Using AI in submissions to PEDW

Artificial Intelligence (AI) tools can support engaging in the planning process. This can be positive when used correctly and transparently. Due to the evolving capability and application of AI tools, we will keep this guidance under review.

AI tools can create content in the form of text, images, videos, audio, computer code, and other types of data. It can also alter or enhance existing content. In such cases, AI draws on existing information, usually from a large database or from the internet, to provide a response to a user’s prompts or requests. 

Whilst we acknowledge the efficiency benefits AI can bring, it also carries risks and can be counterproductive if used inappropriately. These risks can include: 

• incorrect or out of date information
• bias
• privacy, and data protection issues 
• missed nuance

Some of these risks have been explored in more detail below. 

PEDW values the views of interested parties. Comments are often most useful when they are based on your own knowledge and experience of the case. 

You should avoid submitting lengthy generic AI content. It can be less effective at making compelling arguments for a case. It can also be unhelpful to the decision maker. 

Written submissions may be subject to scrutiny at oral hearings and inquiries. You may need to explain your submission and answer questions about it. This may include questions under cross-examination. 

You should never make written submissions that you do not understand or know to be accurate. 

You may have to pay costs if you submit inaccurate evidence. This may happen if PEDW or other parties in the appeal incur expense checking that evidence or responding to it.

When using AI to generate evidence, please follow these guidelines:

1. Transparency

Reference the original source

If the AI uses data or information from another source, provide a web link to the original source or document. Do not list the AI tool itself as the source. The Inspector may reject evidence if the original source is unclear.

Use official planning sources

AI can help explain information, but you must use and reference official planning sources.

2. Accuracy and content integrity

Do not alter images or videos

You must not use AI or any other tool to edit or alter images or videos submitted as evidence. 

The only exception is where you declare the changes and they help the Inspector understand the evidence. 

PEDW will disregard any images or recordings that have been altered but not declared. Submitting altered evidence may also lead to an award of costs against you for unreasonable behaviour.

Check AI-generated content

AI can produce answers that sound confident but may be incorrect or out of date. These are sometimes called a ‘hallucination’.

You are responsible for the accuracy of any content you create with AI. You should always check the veracity of evidence you rely on. 

Make sure you refer to the correct legislation applicable in Wales. You should also check that any case law referred to is relevant and accurately interpreted. 

Knowingly or negligently presenting inaccurate evidence would constitute ‘unreasonable behaviour’. You can find a description of unreasonable behaviour in the Development Management Manual (Section 12 annex: award of costs). You may have to pay costs if you submit inaccurate evidence. This may happen if PEDW or other parties in the appeal incur wasted expense checking that evidence or responding to it.

Do not include unacceptable content

Representations that contain abusive, racist, or potentially libellous comments will not be seen by the Inspector. The comments will be returned to you and removed from PEDW’s systems.

3. Privacy and data protection

Protect personal data

Entering personal data, addresses or sensitive documents into AI tools can create privacy risks. 

Any AI-generated content you send to PEDW must comply with relevant data protection laws. 

For details, visit the Information Commissioner's Office website.

4. Intellectual property (IP) and copyright

Follow copyright laws

Text or images generated by AI may raise questions about copyright or ownership. 

You are responsible for making sure all AI-generated content follows copyright rules. Where needed, you must obtain necessary permissions. 

Do not submit copyrighted material to any AI service to generate summaries other content. This includes copyrighted content from PEDW’s Appeal Casework Portal.

5. Review and oversight

Review AI-generated content regularly

If you use AI-generated content more than once, such as across several cases over time, you should review it regularly. This helps make sure the content remains accurate and relevant.

Keep human oversight

AI tools can change over time when they are updated or trained on new data. 

Always ensure a person remains responsible for decisions, advice and submissions. You should make sure that AI outputs are appropriate and contextually accurate.