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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

 

4.1 National Park Purposes

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.

 

4.2 Appropriate Development in the National Park

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.

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 Major Development in the National Park

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

 

4.4 Ministry of Defence Developments

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 Notifiable Installations

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 Environmental Protection

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.

²¹ See Appendix 4 Special Qualities of the National Park

 

The strategic policy is supported by the following detailed guidance.

 

4.7 Biodiversity

4.7.1.1            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).

4.7.1.2  Please refer to Chapter 5 PPW ‘Conserving and Improving Natural Heritage and the Coast’.

4.7.1.3  Sites are identified on the Proposals Map. 

 

4.7.2 Sites of European Importance

4.7.2.1            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.

4.7.2.2  Sites are shown on the Proposals Map.

4.7.2.3  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.

 

4.7.3 Sites of National Importance

4.7.3.1            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.

 

4.7.4   SINCS (Site of Interest for Nature Conservation)

4.7.4.1            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.

4.7.4.2  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

 

4.7.5   Local Sites of Nature Conservation Interest

4.7.5.1  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.

4.7.5.2  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.

4.7.5.3  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.

4.7.5.4  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.   

4.7.5.5  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.

 

4.8     Trees and Development

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.

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

 

4.9 Water Resources

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

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.

 

4.11 Soil Quality

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

 

4.12 Air Quality

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

 

4.13 Natural Resources, Ecosystem Services and Food Security

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.

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	Cross Reference
Retaining and enhancing the Park’s special qualities	National Park Policy SP3
The provision of Spaces for growing food within and close to settlements	Spatial Policy E LP1 and SP15
The construction of buildings using sustainably sourced timber and recycled aggregates	SP11 and Policy 47
The provision of spaces for growing new woodland within and close to settlements	Spatial Policy E LP1
Development which meets the standards for provision of accessible natural greenspace
The sustainable use of ecosystem services
Proposals which integrate biodiversity conservation into the design of the development
Minimising pollution in all new development	in line with environmental protection regulations
Proposals which make efficient use of Water, Energy and Fuel Resources	Policy 5 Water Resources Policy 8 Air Quality Strategic Policy 11 Sustainable Development; Strategic Policy 9 Renewable Energy
Ensuring that all new development does not affect soil quality	Policy 7 Soil Quality
Ensuring that development does not take place on grade 3a agricultural land (national policy) or above, and supporting appropriate proposals for agricultural businesses in order to maintain sufficient farmland and infrastructure for sustainable, resilient and viable farm businesses.31
More sustainable economies and communities	SP12 Economic Wellbeing
Ensuring that all new development does not result in an increase in people’s and businesses’ ecological footprints32	SP4 Climate Change and SP11 Sustainable Design
Supporting appropriate proposals for new farm and food production-based businesses	SP12 Economic Wellbeing Policy 20 Farm Diversification Policy 26 Neighbourhood village and Rural Shops)
Supporting appropriate proposals for new rural enterprises based upon the sustainable management of natural resources	SP12 and supporting policies
Supporting appropriate proposals for economic diversification through green industries	SP12 and supporting policies

 

4.14 Conserving the Historic Environment

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.

4.14.3.1           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.

4.14.4.1 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.

 

4.14.5 Scheduled Ancient Monuments and archaeological remains

4.14.5.1 See PPW for policy on the protection of Scheduled Ancient monuments and archaeological remains.

4.14.5.2           Scheduled Ancient Monuments are shown on the Proposals Maps.

4.14.5.3 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.

4.14.5.4 This record is officially recognised by the National Park Authority.  

 

4.14.6 Areas for Archaeological Evaluation

4.14.6.1            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.

4.14.6.2            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.

 

4.14.7 World Heritage sites

4.14.7.1              Development in this area is covered by National Policy (Planning Policy Wales para 6.5.22.).

4.14.7.2            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.

 

4.15 Climate Change

4.15.0.1           Climate change, caused by increasing levels of greenhouse gases, is the most significant challenge facing the future of the National Park.

4.15.0.2 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. 

4.15.0.3           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

4.15.0.4           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. 

4.15.0.5            In implementing this strategy all development will be subject to meeting the aims of Strategy Policy 4 Climate Change.

4.15.0.6           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. 

4.15.0.7 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. 

4.15.0.8 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.

4.15.0.9 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.

 

4.15.1 Sustainable Development and Design

4.15.1.1           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.

4.15.1.2Para 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.

4.15.1.3Para 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). 

4.15.1.4A 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).

4.15.1.5Clear 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.

4.15.1.6The 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. 

4.15.1.7To 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. 

4.15.1.8The 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.

4.15.1.9  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. 

4.15.1.10The 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.

 

4.15.2 Renewable Energy

4.15.2.1As 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.

4.15.2.2In 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.

4.15.2.3 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.

4.15.2.4 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. 

4.15.2.5 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. 

4.15.2.6Therefore 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.

4.15.2.7 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.

4.15.2.8 SPG will be prepared in order to help implement this policy to the benefit or our communities.

4.15.2.9 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. 

4.15.2.10 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.

 

4.15.3 Location of Development Avoiding Areas Subject to Flooding

4.15.3.1 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.

4.15.3.2 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). 

4.15.3.3However 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.

4.15.3.4 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. 

4.15.3.5The 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

Brecon (1)

Clydach (3C)

Crickhowell(2)

Defynnog (4A)

Gilwern (3C)

Govilon (3A)

Hay on Wye (2)

Llangattock (4A)

Llangors (3A)

Llangynidr (4C)

Llanigon(3A)

Pencelli (3C)

Pontneddfechan(3A)

Sennybridge (4A)

Talgarth (2)

Talybont on Usk (3C)

Ynyswen (4C)

Ystradfellte ( 4B)

Brecon Beacons National Park - Deposit Local Development Plan 2007 - 2022