4 Overarching Policies
These are policies which set out the strategic themes of the Preferred Strategy. These policies seek to:-
- put the National Park purposes at the heart of everything the LDP is seeking to achieve
- promote addressing and limiting the effects of climate change as a key theme
Special Qualities (Policy SP1 & SP3)
To conserve and enhance the special qualities of the
Brecon Beacons National Park
Landscape (SP1, SP3, SP10)
To ensure that all future development will protect and
enhance the beautiful and varied character of the landscape
4.1.1 The overarching policy below deals with National Park purposes and duty.
4.1.2 National Park purposes are set out in the 1995 Environment Act. Whilst it is recognized that national legislation should not ordinarily be repeated in the Local Development Plan it is considered that purposes coupled with the duty are so fundamental to the work of the Park Authority that it is essential that they are placed at the heart of the development plan.
4.1.3 Whilst the National Park is a landscape designation there are instances where strict application of the boundary in making decisions would not be appropriate. Cross boundary issues include wind energy development and transport infrastructure. The Authority will use this policy in considering proposals within its planning jurisdiction and in commenting on proposals that impact on the National Park.
4.1.4 The following strategic policy is therefore the fundamental policy at the core of this Plan from which all other strategies and policies flow.
We want to ensure that the purposes and the statutory duty set out in legislation is central in determining what constitutes appropriate development within the National Park, and will do this by:
- enabling development that conserves or enhances the natural beauty, wildlife and cultural heritage of the National Park;
- enabling development that provides for, or supports, the understanding and enjoyment of the special qualities of the National Park in a way that does not harm those qualities;
- enabling development which fulfils the two purposes above and that assists the economic and social well-being of local communities
4.2.1 National Guidance provides much of the necessary guidance relating to detailed development control matters (access statements, transport impact statements, design statements). Other matters are dealt with by other agencies, such as highways or building control.
4.2.2 Appendix 3 of this plan sets out National Planning Guidance by topic area. Applicants are advised to consult the relevant documents when considering development proposals within the National Park.
4.2.3 However, National Guidance does not provide criteria by which to assess what is appropriate development in a National Park. This is the role of the NPA.
4.2.4 Based on Appendix 1 which paints a picture of the National Park (see introductory chapter), the following policy seeks to set out the necessary detailed criteria by which we will ensure that development does not impact on the National Park’s ability to deliver it’s statutory purposes and duty. Policy 1 therefore provides a framework against which all proposals for development will be assessed.
Appropriate Development in the National Park
All proposals for development or change of use of land or buildings in the National Park must comply with the following criteria, where they are relevant to the proposal:
- the scale, form, design, layout, density, intensity of use and use of materials will be appropriate to the surroundings and will maintain or enhance the quality and character of the Park’s landscape and built environment;
- the proposed development is integrated into the landscape to the satisfaction of the NPA through planting and appropriate management of native species or through the construction of appropriate boundary features19;
- the proposed development does not have an unacceptable impact on the economic, social, cultural and linguistic vitality and identity of any community, either in its own right or through cumulative impact (See Policy ES33).
19 Where landscaping schemes are required, they must involve a design in keeping with the site, using native plant species of local provenance suitable for the National Park as listed in Appendix 3;
4.3.1 Statutory designation does not necessarily prohibit development, but proposals for development must be carefully assessed for their effect on those natural heritage interests which the designation is intended to protect. In National Parks, special considerations apply to major development proposals which are more national20 than local in character.
4.3.2 It is the potentially serious impact that a development may have on the qualities of the Park that qualifies it for the title 'Major Development' and, in addition to needing to be in accordance with Local Development Plan policies, the proposal will have to fulfill national planning policy criteria before being permitted, known as the ‘Major Development Test’. The ‘Glossary of Terms’ sets out the types of impact that in the opinion of the National Park Authority may mean that a development will be considered as ‘Major Development’. Planning Policy Wales, Welsh Assembly Government, March 2002, paragraphs 5.5.5 and 5.5.6 sets out the actual test in terms of the need for the development, exploring how the development could be met in another way and impacts on the environment and landscape.
4.3.3 The Policy Statement for the National Parks in Wales “Working Together for Wales” WAG 2002 reiterates that major development should not take place within the National Park unless in exceptional circumstances. The policy statement makes it a requirement that the LDP sets out the ways in which such development proposals will be assessed by the Park
20 ‘National’ in this context means UK.
We want to rigorously apply the required tests in respect of major development in the National Park, which should only take place in exceptional circumstances where proven to be in the public interest.
This will include an assessment of:
- the need for the development, including any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
- the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and
- any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which these could be moderated.
4.4.1 The Ministry of Defence has an administrative headquarters and three training camps in the Park. Should it propose further development on these or elsewhere, the NPA would consider such applications in the light of the relevant policies in this LDP.
4.5.1 Development proposals for Notifiable installations or proposals affecting Notifiable sites will not be permitted unless the NPA is satisfied that there is no risk to public health and safety, following consultation with the Health and Safety Executive. Notifiable Installations will be shown on the Proposals Maps.
4.6.1 The following strategic policy seeks to conserve and enhance the natural and manmade resources that make up the National Park’s protected landscape.
4.6.2 In addition to the policy requirements set out below, and in line with the Habitats Regulations (March 2010) and in consultation with CCW, survey and project level HRA should be undertaken if necessary where there is potential for significant effects on linear habitat features (e.g. hedgerows and woodland belts) ‘dark corridors’ and roosts used by the Lesser Horseshoe Bats.
All proposals for development or change of use of land or buildings in the National Park must demonstrate that the proposed development does not have an unacceptable impact on, nor detract from or prevent the enjoyment of;
- the special qualities of the National Park as identified in the National Park Management Plan21.
- ecology and biodiversity assets beyond designated sites (see Policies 2, 3 and 4).
- the water environment (see Policy 5).
- geodiversity, including the Fforest Fawr European Geopark.
- cultural and historic heritage, including Blaenavon Industrial Landscape World Heritage Site, Registered Historic Parks Gardens and Historic Landscapes, (see Conserving the Historic Environment Below).
- the character of the built heritage, including listed buildings, conservation areas and archaeological features (see Conserving the Historic Environment Below).
- employment land and buildings (see also SP12 and supporting detailed policies).
- the important network of public open space and recreation facilities (See also SP15 and supporting detailed policies).
- soil and air quality (see Policy 7 and 8)
21 See Appendix 4 Special Qualities of the National Park
The strategic policy is supported by the following detailed guidance.
188.8.131.52 Planning Policy Wales sets out clear statements of national development control policy on areas and sites and protected species with statutory nature conservation designation (including Sites of Special Scientific Interest, Special Protection Areas and Special Areas of Conservation).
184.108.40.206 Please refer to Chapter 5 PPW ‘Conserving and Improving Natural Heritage and the Coast’.
220.127.116.11 Sites are identified on the Proposals Map.
18.104.22.168 Development affecting sites of European Importance as shown on Proposals Maps is governed by National Policy and European legislation. Applicants are referred to Technical Advice Note 5: Nature Conservation and Planning.
22.214.171.124 Sites are shown on the Proposals Map.
126.96.36.199 In addition developments which may alone or in combination have an impact on a Natura 2000 (N2K) including SACs may be required to undertake Appropriate Assessment in accordance with the Habitats Directive referred to as HRA. Technical Advice Note 5 provides further guidance in relation to this matter.
188.8.131.52 Development affecting sites of national importance as shown on Proposals Maps is governed by national policy and national legislation. Applicants are referred to Technical Advice Note 5: Nature Conservation and Planning.
184.108.40.206 Development on sites identified as important for Local Nature Conservation (SINCs) as shown on Proposals Maps will only be enabled where the need for the development outweighs the nature conservation importance of the site, and the impact on biodiversity and or/protected species can satisfactorily managed to the satisfaction of the NPA.
220.127.116.11 Where appropriate the NPA will consider the use of conditions and/or planning obligations to provide appropriate compensatory / enhancement measures22.
22 See Policy 35 and BBNPA Planning Obligation Strategy
18.104.22.168 Sites may be formally recognized through designation as Local Nature Reserves or SINCs (as above, shown on the Proposals Map). However some sites may not be formally recognized but provide important nature conservation value. It is not therefore possible to show these sites on the Proposals Map.
22.214.171.124 The value of a site may include its role as a wildlife corridor or stem from lack of disturbance for example. Habitats such as unimproved grassland and heath and moorland, as well as features such as road verges have a nature conservation value in their own right and as stepping-stones to other habitats. It is not possible to identify such sites on the Proposals Map and this policy is intended to ensure that development which would harm the nature conservation value of a site provides appropriate steps to mitigate or minimize harm, or provides compensation to offset harm. This may be in the form of habitat creation elsewhere.
126.96.36.199 The Biodiversity Information Service (BIS) holds a geodatabase of species records and habitat information, constantly updated by maintaining strong links with public bodies, conservation organizations and individual biological recorders. This enables the centre to assist nature conservation by informing decision makers, conservation organizations and the general public on the occurrence and locations of EU and UK priority species and habitats, and those of Welsh and local importance in the region.
Important Wild Species
Proposals on land or buildings that support important species will only be permitted where;
- the need for the development outweighs the nature conservation importance of the site.
- positive measures are provided to contribute to species and habitat conservation targets; and
- the developer proves to the satisfaction of the NPA that
- the disturbance of the species and habitat in terms of the effect on species survival and reproductive potential or habitat function is kept to a minimum; or
- alternative areas are provided to sustain at least the current levels of populations or size of habitat affected by the proposal
188.8.131.52 Wild species where not legally protected may still be important. They are often widely dispersed in the landscape and their populations may be isolated from each other. The National Park LBAP contains details of the species that are of particular importance in the National Park and those which require urgent action for the maintenance of population levels. Landscape features may provide wildlife corridors for some species, as well as links or stepping-stones between habitats. Habitats themselves are not confined to particular sites but constitute the Park as a whole, both to safeguard our current levels of biodiversity. This cannot be achieved without also safeguarding and managing the intervening habitats and areas. The protection management and enhancement of ecological networks are identified as being particularly important in the EU habitats Directive and as such this LDP aims to encourage the positive management of landscape features which make up this network and are of major importance for wild flora and fauna.
184.108.40.206 Policy 3 below sets out how the NPA aims to manage impacts on biodiversity from development within the National Park area. If there are over-riding material planning considerations in favour of development, then it is reasonable for the NPA to secure measures from developers that minimise or offset any impact or loss of habitat features or species present on a site prior to the commencement of development.
Biodiversity and Development
Development will only be permitted where;
- the developer proves to the satisfaction of the NPA that there is no unacceptable loss or fragmentation of a characteristic habitat or landscape feature and/or increased isolation of important species as defined in the NPA's LBPAP,
- the developer identifies habitats and landscape features of importance for wildlife within the site and provides for the further creation, positive management, restoration, enhancement or compensation for these habitats and features to ensure that the site maintains its nature conservation importance, and
- full provision is made for the future management of the site's habitats and features of nature conservation value. This will be secured either through planning obligations or the imposition of planning conditions.
- there is no unacceptable loss/breaching of linear features (e.g. hedgerows, woodland belts) Development should seek to enhance linear habitat features (e.g. hedgerow, woodland belts) ‘dark corridors’ and roosts used by lesser horseshoe bat
The NPA will require all development being judged against this policy to provide biodiversity enhancement through the scheme in accordance with the direction of the Planning Obligation Strategy.
4.8.1 Groups and individual trees, including old and veteran trees, play an important role in enhancing the Park’s landscape and biodiversity. They add to both the amenity and natural habitat of towns and villages and individual buildings, and should where at all possible be protected from development. Trees also provide shade and help to reduce pollution, as well as absorbing carbon dioxide. Where appropriate the NPA will use planning conditions or Tree Preservation Orders to protect important woods or trees. In general the NPA wishes to see trees retained and protected on any development site, whether they are protected by legislation or not.
Trees and Development
Proposals for development on sites containing tress will be required to submit a Tree Survey and Management Proposals23. Permission will be granted were the NPA is satisfied with the Tree Survey and Management proposals and where:
- trees and their root systems are retained and adequately protected prior to, during, and after development.
- where it is agreed that trees are to be removed, appropriate replacement will be required using native tree species. A scheme for replacement shall be agreed with the NPA prior to the commencement of development24.
TThe NPA will use conditions and or planning obligations to ensure that necessary compensation and enhancement measures to mitigate loss engendered.
23 This will be in line with British Standard BS5837: 2005 Trees in relation to construction: Recommendation and undertaken by a suitably qualified independent Arboriculturalist to the satisfaction of the NPA
24 See Appendix 5 for details of native species trees and shrubs
4.9.1 The overarching strategy of the LDP is to ensure a vital and viable sustainable future for our communities in response to facing the challenges of climate change. The key mechanism by which we deliver our strategy is through enabling new development in keeping with the strategic direction.
4.9.2 In essence, new development needs two things – land to accommodate it and the provision of essential services to make it habitable. Of primary importance within the latter are the provision of clean drinking water (known as potable water) and the removal of effluence and other waste water components.
4.9.3 In producing the LDP we are charged with identifying land to meet the future needs of our communities. In identifying that land we need to ensure that it is deliverable, that it can be developed and that it will provide viable development land for the future. Central to this has been the need to identify that there is water to supply the proposed levels of dwellings without impacting on existing development and their ability to meet their own water needs.
4.9.4 Ensuring that we provide both of these in the most sustainable way is key to ensuring that we provide for the future of our communities in a responsible and appropriate fashion that is both responsive to our status as a National Park and responsive to the likely and anticipated effects of climate change.
4.9.5 Data from the Environment Agency shows that the current arrangement for licensing abstraction for drinking water is reaching a critical point across the majority of the Park. Only western areas have water available. In areas where Water Resource Issues have been identified, abstraction licenses will be regularly reviewed and their impact assessed. Therefore growth of levels of abstraction to meet rising water demands associated with new development cannot be taken for granted.
4.9.6 This makes tangible issues which so far have been part of a wider and somewhat abstract sustainability agenda – to conserve water. Climate change may result in increased variability in weather patterns increasing both the risk of flooding and extended dry spells. Water consumption is likely to become an increasing national problem. Water is becoming more scarce at the same time as population and demand for water is increasing, the development of practical ways to reduce water demand is crucial.
4.9.7 Given the above the National Park is proposing to ensure that in areas where water provision is under strain new development is built to high standards relating to the conservation of water. The aim will be to ensure that new development is built with the aim of reducing water consumption from the average 105 litre/person/day to the more sustainable 80 litres/person/day.
4.9.8 Practical application of water saving measures is easily achievable if they are integral to the design of the building or home (see appendix 5 for further guidance).
4.9.9 A key mechanism by which we can ensure that development incorporates water conservation is by making highest standards of water management mandatory within the design of a scheme. The quality of the design in saving water will be judged utilising the WAG adopted national standards for sustainable buildings. At time of writing the LDP these are: -
- The Code for Sustainable Homes for residential development
- Building Research Establishment Environmental Assessment Method (BREEAM) for all other types of development.
4.9.10 Both standards have a means to judge water conservation and management methods employed within the building. MIPPS 01/2009 gives provision for Local Planning Authorities to employ higher standards for sustainable buildings where evidence supports the need. This LDP will therefore utilise the national standards and the direction of MIPPs 01/2009 to make the requirement to achieve the highest standards relating to water management mandatory in development in areas where water resources are under strain;
- For residential development – Achieving highest credit rating under Issues WAT 1&2 and SUR 125
- For all over development – Achieving highest credit rating under Water Issue26
25 Code for Sustainable Homes http://www.communities.gov.uk/documents/planningandbuilding/pdf/codesustainhomesstandard.pdf
26 BREEAM Standard http://www.breeam.org/page.jsp?id=40
4.9.11 These code levels relate to high standards at the time of the publication of this deposit, however it is possible that during the life of the plan as technologies and techniques improve the above standards may become outdated and superseded. It is therefore anticipated that there may be change;
- In the rating of Water Resource Issue Zones
- In the targets for sustainable water management
4.9.12 It is the aim to ensure that development always employs best practice in water conservation where there is an evidenced need to respond to water constraints. As such Policy 5 below by which the above aim is implemented requires development to reach maximum standards at the time the application is submitted.
4.9.13 The standards required to be met and guidance on how that can be implemented will be supplemented through the Authorities Sustainable Design Guide, which acts as SPG to this policy. This will be updated as changes to National standards and evidence base supporting this policy evolve.
4.9.14 In addition to the above and in line with the Habitats Regulations and in consultation with CCW, EAW, and DCWW, development proposals must ensure that the water supply necessary for the development can be supplied sustainably (and without adverse effects on European Sites).
4.9.15 The aim of this policy is to respond to local evidence that shows that the water resource available to serve new development has reached or is beyond capacity.
Water Resource Issue Zones
We want to ensure that all future development mitigates the impact it has on Water Resources.
Areas where the current resource is under constraint are shown on the Proposals Maps as Water Resource Issue Zones.
For development proposals falling within these areas the highest standards of water conservation will be required.
The effectiveness of water management techniques employed within a development scheme will be judged in accordance with the relevant National Standard for Sustainable Design. Within Water Resource Issue Zones, developers must demonstrate that the proposed scheme will achieve the maximum credits available for water management, evidenced through independent assessment.27
27 At the time of writing this would entail
All new residential development to achieve
5 Credits under WAT 1 issue of the Code for Sustainable Homes
1 Credit under WAT 2 issue of the Code for Sustainable Homes
2 Credits under SUR2 issues of the Code for Sustainable Homes
All new non-residential buildings would be required to achieve the mandatory credits for “Excellent” under Water issue of the BREEAM standard.
4.9.16 In addition to water usage, the management of surface water is also of key importance within this area, and is incorporated within the requirements of Policy 2. As such in meeting the necessary targets Sustainable Drainage Solutions SUDs will be a mandatory requirement of new development falling within Water Resource Issue Zones by default of meeting the requisite standards. Outside of Water Resource Issues Zones the NPA has a requirement that Sustainable Drainage is incorporated as a design philosophy of all new development proposals – please see Climate Change Section and Policy 38 SUDS.
4.10.1 An objective of the National Park Management Plan is to minimise light and noise pollution. Dark night skies are recognised as a key contributor to the sense of tranquillity and remoteness which is often cited as a key special quality of the National Park. The following policy therefore seeks to protect dark night skies from the impact of lighting and to relate any lighting proposed to its purpose, such as site security or floodlighting recreational facilities, so that careful design and the use of appropriate means of lighting and lighting levels minimise the impact on adjoining areas. There is also a possibility that light pollution could adversely affect the integrity of a Natura 2000 site where development coincides with roost sites/transit routes.
4.10.2 Proposals which individually or cumulatively have an unacceptable adverse effect on dark night skies will be resisted.
4.10.3 The National Park Authority will prepare SPG to provide further guidance on the implementation of this policy.
Proposals where lighting is required shall include a full lighting scheme and will be permitted:-
- where the lighting proposed is appropriate to its purpose; and,
- where there is not a significant adverse effect individually or cumulatively on
- the character of the area;
- local residents;
- vehicle users;
- biodiversity; and
- the visibility of the night sky.
- bat habitat ‘dark corridors’
4.11.1 In accordance with the principles of sustainable development there is a need to ensure that land management practices effectively take account of the need to maintain and improve soil quality, structure and functions. This must be achieved by avoiding inappropriate use and development, by prevention of soil erosion, shrinkage, contamination, burial and loss and preventing irreversible declines in soil organic matter and pH levels.
4.11.2 Development has the potential to negatively affect soil quality, structure and function, which could impact on the viability of farming, affect water quality and biodiversity, land drainage, negatively impact on carbon stores and undermine the structural integrity of the built environment.
4.11.3 In order to ensure that development within the National Park does not contribute to negative impacts the NPA will require all proposals to set out a management plan for the protection of soil during and post construction. This will be in accordance with standards set out by the Department for the Environment, Food and Rural Affairs in its comprehensive practical guide to soil protection Construction Code of Practice for the Sustainable Use of Soils on Construction Sites.28
28 Construction Code of Practice for the Sustainable Us of Soils on construction Sites http://www.defra.gov.uk/environment/quality/land/soil/built-environ/documents/code-of-practice.pdf
Development proposals must demonstrate that they adhere to good practice on the sustainable use and management of soil in development and construction through adherence to DEFRA’s Construction Code of Practice for the Sustainable Use of Soils on Construction Sites.
Developments which have an adverse impact on soil quality will not be permitted.
4.12.1 In accordance with the principles of sustainable development there is a need to ensure that development proposals effectively take account of the need to maintain and improve air quality within the National Park. Air quality is affected by activities beyond the Park boundary, particularly to the south and west, as well as by activities within it. Therefore development proposals must be mindful of their potential cumulative contribution to critical thresholds of the known atmospheric pollutants and must aim to avoid adding to background loads.
4.12.2 Deposition of air pollutants can contribute to soil and water pollution, for example acidification of water and nutrient enrichment and this in turn can have a negative impact on biodiversity. Compliance with air quality standards is used as a measure of social deprivation and some areas along the southern boundary of the National Park, as well as areas adjacent to the larger settlements within the Park, fall significantly short of the 100% compliance with public air quality standards achieved throughout the rest of the Park (EAW). The main sources of air pollution will arise from vehicle emissions, combustion and industrial processes, quarrying, soil disturbance, large scale agricultural operations and interactions between the atmosphere and land surface changes such as land drainage. Within the BBNP, critical loads for atmospheric acid and nitrate deposition are exceeded for nine of the eleven Special Areas of Conservation (SACs) modelled in 2010 (EAW). 29
29 See HRA Screening Report of BBNPA NPMP and SA Report of BBNPA NPMP and Pages 43-51 of EAW Evidence Pack for the Brecon Beacons National Park (draft)
Proposals for development will only be permitted where it is proven that no detrimental impact, individually or cumulatively will be had on air quality. Proposals for development which are likely to impact negatively on air quality or are potentially polluting will not be permitted unless mitigation measures to avoid the impact are provided.
4.13.1 The National Parks in Wales have been tasked by the Minister in the Welsh Assembly Government to be test beds of innovation, including new ways of thinking and new approaches to policy development.
4.13.2 This LDP therefore takes seriously the need to respond to change in the light of the wealth of evidence and research which is emerging and being constantly updated which points to the importance of safeguarding natural resources and ecosystem services30. The ability of local areas, and particularly rural areas to become more self sufficient will be crucial over the lifetime of this plan.
30 See Issues Paper – Natural Resources, ecosystem services and food security
4.13.3 Maintaining and enhancing the National Park’s natural resources and ecosystem services is therefore a crucial element in meeting the National Park’s purposes and duty. Both the sustainability of our landscape and the people who depend on it for their homes and livelihoods are directly linked to the conservation of natural resources.
4.13.4 The control of new development presents opportunities to ensure that both the development itself, and the communities within the Park will be much more responsive and flexible to the ever changing challenges of climate change that will arise over the lifetime of this plan.
4.13.5 The following objectives are fundamental to the strategy of this LDP.
- Maintaining and enhancing National Park’s natural resources and ecosystem services (in accordance with SP1 and SP3 policy).
- Providing opportunities for our communities to become more self sufficient in terms of both fuel and food production (in with Spatial Policy E LP1).
4.13.6 There is no single policy which will achieve the above objectives. In essence, all LDP policies seek to contribute to the pursuit of maintaining and enhancing the natural assets of the National Park whilst ensuring the economic and social well being of its communities. This is in accordance with Policy SP1 and SP3.
4.13.7 The National Park Authority has several means by which it can implement the objectives of these strategic polices through the control of development.
4.13.8 The Section below lists the areas where the National Park Authority is able, through its development control function, to encourage a more coherent response to the challenges of maintaining ecosystem services.
4.13.9 Each area of influence is listed together with cross references to the relevant LDP policy which will aid in the delivery.
Area of influence
National Park Policy SP3
Spatial Policy E LP1 and SP15
SP11 and Policy 47
Spatial Policy E LP1
in line with environmental protection regulations
Policy 5 Water Resources
Policy 7 Soil Quality
SP12 Economic Wellbeing
SP4 Climate Change and SP11 Sustainable Design
SP12 Economic Wellbeing
SP12 and supporting policies
SP12 and supporting policies
31 As shown on the BMV Map for Wales see PPW 2.8.1 further guidance in this matter is available from DEFRAs website
32 Measured as global hectares per capita, the biological ecological footprint (i.e., the amount actually available on the Earth per person) is 1.8 global hectares per capita. The global average is 2.2. For Wales it rose from 5.16 in 2003 to 5.25 in 2005. It is 5.3 to 5.46 global ha/capita in the BBNP.
4.14.1 Planning Policy Wales sets out clear statements of national development control policy on certain matters which is not repeated here. Please refer to Chapter 6 ‘Conserving the Historic Environment’ of Planning Policy Wales for guidance on the following issues:
4.14.2 Listed Buildings: The preservation of listed buildings, optimum viable use and their demolition.
4.14.3 Conservation Areas: development in a conservation area including demolition, advertisements and trees.
220.127.116.11 Within the National Park the following settlements contain designated Conservation Areas: Brecon, Hay-on-Wye, Talgarth, Crickhowell & Llangattock. The Conservation Area boundaries are shown on the Proposals Map. Conservation Area assessments and proposals documents are currently being prepared.
4.14.4 Historic Parks and Gardens and Historic Landscapes: See PPW for policy on protecting historic landscapes, parks or gardens and their setting.
18.104.22.168 Areas in the National Park which are listed within
- Part 1 of the 'Register of Landscapes, Parks and Gardens of Special Historic Interest in Wales' or
- Part 2 of the Register of Landscapes, parks and Gardens of Special Historic Interest in Wales'
are shown on the proposals Map. A list of areas in the Register is shown at Appendix 7.
22.214.171.124 See PPW for policy on the protection of Scheduled Ancient monuments and archaeological remains.
126.96.36.199 Scheduled Ancient Monuments are shown on the Proposals Maps.
188.8.131.52 In assessing the archaeological potential of a proposed development site information from the Historic Environment Record held by our 3 constituent archaeological trusts33 will be taken into account.
184.108.40.206 This record is officially recognised by the National Park Authority.
33 Clwyd Powys Archaeological Trust, Glamorgan Gwent Archaeological Trust and Dyfed Archaeological Trust
220.127.116.11 Areas for archaeological evaluation that were identified during a survey of historic settlements in the Park are shown on the Proposals Map. The survey report Historic Settlements in the Brecon Beacons National Park can be consulted at theNational Park Office. Other sites may be identified in future by the Regional Archaeological Trusts and others, both in and outside settlements. They are areas that have not been fully investigated by archaeologists, but which are likely to contain important archaeological features.
18.104.22.168 Prospective developers of sites in these areas are advised to discuss with the NPA the scope and detail of the evaluation work that will be required before making an application. Information resulting from evaluation will be used in determining an application. Where an application is permitted there may be further requirements of the developer. These will depend on the nature of the remains and may range from full excavation of the remains prior to development to recording via a watching brief.
Areas of Archaeological Evaluation
Where important archaeological remains are known to exist or may exist within an area for archaeological evaluation, the archaeological implications of development proposals shall be evaluated before planning applications are determined. Planning permission will not be granted where the evaluation is deemed inadequate.
22.214.171.124 Development in this area is covered by National Policy (Planning Policy Wales para 6.5.22.).
126.96.36.199 The Blaenavon Industrial Landscape World Heritage Site lies partly within the National Park. The area includes the town of Blaenavon outside the National Park as well as land surrounding, some of which lies within the National Park. The boundary also now includes parts of Govilon. The area of the site is shown on the Proposals Map.
188.8.131.52 Climate change, caused by increasing levels of greenhouse gases, is the most significant challenge facing the future of the National Park.
184.108.40.206 Our strategy, borne out of a World Wide commitment to address the causes of climate change34, seeks to ensure that all future development in the Park is able to adapt to the likely effects of climate change beyond the plan period.
220.127.116.11 Although the exact impact of the changing climate is uncertain, predictions indicate that a future increase in temperature during the summer is most likely, with South Wales expected to have amongst some of the highest summer temperatures. The pattern of rainfall is also expected to change, with summers becoming drier and winters becoming wetter. Winter rainfall is also predicted to fall in more intense storm events than at present. The degree of change is influenced by the level of global carbon emissions and although the LDP alone can have little impact on the wider global CO2 levels, it can act to make a profound impact on the local level through ensuring that carbon emissions from new development are limited to the minimum practicable amount. This is in keeping with the challenge set for all Welsh National Parks to become places that experiment with new approaches to sustainable development and environmental conservation, providing exemplars of best practice for rural development in the wider region.35
18.104.22.168 Responding to this challenge will have significant implications on the way buildings are designed and constructed, heated, lit, serviced, as well as their location and orientation. To respond to these issues the LDP strategy makes a commitment to ensure that all development in the Park is able to adapt to the likely effects of climate change beyond the plan period. In order to do this we will ensure that all development takes account of future risks of flooding, is intelligently sited, climate responsive, built with sustainable materials, resource efficient, and accessible to all for the lifetime of the development.
22.214.171.124 In implementing this strategy all development will be subject to meeting the aims of Strategy Policy 4 Climate Change.
All proposals will be expected to demonstrate how the development will;
- be resilient and adaptable to the likely effects of climate change.
- limit and mitigate the causes of climate change.
- contribute to the aim of carbon neutrality in all new development.
34 In accordance with the Kyoto Protocol of 1997 there is an international commitment to “the stabilization and reconstruction of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system” see http://unfccc.int/index.html for more information
35 WAG Policy Statement for the Welsh National Parks Working Together for Wales 2002p. 4
126.96.36.199 Through this policy we will ensure that all new development takes the principal of future proofing against the likely and predicted impacts of climate change as central within their design philosophy.
188.8.131.52 This policy will also form the strategic framework from which the LDP will support schemes which will have a positive impact on mitigating the causes of climate change of a scale commensurate with the special qualities of the National Park.
184.108.40.206 In essence therefore SP4 is implemented through detailed policy responses which seek to enable development;
- in areas which will be least affected by climate change,
- using construction and design which is sustainable,
- utilising low and zero carbon technologies within design schemes,
- or enabling appropriately scaled renewable energy schemes which serve our communities.
220.127.116.11 The LDP makes this commitment to address the issue of climate change with the acknowledgment that it is just one mechanism by which the above practical mediations can be enabled. The following sections consider these policy areas in more detail.
18.104.22.168 National Planning Policy is already providing a strong base line for standards in new development designed to respond to the challenge of climate change which the NPA in its position as exemplar authority seeks to capitalise upon.
22.214.171.124Para 2.12.4 of MIPPS 01/2009 Planning for Sustainable Buildings makes it a requirement of planning permission that all new development achieves a minimum target for sustainable design, with specific targets aimed at reducing CO2 emissions from energy generation36.
126.96.36.199Para 2.12.5 of this statement also enables LPAs to set higher targets within their LDPs on strategic sites where there is supporting evidence to justify the need. As our strategy is built around the vision to enable growth to support community vitality and viability in keeping with a defined need it therefore follows that all identified locations for development become key in delivering the strategy. In instances where the need for development to support the community is compromised by locational sustainability the LDP has encompassed the direction of the MIPPS to mitigate against the impact of increased reliance on private transport by setting higher targets for sustainability in the design and construction of new development (see LGS LP3).
188.8.131.52A similar approach has been taken where the evidence suggests that Water resources will be under pressure, and higher standards of sustainable design relating to water conservation and sustainable drainage have been adopted (see Policy 2).
184.108.40.206Clear evidence demonstrates that the particularities of rural living have a significant impact on the ability of our communities to face the challenge of climate change. Ecological footprinting is one way we can measure the current impact we are having upon natural resources, and as such the extent to which we are contributing to the impacts of climate change. Ecological footprinting is measured as global hectares per capita, the biological ecological footprint (i.e., the amount actually available on the Earth per person) is 1.8 global hectares per capita. The global average is 2.2. For Wales it rose from 5.16 in 2003 to 5.25 in 2005. Within the National Park area it is 5.3 to 5.46 global ha/capita in the BBNP37 . This clearly demonstrates the extent to which current patterns of development and living are unsustainable. As responsible body for the control of future development, the NPA is in a prime position to ensure that the future of our communities is secured in a more sustainable manner, and to take action to reduce the strain we are having on natural resources. As such the NPA is committed to ensuring that best practice in sustainable development is adhered to.
220.127.116.11The NPA will therefore require all development to reach at least national standards for sustainable design as set out in MIPPS 01/2009, with the aim of higher sustainable building standards where evidence suggests the necessity; and to respond to the requirements of Strategic Policy 11 Sustainable Design set out below.
18.104.22.168To support application of this aim, the NPA is committed to ensuring that all listed settlements will have their individual carbon and ecological footprint assessed. This assessment will be used as evidence to support the setting of the required target for sustainable building standard higher than the national minimum. Where no evidence is forthcoming to suggest that there is a need to raise sustainable design standards, the NPA will apply National Standards as set out in MIPPS 01/2009.
22.214.171.124The development of the NPA’s Sustainable Design Guide to be adopted as SPG to the LDP will provide developers with detailed guidance on the application of Sustainable Development requirements within the National Park area.
36 At time of writing the requirement is Applications of 1 or more dwellings received on or after 1 September 2010 to meet CFSH Level 3 and obtain 6 credits under issue Ene1 – Dwellings Emissions Rate . Applications received on or after 1st September 2009 for non-residential development which will either have a floor space of 1000sqm or more, or will be carried out on a site having an area of one hectare or more to meet BREEAM ‘very good standard’ and achieve the mandatory credits ‘Excellent’ under issue Ene 1 – Reduction of CO2 emissions
37 Dawkins, E. Paul, A., Barratt, J., Minx, J. and Scott, K. “Wales’ Ecological Footprint Scenarios 2020,” (2008) Stockholm Environment Institute report to the Welsh Assembly Government http://www.sei.se/editable/pages/sections/implement/WalesEFreport.pdf
All proposals for development will be expected to address the principles of sustainable development by demonstrating that they:
- meet National requirements for sustainable design or higher in accordance with the local evidence base and in line with the NPA’s Sustainable Design Guide38 and relevant spatial policies,
- are able to demonstrate consideration of the use of renewable energy sources. Larger developments of more than 3 dwellings or 500sqm of gross floor space for commercial development, will be expected to provide at least 20% of their energy requirements from low or zero carbon resources,39
- contribute to the provision or maintenance of a wide range of facilities, services and infrastructure. The Authority will negotiate planning obligations where necessary for social, economic and environmental infrastructure required as a result of development or to mitigate the impact of development on an area.40
38 Guidance for Sustainable Design in the National Parks in Wales, Brecon Beacons National Park Authority, October 2008
39 Guidance for Sustainable Design in the National Parks in Wales, Brecon Beacons National Park Authority, October 2008
40 Planning Obligations Strategy, Brecon Beacons National Park, October 2008
126.96.36.199 In addition to the requirements of National Policy for all new development which results in the creation of new dwellings or other forms of building, it is clear that all development which results in the consumption of natural resources through construction and use will be required to mitigate its impact through adherence to the principles of sustainable development. Therefore the principle of SP11 will be directed to all new development which results in the creation of new habitable space. This includes house extensions and the conversion of existing buildings to dwellings.
188.8.131.52The national minimum standards utilises the Code for Sustainable Homes for residential development and BREEAM standards for all other forms of development. These standards, at the time of writing only relate to the construction of new buildings, as such it will not be a requirement to achieve a code rated/BREEAM certificate for such development, however it will be necessary to demonstrate to the NPA that the standards which are relevant to the type of accommodation being proposed in the extension/conversion have been met. This is particularly pertinent in the area of energy consumption, where evidence will be required that the scheme will achieve the required national saving under that Current Building Regulations Dwelling Emission Rate 41, relevant to the new type of accommodation proposed to be created.
41 at time of writing this would relate to achieving the equivalent of 6 credits under issue Ene 1 Dwellings Emissions Rate under the CFSH or Excellent under BREEAM ‘Excellent’ under issue Ene 1 – Reduction of CO2 emissions,
Sustainable Design in the Adaption and Re-use of Existing Buildings
All proposals which would result in the creation of new habitable space either through
- the extension of an existing dwelling; or
- the conversion of an existing building
will be required to adhere to the principles of sustainable development in their design, construction and energy performance.
All such proposals will be required to demonstrate that they would achieve national minimum standards for sustainable design and energy performance relevant to the time of their application.
The application of Low and Zero Carbon technologies within the scheme to address increased energy consumption must be investigated and where found to be applicable must be employed within the scheme.
184.108.40.206As well as being integral to improving sustainability in development proposals the application of Renewable Energy within the Park is a key mechanism by which the strategy to mitigate the impact of Climate Change can be achieved. The following strategic policy sets out the scale of such development which is appropriate within the National Park.
We will enable proposals for micro renewable energy schemes which are appropriate to their location and the special qualities of the
National Park.Proposals for Major Development for renewable energy schemes will not be permitted in the National Park (See SP2)42
42 In accordance with WAG Policy Statement for the National Parks in Wales 2002, para 15a In line with the WAG’s policy on major developments within the Welsh Parks – and as set out in TAN8 – there should be no significant change in landscape character as a result of wind turbine development within the National Parks. This principle extends to all such major development of national importance.
220.127.116.11In implementing this policy we want to ensure that projects for community led renewable energy provision and small scale energy generation relating to farm diversification are enabled. We also want to provide the guiding framework to ensure that new development proposals can easily integrate provision of low and zero carbon technologies into schemes with confidence and that this will be looked upon favourably within assessment of design43.
43 Para 2.12.6 MIPPS 01/2009 Applications that reflect the key principles of climate responsive developments and meet or exceed the standards set out in para 2.12.4 should be encouraged
18.104.22.168 The National Park Authority through action outside of the LDP is already making strong progress in enabling the area to address alternative and sustainable means by which to meet its future energy needs. The Green Valleys project, is a not for profit Community Interest Company based in the Brecon Beacons National Park. Established in May 2009 the Green Valleys Organisation was Wales' only finalist in NESTA's Big Green Challenge competition and enables and supports community groups in the area in sourcing and installing community owned micro generation projects for community benefit. This project has wide spread support amongst our communities, and many projects are developing as a result of the strategic vision of the Green Valleys. The project primarily focuses on hydro-electricity schemes; throughout early 2009 the community groups in The Green Valleys identified 92 possible hydro schemes. The first 23 sites that were surveyed came back as having the potential to generate 399kW (which represents 6% of the annual electricity demand for the homes in the Brecon Beacons). This presents a significant contribution to ensuring a sustainable future for our residents .Work continues to address the full feasibility of the NPA area to generate its own electricity.
22.214.171.124 In our role as Local Planning Authority, we want to take an enabling approach to schemes which will make a positive contribution to limiting the ecological and carbon footprint of the National Park area, especially if they form part of the wider framework of projects that form the vision of the Green Valleys.
126.96.36.199 Such schemes will therefore be looked upon favourably. However it is imperative that in enabling such development we do not fail in our statutory duty to protect and enhance the special qualities of the National Park, including the unique biodiversity of the area.
188.8.131.52Therefore proposals relating to the provision of renewable energy of an appropriate scale and impact, in keeping with their location will be enabled through the SP 9 and relevant Spatial Policies. The appropriateness of the scheme for the given location will be judged in accordance with all relevant policies relating to appropriate design and impact, including impact on biodiversity. Where renewable projects relate to the generation of energy from waste, these will be considered under policies relating to the treatment of waste (and where relevant Farm Diversification policies) See Policy 43 Energy from Waste, and Policy 20.
184.108.40.206 It is important to note that in areas where hydro-schemes are proposed it is likely that Screening under the Habitats Regulations should be undertaken, especially where the proposal will impact on a SAC or its tributary, or in combination will have an impact on a SAC or its tributary. Applicants are advised to contact CCW for further guidance in relation to this matter.
220.127.116.11 SPG will be prepared in order to help implement this policy to the benefit or our communities.
18.104.22.168 Large Scale Renewable Energy Projects
Strategic Policy SP9 also integrates the general national presumption against the provision of large scale renewable energy projects within the Park. Such schemes have significant landscape impacts which are considered at a National level to be in conflict with the purposes of designation of the National Park as a protected and special landscape. We do however acknowledge the need to provide for such development, and areas identified at a national strategic level (TAN 8) as being suitable for development should be encouraged. However these schemes have the potential to impact on the National Park, it is therefore imperative that we remain as statutory consultees within this process and have due influence on the siting and design of future proposals located on the fringes of the National Park. All development for large scale renewable energy proposals which are likely to impact on the National Park will be required to demonstrate how considerations for the special qualities of the National Park have been taken into account in developing the proposal. Proposals will be required to address impact from key landscape viewpoints and demonstrate to the satisfaction of the NPA that no negative impact on the special qualities will result.
22.214.171.124 The impact of large scale Renewable Energy projects located on our peripheries will be judged in accordance with SP2 Major Development in the National Park.
126.96.36.199 The easiest way the NPA can ensure that we meet our strategic objective to mitigate for the likely and predicted effects of climate change is by ensuring that the location of development does not in itself impact upon the causes of climate change or would be impacted by the likely and predicted effects of climate change.
188.8.131.52 This is primarily achieved through the spatial strategy which aims to locate development in the most sustainable locations, so as to limit as far as practicable carbon emissions generated by the need to travel to access work and essential services. Where this is compromised by the need to support community vitality and viability mitigatory measures are required of development (see spatial policies S LP3 & LGS LP3).
184.108.40.206However our other main means of implementation is to ensure that all new development is located in areas which are not likely to be subject to flooding. As previously stated, increased levels of flooding forms the major predicted likely result of climate change, and as such is one of the major risks presented by the changing climate to our communities. This presents a significant challenge to the NPA, as our traditional and historical settlements are predominately located within floodplains. Whereas in the identification of future development sites we have used the Environment Agencies Flood Risk Maps to identify areas at risk of flooding and remove these locations from the areas of search, there remains the problem that large areas of the existing built environment of our settlements are located within flood plains. As such development boundaries cover areas that have been identified by the Environment Agency as being at risk of flood.
220.127.116.11 This identification does not preclude some development occurring within these areas, however there may be need to undertake assessment to determine the risk of flooding and to present mitigation measures as part of the proposed scheme. For further guidance in this matter please refer to PPW 13.2 and TAN 15 Development and Flood Risk for more information.
18.104.22.168The Environment Agency will also be able to advise you if your proposal lies within an area of flood, and their maps are available from their website. If your site is identified to be at risk of flood the EA will be able to advise you of the supporting information they will require when commenting on a planning application. For guidance settlements where the development boundary interacts with the Environment Agency’s flood zones are given below.
Settlements affected by flooding
Hay on Wye (2)
Talybont on Usk (3C)
Ystradfellte ( 4B)