Part of 1. Questions to the Minister for Environment, Energy and Rural Affairs – in the Senedd at 1:33 pm on 13 November 2019.
Minister, the national development framework clearly is primarily the responsibility of the Minister for Housing and Local Government. But you've explained to us here previously how you've worked closely with her in developing many aspects relevant to your portfolio, and it will clearly have a huge bearing on your and the Government's ability to deliver on your aspirations in relation to biodiversity, carbon reduction, renewable energy, et cetera.
And I'd like to start with renewable energy, if I may. There are 11 energy priority areas designated for onshore wind development in the NDF—the draft NDF. But there have been huge concerns from many in the sector, and beyond actually, that the Arup assessment used to underpin the proposal is fundamentally flawed, and that those areas, as a result, are largely unusable for onshore wind. Arup have applied, I'm told, inappropriate constraints, onerous buffers around designations, they failed to include separation distances from residential properties, which developers apply as standard to mitigate against the impacts of noise, visual amenity, or shadow flicker impacts. Now, that means that less than 10 per cent of the priority areas are actually suitable for wind, and only 5 per cent is available once, of course, existing windfarms have been excluded. Now, furthermore, available areas are only likely to be suitable for projects of less than 10 MW. That won't, then, fall under the development of national significance system and will therefore not be assessed against the NDF. So, do you accept that these proposals are flawed and that we should replace the place-based system of energy priority areas with a broader criteria-based approach?