales and the adoption of SDPs. The first SDP in South East Wales could be 5-7 years away from adoption. Some local authorities have outdated and ineffective adopted Local Development Plans (LDP). A number of LDP reviews are underway.

Where does this vacuum leave developers and decision makers? Will planning applications in authorities such as Caerphilly (LDP adopted in 2011) now be determined on the basis of primary weight being given to Future Wales and PPW11? How does this sit alongside recent Welsh Government decision making in the county borough, which gives absolute primacy to the local development plan?

When tackling the strategic matters at the regional level, decision makers need clarity on the everyday job of delivering sustainable development to meet identified needs in the immediate term. Without this, the development industry will struggle to deliver the positive growth aspirations championed by Welsh Government.

Ambition and opportunity

Future Wales is certainly an improvement on the Wales Spatial Plan. It has ambition, a spatial strategy and a growth agenda. The devil is in the detail of a development plan document published for the first time without any genuine scrutiny through the proper plan making process. This remains uncomfortable. The policy vacuum and balance of weight given to often competing policies in the decision making process are likely to undermine deliverability. Effective collaboration with a suite of co-operating development plan documents (starting with SDPs), that drive a genuine sustainable growth agenda for Wales, is essential.

We are keen to start a dialogue on a Welsh approach to regional planning. Future Wales and its emphasis on the regional tier makes this dialogue essential. We urge plan and policy makers to engage with industry to set a realistic and deliverable regional agenda without delay.

This same dialogue must address the immediate policy vacuum. Without both, the delivery of new development required to meet the social, economic and environmental needs of our communities in the ambitious manner envisaged in Future Wales will be significantly impacted.

Follow our thoughts over the coming weeks on our website and social media platforms. Our Cardiff based team is well placed to advise on all policy matters that impact on your development strategies and projects across all sectors throughout Wales. Please get in touch with Owen Francis or Huw Jones for more information.

16 March 2021