The problem is not ‘development’ or ‘carbon emissions’,
the problem is ‘consumption’

Paul Mobbs & MEIR:

A response to the Welsh ‘NDF 2020-2040’

A report commissioned for the Free Range Network by the Llandeilo Green House, it details the ecological case against the Welsh Government's ‘National Development Framework 2020-2040’. The report takes elements of the NDF’s policy objectives and shows – with reference to present-day data and research evidence – how we can easily invalidate the claims of the NDF when we look at their impact on ecological and social sustainability.

Main index
About my work
‘Ecological Futures’
Writing & Research
dowload PDF click to download PDF of
‘A Response to the Welsh Government's ‘National Development Framework 2020-2040’’

The Llandeilo Greenhouse has commissioned and funded this study of the Welsh ‘Draft National Development Framework’ (NDF) in order to test the validity of the proposed spatial development framework, and whether or not it can be considered to represent ‘sustainable development’ – as defined within Welsh law.

Download the NDF consultation here –
dowload PDF
‘Consultation Draft: National Development
Framework 2020-2040’
, Welsh Government, 2019

There are key legal requirements placed upon the Welsh Government which they must fulfil when framing the content of that strategy. Failure to discharge that duty creates the possibility of a judicial review to test the law in this case.

NDF img

To quote the introduction to the report:

This National Development Framework sets out where we think we should try to grow and the types of development we need over the next twenty years to help us be a sustainable and prosperous society.

In our view, the failure to quantify the effects of policy with regard to national environmental and climate baselines, or even create a baseline of impacts with reference to the state of the environment today, represents a clear failure of the duty upon ministers under section 5 of the Well-being of Future Generations (Wales) Act 2015.

The problem for the Welsh Government is that the NDF contains no measured strategy or evidential substantiation for their claim that Wales can be a “sustainable and prosperous society”. By ‘measured’, we mean a quantified baseline for resource and consumption impacts within Wales today, and how the strategy will change key indicators as a result of changing development patterns.

dowload PDF
‘Economics for the future – Beyond the super-organism’
, N.J. Hagens, Ecological Economics, vol.169 no.106520, March 2020

At various points the consultation alludes to the promotion of attainment of ‘economic growth’. Whether that can be achieved within an objective definition of ‘sustainability’, and certainly within the requirements to significantly reduce carbon emissions to ‘net zero’, has not been demonstrated within the NDF.

Our query is whether that is a valid assumption, given the over-riding legal requirement to enact ‘sustainable development’. In an age of planetary boundaries and globalised trade, we must provide a measure of present-day impacts, and shift toward policies which bring that within ‘planetary boundaries’. Under such an analysis, Wales is already consuming “more than its fair share”.

dowload PDF
‘Time to leave GDP behind’
, Robert Costanza, Nature, vol.505, 16th January 2014

The only current model within economic research which is able to address that within planetary boundaries is ‘degrowth’. Consequently any future strategy must embrace the concept of ‘degrowth’, and map a national development framework which creates patterns of development and resource use which institute such a transition.

Transport and mobility are a critical area within the strategy, and within that, the creation of a highly mobile population using more electrified methods of transport. Given the clear restrictions on the development of electric vehicles, which have been consistently ignored by the politicians for some years, there is a doubt as to whether the desire for mobility can be met without violating the ‘sustainability’ requirements placed upon the Welsh Government in law.

dowload PDF
‘The Coming Copper Peak’
, Richard Kerr, Science, vol.343, 14th February 2014

We cannot accurately predict what the future will be, but we can say, based upon scientific principles, what is physically impossible.

Today ‘technological society’ is thoroughly unsustainable because the resources it depends upon are in short supply and are not being recycled. Even seemingly common metals, such as copper – essential for modern electronics – are approaching the ecological limits of resource production.

Due to the reliance upon electric vehicles, the transport elements of the development framework are physically impossible, unless the Welsh Government publicly abandons its commitment to taking only its “fair share” of the world’s resources. That is because implementing that strategy would demand an impossibly large share of the world’s metal resources.

This is why the focus on measuring a baseline for material consumption, and then planning policies which directly address consumption, is so critical to whether it can be considered to enact a “sustainable and prosperous society”.

carbon lifestyle
‘Extreme Carbon Inequality’
, Oxfam, December 2015.

The only way it would be feasible to carry out the Welsh Government’s strategy would be – as shown in relation to carbon emissions in the graph on the left – if the top few percent of the world’s population consumed the majority of the world’s natural resources.

That is not ‘sustainable’.

The cover picture chosen for this report was not random. It pictures the Rhinogydd mountains in the southern Snowdonia National Park. The trees in front are part of the Coed-y-Brenin Forest – which contains 200 million tonnes of copper and traces of rarer metals, which would have to be exploited should the Welsh Government’s technology-led agenda be enacted.

dowload PDF
‘Global Greenhouse Gas Abatement Cost Curve’
McKinsey & Associates, 2010

The NDF does not quantify any aspect of energy and resource use with reference to present-day data. If we fill-in the blanks with the latest energy and carbon statistics for Wales, we can very quickly see that the promises made in the energy and decarbonisation policies are meaningless and ineffectual.

dowload PDF
‘A safe operating space for humanity’
, Johan Rockström, Nature, vol.461, 24th September 2009

There is no rational way, based on current data, of demonstrating that NDF’s strategy on energy or carbon will have any impact commensurate with the scale of action required over the time-scale remaining.

There must be a development model which respects ‘planetary boundaries’. The NDF not only fails to provide this, but it seeks to perpetuate historic patterns of rural development which create the opposite outcomes. The NDF must lead with a new strategy to deliver opportunities for small-scale, low impact lifestyles in the countryside.

Wales must look beyond the industrial model in order to solve this. In order to reduce carbon emissions and resource demands, people must live closer to their food and work. That requires a wholly different model from the present urban model, developed almost two centuries ago in Britain as part of industrial urbanism.

dowload PDF
‘Practice Guidance: One Planet Development – Technical Advice Note 6’
, Welsh Government, October 2012

Luckily, Wales already has a framework for how this transformation can be achieved: The ‘One Planet Living’ model and the planning framework designed to accompany it.

Currently ‘One Planet Living’ is tolerated by many local authorities across Wales. What the Welsh Government should be doing is actively promoting this approach as a low-cost means to repopulate the countryside, thereby creating more support for local communities, public services and businesses in more remote locations. The NDF not only fails to provide this, but it seeks to perpetuate historic patterns of rural development which create the opposite outcomes. The NDF must lead with a new strategy to deliver opportunities for small-scale, low impact lifestyles in the countryside.

In conclusion:

The ‘National Development Framework 2020-2040’ report contains fundamental errors which render, in our view, the strategy chosen unlawful – because it violates the duty on the Welsh Government to implement ‘sustainable development’, and because the strategy cannot deliver the legally-binding requirements of the Climate Change Act 2008.

To the network of local environmental and green activists who commissioned this report, our conclusion is “find a lawyer”. Given the duties upon Welsh ministers, and their singular failure to discharge those duties in forming the the policies of the National Development Framework, should this document be enacted as policy this document represents a tremendous opportunity to test the limits of the law on sustainable development in Wales.