Future Wales and how the national plan applies to your site
Future Wales: The National Plan 2040 is part of the development plan in Wales, not a material consideration like the English framework. What that means for how a planning statement is structured.
This article covers Wales only. Future Wales: The National Plan 2040, published in February 2021, is not guidance. It forms part of the statutory development plan in Wales, which means section 38(6) of the Planning and Compulsory Purchase Act 2004 applies to it directly: applications are determined in accordance with the development plan unless material considerations indicate otherwise. A consultant used to the English system, where the National Planning Policy Framework is a material consideration rather than part of the plan, has to make that adjustment before writing a single paragraph of a Welsh planning statement.
The practical consequence is that a Future Wales policy is not weighed against the local development plan as an outside factor. It sits inside the plan alongside it.
What Future Wales is and its status in the plan
The Planning (Wales) Act 2015 created a tiered development plan for Wales and put the national development framework at the top of it. Future Wales is that framework.
The tiers run national, regional and local. Future Wales sits at national level. Strategic development plans sit at regional level, covering more than one authority. Local development plans sit at authority level, and place plans can sit below them as supplementary material where a community prepares one.
Each tier must be in general conformity with the tier above. So a local development plan adopted after Future Wales has to conform to it, and an older local development plan adopted before it may not.
Planning Policy Wales is a different animal, and conflating the two is the most common error in English-trained submissions. Planning Policy Wales is national planning policy and a material consideration. It is not part of the development plan. The Technical Advice Notes sit beneath it in the same category.
The regional structure and growth areas
Future Wales divides the country into regions, each with its own set of regional policies addressing that region's growth, infrastructure and landscape.
Above that sits a spatial strategy identifying national growth areas, which are the places the plan directs the largest share of growth: the Cardiff, Newport and Valleys area in the south east, Swansea Bay and Llanelli in the south west, and Wrexham and Deeside in the north east. Regional growth areas sit below them.
For a site promoter this matters in a specific way. A proposal inside a national growth area can point to the plan's own strategy as support for the principle of growth in that location. A proposal outside one cannot, and has to make its case on the plan's rural and smaller settlement policies instead. That is a different argument with a different evidence base.
Do not overstate it either way. Being inside a growth area is not a permission, and being outside one is not a refusal.
Policies that apply directly to applications
Several Future Wales policies bear on individual applications rather than only on plan making, and these are the ones to have open when drafting.
The opening policies set out where Wales will grow and how urban growth and regeneration should be shaped, which supports a sustainable placemaking argument for brownfield and town centre sites. There are policies on resilient ecological networks and green infrastructure, on flooding and water, on renewable and low carbon energy, and on the Welsh language and community facilities.
The energy policies are the ones with the sharpest application effect. Future Wales identifies pre-assessed areas for wind energy, where the principle of large-scale wind development has already been accepted at national level subject to local assessment. A scheme inside one of those areas starts from a materially different position from one outside.
Where you cite a policy, cite it as "Future Wales: The National Plan 2040, Policy [number]" and state that it forms part of the development plan. Then cite the local development plan policy alongside it. An officer reading a statement that treats Future Wales as background material will discount the argument.
The relationship with local development plans
Three situations come up, and they need different handling.
Where the local development plan was adopted after Future Wales and has been found in general conformity with it, the two should read consistently and the statement can cite them together.
Where the local development plan predates Future Wales, there will be gaps and occasional conflict. Section 38(5) of the 2004 Act deals with conflict within the development plan by giving precedence to the policy in the document last adopted or approved, which in that situation is Future Wales.
Where the local development plan is out of date or past its plan period, Future Wales carries more of the weight and the argument moves towards the national policies plus Planning Policy Wales.
Check the adoption date of the local development plan first, every time. It determines the structure of the policy section of your Planning Statement more than anything else about the site.
Strategic development plans and their progress
The regional tier is the part of the structure that is still being built. Strategic development plans are being prepared by the corporate joint committees established under the Local Government and Elections (Wales) Act 2021, and progress varies by region.
Until one is adopted in a region, the development plan for a site there is Future Wales plus the local development plan. Check the current position with the relevant corporate joint committee before referring to an emerging strategic plan, and where one is at an advanced stage treat it as an emerging plan with weight to be argued, not as part of the plan.
An emerging strategic development plan is a material consideration whose weight depends on its stage, the extent of unresolved objections and its consistency with Future Wales. That is familiar territory for anyone who has argued emerging local plan weight in England.
Where conflict between tiers arises
| Situation | How to handle it |
|---|---|
| Local plan silent, Future Wales has a policy | Apply the Future Wales policy directly as part of the development plan |
| Local plan and Future Wales conflict, local plan older | The later document takes precedence under section 38(5) |
| Local plan and Future Wales conflict, local plan adopted later and found in conformity | Read them together; genuine conflict should be rare |
| Both silent | Planning Policy Wales and the Technical Advice Notes as material considerations |
| Site in a pre-assessed area for wind energy | Cite the national acceptance of the principle, then address local assessment |
The middle row is where consultants get caught. A local development plan adopted after Future Wales was examined for general conformity, so an apparent conflict is more often a misreading of one of the two documents than a real inconsistency.
Citing the plan correctly in a statement
Structure the policy section in the order the plan hierarchy sits in, which is not the order an English statement uses.
- Identify the development plan for the site by name and adoption date, listing Future Wales, any adopted strategic development plan, and the local development plan.
- Set out the Future Wales policies engaged, by number, with the relevant text summarised.
- Set out the local development plan policies engaged, and state whether the plan predates or postdates Future Wales.
- Address conflict expressly where it exists, with the section 38(5) position.
- Then turn to Planning Policy Wales and the Technical Advice Notes as material considerations, clearly labelled as such.
- Deal with any emerging strategic development plan last, with a reasoned position on weight.
Where heritage is engaged, the Welsh consent regime has its own features, and the position on listed building consent in Wales and the role of Cadw sets those out. Flood risk in Wales runs on Technical Advice Note 15 rather than the English sequential and exception tests, and the contrast with the avoidance principle under NPF4 in Scotland and with retained policy under the SPPS in Northern Ireland is a reminder that none of the four frameworks can be treated as a variant of another.
PlanScope's drafting is grounded in English national policy and local plans, so a Welsh application needs the reviewer to check Future Wales, Planning Policy Wales and the Technical Advice Notes before the document is relied on. Reports should be reviewed before submission, and PlanScope does not guarantee planning approval. Browse the report types by category to scope the supporting documents a Welsh application needs. This is general guidance, not legal advice; check the position with the local planning authority or a qualified professional before relying on it.
Frequently asked questions
Is Future Wales part of the development plan?
Yes. The Planning (Wales) Act 2015 created a tiered development plan for Wales with the national development framework at the top, and Future Wales: The National Plan 2040 is that framework. Section 38(6) of the Planning and Compulsory Purchase Act 2004 therefore applies to its policies directly rather than treating them as material considerations.
How does Future Wales differ from Planning Policy Wales?
Future Wales is part of the statutory development plan. Planning Policy Wales is national planning policy and a material consideration, as are the Technical Advice Notes beneath it. Treating the two as equivalent is the most common error in submissions written by consultants trained in the English system.
What happens when the local development plan conflicts with Future Wales?
Section 38(5) of the 2004 Act gives precedence to the policy in the document last adopted or approved. Where the local development plan predates Future Wales, the Future Wales policy prevails. Where the local plan was adopted afterwards and found in general conformity, an apparent conflict usually turns out to be a misreading.
What are the national growth areas?
The places Future Wales directs the largest share of growth: the Cardiff, Newport and Valleys area in the south east, Swansea Bay and Llanelli in the south west, and Wrexham and Deeside in the north east. A site inside one can rely on the plan's own strategy for the principle of growth; a site outside one argues on the rural and smaller settlement policies.
Are strategic development plans in place yet?
The regional tier is still being built, with strategic development plans being prepared by the corporate joint committees established under the Local Government and Elections (Wales) Act 2021. Progress varies by region, so check the current position before citing one and treat an advanced plan as emerging with weight to be argued.
How should a Welsh planning statement be structured?
Identify the development plan by name and adoption date, set out the Future Wales policies engaged by number, then the local development plan policies with a note on whether that plan predates Future Wales, address any conflict under section 38(5), and only then turn to Planning Policy Wales and the Technical Advice Notes as material considerations.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.