PPW and the Welsh Planning Framework
Wales has its own planning legislation, national policy, and development plan hierarchy, distinct from both England and Scotland. Planning is governed by the Planning (Wales) Act 2015, which introduced a three-tier development plan system. At the top sits Future Wales: The National Plan 2040, adopted in February 2021, which sets the spatial strategy for the whole of Wales. Beneath that, Strategic Development Plans (SDPs) will cover regions such as the Cardiff Capital Region and South West Wales, though these are still emerging. At the local level, each of the 22 principal councils adopts a Local Development Plan (LDP) that contains detailed site allocations and development management policies.
Planning Policy Wales (PPW) Edition 12 is the Welsh Government’s overarching policy guidance, equivalent in function to the NPPF in England but distinct in content and emphasis. PPW is structured around the concept of placemaking and the well-being goals of the Well-being of Future Generations (Wales) Act 2015. The Technical Advice Notes (TANs) supplement PPW with topic-specific guidance — TAN 12 (Design), TAN 18 (Transport), TAN 24 (The Historic Environment), and TAN 15 (Development, Flooding and Coastal Erosion) are among the most frequently engaged in objection letters.
While PPW and the NPPF share common ground on issues like protecting amenity and requiring good design, there are significant differences that affect how objections are framed. First, Future Wales forms part of the statutory development plan — so its policies carry plan weight in the same way that local plan policies do, unlike the NPPF which is a material consideration but not part of the plan. Second, the Welsh language is a material planning consideration in Wales: PPW and TAN 20 (Planning and the Welsh Language) require local planning authorities to consider the impact of development on Welsh-speaking communities. Third, Wales retains its own TAN framework which differs from England’s approach in several areas — notably TAN 15 on flood risk, which takes a more restrictive stance than the equivalent English policy. Fourth, the Welsh Government’s emphasis on placemaking principles pervades PPW in a way that goes beyond the NPPF’s design policies.
Each of Wales’s 22 principal councils has or is preparing an LDP. Swansea Council adopted its LDP in 2019, while Conwy County Borough Council’s LDP covers the period to 2022 with a replacement plan under preparation. Wrexham County Borough Council, Bridgend County Borough Council, Carmarthenshire County Council, Ceredigion County Council, Monmouthshire County Council, the City of Newport, and Rhondda Cynon Taf County Borough Council each maintain their own adopted plans with locally specific policies on design, housing mix, amenity standards, and environmental protection. When preparing an objection in Wales, we identify the precise LDP policies that apply — these vary considerably between authorities — and combine them with the relevant PPW chapters and TANs.
Planning Voice has prepared objection letters across a wide range of Welsh council areas, including Wrexham, Ceredigion, Carmarthenshire, Bridgend, Conwy, Swansea, Newport, Rhondda Cynon Taf, and Monmouthshire. Our work in Wales has addressed HMO conversions in conservation areas, rear and side extensions causing loss of light and overbearing impact, new dwelling proposals in sensitive rural and heritage settings, and large-scale residential developments on unallocated greenfield sites beyond settlement boundaries. In each case, we have grounded our objections in PPW, the relevant TANs, and the specific LDP policies that apply to the council area in question.
In Wrexham, we objected to the conversion of a dwelling to a large House in Multiple Occupation within the Fairy Road Conservation Area. Our objection engaged the Wrexham LDP’s policies on HMO concentrations, historic environment protection, and transport impact, arguing that the proposal would result in overconcentration of HMOs in an area where nearly half the borough’s HMOs were already clustered, would harm the architectural integrity and character of the conservation area through external alterations and increased transient occupation, and would exacerbate existing parking pressures on already congested streets.
In Ceredigion, we objected to a proposal to replace a single-storey garage within the Aberystwyth Conservation Area with a two-storey building containing multiple flats, adjacent to a Grade II listed building. We raised loss of light to at least six neighbouring homes already constrained by limited sunlight access, overdevelopment and excessive housing density in an already strained residential area, and harm to heritage assets including the conservation area and the setting of the adjacent listed building, contrary to the Ceredigion LDP’s policies on design, conservation areas, and sustainable growth.
In Carmarthenshire, we objected to a new dwelling proposal on the basis of insufficient demonstrated need, engaging Welsh Government circular guidance on accommodation assessments together with the LDP’s policies on development need, traffic safety, accessibility, and landscape impact. In Bridgend, we objected to a two-storey side extension and single-storey rear extension with balcony, arguing that the elevated balcony and associated privacy screening would cause serious overlooking of the adjacent property, loss of daylight to habitable rooms, and an overbearing visual impact along the shared boundary, contrary to the Bridgend LDP and SPG 02 on householder development.
In Conwy, we prepared a pre-application objection to a proposed development of up to 95 dwellings on land beyond the settlement boundary within a designated Special Landscape Area. Our objection argued that the proposal represented a speculative departure from the LDP’s spatial strategy, that the site was not allocated for housing and the council’s housing requirements were being met, and that the development would cause unacceptable landscape harm and conflict with policies protecting the settlement boundary, countryside, and environmental assets.
The conversion of dwellings to Houses in Multiple Occupation is a recurring issue across Welsh towns, particularly where proposals fall within or adjacent to conservation areas. We have objected where the cumulative effect of HMO concentrations erodes community cohesion and the character of established residential areas. In Wrexham, the ward containing the application site held nearly half of the borough’s total HMO stock, far exceeding the threshold at which research indicates that HMO-related concerns become significant. External alterations associated with HMO conversions — including new soil pipes, frosted glazing, mechanical ventilation, and modified window openings — can harm the architectural integrity of Victorian and Edwardian properties within conservation areas. In Ceredigion, a proposed intensification within the Aberystwyth Conservation Area threatened the setting of a Grade II listed building. Welsh LDP policies on HMO concentrations, conservation area character, and the SPPS provisions on the historic environment provide robust grounds for objection where these cumulative impacts arise.
Householder extensions remain one of the most common sources of planning objections in Wales. We have objected to rear and side extensions where the scale, height, and proximity to boundaries would cause unacceptable loss of light and overshadowing to neighbouring habitable rooms. In Bridgend, the introduction of a first-floor balcony with an associated privacy screen along the shared boundary was argued to create a wholly new form of overlooking — providing an elevated external platform for sustained observation into the neighbour’s garden, patio, conservatory, and first-floor bedrooms. The privacy screen itself, intended as mitigation, became an additional source of visual harm through its overbearing height and proximity. In Ceredigion, a proposed two-storey building would have reduced daylight penetration to at least six neighbouring homes, increasing dependency on artificial lighting and contradicting the principles of sustainable development. Welsh LDP design policies, PPW Chapter 3, and TAN 12 provide the framework for these amenity-based objections.
Wales contains extensive areas of protected and sensitive landscape, including Special Landscape Areas, Areas of Outstanding Natural Beauty, and the settings of historic towns and villages. We have objected to new dwelling proposals and large-scale residential developments where the site lies outside the defined settlement boundary or within a landscape designation. In Conwy, a proposal for up to 95 dwellings on unallocated greenfield land within a Special Landscape Area was argued to represent a speculative departure from the LDP’s spatial strategy, conflicting with policies that direct housing to allocated sites within settlement boundaries. In Carmarthenshire, we engaged the evidence base on accommodation need to demonstrate that the identified requirement had already been met through existing consents, rendering the proposed development unjustified. Welsh policy, through PPW and the LDP framework, places the burden on applicants to demonstrate that development beyond settlement limits is necessary and would not cause unacceptable landscape harm, making these cases well-suited to policy-led objections.
If a planning application in Wales affects your property, our Chartered Town Planners will assess your case free of charge. We prepare each objection around PPW, the relevant TANs, and your council’s adopted LDP policies, ensuring your representation carries weight with the local planning authority. Contact us with the application reference for a same-day assessment.
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Yes. Under Planning Policy Wales and TAN 20 (Planning and the Welsh Language), the impact of development on Welsh-speaking communities is a material planning consideration. This is particularly relevant in areas where a significant proportion of the population speaks Welsh, such as parts of Gwynedd, Ceredigion, Carmarthenshire, and Conwy. Where a development would result in a significant influx of non-Welsh-speaking residents or undermine the linguistic character of a community, this can form a legitimate ground of objection. Local development plans in these areas often contain specific policies requiring Welsh language impact assessments for larger housing proposals.
TAN 15 (Development, Flooding and Coastal Erosion), updated in 2021, takes a notably precautionary approach to flood risk in Wales. It classifies land into flood zones and establishes a presumption against highly vulnerable development in high-risk flood areas. In practice, TAN 15 has been the basis for many planning refusals in Wales, particularly in valley communities where development sites are constrained by river floodplains. If a proposed development in Wales is located in or near a flood zone, TAN 15 provides strong policy grounds for objection — often stronger than the equivalent Framework policy in England.
Planning appeals in Wales are determined by Planning and Environment Decisions Wales (PEDW), the Welsh Government’s equivalent of the English Planning Inspectorate. As in England, only applicants can appeal — there is no third-party right of appeal for objectors. Appeals can be made against refusal of permission, non-determination, or conditions attached to a grant of permission. PEDW inspectors apply the same Welsh policy framework (PPW, TANs, Future Wales, and the relevant LDP) when determining appeals. This means that the objection grounds you raise at the application stage remain relevant throughout the appeal process, making a well-prepared initial objection essential.
We have prepared objection letters across multiple Welsh council areas including Wrexham, Ceredigion, Carmarthenshire, Bridgend, and Conwy. Our work has covered HMO conversions in conservation areas where overconcentration and harm to heritage character were the primary concerns, extensions and balconies causing loss of light, overlooking and overbearing impact, new dwelling proposals where the demonstrated need had already been met, and large-scale residential developments on unallocated greenfield sites beyond settlement boundaries within Special Landscape Areas. We have also prepared objections in Swansea, Newport, Rhondda Cynon Taf, and Monmouthshire.
Yes. Unlike England, where some HMO conversions fall under permitted development, Wales requires planning permission for changes of use to HMOs. Local development plans often contain specific policies on HMO concentrations, parking standards, and the protection of residential character. Where an area already has a high density of HMOs, the cumulative impact on community cohesion, parking, noise, and general amenity provides strong grounds for objection. Our Chartered Town Planners will assess whether the specific LDP policies and PPW guidance support an objection in your case.