Ein cyf/Our ref: NICW/25/DC/PDRC
Changes to Permitted Development Rights Consultation
26th June 2025
Dear Sir / Madam
Changes to Permitted Development Rights Consultation 2025
The National Infrastructure Commission for Wales (NICW) welcomes the opportunity to respond to the Welsh Government’s consultation on proposed changes to permitted development rights (PDRs).
Our response focuses on the proposals for air source heat pumps (ASHPs) and is grounded in the Commission’s strategic vision for a resilient, low-carbon Wales, as set out in our 2023 report "Preparing Wales for a Renewable Energy 2050." This report outlines recommendations to assist the Welsh Government in achieving a net zero Wales by 2050 and provides a comprehensive framework for enhancing renewable energy development in Wales.
Our key recommendation requested that “Permitted development rights should be immediately reviewed with a specific focus on eliminating impediments to measures that increase renewable energy generation, with a shifted focus on the climate crisis.”
Whilst it is disappointing that the Welsh Government has not seen this consultation as an opportunity to review permitted development rights for all technologies through the lens of climate change, NICW welcomes the steps being taken to help further roll-out diverse sources of renewable energy at all scales.
Our renewable energy report identifies heat pumps—particularly air source heat pumps—as a key technology for decarbonising heat in buildings. It notes that the UK Government plans to increase the rate of heat pump installations from 30,000 per year to 600,000 per year by 2028. If planning applications are required for even a small proportion of these installations in Wales, it would place a significant and unnecessary burden on local planning authorities. The further relaxation of permitted development rights is therefore a necessary and positive step.
Q1. Do you agree that condition G.3 (a), which requires ASHP be used solely for heating purposes, should be removed to also enable the installation of an air-to-air heat pump?
Yes.
NICW supports the removal of condition G.3 (a) to allow the installation of air-to-air heat pumps. This change will increase consumer choice and flexibility, enabling the use of both air-to-water and air-to-air systems in both the heating and cooling of buildings.
NICW has previously highlighted the importance of diversifying renewable energy technologies to meet Wales’s net zero targets to promote a range of renewable energy technologies to ensure resilience and adaptability in the energy system.
Q2. Do you agree that the limitation requiring an ASHP to be 3 metres from the property boundary should be removed?
Yes.
The existing 3-metre rule poses significant challenges to the widespread adoption of ASHPs. Removing this limitation will simplify the installation process and reduce barriers to uptake. Our renewable energy report recommended streamlining planning processes for low-carbon technologies to accelerate their deployment.
Q3. Do you agree that the current external volume of an air source heat pump should be increased from 1 cubic metre to 1.5 cubic metres?
Yes.
Increasing the size limit to 1.5 cubic metres will offer households greater flexibility, enabling the installation of larger, more efficient units.
Q4. Do you agree that the existing limitation of one ASHP on or within the curtilage of a dwelling house should be increased to a maximum of two where the dwelling house is a detached property?
Yes.
Allowing up to two ASHPs on detached properties will benefit larger dwellings with greater heat demands. This change supports our call for a planning system that enables decarbonisation across all building types.
Q5. Do you think that permitted development rights should permit the installation of ASHPs on or within the curtilage of a block of freestanding flats?
Yes.
Extending PDRs to blocks of flats will enable decarbonisation beyond single-family homes. Our report emphasizes the need for whole-system thinking to achieve net zero. We need to go beyond traditional thinking of a standard form of building type and dwelling and make permitted development rights as flexible as possible.
Q6. Do you agree that ASHPs should be permitted on a wall fronting a highway (where it is not proposed within a Conservation Area, on a listed building, or on a scheduled monument)?
Yes.
Permitting ASHPs on walls fronting highways, with appropriate safeguards, will increase installation flexibility.
Q7. Do you agree that the limitation of not permitting the installation of an ASHP where a wind turbine is located in the curtilage of a dwelling should be removed?
Yes.
Removing this limitation will simplify the installation process and support the deployment of multiple renewable technologies.
Q8. Do you agree that the limitations listed in paragraph 2.33 above (and in relation to paragraph 2.31-2.32) should include reference to restricting installations on a wall (or roof) of a dwellinghouse or within the curtilage of a dwellinghouse (including on a building within that curtilage) which fronts a highway in a Conservation Area?
Yes.
We agree that installations in Conservation Areas should be subject to additional safeguards to protect heritage assets.
Q9. Do you agree that the other limitations listed in paragraph 2.33 above should remain unchanged?
Yes.
Maintaining these limitations will ensure that ASHP installations do not adversely impact local amenity. Our report supports the need for planning policy to balance enabling deployment with protecting community interests.
Q10. Are there any other planning issues regarding ASHPs that you feel are not covered in the questions above and that you wish to raise?
NICW recommends that the Welsh Government commit to monitoring the impact of the revised PDRs for ASHPs.
In addition, the Welsh Government may wish to explore an alternative way of updating permitted development rights on a regular basis which is done in a less bureaucratic way. This has been exemplified recently by the proposed way in which planning fees will be changed in future.
The National Infrastructure Commission for Wales welcomes the proposed changes to permitted development rights for air source heat pumps. These changes are consistent with our recommendations and represent a meaningful step towards a more enabling planning system that supports the transition to net zero. We encourage the Welsh Government to continue to review the situation with ambition, clarity, and a commitment to increasing renewable energy production and tackling climate change.
We would be pleased to engage further with officials as the proposals are refined and implemented.
Yours sincerely,
David Clubb
Cadeirydd/Chair