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WAG Consultation: Microgeneration and Low Carbon Energy Technologies: Proposed Changes to PDR

ACE has submitted a written response to the Welsh Assembly Government consultation: “Microgeneration and Low Carbon Energy Technologies: Proposed Changes to Permitted Development Rights”

A summary of our response is given below or download our full response by clicking here.

ACE welcomes the Welsh Assembly Government’s decision to grant permitted development rights to microgeneration technologies. It is clear that microgeneration will have a significant role to play in meeting the Welsh Assembly Government’s ambitious carbon reduction targets only if the current barriers to their installation are substantially reduced. We welcome many of the proposals set out in the consultation paper as a small step in the right direction.

However, we believe the approach taken in much of the consultation paper is too restrictive and is out of step with the Welsh Assembly Government’s ambition to significantly cut carbon emissions in Wales.

The proposals as they currently stand lack ambition for Wales.While the proposals in this consultation represent a step in the right direction, if the Welsh Assembly Government is serious about increasing the uptake of microgeneration by removing potential costs or administrative barriers, then we would like to see more ambitious proposals brought forward.

As a general rule, while we understand the motivation behind the proposal not to grant permitted development rights in and around historic buildings, we do not believe that such a ‘blanket exemption’ approach is helpful. Rather, because of the importance of rapidly reducing greenhouse gas emissions from the built environment, we would prefer permitted development within and around historic buildings to be granted, and for planning authorities to issue ‘Article 4 directions’ for specific historic buildings which should be protected against inappropriate development. We prefer this approach for two reasons:

Firstly, because of the importance of reducing greenhouse gas emissions from the built environment, the presumption should always be in favour of granting permitted development, even in designated areas, unless there is good reason not to do so. Treating designated areas as a ‘class exemption’ from PD would run counter to this and would not in our view be appropriate.

Secondly, where PD rights are withdrawn under Article 4 Direction, no planning fee is required, thus removing one of the barriers to the take up of microgeneration. This would again be preferable to granting a ‘class exemption’ from PD in designated areas, which would then require a planning fee.

To read our full response please click here.


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