Snowdonia National Park Authority Local Development Plan Short Form Revision Strategic Environmental Assessment and Sustainability Appraisal Volume 1 - SA Report
Snowdonia National Park Authority
Local Development Plan Short Form Revision
Strategic Environmental Assessment and Sustainability Appraisal
Volume 1 - SA Report
Contents
1 Introduction
1
2 The SA Process
8
3 Review of Relevant Plans, Policies and Programmes
14
4 Baseline Context and Sustainability Issues
16
5 Assessment Methodology
26
6 Strategic Options Development and Assessment
46
7 Compatibility of the Vision and the SA Objectives
63
8 Compatibility of the SA Objectives and LDP Objectives
65
9 Assessment of the Strategic Policies and the Development Policies
69
10 Assessment of the LDP Housing and Employment Allocations
95
11 Cumulative and Synergistic Effects
100
12 Monitoring Framework
116
13 Next Steps
128
Abbreviations
BAP
Biodiversity Action Plan
NRW
Natural Resources Wales
CROW
Countryside and Rights of Way
cSAC
Candidate Special Area of Conservation
Defra
Department for Environment, Food and Rural Affairs
DfT
Department for Transport
ESDP
European Spatial Development Programme
EU
European Union
GCR
Geological Conservation Review
H/SAP
Habitat/Species Action Plan
ICZM
Integrated Coastal Zone Management
LBAP
Local Biodiversity Action Plan
LDP
Local Development Plan
LNR
Local Nature Reserve
MIPPS
Ministerial Interim Planning Policy Statement
NNR
National Nature Reserve
NPMP
National Park Management Plan
ODPM
Office of the Deputy Prime Minister
PPP
Plans, Policies and Programmes
pSPA
Potential Special Protection Area
RIGS
Regionally Important Geological/Geomorphological Sites
RSAP
Restoring Sustainable Abstraction Programme
SA
Sustainability Appraisal
SEA
Strategic Environmental Assessment
SME
Small and Medium Sized Enterprise
SNPA
Snowdonia National Park Authority
SoPR
State of the Park Report
SSSI
Site of Special Scientific Interest
SuDS
Sustainable (Urban) Drainage Systems
TAN
Technical Advice Note
TPO
Tree Preservation Order
WAG
Welsh Assembly Government
WIMD
Welsh Index of Multiple Deprivation
This abbreviations list is applicable to Volumes 1 and 2 of this SA Report.
1 Introduction
1.1 Background
The Snowdonia National Park Authority (SNPA) is currently revising its Local Development Plan (LDP) for the Snowdonia National Park area (hereinafter referred to as the National Park). The Eryri LDP (2007-2022) was adopted in 2011. A full review of the Plan is required every 4 years from the time of adoption. SNPA circulated a draft Review Discussion Paper (March 2016) following the production of its 3rd formal LDP Annual Monitoring Report. Feedback from key stakeholders on the Discussion Paper informed the review process and subsequently a Review Report was produced. The Annual Monitoring Reports have concluded that the LDP is delivering in terms of sustainable development in line with the SA objectives. Due to consensus that the existing Plan strategy remains relevant, the finalised Review Report (July 2016) concluded that a short form revision would be required. As part of this process, a combined Sustainability Appraisal (SA) and Strategic Environmental Assessment (SEA) is also being reviewed. The term SA shall be used to refer to the combined SA/SEA for the remainder of this report. This report documents the SA process for the LDP revision.
An update to the SA Scoping Report was prepared for the SA of the LDP, and released for statutory consultation in July 2016. Following receipt of consultation responses (statutory consultees), the Update Scoping Report was published on the Snowdonia National Park website.
A Deposit Version of the LDP has been prepared and it has been assessed as part of the SA process. This SA Report documents this assessment.
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1.2 Sustainability Appraisal and Strategic Environmental Assessment
SA is a process for assessing the social, economic and environmental impacts of a plan and aims to ensure that sustainable development is at the heart of the plan- making process.
It is a legal requirement that the LDP is subject to SA, under the Planning Act Wales (2015) and the Town and Country Planning (Local Development Plan) (Wales). This Act stipulates that the SA must comply with the requirements of the SEA Directive
1 which was transposed directly into UK law through the SEA Regulations2.
The aim of the SEA is to ‘provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development’ (Article 1 of the SEA Directive).
The principle of ensuring a better quality of life for everyone, now and in the future, lies at the heart of sustainable development. SA is an essential tool for ensuring that the principles of sustainable development are inherent throughout the preparation of the LDP and that it broadly complies with and contributes to relevant planning guidance. The overarching aim of the process is to ensure better decision-making and planning. It should be initiated at the earliest possible stage of the LDP preparation.
1.3 SA/SEA Guidance
The following guidance documents were consulted throughout the initial SA process:
• Office of the Deputy Prime Minister (ODPM) et al. (2005): A Practical Guide
to the Strategic Environmental Assessment Directive
• Welsh Assembly Government (WAG) (2015) LDP Manual Edition 2
• Countryside Council for Wales (CCW) (September, 2007) Strategic Environmental Assessment: Guidance for Practitioners, SEA Topic: Biodiversity
• CCW (November, 2007) Strategic Environmental Assessment: Guidance for Practitioners, SEA Topic: Water
• CCW (August, 2007) Strategic Environmental Assessment: Guidance for Practitioners, SEA Topic: Material Assets
• CCW (September, 2007) Strategic Environmental Assessment: Guidance for Practitioners, SEA Topic: Landscape
• CCW (September, 2007) Strategic Environmental Assessment: Guidance
1 Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the
environment, June 2001 2 S.I. 2004 No. 1633: The Environmental Assessment of Plans and Programmes Regulations, 2004
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for Practitioners, SEA Topic: Soil
• CCW (November, 2007) Strategic Environmental Assessment: Guidance for Practitioners, SEA Topic: Air
1.4 National Park Purposes
The National Park Purposes are to:
• Conserve and enhance natural beauty, wildlife and cultural heritage of the area.
• Promote opportunities for the understanding and enjoyment of the special qualities of the area by the public.
In pursuing these purposes the SNPA has a duty to:
• Seek to foster the social and economic well-being of local communities within the National Park.
The implementation of the LDP, together with the NPMP, will have a considerable impact upon the environment and the social and economic well-being of the local communities. These plans will deliver the strategy and policy that reflects the needs of the local community, within the context of the special status of the National Park.
1.5 Purpose of the LDP
The preparation of the SNPA LDP Short Form Revision commenced in 2016, as a requirement under the Planning Act Wales (2015). Once adopted it will replace the existing Eryri Local Development Plan for the National Park, and will cover a fifteen year period from 2016 – 2031.
The LDP is principally concerned with the use and development of land, and comprises the policy context for the assessment of development proposals. The LDP includes strategic policies and development policies that will ensure that any new development within the National Park is of a good quality and is located optimally, as well as delivering the long-term spatial vision for the future of the Snowdonia National Park. It will be used to help decide which planning applications for development should be accepted or refused.
1.6 Purpose and Structure of this SA Report
This SA Report provides a summary of the SA process. This SA Report will be consulted upon alongside the Deposit Version LDP. It will be issued to all statutory consultees and made available for public viewing. It is essential that the Deposit Version LDP is read in conjunction with this SA Report.
Table 1-1 outlines the contents and structure of this SA Report. Volume 1 of this SA Report comprises the main text and includes a summary of the assessment findings. The appendices to this report are presented in a separate Volume 2.
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Table 1-1
Section of SA Report Outline Structure and Context Non Technical Summary (Separate Document)
Summary of the SA process and SA Report in plain English (a legislative requirement
Abbreviations Abbreviations used in this report 1. Introduction Provides background to the SA and LDP and includes the
purpose and structure of the report. 2. The SA Process Outlines the key elements of the SA process and the
adopted approach to the assessment. Provides a summary of the SA process undertaken to date. Provides details of how to comment upon this SA Report
3. Review of Relevant Plans, Policies and Programmes (PPP
Sets the context for the LDP within the hierarchy of international, national and regional sustainability objectives. Identifies the key findings of the PPP review. The full review is presented in Appendix B of Volume 2
4. Baseline Context and Sustainability Issues
Explains the link between the SA process and the State of the Park Report (SoPR) and highlights some key sustainability issues and opportunities in the National Park.
5. Assessment Methodology
Outlines the alternatives that were considered and assessed as part of the development of the current LDP and explains how the components of the LDP have been assessed through the SA process
6. Strategic Options Development and Assessment
Presents the main recommendations from the assessment of options and also consultee comments regarding the options
7. Compatibility of the Vision and the SA Objectives
Provides an assessment of the compatibility of the Vision and the SA Objectives. It also includes a summary of the recommendations made in the Initial SA Report to improve the Vision
8. Compatibility of the SA Objectives and the LDP Objectives
Presents the results of the assessment of the compatibility assessment of the SA Objectives and the LDP Objectives. It also includes a summary of the recommendations made in the Initial SA Report to improve the LDP Objectives
9. Assessment of the Strategic Policies and the Development Policies
Presents the assessment of the LDP (Short Form Revision) strategic policies and development policies and recommendations to improve their sustainability performance
10. Assessment of the LDP Housing and Employment Allocations
This presents an assessment of the sites allocated for housing and employment in the LDP (Short Form Revision).
11. Cumulative and Synergistic Effects Presents the assessment of the main cumulative and synergistic effects of the LDP (Short Form Revision
12. Monitoring Framework
Provides a monitoring framework to monitor the significant effects of implementing the LDP (Short Form Revision).
13. Next Steps Outlines the next steps in the development of the LDP (Short Form Revision)
Appendix A. Scoping Report Consultation Responses
Comprises copies of the consultation responses to the Updated Scoping Report
Appendix B. Review of Plans, Policies and Programmes
Review of other relevant plans, policies and programmes that have influenced the SA process and the development of the LDP
Appendix C. SA Objective Compatibility A compatibility matrix of the SA Objectives to identify any potential areas of inconsistency between the objectives.
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Appendix D. LDP and SA Objective Compatibility
A compatibility matrix of the SA Objectives and the LDP Objectives to identify any potential areas of inconsistency between the two sets of objectives
Appendix E. Policy Assessment Matrices
Matrices assessing the strategic policies and the development policies against the SA Objectives
Appendix F. Assessment of Site Allocations Assessment of the housing and employment land allocations against the SA Objectives
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1.7 The Sanford Principle
During the preparation of the LDP, areas of irreconcilable conflict may arise between the National Park Purposes. In such circumstances, the Sanford Principle states that conservation purposes shall prevail. The SA process has also been mindful of this principle.
1.8 Habitat Regulations Assessment (HRA)
European Council Directive 92/43/EEC (the ‘Habitats Directive’) requires that any plan or programme likely to have a significant impact upon a Natura 2000 site (Special Area of Conservation (SAC), candidate Special Areas of Conservation (cSAC), Special Protection Area (SPA), potential Special Protection Area (SPA) and Ramsar site), which is not directly concerned with the management of the site for nature conservation, must be subject to an Appropriate Assessment.
A separate screening exercise in accordance with the Habitats Directive requirements was undertaken for the original LDP, in parallel to the SA process. The aim of the screening exercise was to determine whether the LDP (either in isolation and/or in combination with other plans or projects) would generate an adverse impact upon the integrity of a Natura 2000 site, in terms of its conservation objectives and qualifying interests. The HRA3 was revisited in the light of revisions to the LDP arising from the inclusion of new policies. It was concluded that;
“a) in the absence of additional material information which might render the earlier findings ‘out of date’, and b) on the basis that the analysis underpinning the earlier March 2009 HRA is considered to be ‘rigorous and robust’,
The findings of the March 2009 HRA can be adopted by the SNPA in respect of all other aspects of the LDP which are unchanged by the revision review. To subject the entire LDP to HRA would represent an unnecessary duplication of assessment effort”. Apart from the new Development Policy27: Snowdonia Enterprise Zone the policy revisions to the LDP were screened out as having no likely significant effect, either, alone or in combination, with other plans and projects. DP27 was then subject to an Appropriate Assessment (AA.) The results of the AA advised that the wording of DP 27 be amended in order to ensure that the LDP will have no adverse effect on the integrity of any European sites. Further details about this process can be obtained from the HRA Screening Report Addendum.
1.9 The State of the Park Report
3 Shadow Habitats Regulations Assessment of the Snowdonia National Park Authority Revised Local Development Plan 2016-2031 HRA ADDENDUM MAY 2017. DTA Ecology May 2017
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The State of the Park Report (SoPR) supports the development and monitoring of both Local Development Plan and the National Park Management Plan (NPMP). The SoPR presents historical data which demonstrates existing trends and provides details of current conditions which will be used as a foundation to establish future trends and performance in the National Park. Comparisons are also drawn with national level data where relevant and appropriate.
The SoPR covers a range of environmental, social and economic issues to enable the reader to fully understand conditions in the National Park. The SoPR, as well as informing the plan-making process has also been used as the evidence base for the SA of the LDP and so the coverage of the SoPR has been broadened to ensure that it addresses all necessary issues, for example socio- economic trends.
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2 The SA Process
2.1 Adopted Approach
By combining the SA and SEA processes, this SA considers environmental, social and economic issues and their interactions, thereby ensuring the principles of sustainable development are integrated into the LDP’s development.
Whilst there are formalised approaches for both SA and SEA, only SEA has a legal obligation to perform certain activities which are stipulated in the SEA Directive. The activities that must be undertaken to ensure compliance with the SEA Directive are highlighted in boxes throughout this report. These legal obligations have been adhered to throughout the SA process. A series of prescribed stages have been followed, through which the elements of the LDP and LDP (Short Form Revision). have been assessed using sustainability objectives.
The aim of the assessment was to ensure the preferred option for the current LDP is as sustainable as possible, by making recommendations to the plan-makers. This should ultimately improve the sustainability of any development that is brought forward within the National Park.
Figure 2-1 outlines the stages in the SA process, alongside the parallel stages of the plan-preparation process. Whilst the process can be subdivided into a number of separate stages, it is the intention that the process is iterative.
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Figure 2-1 The LDP and SA Processes (Revision italics)
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2.2 SA Progress to Date
Table 2-1 presents details of the SA progress to date.
SA Stage and Task Element of SA Process Key Inputs and Processes
Stage A: Setting the context and
objectives, establishing the baseline
and deciding on the scope
A1: Identifying other relevant policies,
plans, programmes and sustainability
objectives
A2: Collecting baseline information
A3: Identifying sustainability issues and
problems
A4: Developing the SA Framework
A5: Consulting on the scope of the SA
Scoping The original SA process commenced in early 2007 with the production of the Scoping Report for
the SA of the LDP and NPMP. The Scoping Report contained:
A characterisation of the environmental, social and economic baseline within the National Park.
A review of relevant plans, programmes and policies that could influence the SA and the
development of the LDP and NPMP.
The identification of key sustainability issues and opportunities.
The SA Framework, against which the elements of the LDP and NPMP would be assessed.
SA Framework The SA Framework was reviewed through the update scoping stage, and acts as the main tool
for assessing the sustainability of the LDP (Short Form Revision). It contains a series of SA
Objectives and guide questions, which address the full-cross section of sustainability issues,
covering environmental, economic and social goals for the National Park. .
The SA Objectives and guide questions are presented in Section 5.2.
Scoping Consultation The Updated Scoping Report was issued for statutory consultation by the SNPA in July 2016 ,
for the statutory five week consultation period.
The Scoping Report was issued to the three statutory consultees (the NRW, Cadw, Welsh
Government.) Responses from Cadw and NRW were received.
Officers subsequently incorporated these responses into the SA process and revised the Scoping
Report accordingly. Copies of the scoping consultation responses are provided in Appendix A in
Volume 2.
Stage B: Developing and refining Initial SA Report and Consultation The SNPA Strategic Options Document was produced in December 2007, outlining the alternative
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SA Stage and Task Element of SA Process Key Inputs and Processes
options and assessing effects
B1: Testing the plan objectives against the
SA Framework
B2: Developing the plan options
B3: Predicting the effects of the draft plan
B4: Evaluating the effects of the draft plan
B5: Considering ways of mitigating adverse
effects and maximising beneficial effects
B6: Proposing measures to monitor the
significant effects of implementing the plans
strategic options for both the original LDP and the NPMP.
An initial review of the first iteration of the Strategic Options was undertaken by the SA Team in
December 2007. This assessment comprised a high-level rapid review of the Strategic Options,
in order to identify any ‘showstoppers’. The results of this review were used by the plan-makers
to inform the second iteration of Strategic Options.
The second iteration of Strategic Options for the original LDP was assessed through the SA
process in order to determine the preferred option. A separate Initial SA Report was prepared for
the original LDP, documenting this assessment (Hyder Report Reference Number: 003-NH51128-
NHR-02-F). This Initial SA Report was consulted upon publicly in Spring 2008 to seek feedback
on the preferred strategy for the original LDP and the options considered during the development
of the preferred strategy. Responses were received from all statutory consultees and incorporated
into the SA process as appropriate. Appendix B of the original LDP SA Report (Hyder Consultants
20 March 2009) presents a table showing the responses from the statutory consultees and an
explanation of how the responses were taken into account in the SA process.
Details of the options considered and key recommendations from the assessment in the Initial SA
Report are provided in Section 6. These remain unchanged for the process of revising the LDP
and SAR
Stage C: Preparing the SA Report
C1: Preparing the SA Report
Stage D: Consulting on the Draft Plan
and SA Report
D1: Public participation on the preferred options of the plan and the SA Report D2: Assessing the significant changes D3: Making decisions and providing information
Final SA Report and Consultation This Final SA Report documents the entire SA process. It will be issued for consultation,
alongside the Deposit Version of the LDP (Short Form Revision), to all statutory consultees and
the public for comments.
Refer to Section 2.3 for further details of consultation and involvement.
Stage E: Monitoring This SA Report contains a monitoring framework that should be used to monitor the significant
sustainability effects of implementing the LDP (Short Form Revision). Monitoring will
commence when the LDP (Short Form Revision) is formally adopted.
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2.3 Consultation and Involvement
This Final Revised SA Report has been issued for consultation alongside the Deposit Version of the LDP (Short Form Review). Please address any consultation responses to Planning Policy Team at the address below:
Snowdonia National Park Authority
National Park Office
Penrhyndeudraeth
Gwynedd
LL48 6LF
Table 2-2 provides details of where copies of the documents are available for public inspection, free of charge during normal opening times.
Table 2-2 Deposit Locations
LDP Deposit (Short Form Revision) Locations Abermaw Ffordd yr Orsaf, Abermaw, Gwynedd, LL42 1LE
Bethesda Ffordd Coetmor, Bethesda, Gwynedd, LL57 3DP
Blaenau Ffestiniog Canolfan Maenofferen, Blaenau Ffestiniog, Gwynedd, LL41 3UA
Dolgellau Ffordd y Bala, Dolgellau, Gwynedd, LL40 2YF
Penygroes Canolfan Dechnoleg, Dyffryn Nantlle, Heol y Dŵr, Gwynedd, LL54 6LR
Tywyn Ffordd Neifion, Tywyn, Gwynedd, LL36 9HA
Porthmadog Healthy Lifestyles Centre and Library Glaslyn, Stryd y Llan, Porthmadog, Gwynedd, LL49 9HW
Y Bala Llyfrgell Bala, Canolfan Hamdden, Heol Pensarn, Y Bala, Gwynedd, LL23 7SR
Cerrigydrudion Yr Hen Glinic, Stryd y Brenin, Cerrigydrudion, Corwen, LL21 9UB
Conwy Neuadd y Dref, Stryd y Castell, Conwy, LL32 6AY
Llanfairfechan Ffordd y Pentref, Llanfairfechan, Conwy, LL33 0AA
Llanrwst Plas-yn-Dre, Ffordd yr Orsaf, Llanrwst, Conwy, LL26 0DF
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Penmaenmawr Ffordd Bangor, Penmaenmawr, Conwy, LL34 6DA
Canolfannau Croeso
Cyfeiriad
Canolfan Groeso Betws y Coed
Stablau’r Royal Oak, Betws y Coed, Conwy, LL24 0AH
Canolfan Groeso Beddgelert
Canolfan Hebog, Beddgelert, Gwynedd. LL55 4YD
Canolfan Groeso Aberdyfi
Gerddi'r Cei, Aberdyfi, Gwynedd. LL35 0EE
They are also available on the Authority’s website at www.eryri- npa.gov.uk/LDP
Your comments are invited on the SA. Please send your comments to the above address, marked for the attention of The Planning Policy Team.
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3 Review of Relevant Plans, Policies and Programmes
3.1 Introduction
A review of PPPs was undertaken in order to identify the relationship between them and the LDP (Short Form Revision). In addition, the review of the PPPs helped to direct the preparation of the SA Framework.
3.2 Requirements of the SEA Directive
The SEA Directive stipulates activities which must be undertaken as part of the SA. The activities relevant to the review of PPPs are outlined in Box 1.
Box 1: SEA Directive Requirements Applicable to Review of Relevant PPPs
The Environment Report should provide information on:
‘an outline of the contents, main objectives of the plan or programme and relationship with other
relevant plans and programmes’ (Annex 1(a))
‘the environmental protection objectives, established at international, Community or Member
State level, which are relevant to the plan or programme and the way those objectives and any
environmental considerations have been taken into account during its preparation’ (Annex 1(e))
3.3 Key Findings of Review
The complete PPP review is presented in Appendix B. The PPP review included a review of relevant international, national, regional, sub-regional and local plans that could potentially influence the development of the original LDP strategy and LDP (Short Form Revision). and the SA. When reviewing the plans it was recognised that a ‘trickle-down’ effect occurs and that key principles raised in international level documents should be translated into lower tier plans e.g. at a national level. Some of the key themes/aims from the review are listed below:
• Protection and enhancement of biodiversity and the natural environment
including the landscape (and townscape).
• Protection and enhancement of cultural heritage resources and the built environment.
• Protection and enhancement of water resources.
• Retaining areas of natural floodplain.
• Recognition of the challenge of climate change and implementing appropriate adaptive action to deal with it.
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• Recognition of the need to reduce greenhouse gas emissions and promote renewable energy and energy efficiency.
• Achievement of resource efficiency and the development of more sustainable patterns of production and consumption.
• Prudent use of natural resources.
• Encouraged use of sustainable design initiatives.
• Promotion of sensitive and sustainable waste management.
• Recognition of the importance of open spaces, sport, and recreation and the contribution that they make to enhancing quality of life.
• Strengthening the Welsh national identity.
• Improved visitor accessibility to Welsh culture.
• Necessity to ensure that new housing development meets local needs, e.g. in relation to affordability.
• Promotion of more sustainable transport choices (e.g. public transport facilities) and improved accessibility.
• Provision of high quality services that are as accessible as possible.
• Achievement of an overall improvement in quality of life for all residents.
• Regeneration of rural communities and livelihoods.
• Improved economic diversification.
• Increased employment opportunities.
• Enhanced health of people living in the National Park.
• Extension of local democracy and local action.
• Reduced incidence of crime and anti-social behaviour.
Within these broad goals, there are potential challenges. Achieving sustainable development is about striking a balance between social progress, economic development and environmental protection and enhancement. In many instances, these issues may try to pull in opposite directions, for example, the desire for economic growth can sometimes be in direct conflict with objectives to protect the natural environment. In contrast, the development of a high quality built and natural environment can in themselves be drivers for investment, improved visitor offer and hence economic growth as well as an improved quality of life for residents.
The SA process has a role to play in identifying the likely consequences of the LDP’s actions. It acts as a decision aiding tool to establish the relative merits and hence the most sustainable options to be taken forward, and also to attempt to mitigate any adverse consequences.
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4 Baseline Context and Sustainability Issues
4.1 Introduction
Characterising the environmental and sustainability baseline, issues and context is an important activity in devising the SA Framework, and involves the following elements:
• Characterising the current state of the National Park’s environment
(including social and economic aspects in addition to the natural environment).
• Using this information to identify existing problems and opportunities which could be considered in the LDP where relevant.
The SoPR presents the baseline data for the original LDP strategy and LDP (Short Form Revision) and this SA and covers a range of environmental, social and economic issues to enable the reader to understand the conditions in the National Park. The SoPR should, therefore, be read alongside this SA Report. The SoPR presents data about the following topics: climate change; air quality; water resources; geology, soils and waste; landscape and land management; biodiversity, flora and fauna; cultural identity/heritage; population (including human health); housing; economy; transport and traffic; public perceptions and understanding; tourism; and Public Rights of Way and access.
4.2 Requirements of the SEA Directive
The SEA Directive stipulates activities which must be undertaken as part of the SA. The activities relevant to setting the context and establishing the baseline are outlined in Box 2.
Box 2: SEA Directive Requirements Applicable to Sustainability Baseline, Issues and Context
The Environment Report should provide information on:
‘relevant aspects of the current state of the environment and the likely evolution thereof without
implementation of the plan or programme’ and, ‘the environmental characteristics of the areas
likely to be significantly affected’ (Annex 1(b), (c))
‘any existing environmental problems which are relevant to the plan or programme including, in
particular, those relating to any areas of a particular environmental importance, such as areas
designated pursuant to Directives 79/409/EEC and 92/43/EEC’ (Annex 1 (d))
The collation of baseline data is a vital part of the SA process, as it provides a context for the rest of the assessment process. An understanding of existing conditions is needed to predict the likely effects of the LDP and how its polices could affect future trends and patterns in the National Park.
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4.3 Sustainability Baseline and Key Issues / Opportunities
Key sustainability issues and opportunities for the National Park were identified through:
• The review of relevant PPPs (see Appendix B of Volume 2).
• The baseline data collation (this is documented in the State of the Park Report ).
• The experience of SNPA officers in relation to issues faced when working on behalf of the SNPA.
The key sustainability issues and opportunities are identified in Table 4-1. Although these have been grouped, many are indirectly or directly linked and are therefore closely related. All of these issues have potential environmental, social and economic implications, and have therefore been taken into consideration by plan-makers when finalising the Deposit Version of the LDP (Short Form Revision). The issues and opportunities have also been taken into account during the SA process. Table 4-1 also provides details of which section of the SoPR provides supporting data in relation to the identified issues
4.4 Other Assessments
The Eryri LDP (Short Form Revision) will also be subject to an Equality Impact Assessment (EqIA). An EqIA of the ELDP (Short Form Revision) is required in law by the Equality Act 2010 and the Welsh Language Act 1993. EqIA is a tool that helps local authorities ensure that they do not discriminate, that they promote equality wherever possible and foster good community relations. Carrying out an EqIA involves assessing the likely effects of policies on people in respect of disability, gender, race, language, age, sexual orientation, and religion or belief. A Health Impact Assessment (HIA) of the ELDP (Short Form Revision) will also be undertaken. Health Impact Assessment (HIA) is a tool that can be used to assess the health impact of a physical development, a proposed change to service delivery or a policy or strategy. The aim is to remove or mitigate any possible negative impacts on people’s health and well-being and to maximise opportunities to help people improve their health. Even though the main health issues are well represented in the SA Framework, the HIA will be conducted as a separate exercise to the SA. Based on the methodology contained in ‘Improving Health and Reducing Inequalities: A Practical Guide to HIA’ – the Welsh guide to HIA. (Welsh Assembly Government and Health Challenge Wales, Improving Health and Reducing Inequalities: a practical guide to health impact assessment, 2004.). Snowdonia Local Planning Authority has developed a Health and Well-being Assessment tool which will be used to assess the ELDP (Short Form Revision). Finally, a Welsh Language Impact Assessment (WLIA) will be undertaken for the ELDP (Short Form Revision). WLIA allows for the identification of possible impacts on the Welsh language that may result from development. The results of the above named assessments have informed the SA process.
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Table 4-1 Key Sustainability Issues and Opportunities
SA Topic (and relevant section of SoPR)
Key Sustainability Issues Key Sustainability Opportunities
Population and Human Health
(Population section of the SoPR)
Statistics from the 2011 Census indicate that the population in the
National Park has remained relatively stable, showing only a small
increase from 2001. However, over recent years that has been a
trend of out-migration of the younger sectors of the population owing
to the lack of availability of employment opportunities and difficulties
associated with housing affordability. This is leading to an
increasingly ageing population in the National Park.
There are a high percentage of people over 65 living in the National
Park which has implications for the provisions of key services and
amenities.
The natural resources of the National Park are a key recreational
resource that offers benefits for well-being and health which must be
protected and enhanced.
Despite having proportionately more people aged 65 and over than
the Welsh average, the proportion of National Park residents with a
limiting long term illness is lower than the overall figure for Wales.
Opportunities should be sought to improve the health and well-being
in the National Park.
There is a need to reduce the outward migration of young people and
to provide a viable and coherent population able to provide and
support vital services, the local economy and to provide vitality and
vibrancy in the National Park settlements.
Economy
(Refer to the Economy and Tourism
sections of the SoPR)
Snowdonia has a relatively low wage economy with tourism and
agriculture being the main employment sectors. Agriculture in the
National Park is almost entirely pastoral; predominantly beef and
sheep farming, but with a small dairy sector.
Studies have been undertaken into the availability and the
requirements of employment land within the National Park which shows that there is generally sufficient land either on existing
There are some sites in the National Park which could potentially be
available for further employment land use.
There is a need to create employment opportunities that encourage
the younger population to continue living in the National Park.
There is a need to develop the economy and economic growth e.g.
increased diversification which would in turn lead to improved skills.
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industrial sites or allocated land close to the National Park to meet
the current employment needs.
Employment centres that are important to the National Park lie
outside the National Park’s boundaries and include: Machynlleth,
Tywyn, Blaenau Ffestiniog, Porthmadog, Penrhyndeudraeth,
Llandudno Junction, Llandygai and Caernarfon.
There was a boom in tourism employment in the National Park
between 2001 and 2003, with a steady decline since 2006. This
highlights fluctuations that occur in employment in the tourist industry.
Within certain parts of the National Park, there are recreational
pressures on parts of the natural environment including Gwydyr and
Coed y Brenin forests. Currently over 100,000 mountain bikers visit
these sites each year.
However, any such changes should not adversely affect the
Special Qualities of the National Park.
Agricultural diversification opportunities exist within the National Park,
provided they are undertaken in a manner that does not adversely
affect the natural environment.
New employment development should re-use derelict land or under-
used buildings where possible.
There is a need to effectively manage the effects of tourism on the
National Park environment. Furthermore, economic diversification is
needed such that employment opportunities are available during the
low tourist season.
Housing
Housing is one of the key concerns for many communities in the
New housing development in the National Park need to meet local
(Housing section of the SoPR) National Park
as there is a lack of affordable housing both to rent
needs in terms of quality and tenure i.e. ensure that an appropriate
and buy. Incomes in the National Park are generally low and there
are limited opportunities for higher paid employment. The high
number of holiday homes in the National Park adds further pressure
to the sustainability of communities and the housing market. This has
led to out-migration and a changing population structure within the
amount of affordable housing is provided.
Existing mechanisms for the provision of affordable housing need to
be reviewed and improved.
It should be ensured that areas allocated for housing development
are well connected to employment opportunities and have access to
National Park. This is likely to have long-term effects on the
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sustainability of communities unless action is taken to address the
issue.
public transport links.
Opportunities should be sought to use brownfield land in appropriate
locations for new housing development.
Deprivation and Living Environment
(Refer to the Housing and
Population sections of the SoPR)
The National Park is one of the least deprived regions within Wales in
for overall deprivation and income deprivation.
One of the key issues affecting quality of life in the National Park
relates to a lack of affordable housing.
There is a very high quality natural environment within the National
Park and this contributes positively to quality of life and overall health
and well-being.
There is a need to maintain and enhance community cohesion and
local distinctiveness, e.g. through increased availability of local
services, opportunities for young people, high quality design and
protection of the Welsh language.
The natural beauty of the National Park contributes significantly to
quality of life in the National Park and should be protected and
enhanced. In promoting new development and accessibility to
services, there should be careful consideration given to the potential
effects of such development on the natural environment.
Biodiversity, Flora and Fauna
(Refer to the Biodiversity, Flora and
Fauna section of the SoPR)
The National Park supports a very rich biodiversity. There are 15
SACs, 3 Ramsar sites, 5 SPAs, 107 Sites of Special Scientific
Interest (SSSI) and 21 National Nature Reserves within, or partly
within, the National Park, as well as the Dyfi Estuary which is a
UNESCO World Biosphere Site, the only one in Wales.
There is an active commitment to raising awareness of the need to
protect and enhance biodiversity in the National Park with an
increasing number of initiatives being pursued to promote
engagement and interest at all levels. This is something that can also
be furthered through work undertaken as part of the NPMP.
The Local Biodiversity Action Plan (LBAP) identifies the most
important habitats and species found in Snowdonia. Habitats and
Species Action Plans (H/SAPs) contained in the document reinforce
the importance of these areas and species, not only in terms of their
national and international significance but also their local importance.
Regular monitoring is undertaken of the H/SAPs and to date it has
Opportunities should be sought to protect and enhance all aspects of biodiversity e.g. important habitats and protected species, as well as those sites protected by legislation.
It is also essential that the aspects of the natural environment which support biodiversity resources are protected from inappropriate development which include water resources and soils.
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than LBAP habitats, although recently, there has been a decline
in the percentage of LBAP species in an improving status.
Air Quality and Climatic Factors
(Refer to the Air Quality and Climate
sections for the SoPR)
Data for Gwynedd and Conwy indicates that air quality is good in the
National Park, as Air Quality Standards are being met.
Since 2011 a substantial number of planning permissions have been
granted for a number of renewable energy technologies in the
National Park, primarily small-scale hydro schemes.
There are a number of areas of the National Park at risk of flooding
including the settlements of Y Bala and Dolgellau and this must be
carefully considered before granting planning permission for new
development.
Opportunities should be sought to reduce levels of traffic, tackle
areas of congestion and promote the use of public transport.
New developments should be encouraged to adopt sustainable
design principles, energy efficiency and the use of renewables e.g.
the inclusion of solar panels and low carbon technologies.
The carbon footprint of new development should be reduced e.g.
through more efficient sustainable land management, transport
accessibility and development location/design.
The degradation and loss of peat should be avoided to maximise
carbon sequestration associated with this type of habitat.
Opportunities should be sought to reduce the threat and risks
associated with climate change e.g. rising sea levels and flooding.
There is a need to investigate and facilitate adaptation of wildlife to
climate change, and establish connectivity and habitats/species
corridors.
Water Resources
(Refer to the Water Resources
section of the SoPR)
Water quality in the watercourses across the National Park is
generally very good. However, agricultural activities are a key factor
affecting water quality and diffuse pollution can be very difficult to
control. Many of the watercourses and water bodies in the National
Park are also designated sites for nature conservation reasons.
The quality of the beaches in and around the National Park is good
and has been improving many beaches achieving Blue Flag status.
A particular challenge in Wales relates to managing water supply and
the high levels of variation in demand throughout the year. One of
the biggest challenges is maintaining public water supply during the
The quality and condition of the water environment is critical to the
wider environment and quality of life. Opportunities should be sought
to improve water quality.
New development should be encouraged to incorporate Sustainable
Urban Drainage Systems (SuDS) to control runoff from new
development.
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Key Sustainability Issues Key Sustainability Opportunities summer months when Wales has a large influx of tourists. However, this responsibility lies with Dwr Cymru Welsh water (DCWW).
Landscape
(Refer to the Landscape and Land
Management sections of the SoPR)
The National Park landscape includes rugged mountains, high
moorland, wooded valleys, lakes, waterfalls, estuaries and coast
which all contribute to the Special Qualities of the Park.
The majority of areas within the National Park are classified as being
tranquil and it is essential to protect this tranquillity. The National
Park gained International Dark Skies Reserve status in 2015.
Supplementary Planning Guidance on Obtrusive Lighting (Light
Pollution) provides advice on how to avoid compromising the status
and protecting the very darkest Core Areas of the Park.
Two Supplementary Planning Guidance documents have been
adopted by the SNPA namely The Landscapes and Seascapes of
Eryri and Landscape Sensitivity and Capacity Assessment. The
quality of the coastline of the National Park has gradually deteriorated
in recent years with significant development occurring in coastal
towns leading to the loss of distinctive landscape features e.g.
saltmarsh. Very few parts of the coastline have an unspoilt character.
It is essential that landscape character and quality is protected and
enhanced in the National Park.
In addition to considering the wider strategic preservation of the
Park’s landscape, opportunities should be sought where appropriate
to enhance design and landscaping at the local level to improve the
quality of the local environment.
Cultural heritage including
architectural and archaeological
heritage
(Refer to the Cultural Identity section
of the SoPR)
Within the National Park there are 14 Conservation Areas, 1911
Listed Buildings (13 are Grade 1 and 119 are Grade 2*), a World
Heritage Site (Harlech Castle) and 377 Scheduled Monuments. In
June 2010 a successful application was made for the Slate Industry
of North Wales to be included on the UK’s tentative list to be
submitted to UNESCO for World Heritage Site status. In addition to
the sites protected by legislation, it is important to recognise that
there are numerous other undesignated features in the National
Park that are also worthy of protection in their own right and form a
valuable component of the National Park’s heritage.
Cadw maintains a register of Historic Parks and Gardens within
Wales. There are currently 21 Historic Parks and Gardens within
In addition to preserving statutory sites it is important to ensure that the
wider historic landscape is protected and that cultural heritage issues are
taken into consideration in all new developments that occur in the Park.
Opportunities should be sought to improve understanding and
appreciation of cultural heritage resources.
There is a need to protect the Welsh language and distinctive cultural
identity and this is also closely linked with the affordable housing
issues in the National Park, as the provision of affordable housing
could help to reduce out-migration of the National Park’s residents.
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the National Park. Whilst they are not statutorily protected Welsh
Office Circular 61/96 establishes the need for local planning
authorities to treat them as a material consideration when
determining planning applications. All cultural heritage features in
the National Park should be.protected and enhanced
Many of the heritage sites are also valuable tourist destinations that
contribute to the National Park’s economy, for example Harlech
Castle.
There are a number of very good examples of local architectural
vernacular across the National Park and these traditional buildings
whilst not necessarily being protected by legislation should be
protected.
The Welsh language is spoken by 58.6% of the total population and
in some communities the language is spoken by over 80% of the
residents.
Geology and Soils
(Refer to the Geology, Soils and
Waste Section of the SoPR)
Land within the National Park is classified as Grade 3 or below.
Whilst there are no areas of very good or excellent quality, the
effective management of agricultural soils is essential owing to the
importance of agriculture for the local economy
The Snowdonia National Park has a unique and visible geological
character that is a fundamental part of its outstanding landscape and
scenery, formed and shaped by complex processes of evolution and
climate change. It contains a wealth of nationally and locally
important geological and geomorphological features, and has a wide-
range of soil types that are influenced by the underlying geology and
rock types and also the land management practice/activity upon it.
Geological designations within the National Park include SSSIs and a
number of Regionally Important Geological and Geomorphological
Sites (RIGS).
Human actions have impacted upon geological and soil resources
through pressures such as commercial afforestation and natural tree
regeneration and erosion due to recreational activities and
overgrazing. There is a need to protect and enhance all soil
functions e.g. carbon sequestration and infiltration. The degradation
and development of peat soils should be avoided. The SNPA in
partnership with other organisations has been restoring upland
peat bogs. In 2016 the SNPA published a draft Peat Strategy report
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Transportation
(Refer to the Transport and Traffic
section of the SoPR)
A number of strategic roads traverse Snowdonia, of which the
primary route is the A55 dual carriageway which links the authorities
along the North Wales coast. This route was designed to carry long
distance heavy goods vehicles travelling between North West Wales,
Ireland and Europe. Other significant trunk roads include the A487,
A5, A470, A494 and A458 which link major settlements to focal
centres and connect Gwynedd and Conwy to other areas of England
and Wales. The A470 through the Lledr Valley and the A487/A470
Caernarfon to Dinas Mawddwy routes carry through traffic from Mid
and South Wales. In recognition of this, the A470 and part of the
A487 are very important North-South links.
The geography, and topography of Snowdonia along with the
dispersed availability of employment opportunities means that
there is a high reliance upon private car.
An effective public transport network will also support the economic
aspiration of the wider region through facilitating employees
commuting and reducing the impact of rising fuel costs upon the
workforce.
The Snowdonia Green Key Initiative focuses on sustainable transport
networks within the National Park. It aims to improve the frequency
and quality of the service, as well as helping achieve the strategic aim
of encouraging people to use public transport. A greatly enhanced bus
service also benefits local people, who have access to an urban
standard of frequency and reliability. The Snowdon Sherpa service is
part of this initiative and provides transport from a number of locations
from both within and outside of the National Park.
Opportunities should be sought to reduce dependence on the private
car and increase public transport use.
There are some areas of the National Park where access to public
transport is inefficient, this can cause segregation and inequalities in
access to services.
It will be important to ensure that any new employment sites can be
easily accessed by public transport.
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The majority of households (84%) in Snowdonia National Park own at
least one car
The National Park includes 2,742km of Public Rights of Way and a
number of cycle paths.
Minerals and Waste
(Refer to the Geology, Soils and
Waste Section of the SoPR)
A variety of minerals including slate, hard rock and metals including
gold, copper and lead are found in the National Park and have been
worked in the past. The British Geological survey has produced
Minerals Resources Maps and Minerals Safeguarding Maps.
Category 1 (high value) aggregates will be safeguarded from
permanent sterilisation by development.
There is a lack of local building stone in the National Park which is
needed for house construction. Other types of stone sourced from
outside of the National Park can look out of place and adversely
affect the quality of the townscape.
Opportunities should be sought to minimise waste generation and for
sustainable waste management principles to be adopted in new
development.
If new mineral workings are developed to source local building stone,
the potential environmental effects must be thoroughly assessed prior
to their development.
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5 Assessment Methodology
5.1 Requirements of the SEA Directive
Box 3 identifies the activities which are required to comply with the SEA Directive as part of the assessment process.
Box 3: SEA Directive Requirements Applicable to Assessment of Effects and Mitigation
Information to be provided in the Environmental Report includes:
• ‘the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage, including architectural and archaeological heritage, landscape and the interrelationship between the above factors. These effects should include secondary, cumulative, synergistic, short, medium and long-term, permanent and temporary, positive and negative effects’ (Annex I (f) and footnote)
• ‘the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme...’ (Annex I (g))
• ‘an outline of the reasons for selecting the alternatives dealt with and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information’ (Annex I (h))
5.2 SA Framework
The SA Framework underpins the assessment methodology and comprises a series of SA Objectives that are used to test the sustainability performance of the LDP’s components. The SA Objectives had been devised using the SEA Directive topics and informed by the issues and opportunities identified through the baseline data collation. This was supplemented with direction from the key international, national, regional and local planning documents identified in Appendix B of Volume 2.
The objectives are intended to be over-arching and aspirational. A series of guide questions have been developed to support each objective, to ensure only issues that are relevant to the National Park are considered during the assessment. These guide questions have been used to assist the assessment team during consideration of the likely impacts on the achievement of an SA Objective.
Indicators have also been devised for each objective through the characterisation of the baseline of the National Park. This supporting baseline evidence helps to determine how current trends might be influenced by the LDP.
Whilst the SA Framework has been designed in relation to the LDP, it could be used for the assessment of other SNPA plans and programmes.
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The SA Objectives and associated guide questions relevant to the LDP are presented in Table 5-1. It should be noted that the SA Framework has been reviewed and updated since the publication of the original LDP SA Report to take account of updates to the plans, policies and programmes and baseline information Table 5-1 also indicates if baseline data for each of the indicators is currently available and included in the SoPR. Further details about the application of this SA Framework are presented in Section 5.4.
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Table 5-1 SA Framework
SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
1
Manage the effects of climate
change through mitigation and
adaptation
Will it secure reduced emissions of
gases linked to climate change?
MONARCH (Modelling Natural Resource Responses to Climate
Change) outcomes10
Information and data about the
MONARCH programme included in
the SoPR. Information about the MONARCH 3
programme will be included in future
updates of the SoPR.
X
Will it reduce energy consumption? Total domestic energy
consumption per household and
per capita
Housing Eco footprint11 (this
measures the impact of fuel
emissions from direct household
energy use for heat, hot water,
lighting and electrical
appliances as well as the impact
from household maintenance
and from household
construction).
Data included in the SoPR.
7 MONARCH aims to evaluate the impacts of climate change on nature conservation (including wildlife and geomorphological features) in Britain and Ireland. Other
participating areas comprise Hampshire, the Cairngorms and Northern Ireland. The outcomes of this study will gradually help to build our understanding of the complex
interactions between climate change, land cover, species and their habitats.
8 The source of this data is Wales’ Ecological footprint Scenarios to 2020. Stockholm Environment Institute 2008.
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
Will it manage the effects of reducing
availability of non renewable energy
sources?
Ratio of renewable energy
(solar, domestic wind and
hydro) project planning
permissions granted against
planning applications per year.
Data included in the SoPR.
2
Ensure that the location and design
of new development is acceptable
in terms of the potential
consequences of flooding
Will it increase flood risk? Number of planning permissions
granted against EA advice on
flooding.
Data is not currently in the SoPR but
will be gathered in the future.
X
Will it increase the use of
Sustainable Drainage Systems?
Number of Sustainable Urban
Drainage Schemes (SuDS)
implemented on new
developments as a ratio to new
planning permissions granted.
Numbers of planning
applications that use the Design
guidance for Sustainable
Development.
Data is not currently in the SoPR but
will be gathered in the future.
3
Promote the use of sustainable
locally sourced material including
energy
Will it promote the use of recycled
building materials?
Ratio of developments granted
planning permission using
largely locally sourced materials
against those that do not.
Number of developments
granted planning permission
achieving green design awards.
Proportion of aggregates used
from secondary and recycled
sources.
This data is not currently in the
SoPR but will be gathered in the
future.
X
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
Will it promote the use of renewable
energy?
Ratio of renewable energy
(solar, domestic wind and
hydro) project planning
permissions granted against
planning applications per year.
Number of micro-renewable
generation schemes developed.
Data included in the SoPR.
4
Promote the use of sustainable
transport modes and reduce the
impact of cars, road freight and
infrastructure
Will it increase the use of public
transport?
Distribution of major transport
systems
Car ownership statistics per
household
Journey to work by mode
Tourist traffic levels in the
National Park
Average distance travelled to
work
Number of bus services running
in the National Park
Data included in the SoPR.
The number of bus services running
through the National Park including
information about origin and
destination will be included in future
updates of the SoPR.
X
Will it reduce the number of journeys
by private car or road freight?
5
Protect and enhance landscape
character and quality
Will it protect and enhance all
landscape character types?
Location and character of
historic landscape areas.
Quantity of Outstanding and
High Value landscape as
defined under LANDMAP’s five
aspects: cultural, geological,
landscape, habitat, and visual
and sensory.
Data included in the SoPR. X
Will it protect tranquillity? Location and extent of tranquil Data included in the SoPR.
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
areas – monitor change through
time.
Change in the amount of light
pollution in the National Park
6
Protect and enhance air quality Will it protect and enhance air
quality?
Number of Air Quality
Management Areas in the
National Park.
Air pollutant levels in the
National Park – based upon Air
Quality Review and
Assessments for Gwynedd and
Conwy Councils.
Data included in the SoPR. X
7
Conserve the quality of soils
through reducing contamination
and protecting soil function
Will it facilitate the removal of
contamination and promote
remediation?
Number of planning applications
which include site remediation
and area of land remediated.
Not currently included in the SoPR
but will be gathered in the future.
X
Will it protect the soil function and
the most valued soils?
Areas of peat land affected Data about the location of peat and
organic soils should be mapped and
included in future updates of the
SoPR.
Will it encourage new development
to be located on previously
developed land in preference to
Greenfield sites?
Percentage of new
developments granted planning
permission on previously
developed land.
Data included in the SoPR.
8
Safeguard National Park geology
and geomorphology
Will it protect nationally important
geological and geomorphological
sites?
Percentage of Geological
Conservation Review (GCR)
sites that are protected as
SSSIs and whether they are in
Data included in the SoPR. X
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
favourable condition or not.
Will it protect Regionally Important
Geological and Geomorphological
Sites?
Number and distribution of
Regionally Important Geological
and RIGS within the National
Park
Data included in the SoPR.
Will it protect and enhance the Percentage of Geological Some data included in the SoPR.
enjoyment of geological resources? Conservation review (GCR) However, additional information
sites that are protected as needs to be collated in relation to
SSSIs and whether they are in coastal access in future updates.
favourable condition.
Number of visitors to
Carneddau/Glyderau, Cadair
Idris and Snowdon
Length of coastline with access
Location of working mineral
sites in Snowdonia
9
Protect and enhance biodiversity Will it protect the most valued
habitats and species?
Condition/Status of LBAP
species and habitats in
Snowdonia.
Number of H/SAPs
Condition/status of other
European Protected habitats/Species and Red Data
List species.
Distribution of invasive species
across the National Park.
Length of hedgerows and field
Data included in the SoPR.
In future updates to the SoPR, data
will be included regarding the length
of hedgerows and field boundaries
within the National Park.
In future updates of the SoPR, data
will be gathered in relation to:
Progress implementing H/SAPs
Post 2002 otter survey data
Number of Natura 2000 sites
threatened by acid deposition.
X
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
boundaries
Will it facilitate the sustainable
management of key wildlife sites?
Conservation Status of
designated sites (SPA, SAC,
Ramsar, NNR, SSSI, LNR)
Number of sustainable land
management schemes and
details about their effectiveness.
Data included in the SoPR. X
Will it work towards achieving
favourable conservation status of
designated wildlife sites?
Conservation Status of
designated sites (SPA, SAC,
Ramsar, NNR, SSSI, LNR)
Data included in the SoPR.
Will it protect and increase areas of
woodland?
Area of ancient woodland,
ancient semi-natural woodland
and planted ancient woodland in
the National Park.
Data included in the SoPR.
Will it protect the integrity of
European designated sites?
Location and conservation
status of designated sites (SPA,
SAC, Ramsar, SSSI, NNR)
Data included in the SoPR.
10
Value and protect and enhance the
historic environment including built
heritage, archaeology and historic
landscape
Will it protect nationally important
heritage features?
Condition of Scheduled
Monuments (by percentage)
and number of listed buildings
at risk as a percentage of total
number of listed buildings.
Data included in the SoPR. X
Will it protect important archaeology? An appropriate indicator needs
to be developed through liaison
with Gwynedd Archaeological
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
Trust
Will it protect the wider historic
environment and landscape?
Locations and number of
Conservation Areas, Registered
Parks and Gardens. Historic
Landscapes
Data included in the SoPR.
11
Value and protect local diversity
and distinctiveness including
townscape character
Will it protect local diversity and
distinctiveness?
Number and location of
Conservation Areas
Data included in the SoPR. X
Will it protect and enhance
townscape/landscape character and
quality?
Location and character of
historic landscape areas.
Quantity of Outstanding and
High value landscape as
defined under LANDMAP’s five
aspects: cultural, geological,
landscape habitat and visual
and sensory.
Number and location of
Conservation Areas and their
condition.
Number of sustainable land
management schemes
Data included in the SoPR.
Information about the condition of
Conservation Areas in the National Park will be obtained in the future
once Conservation Area
Management Plans have been
developed.
Will it promote well-designed
developments?
Number of new developments
with design statements
Number of new developments
awarded green design awards
Data not currently included in the
SoPR but could be gathered in the
future.
12
Conserve, promote and enhance Will it promote the use of the Welsh Percentage of Welsh Speakers Data included in the SoPR. X
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
Snowdonia’s cultural heritage and
the Welsh language
language? in the National Park and their
distribution
Number of Eisteddfodau held in
the National Park
Number of Welsh language
groups
Information about the number of
Welsh language groups will be
included in future updates.
13
To safeguard the quality and
quantity of water resources
Will it protect and improve water
quality?
Percentage of Snowdonia’s rivers that are classified as Very Good, Good or Fairly Good for chemical and biological quality.
Blue Flag and Green Coast Award beaches in Snowdonia
Acid deposition statistics Eutrophication statistics Main salmon rivers in the National Park Bathing water quality Estuary water quality
Data included in the SoPR. X
Will it ensure the sustainable use of
water resources?
Estimated household water
consumption (litres per head per
day)
Number of metered and
unmetered households
Dyr Cymru estimates of total
leakage
Water abstraction and
discharge statistics
Data included in the SoPR (with the
exception of leakage statistics)
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
14
To promote mechanisms for waste
minimisation, increased re-use and
recycling
Will it increase levels of recycling
and re-use?
Percentage of household and
industrial/commercial waste
recycling.
Data will be included in future
updates of the SoPR
X
Will it promote the up-take of
sustainable waste management
techniques?
Number of sustainable waste
management facilities approved
in the National Park.
Number of bring banks available
in the National Park
Data included in the SoPR.
15
Improve the quantity and quality of
publicly open space
Will it increase the area of publicly
accessible open space?
Hectares of Open Country in the
National Park
Area of Registered Common
Land in the National Park
Data included in the SoPR (with the
exception of data relating to the
length of coastline with access).
X
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
Area of Forestry Common Land
with access
Length of coastline with access
Total access secured under the
Countryside and Rights of Way (CROW) Act
Will it promote access for all through
‘Right to Roam Act’?
Total access secured under the
Countryside and Rights of Way
(CROW) Act
Percentage of PRoW in
Snowdonia that are easy to find.
Length of PRoW and wheelchair
accessible paths in National
Park
Data included in the SoPR.
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
16
To provide housing to meet local
need
Will it increase the availability of
affordable housing?
Affordable dwellings completed
as a percentage of all new
housing completion
House price to income
affordability ratio
Data included in the SoPR. X
Will it provide housing that meets the
physical and social needs of the
community?
Percentage of vacant housing
Percentage of homes unfit for
use
Welsh Index of Multiple
Deprivation (WIMD) – Housing
Deprivation Domain
Number of homeless
Data included in the SoPR.
17
To promote improved access to
local services and amenities for all
Will it improve access to essential
services and facilities?
WIMD – Geographical Access
to Services Deprivation Domain
Data included in the SoPR X
Will it improve access to cultural,
sporting and leisure facilities?
Number of visitors to key
libraries, leisure centres,
museums and tourist attractions
Data included in the SoPR.
18
To promote safe, healthy and
sustainable communities
Will it improve the levels of physical
and mental health for all?
Percentage of persons with
long-term limiting illness in
Snowdonia.
Percentage of persons whose
health was ‘good’ over the last
12 months in Snowdonia
WIMD – Health Deprivation
Domain
Data included in the SoPR. X
Will it increase participation in Number of mountain bike Data included in the SoPR.
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
outdoor pursuits? visitors (this is a key area of
visitor pressure in the National
Park)
Number of visitors to
Carneddau/Glyderau, Cadair
Idris and Snowdon
Will it reduce crime and fear of
crime?
Offences per 1000 population Data included in the SoPR.
19
To promote and facilitate improved
community involvement
Will it develop opportunities for
community involvement for all?
WIMD – Geographical Access
to Services Deprivation Domain
Data included in the SoPR X
Will it promote a sense of belonging
and well-being for all?
Percentage of National Park
residents born in the National
park
Data included in the SoPR.
20
To promote good transport links to
support the local economy
Will it reduce the distance between
homes and jobs?
Average distance travelled to
work.
Data included in the SoPR.
Data regarding the main destinations
individuals commute from will be
collated in the future.
X
Will it reduce traffic congestion? Known areas of traffic
congestion
Data will be included in future
updates of the SoPR.
21
To aid the creation of local
employment opportunities and
businesses related to National Park
purposes
Will it increase the number of Small
and Medium Enterprises (SMEs)?
Number of new business start-
ups in the National Park
Data from Business Eye service
regarding business start-ups will be
included in future updates of the
SoPR.
X
Will it increase employment
opportunities?
Economic activity rates in the
National Park
Availability of employment land
Data included in the SoPR.
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SA Objective Guide Questions Indicator Link to the SoPR Relevant to LDP SA
Will it encourage the update of local
diversification schemes?
Employment by sector
Number of sustainable land
management schemes
Data included in the SoPR.
Will it increase the number of
tourists?
Number of tourist days spent in
the National Park.
Number of people employed in
the tourism industry.
Economic impact of visitor
numbers.
Data included in the SoPR.
Will it reduce economic disparities? Employment by occupation
group.
Average income per household
across the community councils.
Data included in the SoPR.
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5.2.1 Internal Consistency of the SA Objectives
The SA Objectives were tested against each other to identify any potential areas of incompatibility. The full compatibility assessment is presented in Appendix C. No significant areas of inconsistency were identified and no amendments were made to the SA Objectives on the basis of this assessment.
5.3 Assessment of the LDP Strategic Options
The SEA Directive requires that reasonable alternatives to the plan are assessed during a plan’s development (that being the original LDP). Options development and assessment remain unchanged is documented in Section 6 of this SA Report.
The Initial SA Report (2008) documented the assessment of the Spatial Vision, Aims and Principles for the LDP, the draft proposed LDP objectives, the Strategic Options for the LDP and a strategic site proposed at Y Bala. The assessment results were used by the SNPA, as well as the consultation responses to develop the contents of the Deposit Version of the original LDP. The detailed results of this assessment are not presented in this SA Report, rather a summary is provided in appropriate stages of the report to highlight the key recommendations that were made. The Initial SA Report was consulted upon publicly in spring 2008. The Eryri LDP ‘Review Report’ (July 2016) concludes that no changes are required to the Plan strategy, therefore it is not subject to further consultation.
5.4 Assessment of the LDP
5.4.1 Scope of the LDP
The following elements of the Deposit Version of the LDP have been assessed against the SA Framework:
• The Spatial Vision for the Snowdonia National Park (not subject of the Short
Form Review).
• The LDP Objectives (reviewed to take into account the removal of NPMP objectives).
• The LDP Strategic and Development Policies (where applicable).
• The LDP Site Allocations.
5.4.2 Assessment of the Spatial Vision
The Spatial Vision was reviewed against the SA Objectives, and the key strengths, weaknesses and recommendations were identified. Recommendations were made to reduce any adverse impacts that were predicted, or to enhance any opportunities that were identified. These comments are presented in Section 7.3.
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5.4.3 Assessment of the LDP Objectives
The Draft LDP Objectives were assessed in the Initial SA Report and a series of recommendations made to strengthen them from a sustainability perspective. The LDP Objectives were subsequently revised and the final SA Objectives were presented in the Deposit Version of the LDP (2009).
The final LDP Objectives have been assessed against the SA Objectives using a compatibility matrix. Recommendations have been made to offset or alleviate any potential conflicts, or to enhance any opportunities that have been identified.
A summary of the key strengths, weaknesses and recommendations is provided in Section 8 and the full compatibility assessment in Appendix D of Volume 2.
5.4.4 Assessment of the Strategic and Development Policies
The Deposit Version of the LDP (Short Form Revision) comprises both strategic policies and development policies that will be used to inform land-use planning in the National Park. Each of the strategic policies and development policies has been assessed against the SA Objectives (partially revised for the Short Form Revision) to determine their key sustainability strengths and weaknesses. This was achieved through the use of a matrix (an extract of the matrix is presented in Table 5-3) and the matrix completed using the notation in Table 5-2.
When undertaking the assessment, the symbols assigned in the matrix were justified in the commentary box along with any uncertainties and assumptions. The ‘level of uncertainty’ column clarified the confidence of the assessors in terms of the accuracy of the predicted impact being realised. The assessment sought to identify the spatial scale over which impacts would be realised. The three spatial scales considered are:
• Settlements and their vicinity – whether impacts would be realised in the
settlements in the National Park and the immediate environs.
• Wider SNPA area – whether impacts would be realised outside of the settlements in the National Park.
• Outside of SNPA – whether impacts could be realised outside of the SNPA in other authority areas.
The results of the assessment of the strategic policies and the development policies are presented in Appendix E of Volume 2.
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Table 5-2 Assessment Notation Used to Complete the Matrices
Impact Description Symbol
Major Positive Impact
The policy/option contributes to the achievement of all elements of the SA Objective.
++
Positive Impact The policy/option contributes partially to the achievement of the SA Objective but not completely.
+
No Impact/ Neutral
There is no clear relationship between the policy/option and/or the achievement of the SA Objective or the relationship is negligible.
ø
Negative Impact The policy/option detracts from the achievement of some elements of the SA Objective.
-
Major Negative Impact
The policy/option detracts from the achievement of all elements of the SA Objective.
- -
Uncertain impact – more information required
It is not possible to determine the nature of the impact as there may be too many external factors that would influence the appraisal or the impact may depend heavily upon implementation at the local level.
?
Positive and Negative Impacts
The policy/option has a combination of both positive and negative contributions to the achievement of the SA Objective.
+/-
Level of Uncertainty
There is a high degree of uncertainty in the impact prediction
H
There is a medium degree of uncertainty in the impact prediction
M
There is a low degree of uncertainty in the impact prediction L
Permanent Impact
A receptor would experience a permanent change as a result of the option/policy
P
Temporary Impact
A receptor would experience a temporary change as a result of the option policy
T
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Table 5-3 Extract of the Matrix Used to Assess LDP Policies
LDP Policy X
SA Objective
Scale Permanency
Level of
uncertainty
Commentary /
Recommendations
Settlements and
their Vicinity
Wider SNPA Area Region /
Transboundary
S-T
(<5yr)
M-T
(5-
10yr)
L-T
(>10yr)
S-T
(<5yr)
M-T
(5-
10yr)
L-T
(>10yr)
S-T
(<5yr)
M-T
(5-
10yr)
L-T
(>10yr)
Temporary /
Permanent
Low/ Medium
/ High
Manage the effects of climate change through mitigation and adaptation
+ + + ø - - ø ø ø Permanent Low
Explanation of the assessment
In the matrix extract presented above, the likely duration of the impacts is also recorded. Short-term impacts are those that will be realised between one and five years, medium-term impacts will be realised between five and 10 years and long- term impacts will be realised after a period of more than 10 years.
Assessment Assumptions
When undertaking the assessment it was vital to remember that the LDP should be read as a whole and as such, certain policies in the plan which might have the potential to result in adverse sustainability effects that could actually be avoided or mitigated through the application of other relevant policies in the plan.
It was also necessary to consider the purpose of each policy when assessing it. For example, a housing policy, whilst having the potential to result in a variety of environmental effects, is unlikely to consider or include wording to mitigate such effects, rather this would be dealt with in another part of the LDP. For this reason, negative effects might not be recorded when assessing this type of policy, although a cross-reference would be indicated in the assessment commentary to the other relevant policy in the plan.
Whilst the process of assessing each policy is very valuable, as it helps to highlight the key strengths and weaknesses of each policy, all the policies must be considered collectively, emphasising the importance of assessing cumulative effects (refer to Section 5.4.6).
5.4.5 Assessment of Site Allocations
As part of the SA process, the sites allocated in the LDP (Short Form Revision) have also been subject to a high-level review against the SA Objectives. This comprised an appraisal of key site constraints and opportunities. Section 10 presents a summary of the findings and Appendix F of Volume 2 presents the assessment matrix.
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5.4.6 Cumulative / Synergistic Effects
The SEA Directive requires that an assessment is undertaken of cumulative and synergistic effects. Furthermore, whilst each of the constituent parts of the LDP have been assessed against the SA Objectives it is important to understand the overall effects of the plan, as the plan will be implemented as whole, rather than in discrete sections. Section 11 of this report presents an assessment of the likely cumulative and synergistic effects of the LDP. Cumulative and synergistic effects of the LDP could be realised in the following ways:
• A policy could involve numerous geographical implications, for example that
would lead to the provision of multiple individual developments. This could result in incremental impacts on the baseline which either cumulatively or synergistically combine to result in a greater overall impact than on a site by site basis.
• There could be cumulative effects between policies. For example, individual policies could have incremental impacts upon the baseline which when combined with other policies may have cumulative or synergistic impacts, both positive and negative.
• Individual policies may have impacts on a number of receptors which could influence other topics either cumulatively or synergistically. For example, a policy could result in a direct impact upon air quality but it could also lead to increased traffic flows which would also affect air quality.
Cumulative effects assessment is, therefore, best addressed using a receptor based approach, rather than one focussed upon SA Objectives and this has been adopted for the LDP. Further details are presented in Section 11.
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6 Strategic Options Development and Assessment
6.1 Requirements of the SEA Directive
The SEA Directive stipulates activities which must be undertaken as part of the SA. The activities relevant to the consideration of alternatives are outlined in Box 4.
Box 4: SEA Directive Requirements Applicable to Alternatives
The Environment Report should consider ‘reasonable alternatives taking into account the
objectives and the geographical scope of the plan or programme” and give “an outline of the
reasons for selecting the alternatives dealt with’ (Article 5.1 and Annex I(h))
6.2 Initial High-Level Review of First Iteration of Strategic Options Document (unchanged)
The SNPA Strategic Options Document was produced in December 2007, outlining the alternative strategic options for both the LDP and the NPMP.
An initial review of the first draft of the Strategic Options was undertaken by the SA Team in December 2007. This assessment comprised a high-level rapid review of the Strategic Options, in order to identify any showstoppers. The results of this review were used by the plan-makers to inform the second draft of the Strategic Options. Eryri LDP Strategy remains unchanged therefore not subject to consultation.
6.3 Assessment of Second Iteration of Strategic Options Document (unchanged)
The second draft of the Strategic Options Document was then assessed through the SA process in order to determine the preferred option for the LDP, which was subsequently documented in the Initial SA Report (Hyder Report Reference Number: 003-NH51128-NHR-02-F).
6.3.1 ‘Business as Usual’ Scenario
The SEA Directive requires the ‘without plan’ scenario to be considered. The ‘Business as Usual’ Scenario was assessed against the SA Objectives prior to the assessment of the options, as it provided a benchmark against which the performance of the other options could be compared. The ‘Business as Usual’ Scenario assumes a continuation of the existing Eryri Local Development Plan strategy. The ‘Business as Usual’ scenario has been revisited in this SA Report and is presented in Section 9.3.1.
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6.3.2 Strategic Options (unchanged)
The Strategic Options identified for the LDP were assessed against the SA Objectives, to enable the identification of the key strengths and weaknesses of each, potential areas for improvement, and determination of the most sustainable options. The Strategic Options were grouped by topic area e.g. biodiversity, landscape, housing growth and presented alternative means of developing policies and strategy for the LDP.
The assessment was undertaken to assist plan-makers with the identification of the most appropriate and sustainable options. This process is documented in the Initial SA Report, with this SA Report presenting a summary of the key strengths, weaknesses and recommendations used to aid the decision-making process.
Recommendations were made to offset or alleviate any adverse impacts that were predicted, or to enhance any opportunities that were identified. The assessment sought to identify the spatial scale over which impacts would be realised. Three spatial scales were considered:
• Settlements and their vicinity – whether impacts would be realised in the
settlements in the National Park and the immediate environs.
• Wider SNPA area – whether impacts would be realised outside of the settlements in the National Park.
• Outside of SNPA – whether impacts could be realised outside of the SNPA in other authority areas.
The full results of this assessment were presented in the Initial SA Report. Whilst the detailed matrices have not been produced in this SA Report, a summary is provided in Table 6-1 which identifies each option assessed, a summary of the overall comments / recommendations made for option(s) to be taken forward into the preferred strategy and also a summary of the consultation comments received in relation to each option.
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Table 6-1 Summary of the Assessment of the LDP Strategic Options (UNCHANGED)
LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
Landscape Options
L1c – Continue to develop programmes
aimed at improving the current landscape
through practical interventions, e.g.
Rhaglen Tir Eryri, control of invasive weeds.
It was considered that Option L1c would generate overall
beneficial impacts upon a range of environmental, social and
economic objectives, both within and around settlements. It was
not considered likely to have any significant weaknesses.
Option L1e would offer very strong protection for the high quality
environment that is integral to the National Park, by ensuring that a
degree of control is maintained. It was considered this option had
potential weaknesses in terms of limiting housing provision.
It was recommended that both options were taken forward for
inclusion within the LDP Preferred Strategy.
CCW suggested that the wording in Option L1c ‘control of invasive
weeds’ should be clarified and qualified so as to ensure that such
control does not damage or compromise indigenous biodiversity
and soils.
L1e – Designate ‘green wedges’ between
settlements to avoid coalescence of
settlements.
Biodiversity Options
B1a – Pursue targets for individual species in accordance with the Eryri Local Biodiversity Action Plan. Develop policies and programmes to
increase levels of biodiversity significantly
through Snowdonia, to reduce the negative
impact of invasive weeds and to encourage
community involvement in relevant
programmes
All of these options address very different aspects of the National
Park’s biodiversity resources.
It was recommended all three options were taken forward into the
Preferred Strategy. Option B1b offers a high degree of protection
to the biodiversity resources of the National Park, in particular
internationally designated sites. Options B1a and B1c both seek
to ensure the protection and enhancement of the National Park’s
biodiversity in the long-term.
CCW suggested that the wording in Option B1a ‘to reduce the
negative impact of invasive weeds’ should be clarified and
qualified so as to ensure that such control does not damage or
compromise indigenous biodiversity and soils.
CCW recommended that Option B1b should be broadened to
incorporate ‘characteristic biodiversity’ and the environmental /
ecological functions and facets that support biodiversity.
The role and importance of soil resource in its own right were also
highlighted.
CCW recommended that Option B1c should be strengthened to
include reference to water in terms of quantity / availability in terms
B1b – Give the highest priority to the
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
conservation and enhancement of the
characteristic biodiversity of Snowdonia.
This gives specific, yet not exclusive
protection to habitats and species
designated under European legislation and
as such affords protection to the integrity of
those sites listed within the Natura 2000
network.
of potable supply, wastewater treatment and/or in terms of
ecological function.
B1c – Progress improvements to water, soil
and air quality with partner organisations
and identify any future changes that may
occur through climate change (recognising
the vital role of all three elements in
reduction and mitigation).
Land Management Options
LM1a – Support agricultural and forestry
diversification only where this is consistent
with National Park purposes, allowing
sensitively designed and sited
development, and encouraging
development which helps to conserve the
National Park’s special qualities or provides
for their understanding or enjoyment.
This option would help to protect the natural and historic
environment by supporting diversification where it is appropriate
and consistent with National Park purposes. The potential for
biodiversity benefits was also identified, e.g. a reduction in grazing
pressures could help to encourage the natural restoration of some
species that have historically been affected by certain types of
land management. There could also be economic benefits
generated by this option.
It was recommended that the option could be expanded upon and
focus more upon the need for a holistic land management
approach.
CCW would have liked to have seen more reference made to the
desirability of protecting peat and organic soils, as the
development of peat/organic soils (including agricultural and
forestry development) is rarely ever appropriate.
Cultural Heritage Options
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
CH1a – Take into account the desirability of
conserving the cultural traditions, practices
and artefacts of Snowdonia in determining
planning applications and formulating
programmes.
All options were recognised as having the potential to benefit the
historic environment with the potential for indirect benefits for
landscape and townscape.
From a sustainability perspective it was recommended that a
combination of options should be taken forward to ensure all
elements of the historic environment are covered in the Preferred
Strategy.
Options CH1a and CH1b would need to be combined with other
options to provide a more holistic approach to the protection of
cultural heritage resources as they address discrete elements of
the historic environment.
It was considered that Option CH1c should be strengthened to be
more proactive and provide protection at a local level in addition to
Snowdonia as a whole.
Option CH1d should be combined with other options and
strengthened in order to provide more focus on protection.
Although Option CH1e is considerably more comprehensive and
pro-active, it has risks associated with the conversion of buildings
Cadw commented that the wording ‘Take into account the
desirability of conserving…’ is not appropriate when dealing with
the historic environment as a whole.
CCW supported the assessment that CH1b has the potential to
generate negative impacts upon biodiversity. CCW recommended
the need to consider protected species outwith designated sites in
their own right, and in the context of their relevance to the
population integrity / favourable conservation status of European
sites.
CCW supported the assessment recommendations that Options
CH1c and CH1d require strengthening. CCW recommended
clarifying whether ‘historic environment’ in CH1c includes common
land.
CH1b – Treat vernacular barns and other
buildings as important features in their own
right, and encourage sensitive re-use of
redundant traditional farm and other
buildings to ensure their conservation.
CH1c – Preserve the historic environment
of Snowdonia and protect it from intrusion
or dilution by change and development,
primarily because Snowdonia’s cultural
heritage is a cornerstone of its identity.
CH1d – In conserving the historic
environment and the landscape of
Snowdonia, recognise that new, innovative,
high quality design, drawing on traditional or
locally sourced materials may be
appropriate.
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
CH1e – Take a pro-active approach to the conservation of the historic environment of Snowdonia through:
1) Encouraging appreciation of its value and particular qualities
2) Strict control of development which may affect it, having regard to its quality, rarity and contribution to Snowdonia’s character
3) Promoting programmes and encouraging development which secures its future and complements it. Lobby for additional funding to support the effective application of Conservation Area status and regeneration initiatives founded on cultural heritage
4) Identify and promote sensitive techniques for the adaptation of buildings and settlements to meet contemporary needs.
Population, Household Growth and Dwelling Requirement – Levels of Growth Options
G1a – The apportionment of the Welsh
Assembly Government’s North Wales
regional household projections proposed an
annual dwelling requirement for the
Snowdonia National Park of 40 dwellings
per year.
A total of 600 dwellings will be required over the 15 year plan period. (85 net).
It was very difficult for the SA alone to identify a preferred option
as the selection of this option needs to be based upon household
growth studies and housing need assessments. From a pure
environmental and Sanford Principle perspective, it was
considered that a lower growth option would be most appropriate
as this would limit the amount of development that occurs in the
National Park. It was therefore recommended that option G1a
No consultation comments were received in relation to this issue.
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
G1b – Annual household growth rate of 0.4
per cent = 45 dwellings per year.
A total of 673 dwellings will be required over
15 year plan period. (158 net).
should be taken forward.
Conversely, it was recognised that there has been a decrease in
the household size in the National Park and that more people are
choosing to live alone which will increase the demand for more
housing. However, this need has to be balanced against the need
to protect the Special Qualities of the National Park.
G1c – Annual household growth rate of
0.45 per cent = 50 dwellings per year.
A total of 757 dwellings will be required over
15 year plan period. (242 net).
G1d – 1991 to 2001 census – an annual
rate of household growth of 0.49 per cent =
requirement for 55 dwellings per year.
A total of 824 dwellings will be required over
15 year plan period. (309 net).
Affordable Housing Target Options
AH1a – Provide an authority wide target It was recommended that Option AH1b should be taken forward as No specific consultation comments were received in relation to this
based on Gwynedd and Conwy Housing this is the only option which would be based on sound evidence. suite of options.
Needs Assessment Affordable housing emerged as one of the key issues affecting
AH1b – Provide an authority wide target
based on results from the Local Housing
Market Assessment (LHMA)
communities in the National Park and so it was considered
imperative that the development of policy is based upon sound
information that will enable this problem to be addressed.
AH1c – Provide a firm authority wide target
based on Rural Housing Enabler (RHE)
local housing needs survey
Settlement Strategy Options
SS1a – Should remain the same as that Continuation of SS1a could potentially protect some of the smaller CCW agreed with the recommendation that Option SS1b is taken
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
currently set out in the Eryri Local Plan. villages and hamlets in the National Park from development,
thereby helping to preserve their character and quality. However,
there are existing issues associated with the highly dispersed
settlement pattern in the National Park and a review of the strategy
may be appropriate to enable a thorough review of facilities in
each settlement.
It was recommended that option SS1b be taken forward, as this is
the most likely to lead to more sustainable decision-making in
relation to the location of new development. However, it was
considered that this strategy would need to be supported by
appropriate biodiversity and townscape/landscape policies to
ensure that development is appropriately controlled.
forward, subject to the support and/or conditions established in
appropriate environmental, landscape and service / infrastructure
policies being strictly adhered to.
The Environment Agency recommended that the final sentence of
the overall comments / recommendations should be changed to
the following:
‘However, this strategy would need to be supported by appropriate
biodiversity, flood risk and townscape/landscape policies to
ensure that development is appropriately controlled’.
SS1b – Re-examine settlement selection
based on criteria such as services, facilities,
accessibility to public transport, education
and population.
Housing Development Boundary Options
HDB1a – Keep the housing development
boundaries predominantly the same as
those in the Eryri Local Plan.
Review after 4 years.
It was considered that although Option HDB1a could potentially
constrain the provision of affordable housing across the National
Park, it would provide a higher degree of protection to the
environment by maintaining the housing development boundaries
in their current form. In addition there would be flexibility to review
the option after four years, thereby presenting an opportunity to
rectify or review any issues before they become established as
long-term problems.
It was considered that the other options would pose significant
risks to settlement character and to the environment, surrounding
the settlements.
CCW agreed with the assessment comments in relation to HDB1a.
The EA strongly agreed with the conclusion that Option HDB1a
should be taken forward.
HDB1b – Review the housing development
boundaries around towns and villages to
accommodate allocated sites and minor
additional windfall sites. No development
boundary around hamlets.
HDB1c – Allocate sites but dispense with
housing development boundaries
altogether. Replace with a criteria based
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
approach to manage the release of small
windfall sites.
Housing Development Criteria Options
HC1a – Continuation of Eryri Local Plan
Policies
It was considered difficult to distinguish between all of the options,
as many performed in a similar way against the SA Objectives.
Options HC1b, HC1c, HC1d would all result in the risk of losing
greenfield land. It was recommended that the release of
greenfield land needs to be very carefully controlled to reduce the
risk of cumulative adverse impacts occurring in the long-term
through the gradual erosion of these areas on the fringes of
settlements.
No single option emerged as being significantly better than any
other.
CCW agreed with the overall recommendations for this suite of
options.
HC1b – Local Service Centres. Windfall
sites: open market allowed within
development boundaries. Where evidence
of need is shown a proportion of such
development shall be Affordable Housing
for Local Needs (AHLN). Allocated Strategic
Site: Y Bala: Land to be released in
phases. A proportion of the development
shall be affordable housing for local needs.
Local Service Villages. Windfall sites: Open
Market. Where evidence of need is shown
a proportion of such development shall be
affordable. Where evidence of need some
sites allocated for affordable housing for
local needs only (100).
Smaller Villages. Windfall sites: open
market allowed where evidence of need is
shown a proportion of such development
shall be affordable housing for local needs.
Where evidence of need some sites
allocated for AHLN only (100%). Adjoining
village boundary small scale affordable
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
housing for local needs.
Hamlets: No settlement boundary. Single
affordable housing for local needs 2/3 in
plan period.
HC1c – Local Service Centres and Local
Service Villages. Same as 5b i.e. open
market with percentage affordable housing
for local needs.
Smaller Villages: Where evidence of need
is shown AHLN only (mix of intermediate
and social rented)
Adjoining village boundary small scale
100% affordable housing for local needs.
Hamlets: Same as 5b.
HC1d – Local Service Centres. Windfall
sites: Open market allowed within
development boundaries. Where evidence
of need is shown a proportion of such
development shall be AHLN. Allocated
Strategic Site: Y Bala: Land to be released
in phases. A proportion of the development
shall be affordable housing for local needs.
Local Service Villages and Smaller Villages.
Where evidence of need is shown
affordable housing for local needs only (mix
of intermediate and social rented). Adjoining
village boundary: 100% small scale
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
affordable housing for local needs.
Hamlets. No settlement boundary. Single
units for affordable housing for local needs 2/3 across 15 year plan period.
Housing Conversions Options
HCC1a – Consider the conversion of
suitable traditional buildings outside the
housing development boundary for
residential purposes for affordable housing
for local needs. Include a set of stringent
development control criteria.
If an agricultural worker’s dwelling is no
longer required, dwelling should be
changed to AHLN.
If holiday accommodation is no longer
required unit should be changed to
affordable housing for local needs.
It was considered there are some sustainability strengths
associated with this option, but there are also a number of
potential weaknesses, particularly from an environmental
perspective.
It was therefore recommended that a strong suite of supporting
policies is developed in the LDP to ensure that the conversions are
appropriate and do not result in the cumulative loss of important
environmental resources e.g. protected species.
CCW highlighted the potential need for such options to be
considered in the HRA Screening Process in accordance with the
requirements of the Habitats Directive.
Housing Size and Type Options
HS1a – Continue Eryri Local Plan definition for affordable housing size (maximum floor
area 112m2).
Performance against the SA Objectives was very similar for all of
these options. It was considered that Option HS1b would offer the
greatest housing affordability benefits as it should ensure diversity
of the housing stock and the provision of a sufficient number of
smaller homes. Option HS1d would offer similar benefits by
addressing housing affordability on a case by case basis.
Option HS1c could lead to housing affordability issues for existing
home owners, therefore it was not recommended that this option is
No specific consultation comments were received in relation to this
suite of options.
HS1b – Restrict the size of all new build
affordable housing for local needs in
accordance with a sliding scale for different
dwelling types (with e.g. a maximum of 100
square metres for a three bedroomed
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
house). pursued.
HS1c – Prevent the extensions of
moderately sized houses.
HS1d – Negotiate appropriate mix of
dwelling types for new mixed development
i.e. intermediate and social rented.
Housing, Size and Type – Partnership Delivery Options
HPD1a – Continue to work with
neighbouring authorities, housing
associations and relevant organisations to
help identify local needs and help deliver to
met the needs, including support for the
Gwynedd Rural Housing Enabler and the
Conwy and Denbighshire RHE. Working in
partnership with partners such as Forestry
Commission.
It was considered that Option HPD1a had the potential to achieve
the greatest sustainability benefits, as it promoted a holistic
partnership approach. This option as well as involving housing
associations would also cast the net wider to organisations with
other interests and so should help to ensure that environmental
issues are taken into consideration when trying to deliver
affordable housing. For example, impacts upon landscape,
heritage and townscape might be more likely to be considered with
this option, compared to option HPD1b.
No specific consultation comments were received in relation to this
suite of options.
HPd1b – Encourage Community Land
trusts and co-operative self-build to address
local affordability issues
Community and Language Options
CL1b – Prioritise consideration of the
language as a material consideration in
decision making throughout the National
Park.
Although Option CL1c was considered to be the most proactive
option, it was recommended that both options were taken forward
to ensure that Welsh language considerations are central to
decision-making in the National Park.
No specific consultation comments were received in relation to this
suite of options.
CL1c – Focus on positive measures to
maintain sustainable Welsh speaking
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
communities by: providing housing and
employment for local people; ensuring that
there is adequate provision of Welsh
medium education; and supporting linguistic
integration initiatives for incomers.
Economic Options
E1a – Support business development
consistent with the National Park purposes,
therefore, encouraging: sensitively
designed and sited development;
development which helps conserve the
National Park’s special qualities or provides
for their understanding or enjoyment;
retention of existing jobs and premises;
growth of new jobs through development of
existing businesses; and upskilling.
Option E1a was considered to be the most holistic, offering the
greatest sustainability benefits in the long-term. The protection of
the environment is imperative and new employment development
should not compromise the quality of the environment.
It was considered that Options E1b and E1c have both strengths
and weaknesses. As the transport links are more advanced in
Dolgellau and Y Bala, Option E1b could be seen as more
sustainable. However, there are uncertainties about the
environmental impacts of these options as the precise location of
new employment development is unknown.
Option E1d led to uncertain impacts being recorded against many
of the SA Objectives, as it solely focuses upon establishing
mechanisms to support the local economy. It was recommended
that high quality employment opportunities should be delivered
where possible to try and retain young people in the National Park.
Whilst these options focus upon new employment opportunities, it
was considered essential for the LDP to continue to provide
support to the agricultural industry which is a vital component of
the National Park’s economy.
CCW supported the assessment’s recommendation that Option
E1a appears to be the most benign. CCW recommended
clarification in relation to which option(s) should be taken forward
into the Preferred Strategy.
The EA disagreed with the assessment of Option E1b against SA
Objective 12, as there are substantial areas of Y Bala and
Dolgallau within flood risk zones.
E1b – Seek to designate appropriate
employment land for commerce only within
local service centres (Dolgellau, Y Bala).
E1c – Seek to designate employment land
dispersed across local service centres and
local service towns and villages.
E1d – Seek to partner commitment to
develop proven mechanisms to support the
local economy in the long-term giving full
consideration to the emerging Convergence
Funding Programme
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
Tourism Development Options
TD1a – Secure a spatial approach to the
development of small scale, sustainable
tourism, identifying locations where
development might be encouraged and
locations where landscape, wildlife or
cultural considerations require constraint
It was considered that options TD1a and TD1b are relatively
similar, both seeking to ensure protection of the natural
environment.
Option TD1c was considered not to be consistent with the National
Park purposes, and does not seek to ensure protection of the
natural environment.
It was considered that Option TD1e is not sufficiently
comprehensive, as it only relates to temporary tourism
accommodation developments.
As each option is very specific, it was recommended that a
combination of all options should be carried forward. It is essential
that local needs and the local economy are considered before any
further tourist development occurs. The tourism strategy must
focus on improving the image, improving skills, increasing
economic return, recognising the need for constraint in some
areas and encouragement in others, and the need for greater
involvement of local people when developing tourism
opportunities.
A number of comments were provided in relation to the tourism
options and the need ensure that the potential environmental
effects of certain types of development are understood. Any
tourism development that could compromise or adversely affect
the Special Qualities of the National Park should not be
considered sustainable.
TD1b – Foster small-scale tourism based
projects with added value, founded on
‘National Park’ assets and sympathetic to
National Park purposes.
TD1c – Allow a small number of high quality
developments within the National Park, with
strong links to the local economy.
TD1d – Encourage relatively large scale
high quality developments to locations
outside the National Park, where public
transport infrastructure is or can be made
available, developing strong links to the
local economy.
TD1e – Seek to develop appropriately
sized, innovative short term and non-
permanent accommodation based on the
principles of sustainable tourism in selected
locations.
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
Recreation and Access – Motorised Sport Options
RA1a – Restrict all motorised sports due to
their effect on the National Park’s tranquillity
and environment
It was recommended that Option RA1a was pursued, as it
specifically ensures the protection of the tranquillity and
environment of the National Park. However, due to the risk with
this option that individuals would continue to undertake such
activities even if a restriction was imposed, it was recommended
that the restriction would need to be carefully controlled.
CCW supported the recommendations.
RA1b – Develop managed and designated
sites for people to enjoy motorised
recreation with attempts made to gain
economic benefits for local communities
Energy – Harnessing Renewable Energy Generation in Buildings Options
Ey2a – All buildings are designed to enable
retrofitting of integrated renewables or 10%
of the development’s energy needs are
provided through renewable energy.
It was considered that Option Ey2a would be difficult to implement
and therefore its full potential may not be realised. Option Ey2b
and Ey2c would generate essentially the same impacts as option
Ey2a.
It was considered Option Ey2d should be carried forward as it
encourages the use of renewable energy, whilst ensuring the
protection of the landscape.
It was recommended that a combination of all options should be
taken forward. It was considered beneficial to have both national
and local targets, with a long-term approach. For example, there
could be a target for adaptation to renewable energy use in the
future, and encouraged use, where possible in the interim. There
also needs to be an emphasis upon protecting
landscape/townscape.
CCW supported the assessment’s recommendations. However,
they recommended that the assessment should consider the
potential effects of energy microgeneration on biodiversity, soils
and water resources.
Ey2b – All developments over 60m2 will be
required to incorporate renewable energy
technologies to provide at least 10% of
predicted requirements.
Ey2c – Allow national policy and building
regulations to dictate the provision or
renewable energy produced from buildings.
Ey2d – Encourage micro-generation from
renewable energy sources, but retain firm
control over siting and design to minimise
effects on the landscape.
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
Coast and Marine Options
CM1a – Continue to protect Undeveloped
Coastline from inappropriate development.
It was considered that each option is relatively specific in its aims,
each dealing with certain aspects of coastal management. It was
therefore recommended that a combination of options be carried
forward.
Potential impacts as a result of option CM1e were considered to
be uncertain as details of future plans (e.g. a Marine Spatial Plan)
were not known at the time of the assessment.
Although option CM1b could be taken forward as a separate
climate change option, it was recommended that further
consideration is needed on the potential for sea-level changes and
the impact of storm incidents on the coastline, and therefore cross-
reference to the Shoreline Management Plans should be provided
within the option taken forward.
CCW recommended that a definition of ‘undeveloped coastline’ is
required. They agreed that a combination of options should be
taken forward.
The EA agreed with the recommendation to take Option CM1b
forward, as a separate climate change option.
CM1b – Ensure that any development on
the coastline is adaptable to, or can mitigate
rising sea levels and increase in the
frequency of storms.
CM1c – Work with partner organisations to
ensure that the coastline is managed in a
holistic and sustainable manner through
Integrated Coastal Zone Management.
CM1d – Work in partnership organisations
to improve access to the coastline.
CM1e – Prepare to undertake any
additional requirements following the
introduction of the Marine Bill, for example
the preparation of a Marine Spatial Plan.
Transport and Communications – Traffic Reduction and Congestion Options
TC1d – Continue to encourage road
improvements.
It was recommended that option TC1e should be taken forward, as
it seeks to allow road improvements whilst ensuring protection of
the surrounding environment. Whilst Option TC1d would help to
improve accessibility in the National Park, it fails to highlight the
need for high quality environmental design.
It was considered that stronger emphasis was required in terms of
the integration of public transport and the provision of such
CWW agreed with the recommendation to take Option TC1e
forward. They recommended clarification as to how this option
would be enabled in the context of Trunk Roads (e.g. A470).
TC1e – Support sympathetic road
improvements only where they meet
environmental and landscape constraints,
contribute significantly to economic and / or
safety objectives, and include mitigation
measures to ensure high quality
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LDP Strategic Option Summary of Overall Comments / Recommendations Consultation Comments Received
environmental design. services to local villages. There is a need to promote public
transport use for tourism both into and within the National Park
(including the Welsh Highland Railway), promote minor roads as
leisure networks, and secure facilities for walkers and cyclists as
part of highway improvements.
Based upon the SA assessment results and the feedback from the consultation process, the SNPA proceeded to develop the Deposit Version of the LDP, which focussed upon developing specific strategic policies and development policies for each topic area.
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7 Compatibility of the Vision and the SA Objectives
7.1 Introduction
The Vision for Snowdonia has been reviewed to determine its compatibility with the SA Objectives. The results of this assessment are presented in the following sections.
7.2 Recommendations from the Initial SA Report
The Vision presented in the SNPA Strategic Options Document was assessed for its broad compatibility against the SA Objectives. The assessment identified that the vision and the SA Objectives were largely compatible. The only recommendations were for the vision to focus more upon enhancement, rather than merely protection and for long-term issues and threats like climate change to be cited explicitly.
Following the receipt of consultation comments the Vision for Snowdonia has been revised.
7.3 The Vision for Snowdonia
The Vision for Snowdonia included in the Deposit Version of the LDP is presented in Box 5.
Box 5: The Vision for Snowdonia
In 2035 Snowdonia will continue to be a protected landscape, rich in wildlife and with a
strong sense of place, providing inspiration within and beyond its boundary.
The purposes of the Snowdonia National Park will be delivered in a diverse and
prospering economy, with thriving bilingual and inclusive communities, which will
be models of sustainability, and continue to be founded on strong relationships with
high quality landscapes and rich cultural traditions.
Partnerships between many different players will have shown that by working together,
we can achieve so much more.
7.3.1 Sustainability Comments
The Vision commits to ensuring that both the landscape and biodiversity resources are protected and this positively fulfils many of the SA Objectives relating to the protection of the natural environment. However, enhancement is not explicitly mentioned in the Vision.
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The Vision’s focus upon delivering a diverse and prosperous economy positively fulfils the SA Objectives relating to the creation of a sustainable economy and in the long-term could benefit the skills base of the National Park. There is also an emphasis placed upon the need for a ‘sense of place’ and the establishment of bilingual and inclusive communities. These elements of the Vision, therefore, positively fulfil those SA Objectives addressing accessibility to amenities and facilities, sustainable communities and community involvement. A strong sense of place is essential to creating feelings of ‘belonging’ and ‘ownership’ amongst communities. There is a large number of small settlements in the National Park and it will be essential for development within them to be appropriate to the settlement size and the facilities available, whilst ensuring that they are prosperous enough to encourage residents (particularly younger sectors of the population) to continue living in the National Park. The emphasis placed upon culture and the Welsh language is also essential to meet the SA Objectives relating to the conservation, promotion and enhancement of Snowdonia’s cultural heritage and the Welsh language and should benefit community spirit and help to foster a good understanding of the National Park’s heritage in the long-term.
The role of partnership working is a key strength and demonstrates that achieving the Vision is dependent upon the work of others and should help to encourage more active involvement in National Park issues in the future.
7.3.2 Recommendations
Following the assessment of the Vision within the Deposit Version LDP, the amendments below should be made to strengthen it from a sustainability perspective:
• There should be a clear commitment to enhancement, rather than just
protection.
• Reference should be made to the long-term threat of climate change and for the need for appropriate mitigation and adaptation to protect the character and quality of the National Park.
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8 Compatibility of the SA Objectives and LDP Objectives
8.1 Introduction
In the Initial SA Report, the draft LDP Objectives were tested against the SA Objectives to determine their compatibility. The recommendations from this assessment are summarised in Section 8.2.
Following the receipt of consultation responses the draft LDP Objectives were reviewed and a final set of LDP Objectives developed for inclusion in the Deposit Version of the LDP. Section 8.3 presents an assessment of the compatibility of the final LDP Objectives against the SA Objectives.
8.2 Recommendations from the Initial SA Report
No significant conflicts were identified through the compatibility assessment in the Initial SA Report. However, some areas of uncertainly were noted, as it was unknown how the objectives would be translated into policy wording.
The following recommendations were proposed in the Initial SA Report while being mindful of the Sanford Principle:
• LDP Objective 2 ‘Encourage development on previously developed land in
preference to the development of greenfield land’ should be extended to include provisions that ensure the protection of brownfield sites that are important for biodiversity.
• LDP Objective 6 ‘Encourage, where appropriate the use of the National Park’s natural resources for small scale renewable energy generating schemes to meet local needs’ should be re-worded to ensure that renewable energy is encouraged only in accordance with the purposes of the National Park, particularly environmental protection.
• LDP Objective 8 ‘Support development which meets the housing needs of the local community, having special regard to affordable housing for local people’ should be re-worded so that it supports this type of development where appropriate, i.e. with consideration of the potential impacts upon the character of the surrounding environment.
• LDP Objective 9 ‘Encourage new development to locations with reasonable access to community services and facilities and public transport’ should ensure that such development is encouraged in accordance with the purposes of the National Park.
• LDP Objective 11 ‘Encourage sustainable economic growth by supporting a rural economy that provides employment opportunities and maintains thriving communities’ could be re-worded to ensure economic development does not conflict with the Special Qualities of the National Park.
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8.3 The Final LDP Objectives and the Results of the Assessment
Table 8-1 presents the Final LDP Objectives presented in the Deposit Version of the LDP and the results of the Compatibility Assessment. Although no significant conflicts were identified, some areas of uncertainty were noted, as the effects of the LDP Objectives would depend upon the specific wording of policies used to implement them. Therefore, a precautionary approach was adopted in the compatibility assessment. However, as later stages of this report demonstrate, (refer to Section 9), the wording of many of the policies is suitably stringent such that many of these areas of uncertainty, in reality would not exist. Furthermore, the suite of LDP objectives is inter-related and should not really be read in isolation, as another LDP Objective could actually help to mitigate any risks posed by some of the other objectives in isolation.
Table 8-1 The LDP Objectives and their Compatibility with the SA Objectives
LDP Objective Potential Areas of Uncertainty or Conflict with the SA Objective
1 - Ensure that all development is
undertaken in a way that respects
designated nature conservation sites
and ensures the protection and
enhancement of the diversity and
abundance of wildlife habitats and
protected species
Uncertainty about compatibility with SA Objective 3 ‘Promote the
use of sustainable locally sourced material including energy’
Micro-generation and renewable energy schemes could affect
nature conservation sites and biodiversity resources depending
upon how such schemes are implemented.
Uncertainty about compatibility with SA Objective 19 ‘To provide
housing to meet local need’ as dependent upon the location and
type of housing development there could be adverse effects on
biodiversity resources.
2 - To manage the effects of climate
change through mitigation and
adaptation including reductions in
greenhouse gas emissions, reduction
in energy consumption and acceptable
development planning with regard to
flood risk
No areas of uncertainty or incompatibility identified.
3 - Encourage where appropriate the
use of the National Park’s natural
resources for small scale renewable
energy power generating schemes to
meet local needs without harm to the
Special Qualities of the area
No areas of uncertainty or incompatibility identified, as the LDP
objective specifically states that small-scale renewable energy
generation should not harm the Special Qualities of the National
Park and so this objective should be compatible with the SA
objectives addressing environmental issues.
4 - Conserve and enhance the
National Park’s natural resources
including its geodiversity and water,
soil, air quality.
Uncertainty about compatibility with SA Objective 3 ‘Promote the
use of sustainable locally sourced material including energy’. For
example, micro-generation and renewable energy schemes could
affect water, soil and air quality depending upon how such
schemes are implemented.
Uncertainty about compatibility with SA Objective 19 ‘To provide
housing to meet local need’ as dependent upon the location and
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LDP Objective Potential Areas of Uncertainty or Conflict with the SA Objective
type of housing development there could be adverse effects on
geodiversity, water, soil and air quality (although effects on the
latter are considered far less likely).
5 - Protect and enhance the natural
beauty of the National Park’s
landscape
Uncertainty about how SA Objective 3 ‘Promote the use of
sustainable locally sourced material including energy’ might be
affected. For example, micro-generation and renewable energy
schemes could affect landscape resources depending upon how
such schemes are implemented.
Uncertainty about compatibility with SA Objective 19 ‘To provide
housing to meet local need’ as dependent upon the location and
type of housing development there could be adverse effects on
landscape quality.
6 - Ensure the provision of
sustainable, integrated waste
management and recycling facilities in
accordance with the Regional Waste
Plan
No areas of uncertainty or incompatibility identified as the LDP
Objective states that the provision of such facilities should be
sustainable and so should be consistent with the SA Objectives.
7 - To understand, value, protect and
enhance the area’s historic
environment including archaeological
remains and historical landscapes,
and to promote development that
enhances Snowdonia’s built heritage
and townscape
Uncertainty about how SA Objective 3 ‘Promote the use of
sustainable locally sourced material including energy’ might be
affected. For example, micro-generation and renewable energy
schemes could affect built heritage resources depending upon
how such schemes are implemented.
Uncertainty about compatibility with SA Objective 19 ‘To provide
housing to meet local need’ as dependent upon the location and
type of housing development there could be adverse effects on the
historic environment and the townscape.
8 - To protect and enhance the natural
beauty of the National Park’s
landscape by ensuring that
development meets good sustainable
design standards and respects the
Special Qualities of the area
Uncertainty about how SA Objective 3 ‘Promote the use of
sustainable locally sourced material including energy’ might be
affected. For example, micro-generation and renewable energy
schemes could affect the natural beauty of the National Park
depending upon how they are developed.
Uncertainty about compatibility with SA Objective 19 ‘To provide
housing to meet local need’ as dependent upon the location and
type of housing development there could be adverse effects on the
landscape.
9 - Support development which meets
the housing needs of the local
community, having special regard to
affordable housing for local people
Uncertainty about how SA Objective 5 ‘Protect and enhance
landscape character and quality’, SA Objective 6 ‘Protect and
enhance air quality’, SA Objective 7 ‘Conserve and enhance the
quality of soils through reducing contamination and protecting soil
function’, SA Objective 9 ‘Protect and enhance biodiversity’, SA
Objective 10 ‘Value and protect the historic environment including
built heritage, archaeology and historic landscape’ and SA
Objective 11 ‘Value and protect local diversity and distinctiveness
including townscape character’ would be affected, as the precise
location and design of new housing is not known.
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LDP Objective Potential Areas of Uncertainty or Conflict with the SA Objective
10 - Support the provision and
retention of key community facilities
and services throughout the area.
No areas of uncertainty or incompatibility identified.
11 - Encourage community
recreational facilities where they meet
local needs and do not conflict with
the Special Qualities of the park.
No areas of uncertainty or incompatibility have been identified as
the LDP Objective states that the community and recreational
facilities should safeguard the Special Qualities of the National
Park and so it is assumed that it would be compatible with a
number of SA Objectives addressing environmental issues.
12 - Promote measures to encourage
development that supports the
vibrancy of the Welsh language and to
protect communities from
developments that are insensitive to
the impact on the Welsh language.
The Local Development Plan housing requirements are modest and the allocation of individual sites will not lead to large population increases or decreases that might affect the balance of English / Welsh speakers. It is concluded therefore that the overall impact on linguistic patterns will be neutral and that other external factors will have a greater influence on future Welsh language usage in the community.
13 - Encourage sustainable economic
growth by supporting a rural economy
that provides employment
opportunities and maintains thriving
communities.
Uncertainty about compatibility with SA Objective 5 ‘Protect and
enhance landscape character and quality’, SA Objective 6 ‘Protect
and enhance air quality’, SA Objective 7 ‘Conserve and enhance
the quality of soils through reducing contamination and protecting
soil function’, SA Objective 9 ‘Protect and enhance biodiversity’,
SA Objective 13 ‘To safeguard the quality and quantity of water
resources’. This uncertainty exists because it is not known what
type of development might occur in rural locations. For example,
some rural diversification opportunities could adversely affect
environmental resources.
14 - Support tourism and recreation
activity which maximise local
economic benefits, minimise
environmental impact and safeguard
the Special Qualities of the National
Park.
No areas of uncertainty or incompatibility have been identified as
the LDP Objective states that the tourism and recreation should
safeguard the Special Qualities of the National Park and so it is
assumed that it would be compatible with a number of SA
Objectives addressing environmental issues.
15 - Encourage new development to
locations that reduce the need to
travel with reasonable access to
community services and facilities and
sustainable modes of transport.
Uncertainty about compatibility with SA Objective 11 ‘Value and
protect local diversity and distinctiveness including townscape
character’. This has been identified as the main services in the
National Park are situated in certain key settlements and whilst
focussing new development in these areas has the potential to
offer a number of benefits for other parts of the National Park it
could lead to increased pressure on the character of some of the
settlements. This would need to be addressed through
appropriate policy wording.
16 - Support initiatives aimed at
encouraging the use of sustainable
modes of transport.
No areas of uncertainty or incompatibility identified.
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9 Assessment of the Strategic Policies and the Development Policies
9.1 Introduction
The revised LDP consists of a series of strategic policies and development policies. The strategic policies provide the overarching approach for development whilst the development policies provide further detail and guidance against which planning applications will be assessed. The LDP is divided into the following sections, each including a range of relevant strategic policies and development policies:
• The Development Strategy. • Protecting, Enhancing and Managing the Natural Environment. • Protecting and Enhancing the Cultural and Historic Environment. • Promoting Healthy and Sustainable Communities. • Supporting a Sustainable Rural Economy. • Promoting Accessibility and Inclusion.
Each of the individual policies has been assessed against the SA Objectives using the method described in Section 5.
9.2 Results of the Assessment of LDP Policies Following the revision of the Plan, each policy was subject to detailed assessment against the SA Objectives using the method described in Section 5 of this report. The detailed matrices are presented in Appendix E of Volume 2.
9.3.1 The Business as Usual Scenario
A Business as Usual Scenario has been assessed prior to presenting the results of policy assessment, as it provides a benchmark against which the performance of the LDP can be compared. The Business as Usual Strategy assumes a continuation of the existing Eryri Local Development Plan (2011) .
The continuation of the existing Plan would see international and national level policy being implemented, as well as environmental regulators continuing to undertake their roles which would continue to provide protection and enhancement to the natural environment in the National Park.
Adoption of the Local Development Plan brings a positive impact on the
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level of protection offered to landscape character and quality. Policies also exist to promote opportunities to make improvements to existing land uses that are deemed harmful to the ‘Special Qualities’ of the National Park, such as static caravan sites.
There are existing issues in the National Park as a result of the highly dispersed settlement pattern which has led to a reliance upon the private car to access services and facilities. Continuation of the current strategy would continue to strive to overcome this problem and so in the long-term the risks of congestion and associated potential adverse air quality, noise, severance and stress impacts would decrease. The LDP attempts to overcome accessibility issues for local residents in terms of being able to access facilities and services. Housing affordability could become a significant long-term problem and could result in the further loss of young people from the National Park and lead to adverse community spirit and cohesion issues. The adopted Local Development Plan has been making good steps in facilitating the delivery of affordable housing. Over the last 3 years 18 units each year have been delivered, which is good news in a difficult financial climate
A significant amount of the National Park is designated as a SPA or a SAC. A continuation of the Business as Usual Scenario would continue to see international and national level protection. Local level interventions can be developed through progress of a planning application. The Annual Monitoring Review reports no loss in SAC, SPA, SSSI and Ramsar sites as a result of the adoption of the LDP. Issues like adaptation to climate change would not be addressed and there could be a localised deterioration in the connectivity of biodiversity resources.
It is considered unlikely that the pursuit of the LDP would increase the use of the Welsh language adopting the Plan has allowed active promotion of its use at the National Park level.
At the national level, policy relevant to energy efficiency and the sustainability performance of buildings continue to be implemented and with the adoption of the Plan there is a policy driving implementation of such schemes and initiatives at the National Park level.
Continuing with the LDP General Development policy, there is a coherent local approach to addressing flood risk and adaptation to climate change in association with Natural Resource Wales advice. .
9.3.2 The Development Strategy
Table 9-3 presents the results of the policy assessment for each of the Strategic and Development Policies within the ‘Development Strategy’ section of the revised LDP. Table 9-2 presents the key used to present the results for each of the summary tables. It should be noted that these tables
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are intended to be a summary only. For further details about whether effects are likely to occur in the short, medium or long-term, refer to Appendix E in Volume 2.
Following Table 9-3, a summary is presented of the key strengths, key weaknesses and key recommendations for the policies within ‘the Development Strategy’ section of the Deposit LDP. The results of the policies in other section of the LDP are reported in the same manner in subsequent sections of this report.
Table 9-2 Notation Used in the Summary Matrices
Impact Description Symbol
Major Positive Impact
The policy/option contributes to the achievement of all elements of the SA Objective.
++
Positive Impact The policy/option contributes partially to the achievement of the SA Objective but not completely.
+
No Impact/ Neutral
There is no clear relationship between the policy/option and/or the achievement of the SA Objective or the relationship is negligible.
ø
Negative Impact The policy/option detracts from the achievement of some elements of the SA Objective.
-
Major Negative Impact
The policy/option detracts from the achievement of all elements of the SA Objective.
- -
Uncertain impact – more information required
It is not possible to determine the nature of the impact as there may be too many external factors that would influence the appraisal or the impact may depend heavily upon implementation at the local level.
?
Positive and Negative Impacts
The policy/option has a combination of both positive and negative contributions to the achievement of the SA Objective.
+/-
Impact Description Symbol
Level of Uncertainty
There is a high degree of uncertainty in the impact prediction
H
There is a medium degree of uncertainty in the impact prediction
M
There is a low degree of uncertainty in the impact prediction L
Type of Impact The impact would be permanent P
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The impact would be temporary T
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Table 9.3 The Development Strategy.
SA Objective Strategic Policy A: National Park Purposes and Sustainable
Development
Strategic Policy B: Major
Development
Strategic Policy C: Spatial Strategy
Development Policy 1: General
Development Principles
Strategic Policy Ch: Social and Physical
Infrastructure in New Developments
Manage the effects of climate change through mitigation and adaptation +PL Ø +PL +PL Ø
Ensure that the location and design of new development is acceptable in terms of the potential consequences of flooding
+PL Ø Ø PL +PL +PL
Promote the use of sustainable locally sourced material including energy Ø Ø Ø +PL +PL Promote the use of sustainable transport modes and reduce the impact of cars, road freight and infrastructure
+PL Ø +PL Ø +PL
Protect and enhance landscape character and quality ++PL +PL +PL ++PL Ø
Protect and enhance air quality +PL +PL +PL +PL +PL Conserve the quality of soils through reducing contamination and protecting soil function
+PL +PL +PL +PL Ø
Safeguard National Park geology and geomorphology +PL +PL Ø Ø Ø
Protect and enhance biodiversity +PL +PL +PL ++PL +PL Value and protect the historic environment including built heritage, archaeology and historic landscape ++PL +PL +PL +PL Ø
Value and protect local diversity and distinctiveness including townscape character +PL +PL +PL +PL Ø Conserve, promote and enhance Snowdonia’s cultural heritage and the Welsh language ++PL +PL +PL Ø +PL To safeguard the quality and quantity of water resources +PL +PL Ø +PL Ø
To promote mechanism for waste minimisation, increased re-use and recycling Ø +PL Ø Ø Ø
Improve the quantity and quality of publicly open space +PL Ø +/-PL +PL Ø
To provide housing to meet local need ++PL Ø +PL Ø +PL To promote improved access to local services and amenities for all +PL Ø +PL Ø +PL To promote safe, healthy and sustainable communities +PL +/-PL +PL +PL +PL To promote and facilitate improved community involvement +PL Ø +PL Ø +PL To promote good transport links to support the local economy +PL Ø +PL Ø +PL To aid the creation of local employment opportunities and businesses related to National Park purposes
+PL -PL +PL Ø Ø
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Key Strengths
The Development Strategy section establishes the framework and context for the remainder of the plan. It highlights the role of the National Park, its Special Qualities and Purposes, as well as identifying how and where development should occur within the National Park. Strategic Policy A: National Park Purposes and Sustainable Development is a very important policy, as it makes a clear commitment to the need to both protect and enhance the natural environment and so both minor and major positive effects have been recorded against many of the SA Objectives. The National Park is a very high quality environment and such a clear focus upon environmental protection is essential. It is considered particularly important that such a strong policy is the first policy within the LDP. Despite the strong environmental focus of this policy, positive effects have also been recorded against other SA Objectives, including those that address meeting housing needs, the provision of open space, accessibility to services and the creation of local employment opportunities. These strengths have been identified in the assessment through a range of clauses in the policy addressing accessibility, services and employment, whilst minimising potential environmental effects.
Strategic Policy B: Major Development addresses major development proposals in the National Park, highlighting that, other than in exceptional circumstances, they will not be permitted. This commitment should protect the National Park from inappropriate development, thereby helping to protect its Special Qualities in the long-term. Whilst this may limit employment opportunities within the Park, there could be benefits for neighbouring authorities, as development of this nature is more likely to occur in those locations. It will, therefore be particularly important in the long-term that public transport connections in the National Park are maintained and enhanced where possible to ensure that residents of the Park are able to access the job opportunities. However, it will also be essential for the National Park Authority to take a very active interest and role in any major development applications that are proposed immediately adjacent or in close proximity to the National Park as they could have indirect effects on the Park’s environmental resources.
Strategic Policy C: Spatial Strategy is a spatially specific policy and focuses upon where development should occur in the National Park. The settlement hierarchy has been developed based upon the existing employment, public transport and community facilities available, as well as the existing demand for housing within them. This approach which focuses upon making settlements self-sustaining, whilst at the same time recognising the links they have with other settlements in the National Park and the wider area, should help to promote vibrancy in the settlements, thereby helping to reduce the trend of out-migration, particularly by younger members of the population. There are also likely to be environmental benefits associated
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with this approach as development is focussed in the larger settlements of Y Bala and Dolgellau, rather than more rural settlements, which should help to protect the landscape of the Park in the long-term. Whilst the strategy allows for some rural conversions to support economic development and replacement dwellings, there are other policies in the LDP which should ensure avoidance or mitigation of adverse effects. There will also be rural diversification and economic development which is important for socio-economic reasons in the National Park.
Development Policy 1: General Development Principles is a vitally important policy from an environmental protection perspective and is cross-referenced in a number of other policies throughout the LDP. It essentially establishes, through a series of clauses the criteria that will have to be fulfilled before development will be permitted in the National Park. Similarly Strategic Policy Ch: Social and Physical Infrastructure in New Developments focuses upon contributions that would need to be made by developers to secure infrastructure and landscape improvements and mitigation measures. Whilst this is a positive policy that should offer benefits, the need for landscape and nature conservation mitigation would be avoided, through the stringent application of policies which seek to avoid adverse effects in the first instance.
Key Weaknesses
Strategic Policy C: Spatial Strategy continues to focus development on the Local Service Centres of Dolgellau and Y Bala. Whilst it is recognised that both of these settlements are supported by better transport links and facilities and have the capacity to accommodate further development, there are areas of floodplain in both settlements.
Key Recommendations
New development in Y Bala or Dolegllau, as well as other settlements in the National Park should not result in the loss of floodplain. New development proposals must be accompanied by Flood Consequences Assessments as necessary.
9.3.3 Protecting, Enhancing and Managing the Natural Environment
Table 9-4 presents the results of the policy assessment for each of the strategic and development policies within the ‘Protecting, Enhancing and Managing the Natural Environment’ section of the LDP.
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Table 9.4 Protecting, Enhancing and Managing the Natural Environment
SA Objective Strategic Policy D: Natural
Environment
Development Policy
2:Development and the
Landscape
Strategic Policy Dd:
Climate Change
Development Policy 3: Energy
Strategic Policy
E(1),(2),(3):
Strategic Policy F:
Waste
Development Policy 4:
Small-scale sites for
household and inert waste
Development Policy 5: Open
Spaces and Green Wedges
Manage the effects of climate change through mitigation and adaptation Ø Ø ++PL +PL Ø Ø Ø
Ø
Ensure that the location and design of new development is acceptable in terms of the potential consequences of flooding Ø Ø +PL Ø Ø Ø Ø +PL Promote the use of sustainable locally sourced material including energy Ø Ø +PL +PL +PL Ø Ø Ø Promote the use of sustainable transport modes and reduce the impact of cars, road freight and infrastructure Ø Ø Ø Ø Ø Ø Ø Ø
Protect and enhance landscape character and quality ++PL ++PL +PL +PL +/-PL +PL +PL +PL Protect and enhance air quality Ø Ø Ø Ø Ø Ø +PL Ø Conserve the quality of soils through reducing contamination and protecting soil function +PL +PL +PL Ø +/-PL Ø Ø +PL Safeguard National Park geology and geomorphology +PL +PL Ø Ø +/-PL Ø Ø Ø Protect and enhance biodiversity ++PL +PL +PL +PL +/-PL +PL +PL +PL Value and protect the historic environment including built heritage, archaeology and historic landscape +PL +PL +PL +PL +/-PL +PL +PL +PL Value and protect local diversity and distinctiveness including townscape character +PL +PL +PL Ø +PL Ø Ø +PL Conserve, promote and enhance Snowdonia’s cultural heritage and the Welsh language Ø Ø Ø Ø Ø Ø Ø ØTo safeguard the quality and quantity of water resources +PL +PL +PL -PL Ø +PL Ø Ø To promote mechanism for waste minimisation, increased re-use and recycling Ø Ø Ø Ø Ø Ø ++PL Ø Improve the quantity and quality of publicly open space +PL +PL Ø Ø Ø Ø Ø ++PL To provide housing to meet local need Ø Ø Ø Ø Ø Ø Ø ØTo promote improved access to local services and amenities for all Ø +PL +PL Ø Ø Ø Ø +PL To promote safe, healthy and sustainable communities +PL +PL +PL +PL Ø Ø Ø +PL To promote and facilitate improved community involvement Ø Ø Ø Ø Ø Ø Ø ØTo promote good transport links to support the local economy Ø Ø Ø Ø Ø Ø Ø ØTo aid the creation of local employment opportunities and businesses related to National Park purposes Ø Ø +PL Ø +TM Ø Ø Ø
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Key Strengths
From an environmental perspective, this section is a critical part in the LDP, as it highlights the need to both protect and enhance natural resources of the National Park, whilst also acknowledging and seeking to adapt to the long-term challenges posed by climate change. Strategic Policy D: Natural Environment is of particular importance as it seeks to protect biodiversity, geodiversity, cultural heritage and the Special Qualities of the National Park and so positive effects (including major positive effects) have been recorded against the SA Objectives covering landscape, soil, geomorphology, biodiversity, the historic environment, water resources and green spaces. There are also likely to be indirect benefits for quality of life and human health in the long-term, as a high quality natural environment is one factor influencing health and well-being. Whilst this policy applies to all spatial areas of the National Park it includes a specific focus upon those nature conservation sites protected by European legislation and ensuring that they are the afforded the highest levels of protection. This is important, not only from a legal perspective but also because of the diversity that these sites add to the National Park and the valuable ecosystem functions they provide. By protecting these sites there will be indirect benefits for soil functions, water resources and also the landscape and heritage of the National Park. Another specific area of the National Park addressed in this policy is the ‘Undeveloped Coast’ which is described as areas of coastline that have a largely unspoilt character. The protection of these areas is a strength as it should help to prevent further loss of this valuable feature of the National Park. Development Policy 2: Development and Landscape focusses on protecting the National Park’s valuable landscapes. It also recognises the designation of the National Park as a Dark Skies Reserve in 2015. The SNPS has also adopted two Supplementary Planning Guidance documents relating the landscape namely: Landscapes and Seascapes of Eryri and Landscape Sensitivity and Capacity Assessment. However, as raised when discussing ‘the Development Strategy’ section, risks to the National Park’s landscape and dark skies exist from development both within and outside of the National Park. The protection of landscape character is also likely to benefit other environmental resources including cultural heritage and archaeological resources, soil, water, air quality and biodiversity. Beneficial effects have been recorded against the SA Objective ‘to promote safe, healthy and sustainable communities’ as the landscape is an important recreational resource and pursuits like walking and cycling offer a number of health benefits. This is also very important from an economic perspective for the National Park, as tourism and recreation are a significance source of income to many residents. Issues relating to recreation and tourism development in the National Park are dealt with in Strategic Policy I: Tourism and Recreation. Development
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Policy 5: Open Space and Green Wedges, benefits landscape and cultural heritage resources. The inclusion of a climate change policy in the LDP highlights the importance of this issue to the National Park and the need for appropriate adaptation and mitigation. There is a proactive focus upon ensuring development is not sited in flood risk locations which positively fulfils the SA Objective ‘Ensure that the location and design of new development is acceptable in terms of the potential consequences of flooding’ and this will have positive impacts for communities both by ensuring new residents are not exposed to such risks but by helping to reduce the risk of inappropriate development having adverse effects in other locations. There is also clear recognition of the role and functions of soil resources, as the benefits of and the need to protect peatland soils is highlighted and so positive results are recorded against SA Objectives relating to soil function, biodiversity, water quality and landscape. Whilst many of the policies in the LDP recognise the importance of protecting designated nature conservation sites, there is an emphasis placed upon maintaining and enhancing wider habitat and biodiversity connectivity which will benefit ecological resources lying outside of designated sites.
Development Policy 3: Energy makes a clear commitment to improving energy efficiency in the National Park and maximising the use of renewable energy sources where appropriate. There are risks of adverse environmental effects associated with the development of small-scale renewable energy developments. However, all such development would have to comply with the requirements of Development Policy 1: General Development Principles and so such effects should be avoided. Improving energy efficiency in the long-term should have long-term benefits for climate change and could also help to reduce the adverse effects associated with the use of non-renewable resources which should benefit locations outside of the National Park as well as within it.
The three sections of Strategic Policy E: Minerals perform both positively and negatively against many of the SA Objectives addressing environmental issues, as the focus is on safeguarding potential high value aggregate resources whilst at the same time seeking to ensure that no large-scale mineral development is permitted, unless exceptional circumstances prevail. Conversely, the development of small-scale extraction sites, whilst providing local employment opportunities and ensuring that appropriate building stone is available for new dwellings in the National Park, presents some environmental risks, however these can be addressed by other Plan policies.
Strategic Policy F; Waste performs positively in that it means that no land is allocated for the development of large-scale waste management sites, these would be very likely to require the importation of wastes from areas outside the national park, contrary to the “proximity principle”. Development
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Policy 4: Existing Waste Management Site and Small-Scale Sites for Household and Inert Waste permits such development providing that there are no adverse environmental impacts. The policy, therefore, performs well against the SA Objectives addressing environmental issues and also against the SA Objective ‘To promote mechanism for waste minimisation, increased re-use and recycling’.
The focus of much of the discussion has been upon the potential environmental benefits of this set of policies and this largely relates to the overall focus of this part of the LDP itself. However, preserving and enhancing the natural environment is critical to the economy of the National Park. There is a careful balance between protection and allowing an appropriate level of tourism development, such that the communities with the National Park are able to benefit economically.
Key Weaknesses
Strategic Policy E: Minerals and the small-scale mineral workings it permits could potentially lead to localised landscape and visual impacts and could adversely affect tranquillity. There could also be adverse biodiversity effects including land- take, disturbance and fragmentation, disruption to soil ecosystems, localised air pollution caused by dust nuisance and potential water contamination issues. However it is considered that these issues can be addressed by reference to Strategic Policy B: Major Development and Development Policy 1: General Development Principles,
Key Recommendations
There are no specific recommendations.
9.3.4 Protecting and Enhancing the Cultural and Historic Environment
Table 9-5 presents the results of the policy assessment for each of the Strategic and Development Policies within the ‘Protecting and Enhancing the Cultural and Historic Environment’ section of the Deposit Version LDP.
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Table 9.5 Protecting and Enhancing the Cultural and Historic Environment
SA Objective Strategic Policy Ff. Historic Environment
Development Policy 6: Sustainable Design and Materials
Development Policy 7: Listed and Traditional Buildings
Development Policy 8: Protection of Non-Designated Sites
Development Policy 9: Conversion and change of use of rural buildings
Development Policy 10: Advertisements and Signs
Manage the effects of climate change through mitigation and adaptation Ø +PL Ø Ø Ø Ø
Ensure that the location and design of new development is acceptable in terms of the potential consequences of flooding
Ø Ø Ø Ø Ø Ø
Promote the use of sustainable locally sourced material including energy Ø +PL Ø Ø Ø Ø
Promote the use of sustainable transport modes and reduce the impact of cars, road freight and infrastructure Ø Ø Ø Ø +PL Ø
Protect and enhance landscape character and quality +PL +PL +PL +PL +PL +PL Protect and enhance air quality Ø Ø Ø Ø Ø Ø
Conserve the quality of soils through reducing contamination and protecting soil function Ø Ø Ø Ø Ø Ø
Safeguard National Park geology and geomorphology
Ø
Ø Ø Ø Ø Ø
Protect and enhance biodiversity +PL +PL +PL Ø +PL Ø
Value and protect the historic environment including built heritage, archaeology and historic landscape ++PL +PL +PL +PL +PL +PL Value and protect local diversity and distinctiveness including townscape character ++PL +PL +PL +PL +PL +PL Conserve, promote and enhance Snowdonia’s cultural heritage and the Welsh language Ø +PL Ø Ø Ø Ø
To safeguard the quality and quantity of water resources Ø Ø Ø Ø Ø Ø
To promote mechanism for waste minimisation, increased re-use and recycling Ø +PL Ø Ø Ø Ø
Improve the quantity and quality of publicly open space +PL Ø Ø Ø Ø Ø To provide housing to meet local need Ø Ø Ø Ø +PL Ø
To promote improved access to local services and amenities for all Ø +PL Ø Ø Ø +PL To promote safe, healthy and sustainable communities Ø +PL Ø Ø +PL Ø
To promote and facilitate improved community involvement Ø Ø Ø Ø Ø Ø
To promote good transport links to support the local economy Ø Ø Ø Ø +PL Ø
To aid the creation of local employment opportunities and businesses related to National Park purposes Ø +PL Ø Ø +PL Ø
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Key Strengths
The protection of heritage assets provided by Strategic Policy Ff: Historic Environment offers benefits not only to the heritage resources themselves but also the townscape and landscape of the National Park. Many of the buildings/structures e.g. World Heritage Sites and Listed Buildings will also have strong cultural associations with the National Park and so positive effects were recorded against the objective ‘ Conserve, promote and enhance Snowdonia’s cultural heritage and the Welsh language’. This policy and Development Policy 8: Protection of Non-Designated Sites provide the protection needed to ensure that the rich heritage of the National Park including 14 Conservation Areas, 21 Historic Parks and Gardens, a World Heritage Site and 377 Scheduled Monuments are not adversely affected by new or changes to existing development. As well as focussing upon designated heritage features protected by national legislation, Development Policy 8 states that assessments should be undertaken of the potential effects on other heritage assets.
Development Policy 7: Listed and Traditional Buildings performs positively against the SA Objectives seeking to protect the landscape, townscape and cultural heritage. The conversion or adaptation of Listed Buildings could potentially pose risks to protected species including bats. However, the LDP has to be read as a whole and the application of other policies relating to biodiversity protection will be particularly important when making planning decisions about such applications.
Development Policy 9: Conversion and Change of Use of Rural Buildings would permit the conversion or use of a redundant rural dwelling for an employment, self- catering accommodation or affordable housing use to meet local need and so this policy could help to promote rural diversification and secure alternative sources of incomes for some residents in the National Park. There is a clear emphasis in the policy upon ensuring that the conversion is appropriate to the character and traditional form of the building and so there should be no loss of traditional heritage features as part of this policy, which could typically be a risk, particularly if multiple conversions occur, leading to a gradual attrition of the resource over time. Conversion to another use has the potential to increase traffic generation. However, the policy clearly states that the building in question should be accessible which should reduce the likelihood of adverse effects associated with increased travel. There is a risk with this policy, as identified for Development Policy 7, for protected species to be adversely affected during the conversion process. However, the LDP has to be read as a whole and the application of other policies relating to biodiversity protection will be particularly important when making planning decisions about such applications.
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Development Policy 6: Sustainable Design and Materials performs positively against many of the SA Objectives including those addressing energy efficiency, climate change and potentially waste minimisation. The benefits offered by this policy are likely to increase in the long-term as the up-take of sustainable design principles and practices is likely to be a gradual process which in turn could lead to greater levels of innovation in the future.
Development Policy 10: Advertisements and Signs by limiting and guiding the size of new signs should benefit townscape and landscape character, whilst also ensuring that facilities are accessible and businesses able to function through the use of appropriate signage. There is also a clear commitment to ensuring that signs are safe.
Key Weaknesses
No significant weaknesses have been identified.
Key Recommendations
There are no specific recommendations.
9.3.5 Promoting Healthy and Sustainable Communities
Table 9-6 presents the results of the policy assessment for each of the strategic and development policies within the ‘Promoting Health and Sustainable Communities’ section of the LDP.
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Table 9.6 Promoting Healthy and Sustainable Communities
SA Objective Strategic Policy G: Housing
Development Policy 11: Affordable Housing on Exceptions
Sites
Development Policy 12:
Residential Care Homes
and Extra Care
Housing
Development Policy13:
Gypsy and Traveller
Sites
Development Policy 14: Annexe
Accommodation
Development Policy 15:
Extensions
Development Policy 16:
Replacement of Existing Buildings
Development Policy 17:
Removal of Agricultural and Holiday
Accommodation
Occupation Condition
Strategic Policy Ng: Community
Services and Facilities
Development Policy 18: the Welsh language and the Social and Cultural fabric of Communities
Manage the effects of climate change through mitigation and adaptation +PL Ø Ø Ø Ø Ø Ø Ø +PL Ø Ensure that the location and design of new development is acceptable in terms of the potential consequences of flooding Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø
Promote the use of sustainable locally sourced material including energy Ø Ø Ø Ø Ø Ø Ø Ø Ø ØPromote the use of sustainable transport modes and reduce the impact of cars, road freight and infrastructure +PL Ø Ø +PL Ø Ø Ø Ø +PL Ø
Protect and enhance landscape character and quality Ø +PL Ø PL +PL +PL +PL +PL Ø Ø Ø Protect and enhance air quality +PL Ø Ø Ø Ø Ø Ø Ø +PL Ø Conserve the quality of soils through reducing contamination and protecting soil function Ø Ø Ø Ø Ø Ø Ø Ø Ø ØSafeguard National Park geology and geomorphology Ø Ø Ø Ø Ø Ø Ø Ø Ø ØProtect and enhance biodiversity Ø +PL Ø Ø TL Ø Ø Ø PL Ø Ø Ø Value and protect the historic environment including built heritage, archaeology and historic landscape Ø Ø Ø +PL Ø +PL +PL Ø Ø Ø
Value and protect local diversity and distinctiveness including townscape character Ø +PL Ø PL +PL Ø +PL +PL Ø Ø Ø Conserve, promote and enhance Snowdonia’s cultural heritage and the Welsh language -/+PL +PL Ø Ø +PL -/+PL Ø Ø Ø ++PL To safeguard the quality and quantity of water resources Ø Ø Ø +PL Ø Ø Ø Ø Ø Ø To promote mechanism for waste minimisation, increased re-use and recycling Ø Ø Ø Ø Ø Ø Ø Ø Ø ØImprove the quantity and quality of publicly open space Ø Ø Ø -TL Ø Ø Ø Ø Ø Ø To provide housing to meet local need +PL ++PL +PL Ø +PL Ø Ø +PL Ø Ø To promote improved access to local services and amenities for all Ø Ø +PL Ø Ø Ø Ø Ø +PL Ø To promote safe, healthy and sustainable communities ++PL +PL +PL Ø Ø Ø Ø +PL +PL ++PL To promote and facilitate improved community involvement Ø Ø Ø Ø Ø Ø Ø Ø +PL +PL To promote good transport links to support the local economy Ø Ø Ø Ø Ø Ø Ø Ø Ø ØTo aid the creation of local employment opportunities and businesses related to National Park purposes Ø Ø Ø Ø Ø Ø Ø Ø +PL +PL
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Key Strengths
This section of the LDP is essential to residents of the National Park as it addresses the provision of housing and meeting housing needs. Housing affordability is a critical issue for the residents of the National Park and unless such housing is provided, there could be long-term risks to the cohesiveness and vitality of the communities in the National Park. There is a trend of out-migration by younger people and in-migration of older people which could cause changes to the structure and provision of facilities and services in the settlements. Strategic Policy G: Housing and Development Policy 11: Affordable Housing on Exception Sites should both help to address this issue as they focus upon ensuring that affordable housing is provided in the National Park and so perform positively against the SA Objective ‘to provide housing to meet local need’. There are also likely to be benefits for communities across the National Park in the long-term, if these policies are successful in securing more affordable housing provision and help to retain and promote sustainable communities in the Park. Many of the effects predicted for Strategic Policy G been previously addressed through the assessment of Strategic Policy C: Spatial Strategy, and have not been duplicated in the housing assessment. Rather, the assessment of Strategic Policy G has focused upon issues pertinent to the principle of providing housing, rather than the spatial location of it.
A significant amount of research and evidence gathering has been undertaken to inform the housing policies in the plan including Local Housing Market Assessments, a Settlement Capacity Study. This information has been used by the authority to inform both the settlement strategy and also decisions about the types of housing that might be appropriate in particular settlements and so should ensure that housing development only occurs in settlements where there are an appropriate range of facilities including schools, shops and public transport accessibility.
The proposals maps include a series of housing allocations that will provide both affordable and mixed affordable and open market housing. Each of these sites has been assessed against the SA Objectives to identify any key opportunities and constraints associated with them. The results of this assessment are provided in Section 10. Whilst it is not known where all housing development will occur in the National Park the level of growth promoted is approximately 51 dwellings per annum. This level of growth is very low and there are a series of comprehensive policies in the plan that will ensure that the housing development will not adversely affect the character and Special Qualities of the National Park. An earlier review of Development Policy 11: Affordable Housing on Exception Sites identified the potential risk posed by this policy to biodiversity resources, as the existing housing development boundaries of
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some settlements lie very close to nature conservation sites protected by European legislation. It was, therefore recommended that a clause be added to the policy stating that such new development should not adversely affect biodiversity resources. Similarly, there could be risks to landscape and townscape character if development occurs on the fringes of settlements. However, the policy clearly states that such developments should not ‘prejudice the character of that settlement or the appearance of the surrounding countryside’. In the long-term there could be benefits to conserving the use of the Welsh language in the National Park, as the provision of affordable housing and meeting the housing needs of the Park residents should help to retain members of the population and deter them from leaving for housing affordability reasons.
The development of residential care homes (addressed in Development Policy 12: Residential Care Homes and Extra Care Housing) performs positively against the SA Objective ‘to provide housing to meet local need’ as it should meet the needs of the older population in the National Park and may lead to homes being vacated which could help to meet the housing needs of other residents in the National Park. The policy states that such homes should be within walking distance of a town or village centre and so should ensure that the residents are able to access key services and facilities.
The development of gypsy traveller sites (addressed in Development Policy 13) has the potential to adversely affect the National Park environment. However, the policy clearly states that proposals which would cause significant harm to the National Park would not be permitted. The policy also includes a clause addressing the need for sites to be well-screened.
Development Policy 14: Annexe Accommodation and Development Policy 15: Extensions should help to meet the housing needs of the National Park residents by enabling them to extend their properties, thereby allowing them to increase the size of their home without necessarily moving out. With regards to extensions, the policy is clear that there should be no effects on the character of the surroundings in which it is situated which should offer protection to landscape/townscape.
Development Policy 17: Removal of Agricultural and Holiday Accommodation Occupation Condition seeks to protect such development from conversion to housing, unless it is demonstrated that there is no longer a need for either of these uses. This should benefit communities in the National Park, as it should help to make buildings available for conversion to affordable housing, yet, it will ensure that economic opportunities associated with holiday and agricultural uses are not under pressure to be converted.
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Strategic Policy Ng: Community Services and Facilities and Development Policy 18: The Welsh Language and the Social and Cultural Fabric of Communities are likely to offer long-term benefits to communities in the National Park. Strategic Policy Ng promotes the provision of new facilities which is likely to encourage people to live and work within the National Park. However, to ensure that such facilities remain economically viable, it is essential that the housing policies are successful in addressing the housing affordability issue. The focus upon the provision of such facilities within the built up area of local service centres, service settlements and secondary settlements should ensure that they are accessible and help to avoid an increase in travel to use the facilities, although to an extent this will be driven by individual travel choices. The housing policies also have a role in helping to maintain and encourage the use of the Welsh language, as they may make it possible for National Park residents to continue living in the Park, if access to housing improves.
In the long-term there are likely to be benefits for communities across the National Park, as a result of the implementation of the policies in this section of the LDP. However, a key issue will be ensuring that those residents living in the smaller settlements are able to access the new facilities that may be provided in the larger settlements in the National Park.
Key Weaknesses
There are no specific weaknesses.
Key Recommendations
There are no specific recommendations.
9.3.6 Supporting a Sustainable Rural Economy
Table 9-7 presents the results of the policy assessment for each of the Strategic and Development Policies within the ‘Supporting a Sustainable Rural Economy’ section of the Deposit Version LDP.
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Table 9.7 Supporting a Sustainable Rural Economy
SA Objective Strategic Policy H: A Sustainable Rural Economy
Development Policy 19: New employment and training development
Development Policy 27: Snowdonia Enterprise Zone
Development Policy 20: Agricultural Diversification
Strategic Policy: I Tourism
Development Policy 21: Tourism and Recreation
Development Policy 28: New Build Serviced Accommodation
Development Policy 22: Chalet and Static Caravan Sites
Development Policy 23: Touring and Camping Sites
Development Policy 29: Alternative Holiday accommodation
Development Policy 24: Retail
Manage the effects of climate change through mitigation and adaptation Ø Ø
-/+PM
Ø +PL +PL +PL Ø Ø +PL +PL
Ensure that the location and design of new development is acceptable in terms of the potential consequences of flooding Ø Ø -/+PM Ø +PL +PL Ø +PL +PL +PL Ø
Promote the use of sustainable locally sourced material including energy Ø Ø Ø Ø +PL +PL Ø Ø Ø +PL Ø Promote the use of sustainable transport modes and reduce the impact of cars, road freight and infrastructure +PL Ø -PM Ø +PL +PL +PL Ø Ø +PL +PL Protect and enhance landscape character and quality Ø +PL -/+PM +PL +PL +PL +PL +PL +PL +PL +PL Protect and enhance air quality +PL +PL -/+PM Ø +PL +PL +PL Ø Ø +PL +PL Conserve the quality of soils through reducing contamination and protecting soil function Ø Ø -/+PM -PL +PL +PL Ø Ø Ø Ø Ø
Safeguard National Park geology and geomorphology Ø Ø Ø Ø +PL +PL Ø Ø Ø +PL Ø
Protect and enhance biodiversity Ø Ø -/+PM -/+PL +PL +PL Ø +PL +PL -PL Ø Value and protect the historic environment including built heritage, archaeology and historic landscape +PL +PL -/+PM +PL +PL +PL +PL +PL +PL +PL +PL Value and protect local diversity and distinctiveness including townscape character +PL +PL Ø Ø +PL +PL +PL +PL +PL +PL +PL Conserve, promote and enhance Snowdonia’s cultural heritage and the Welsh language Ø Ø -/+PM Ø +PL +PL Ø Ø Ø +PL Ø
To safeguard the quality and quantity of water resources Ø Ø -/+PM +PL Ø +PL Ø Ø Ø +PL Ø To promote mechanism for waste minimisation, increased re-use and recycling Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Improve the quantity and quality of publicly open space Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø Ø
To provide housing to meet local need Ø Ø Ø Ø Ø Ø +PL Ø Ø Ø Ø
To promote improved access to local services and amenities for all +PL +PL Ø Ø +PL +PL Ø Ø Ø +PL +PL To promote safe, healthy and sustainable communities +PL +PL Ø Ø Ø Ø Ø Ø Ø Ø Ø To promote and facilitate improved community involvement +PL +PL Ø Ø Ø Ø Ø Ø Ø Ø Ø To promote good transport links to support the local economy +PL Ø Ø Ø Ø Ø Ø Ø Ø Ø +PL To aid the creation of local employment opportunities and businesses related to National Park purposes +PL ++PL ++PL +PL +PL +P/TL +PL Ø Ø +PL +PL
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Key Strengths
The LDP’s influence on economic development of the National Park is fairly limited. It primarily focuses upon ensuring that there is a sufficient supply of land available to facilitate/support new employment initiatives, without adversely affecting the Special Qualities of the National Park. Strategic Policy H: A Sustainable Rural Economy and Development Policy 19: New Employment and Training Development both perform positively against the SA Objective ‘to aid the creation of local employment opportunities and businesses related to National Park purposes’.
Strategic Policy H supports: new employment development within local service centres, local service towns and villages and secondary villages; rural diversification; tourism and recreation development; and working from home which should benefit residents within the larger settlements of the Park e.g. those in Y Bala and Dolgellau, whilst also seeking to benefit those in more rural locations who may be more dependent upon incomes from rural enterprises. This is particularly important as both Dolgellau and Y Bala are situated in the southern section of the National Park and so it could be argued that accessibility to employment opportunities might be better for those living in more southerly areas. However, the northern settlements in the National Park have access to other key employment centres outside of the National Park including Bangor and Conwy, although retaining employment opportunities would be better to try and reduce commuting distances. Travel to and from work has the potential to increase traffic movements across the Park which in the long-term could adversely affect air quality which is currently good, although the levels of traffic increase are likely to have a negligible effect on air quality. The policy states that live-work units and home working will be permitted which should help to reduce the likelihood of this occurring. Furthermore, the provision of new employment development in a variety of different settlement types across the Park should help to improve accessibility to job opportunities. However, the maintenance of public transport services will be critical to reducing vehicular movements.
Rural diversification and new employment opportunities could have benefits for community spirit and vibrancy by encouraging individuals to continue living within the Park. Benefits are more likely to be gradual as new employment opportunities develop and again will depend to a large extent upon the types of employment opportunities that are created and if they meet the needs of the residents. However, it should be a positive step towards encouraging younger people to remain living within the National Park.
With any new employment development there is a risk of adverse environmental effects both direct and indirect including land-take, habitat fragmentation, disturbance effects e.g. increased noise, pollution of air, soil and water and
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increased use of natural resources. Strategic Policy H: A Sustainable Rural Economy refers throughout to the Special Qualities of the National Park and this
should ensure that rural diversification and tourism and recreation development should not result in adverse environmental effects. However, these issues are discussed in further detail with reference to Development Policy 20: Agricultural Diversification and Strategic Policy I: Tourism and Recreation.
Development Policy 27: Snowdonia Enterprise Zone is a new policy formulated to provide a framework for decision-making on applications for developments on the two sites (Trawsfynydd power station and Llanbedr airfield) which make up the EZ which was designated in 2012.There is potential for substantial development to occur, bringing much need employment opportunities in the low carbon energy, ICT and aerospace sectors. Large-scale developments could however be potentially damaging to the “special qualities” of the Snowdonia National Park. The siting of such developments in a nationally important and highly valued landscape could be controversial. Care would be required to ensure that any adverse effects could be avoided, mitigated or compensated for.
However major development at Trawsfynydd or Llanbedr would need to be considered against all relevant plan policies and Strategic Policy 2: Major Development in particular, to ensure that there would be no harm to the National Park’s special qualities, landscape and nature conservation interest.
Agricultural diversification can present both a number of opportunities but also threats. For example, it could lead to pollution affecting soil and water resources, the loss of key soil functions including carbon and water storage, the loss of biodiversity resources or fragmentation of habitats and disturbance effects, as well as potential landscape changes. These types of effects could be triggered by a more intensive use of the land or the introduction of a more polluting land-use. Conversely, agricultural diversification may lead to a reduction in the intensity of certain agricultural practices which can benefit the environment and improve consistency of incomes for the landholders. Development Policy 20: Agricultural Diversification clearly states that diversification should further the National Park purposes and this should ensure that environmental resources are protected. However, there is a greater degree of uncertainty surrounding the potential environmental effects of this policy, as the effects will depend upon the types of agricultural practices already undertaken on the site and what is proposed. Therefore, each application will need to be subject to scrutiny on a case-by-case basis.
Whilst tourism and recreational development in the National Park (addressed by Strategic Policy I: Tourism and Recreation) generates significant revenue for the National Park, it is essential that increasing recreational pursuits does not adversely affect the character and quality of the National Park. Reference in the supporting text to SPG 13 (Landscape Sensitivity and Capacity Assessment,) and the application of the guidelines contained therein, will ensure that development of this kind does not harm the National Park’s environment. Increased levels of tourist traffic have the potential to adversely affect air quality in the National Park. Whilst access to the Park may be by private car for many visitors, through the
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development of sustainable transport networks in the Park, levels of vehicular traffic could be reduced. A strength of Strategic Policy I is its clause which states that new tourism and recreation developments should be accessible by various modes of transport which should help to avoid increased traffic flows in certain locations. There are likely to be both permanent and temporary economic benefits created by Strategic Policy I, largely owing to the highly seasonal nature of tourism in the National Park.
Development Policy 28: New Build Serviced Accommodation is a new policy which would facilitate the development of new serviced accommodation within, or adjacent to, settlements provide there is no identified need for affordable housing on the site in question. The policy states that new build serviced accommodation development will be permitted providing it is located within the main built up areas. This reduces the dependency on the private car, reduced the visual impact on landscape and townscape and is supported in sustainable terms.
Both Development Policy 22: Chalet and Static Caravan Sites and Development Policy 23: Touring and Camping Sites seek to avoid such new development within the National Park which is likely to have benefits for the character and quality of the Park in the long-term.
Development Policy 29: Alternative Holiday Accommodation is another new policy. It has been developed in response to the increase in demand for “glamping” in self-catering temporary/mobile accommodation such as yurts, camping pods, shepherds’ huts and teepees. These types of accommodation are generally less visually intrusive than static and touring caravans. However due to the landscape sensitivity of the National Park, and in order to prevent the proliferation of such sites, only proposals that are part of an agricultural diversification scheme, or are ancillary to a new, or existing, tourist attraction, will be acceptable.
Providing access to appropriate retail facilities is important to the establishment of sustainable communities. Furthermore, ensuring that residents have access to basic retail facilities can help to reduce travel distances which in turn can have beneficial environmental effects. Development Policy 24: Retail states that new development should be sited within the main retail area of a settlement or be within reasonable walking distance of it and this could help to reduce the use of the private car to access such facilities. The policy performs positively against the SA Objective ‘to promote improved access to local services and amenities for all’ and is also likely to provide employment opportunities.
Key Weaknesses
Large-scale developments on the Snowdonia Enterprise Zone could be potentially damaging to the “special qualities” of the Snowdonia National Park. The siting of such developments in a nationally important and highly valued landscape could be
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controversial. Care would be required to ensure that any adverse effects could be avoided, mitigated or compensated for.
Key Recommendations
Whilst many of the policies in this section of the LDP make clear reference to the need for employment development to be appropriate to the Special Qualities of the National Park, it will be imperative that planning applications for such development are thoroughly assessed on a case-by-case basis to ensure adverse effects do not occur.
Development Policy 27: Snowdonia SEZ sets out a framework for judging planning applications within the Enterprise Zone. However as there is some potential for large-scale schemes to come forward extreme care must be taken to ensure that there are no harmful effects on the National Park. Proposals must also be judged against other relevant plan policies and Strategic Policy B: Major Development, in particular.
9.3.7 Promoting Accessibility and Inclusion
Table 9-8 presents the results of the policy assessment for each of the Strategic and Development Policies within the ‘Promoting Accessibility and Inclusion’ section of the Deposit Version LDP.
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Table 9.8 Promoting Accessibility and Inclusion
SA Objective Strategic Policy L: Accessibility and Transport
Development Policy 24: Visitors Car Parking
Development Policy 25: Telecommunication
Manage the effects of climate change through mitigation and adaptation +PL Ø Ø
Ensure that the location and design of new development is acceptable in terms of the potential consequences of flooding
Ø Ø Ø
Promote the use of sustainable locally sourced material including energy Ø Ø Ø Promote the use of sustainable transport modes and reduce the impact of cars, road freight and infrastructure
++PL Ø Ø
Protect and enhance landscape character and quality +PL +PL +PL Protect and enhance air quality +PL -PL Ø
Conserve the quality of soils through reducing contamination and protecting soil function Ø Ø Ø Safeguard National Park geology and geomorphology Ø Ø Ø Protect and enhance biodiversity +PL Ø Ø
Value and protect the historic environment including built heritage, archaeology and historic landscape +PL +PL +PL Value and protect local diversity and distinctiveness including townscape character +PL +PL +PL Conserve, promote and enhance Snowdonia’s cultural heritage and the Welsh language Ø Ø Ø To safeguard the quality and quantity of water resources Ø Ø Ø To promote mechanism for waste minimisation, increased re-use and recycling Ø Ø Ø Improve the quantity and quality of publicly open space Ø Ø Ø To provide housing to meet local need Ø Ø Ø To promote improved access to local services and amenities for all +PL Ø Ø
To promote safe, healthy and sustainable communities +PL +PL +PL To promote and facilitate improved community involvement Ø Ø Ø To promote good transport links to support the local economy +PL +PL Ø
To aid the creation of local employment opportunities and businesses related to National Park purposes
Ø Ø Ø
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Key Strengths
The ‘Promoting Accessibility and Inclusion’ section of the LDP sets out policies that encourage new development to be situated in locations that reduce the need to travel, as well as highlighting the need for new development to be within a reasonable distance of community services and facilities and sustainable modes of transport. Strategic Policy LI: Accessibility and Transport makes a commitment to improving access to local facilities and reducing the need to travel (especially by private car). It also supports appropriate sustainable transport and community transport initiatives, therefore, many positive effects have been recorded against the SA Objectives. The National Park is a very high quality environment and a clear focus on sustainable transport is essential to protecting it from the adverse effects generated by the use of the private car. Promoting sustainable transport could encourage a ‘modal shift’ in the long-term which could lead to many benefits, including improving air quality, protecting biodiversity and the landscape.
Development Policy 24: Visitors Car Parking, addresses the provision of new visitor car parking within the Park, highlighting it will not be permitted outside local service centres unless it is part of a planned traffic management scheme, or an integral part of a new or extended visitor attraction. The policy makes a commitment to ensuring roads are safe, new car parks are unobtrusively located or designed and landscaped in a way that fits in sympathetically with their surroundings. Indirect positive effects have also been recorded against the SA Objective ‘to promote good transport links to support the local economy’ as new car parks could help to support local business as they may provide individuals with improved access. The provision of a new visitor car park could also help to alleviate congestion issues within settlements caused by on-street parking.
The National Park Authority is fully aware of the need for modern communications in order to fully exploit the social and economic development potential of the Park. Therefore Development Policy 25: Telecommunication is an important policy, as it sets out criteria that new telecommunication proposals must fulfil to be permitted. The criteria should protect the National Park from inappropriate development, therefore helping protect its Special Qualities. Positive effects have been recorded against SA Objectives addressing the protection of the landscape, historic environment and the townscape.
Key Weaknesses
Development Policy 24: Visitors Car Parking has the potential to have negative effects on the air quality of the National Park, as the provision of new car parks in settlements could lead to increased traffic flows which in turn could adversely affect air quality.
Key Recommendations
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It is recommended that provision for new car parking in the National Park is avoided unless absolutely necessary and should not occur where there are existing congestion issues, as a result of excessive vehicle numbers.
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10 Assessment of the LDP Housing and Enterprise Zone Allocations
10.1 Introduction
The LDP includes housing and enterprise zone land allocations in a small number of the settlements. The LDP Manual states ‘the SA report should cover a strategic assessment of sites on any site register identifying where feasible those that perform well against the SA framework...’. (Section 6.5. p.72 of the LDP Manual)
This SA Report, therefore, includes a high-level review of the site allocations for housing and employment against the SA Objectives.
10.2 Site Allocation at Red Lion Farm in Y Bala
The Initial SA Report included an assessment of one site that had been identified for potential inclusion in the LDP. This site was identified as providing both mixed market and affordable housing. The SA process identified that this site was situated in Flood Zone 2 and part of the site in Flood Zone 3. As a result of this assessment and the receipt of consultation responses, this site allocation has been reduced in size and the part of the site within Flood Zone is no longer included. This again demonstrates the value of the SA process and iterative working between the SA and plan-making teams.
10.3 LDP Allocations
A number of sites have been allocated in settlements within the National Park for affordable housing alone, or a combination of open market and affordable housing. Details about the locations of these sites can be found in the Proposals Map and Insert Maps for the LDP. Each of these sites has been subject to a high-level review of their performance against the SA Objectives to identify any potential sustainability issues. This assessment has been undertaken using a matrix with the results presented in Appendix F of Volume 2. Table 10-1 presents details of the name of the allocation and a summary of its key sustainability features.
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Table 10-1 Sustainability Performance of the LDP Housing Allocations
Name of Site (Approximate Number of Housing Units to be Provided)
Sustainability Summary and Site Specific Mitigation
Land adjacent to Cysgod y
Coed – Bala (10 AH units)
Small, well located site near to town centre facilities and public
transport hub on the fringes of the housing development boundary.
Greenfield site but no significant environmental constraints. Near to but
not in floodplain. Within close proximity of a recreational route.
Potential townscape sensitivities.
Consideration should be given to protecting historic and townscape
character through careful design.
Land at Red Lion Farm –
Bala (55 units 20% AH,
phased)
Small, well located site near to town centre facilities and public transport hub. The site is within the housing development boundary.
Greenfield site but no significant environmental constraints. Near to but not in floodplain. Within close proximity of a recreational route.
Potential townscape sensitivities.
Consideration should be given to protecting historic and townscape character through careful design. Potential linguistic impacts.
Land adjacent to Wenallt –
Dolgellau (15 AH units)
Small, well located site near to town centre facilities and public transport hub. The site is on the fringes of the housing development boundary but is close to hospital and school facilities.
Greenfield site but no significant environmental constraints. Near to but not in floodplain.
The site does not lie within the Conservation Area boundary.
Consideration should be given to protecting historic and townscape character through careful design.
Land adjacent Pentre Uchaf
– Dyffryn Ardudwy ( 10 AH
units)
Small site near to village centre facilities including a library. There is a primary school in this secondary settlement but no secondary school provision. The main centre of Dyffryn Ardudwy is a Conservation Area. The design of the housing site must be in-keeping with the Conservation Area and the existing townscape
Land Adjacent to Capel
Horeb – Dyffryn Ardudwy (5
units, 50% AH)
Very small site near to village centre facilities. There is a primary school in this secondary settlement but no secondary school provision.
The main centre of Dyffryn Ardudwy is a Conservation Area. The design of the housing site must be in-keeping with the Conservation Area and the existing townscape.
Former Primary School – Aberdyfi (6 AH units)
Very small, well-located brownfield site within the housing development boundary.
Land adjacent Maes Y
Pandy – Llanuwchllyn (7 AH
units)
Very small, reasonably well-located site within the housing development boundary. The settlement includes a primary school and there is a good local bus service.
Greenfield site but no significant environmental constraints. Near but not in floodplain.
Land behind Garreg Frech, Very small, reasonably well-located site on the fringes of the housing development boundary.
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Llanfrothen (6 AH units)
Situated in close proximity to a playground. Llanfrothen is well-served by public transport. Greenfield site but no significant environmental constraints.
Land at Tŷ Peniel – Trefriw
(5 units, 50% AH)
Very small, well located site, near to facilities. Trefriw is well-served by public transport. Site lies within the housing development boundary. Greenfield site but no significant environmental constraints. Near to but not in floodplain.
Land adjoining Lawnt y Plas
– Dinas Mawddwy (6 AH
Units)
Small, reasonably well located site. Greenfield site but no significant environmental constraints. Near but not in floodplain. Encourage use of SuDS to mitigate surface run-off. Encourage sensitive design with respect to townscape, character and historic landscape. Recommend safety by design principles.
Land adjacent Glan Gors – Dolwyddelan (6 AH units)
Small, reasonably well located site. Greenfield site but no significant environmental constraints. Near but not in floodplain. Encourage use of SuDS to mitigate surface run-off. Undertake ecological surveys prior to development and appropriate mitigation. Encourage sensitive design. Recommend safety by design principles.
Land adjacent to Penyrhwylfa – Harlech (24 units, 33% AH)
Large, reasonably well located site. Greenfield site but no significant environmental constraints. Near but not in floodplain. Encourage use of SuDS to mitigate surface run-off. Encourage sensitive design with respect to townscape, character and historic landscape. Recommend safety by design principles
Land at Y Rhos - Llanegryn (8 units, 50% AH)
Small site in settlement boundary and reasonably close to facilities in Llanegryn and nearby Tywyn. No significant environmental constraints. Site would be locally visible so sensitive design should be promoted to avoid adverse townscape effects. Encourage use of SuDS to mitigate surface run-off. Encourage sensitive design with respect to townscape, character and historic landscape. Recommend safety by design principles.
Land adjacent to Bryn Deiliog - Llanbedr (6 AH units)
Small site in settlement boundary and reasonably close to facilities in Llanbedr and nearby Abermaw. No significant environmental constraints. Site would be locally visible so sensitive design should be promoted to avoid adverse townscape effects. Encourage use of SuDS to mitigate surface run-off. Encourage sensitive design with respect to townscape, character and historic landscape. Recommend safety by design principles.
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Land adjacent Bro Prysor – Trawsfynydd (10 AH units)
Small site within village on an open grassed area. This may represent a loss of informal open space. Close to facilities in the village and public transport routes. No significant environmental constraints. Site would be locally visible so sensitive design should be promoted to avoid adverse townscape effects. Promote sensitive design. Recommend satiety by design principles. Encourage use of SuDs. Secure open space of equal amount and quality to suite
Land adjacent to Maesteg Pennal (5 AH units)
Small site within village on an open grassed area. This may represent a loss of informal open space. Close to facilities in the village and public transport routes. No significant environmental constraints. Site would be locally visible so sensitive design should be promoted to avoid adverse townscape effects Promote sensitive design. Recommend satiety by design principles. Encourage use of SuDs.
Snowdonia Enterprise Zone Large-scale developments could be potentially damaging to the “special qualities” of the Snowdonia National Park. The siting of such developments in a nationally important and highly valued landscape could be controversial. Care would be required to ensure that any adverse effects could be avoided, mitigated or compensated for. Any development proposals for development at this site should be considered against Development Policy 27: Snowdonia Enterprise Zone, other relevant plan policies and Strategic Policy B: Major Development, in particular.
Cumulative Effects The development of the allocated sites, along with other small-scale housing developments in accordance with the requirements of the spatial strategy (Strategic Policy C: Spatial Strategy) has the potential to result in cumulative effects that include increased surface run-off, and the loss of greenfield sites. However, the LDP is clear that new development must fulfil specific development principles and requirements.
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10.3.1 Generic Mitigation Measures
The following generic mitigation measures should be taken into account when all the above site allocations are brought forward for development:
• Encourage use of SuDS to mitigate surface run-off.
• Encourage sensitive design with respect to townscape, character and historic landscape.
• Undertake a Flood Consequences Assessment for any sites that are brought forward for development in floodplain.
• An appropriate mix of affordable housing units should be provided on all sites.
• Careful landscaping of all sites and the inclusion of gardens in new properties to retain soil functions where possible and to reduce the total loss of permeable surface associated with the development.
• Safety by design principles should be promoted.
• Whilst many of the sites are situated close to public transport links, it is recommended that prior to granting planning permission, the status of public transport at the time should be verified to reduce the likelihood that use of the private car will increase.
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11 Cumulative and Synergistic Effects
11.1 Introduction
As described in Section 5 of this report, there are a number of different types of cumulative effects. This section of the SA Report presents an assessment of the cumulative and synergistic effects of the LDP on social, economic and environmental receptors in the National Park.
11.2 The Assessment of Cumulative and Synergistic Effects
The identification and assessment of cumulative and synergistic effects is usually undertaken adopting a receptor-based approach. This essentially means considering the impacts on a topic by topic basis e.g. biodiversity, landscape etc. rather than defining impacts by SA Objective. Table 11-2 presents the potential effects that could be realised as a result of the implementation of this preferred strategy by receptor topic. The receptor topics include the SEA Directive topics but also cover wider social and economic topic areas. An indication is provided of the likely direction of the impacts, some explanatory commentary highlighting how specific aspects of the LDP could lead to such cumulative effects, the related topic areas that could be affected and any key mitigation measures or recommendations that should be considered by the plan-makers.
/
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Table 11-1 Cumulative Effects Assessment
Receptor Topic Likely Cumulative Effect (positive, Negative, Neutral)
Commentary and Reference to LDP Policies Links to Other Receptor Topics
Mitigation
Biodiversity, flora and fauna Positive Positive cumulative effects on biodiversity resources as a result of a number of policies seeking to both protect and enhance the natural environment of the National Park. Throughout the LDP there is a very strong commitment that any new development within the National Park, either employment, housing, recreational or retail should not adversely affect the natural environment and the Special Qualities of the National Park. There is the potential for multiple developments across the National Park to result in the cumulative loss of biodiversity resources. However, a number of policies in the plan are worded such that this impact should not occur (specifically Strategic Policy D: Natural Environment). Whilst Section 3 of the LDP ‘Protecting, Enhancing and Managing the Natural Environment’ addresses the protection of the Park’s natural resources, there are appropriate biodiversity protection clauses included throughout policies in other sections of the LDP. Across the National Park there are a number of nature conservation sites protected by European legislation which must be afforded the highest levels of protection and so the requirements of Strategic Policy D: Natural Environment are critically important. Whilst the protection of designated sites at both a national, regional and local level is very important, it is essential to recognise the value of non-designated resources that are critical to the connectivity and stability of the designated sites. These features are also protected throughout policies in the LDP
Population,
human
health, water
resources, air
quality,
landscape,
water
resources,
climatic
factors,
economy,
geology and
soils, material
assets,
cultural
heritage,
economy and
housing.
No mitigation
measures required.
Air Quality Positive Positive in the long-term owing to the focus upon reducing travel distances and promoting more sustainable modes of transport.
Biodiversity, flora, fauna, human health,
The SNPA has no powers over public transport or the development of the road
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Receptor Topic Likely Cumulative Effect (positive, Negative, Neutral)
Commentary and Reference to LDP Policies Links to Other Receptor Topics
Mitigation
Transport is a key factor which impacts upon air quality in the National Park. Despite the high dependency on the car in the National Park, air quality is good. Whilst the LDP includes policy which would enable housing, employment, retail, tourism and recreational development which could lead to greater use of cars as a result of a larger population, the level of growth proposed is very low. Furthermore, many of the policies highlight the need for new developments to be accessible by means other than the private car. This is highlighted in Section 2 ‘The Development Strategy’ in Strategic Policy A: National Park Purposes, Development Policy 1: General Development Principles and also inherently in the Spatial Strategy as it seeks to ensure that development is sited appropriately in the National Park in view of existing accessibility by public transport and the availability of facilities. Furthermore, Y Bala and Dolgellau are the Local Service Centres where most development is likely to be focussed and these are both well supported by the public transport network. This could help to reduce reliance on the private car in the long-term but this also affected by individual behaviours. Development Policy 3: Energy addresses the need to reduce reliance on fossil fuels and promote the use of renewable energy sources which could also benefit air quality in the long- term both within and outside of the National Park.
population, economy, housing,
network. Overcoming issues relating to air quality and congestion are likely to require long-term action and will need the buy-in of a number of stakeholders and also the action of individuals. This is something the LDP has only limited control over.
Climatic Factors Positive and Negative
Combination of positive and negative effects as there is a
strong commitment throughout the LDP to reducing
travel distance and use of the private car. However,
wider action will be needed (i.e. from other
organisations) to help promote a modal shift. There is
also a focus upon ensuring development is situated
away from flood risk areas.
In the National Park the two main contributors to carbon
dioxide emissions are transport and buildings. The LDP
seeks to reduce emissions from new development through
Biodiversity, flora and fauna, water resources, population, human health, soils, economy, housing
The NPMP may have a
role to play in promoting
the uptake and use of
renewable energy
technologies across the
National Park.
The NPMP should ensure
that it promotes the use of
public transport measures
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Receptor Topic Likely Cumulative Effect (positive, Negative, Neutral)
Commentary and Reference to LDP Policies Links to Other Receptor Topics
Mitigation
Development Policy 3: Energy. However, the benefits of such
a policy are likely to have long lead-in times and so are likely
to be realised in the long-term. Section 7 of the LDP
‘Promoting Accessibility and Inclusion’ includes Strategic
Policy LI: Accessibility and Transport which seeks to reduce
reliance on the private car. There are also other policies in
the LDP which promote the use of more sustainable modes of
transport. These policies should help to mitigate the risk that
cumulative developments across the National Park for
housing employment, retail, recreation could lead to
increased use of the private car and hence adverse climate
change effects in the long-term. The revised spatial strategy
presented in Strategic Policy C: Spatial Strategy should also
assist in addressing this issue in the long-term. However,
actions will also be required by others within the National
Park to achieve this including the public transport operators.
Development Policy 11: Affordable Housing on Exception
Sites permits the development of affordable housing units
adjoining housing development boundaries providing certain
conditions are met. There is a risk that with all development
that there could be the cumulative loss of areas of greenfield
land which could reduce infiltration capacity and increase
runoff rates. This risk is considered to be fairly low, as the
amount of development proposed in the LDP is so small.
Strategic Policy Dd: Climate Change specifically addresses
the need to mitigate and adapt to the risks posed by climate
change and a very important clause in this policy is the need
to protect peatland soils as they are very important for carbon
sequestration. The policy also clearly states that new
especially by tourists to try
and reduce future carbon
dioxide emissions.
Road improvements in the
National Park, as well as
addressing any necessary
safety issues, should also
focus upon assisting the
further development of the
public transport network
across the National Park.
However, it is recognised
that the SNPA does not
have any powers over
public transport or the
development of the road
network.
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Receptor Topic Likely Cumulative Effect (positive, Negative, Neutral)
Commentary and Reference to LDP Policies Links to Other Receptor Topics
Mitigation
development should be directed away from flood risk areas.
Water Resources Positive and negative
Clear focus in the LDP upon directing development away
from flood risk locations and upon protecting the quality
of surface and groundwater sources. New development
will increase water resource demand.
New development within the National Park is likely to
increase water demand. Most towns and villages in the
National Park source their water from small, local
reservoirs. The larger reservoirs in the National Park are
currently at sustainable levels and the low levels of growth
in the National Park, are considered unlikely to result in a
cumulative adverse impact upon water supply in the
National Park. To understand the potential cumulative
effects associated with new development and water
demand it is also important to consider the Water
Resources Management Plan published by Dwr Cymru
Welsh Water (DCWW) in 2015. The Plan outlines a 25-
year strategy for managing water resources across the
DCWW supply area and maintaining the balance between
supply and demand.
Other than Development Policy 27: Snowdonia Enterprise
Zone which could potentially generate significant wastes
there are no other particularly polluting developments
proposed as part of the LDP. Furthermore, pollution
prevention is addressed in Development Policy 1: General
Development Principles which states that development
should not have an unacceptable impact on surface and
ground water.
Biodiversity, flora, fauna, human health, housing, economy, population
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Strategic Policy E: Climate Change addresses flood risk and
states that development should be directed away from flood
risk areas
Geology and Soils Positive Clear commitment throughout the plan to theprotection and enhancement of geodiversity.
The National Park contains a wealth of geology and geomorphology and there are numerous geological SSSIs and RIGS. Whilst the preferred strategy promotes more housing development in the National Park, the geological sites are situated in areas outside of settlements and are considered unlikely to be adversely affected. Strategic Policy D: Natural Environment also commits to protecting geodiversity.
There could be a localised loss of soil resources and functions including infiltration capacity associated with the loss of small greenfield areas on the edges of settlements. However, there is a clear commitment in the LDP to the need to protect these soil resources in Strategic Policy E: Climate Change
Water resources, biodiversity, flora and fauna, landscape, cultural heritage
Material Assets (including waste and natural resources
Positive and
negative
Increased waste generation as a result of new
development (albeit on a very small scale). However,
there is a clear commitment in the LDP to providing
recycling facilities in appropriate locations.
Any new development is likely to increase demand for
natural resources, generate greater amounts of waste and
increase energy consumption. However, the LDP includes
Development Policy 4: Small-Scale Sites for Household and
Inert Waste which permits the development of small scale
civic amenity waste sites which could help to encourage
effective waste management in the long-term. Impacts upon
Biodiversity,
flora and
fauna,
cultural
heritage,
landscape,
housing,
soils and
geology,
water
resources.
No mitigation measures
required.
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Mitigation
material assets could be realised outside of National Park
boundaries if increased waste leads to the disposal of greater
amounts of waste in areas outside of the National Park.
Energy efficiency is addressed in Development Policy 3:
Energy which should help to mitigate any effects that could
result from other policies in the LDP.
Strategic Policy E: Minerals addresses Minerals
Safeguarding and mineral extraction in the National Park and
prohibits large scale abstractions unless there are exceptional
national reasons for permitting such development. However,
small scale abstractions will be permitted for the removal of
slate waste and the provision of building stone. Whilst there
could be localised temporary benefits associated with such
mineral workings e.g. employment and potentially localised
environmental effects e.g. dust generation, they will be judged
against other policies in the LDP.
The transport network across the National Park already
experiences congestion problems in some locations (often
this is a seasonal issue being worse in summer months) and
the increase in development could put further strain on the
network. However, the LDP promotes a very limited amount
of growth in the National Park and the settlement strategy
promotes development in certain locations dependent upon
an understanding of existing service and public transport
provision. Whilst this would not actively reduce carbon
dioxide emissions it could help to reduce a further increase in
vehicle numbers.
Issues relating to water resources and soils have been
addressed in separate rows in this table.
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Receptor Topic Likely Cumulative Effect (positive, Negative, Neutral)
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Mitigation
Population and human health
Positive Clear commitment throughout the LDP to protecting and enhancing the natural environment, as well as allowing limited development (affordable housing, employment development) in suitable locations and the provision of new community facilities. Health is affected by a range of factors and so there should be long-term cumulative benefits upon this receptor group.
Section 5 of the LDP ‘Promoting Healthy and Sustainable
Communities’ addresses some key issues that are likely to
affect the health and well being of residents in the National
Park, as well as potentially helping to avoid the out-migration
of younger residents. Strategic Policy G: Housing supports
the development of housing to meet the needs of the National
Park communities including the provision of affordable
housing. Whilst the provision of such housing and meeting
the affordability needs of the residents is likely to be a gradual
process, in the long-term it could benefit the vibrancy of local
communities and lead to a more balanced population
structure within the National Park. Linked to the provision of
housing is the need for community facilities which is
addressed in Strategic Policy H: Community Services and
Facilities.
One of the factors affecting quality of life and human health is
the quality of the built and natural environment. The
‘Protecting, Enhancing and Managing the Natural
Environment’ section of the LDP includes a number of
policies addressing the protection and enhancement of the
natural environment. These policies include a policy
addressing the need to protect areas of open space
(Development Policy 5: Open Space and Green Wedges).
All SEA
Directive
topics,
housing,
deprivation
and living
environment
No mitigation measures
required
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All of these policies can collectively help to protect the quality
of the natural environment offering indirect benefits to human
health. The ‘Supporting a Sustainable Rural Economy’
section of the LDP addresses the need for there to be
appropriate land available to support the economic
development of the National Park, whilst at the same time
ensuring that such development respects and does not
compromise the Special Qualities of the National Park.
Improving the availability of employment opportunities is likely
to benefit the population of the National Park in the long-term.
Development Policy 25: Telecommunication is also likely to
offer indirect cumulative benefits as well as it will enable
appropriate telecommunications developments to occur which
could help to support the economic development of the
National Park. Issues surrounding potential human health
effects of telecommunications development are addressed in
a specific clause within the policy Cultural heritage including architectural and archeological heritage
Positive Number of policies in the LDP committed to
protecting and enhancing cultural heritage resources
and also restoring them where appropriate.
Development will be permitted across the National Park for
housing, retail, community, recreational, tourism and
employment purposes which has the potential to impact upon
cultural heritage resources, if developed in an inappropriate
manner. The LDP includes a number of policies addressing
the need to protect cultural heritage resources (Strategic
Policy G: Historic Environment; Development Policy 7:
Listed and Traditional Buildings; Development Policy 8:
Protection of Nationally Important Heritage Assets). Whilst the
Living
environment,
landscape,
economy,
housing,
biodiversity,
townscape
No mitigation required
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Mitigation
focus of these policies is upon assets protected by legislation,
they also acknowledge the need to protect non-designated
heritage assets. This issue is also addressed in Development
Policy 1: General Development Principles. There are some
policies within the LDP that address conversion of traditional
buildings or modifications to existing dwellings which could
lead to the cumulative loss of traditional features and the
cultural heritage resource (Development Policy 9:
Conversion and Change of Use of Rural Buildings;
Development Policy 15: Extensions; Development Policy 16:
Replacement of Existing Dwellings). However, within all of
these policies, there is either a commitment to the protection
of heritage features, or a cross-reference to another
appropriate policy within the LDP and so there should be
sufficient protection to heritage resources.
Development Policy 11: Affordable Housing on Exception Sites enables affordable housing on the edge of housing development boundaries providing certain conditions can be met. This could potentially lead to the cumulative loss of unknown heritage resources and archaeological deposits. However, this issue is addressed clearly through other policies in the plan and so this should not occur
Landscape and Townscape Positive LDP policies seek to protect and enhance all
aspects of the built and natural environment in the National Park which should benefit landscape/townscape. The LDP includes policies which permit housing, employment, retail, recreation and tourism development providing it is consistent with other policies in the LDP. There is the potential for such development to have adverse effects on the landscape and townscape of the National Park. However, Strategic Policy Dd: Landscape and Development
Biodiversity,
cultural
heritage,
living
environment,
water
resources.
No mitigation measures
required
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Policy 2: Development and Landscape clearly state that development will only be permitted which conserves and enhances the Special Qualities of the landscape. Development Policy 5: Open Space and Green Wedges is also a key strength as it seeks to protect areas of public and private open space. It also states that no development will be permitted in areas of Green Wedge along the Ardudwy Coast There are a number of policies in the LDP which permit development in rural areas that could affect the landscape (these include: Development Policy 9: Conversion and Use of Rural Buildings; Development Policy 11: Affordable Housing on Exception Sites; Strategic PolicyH: A Sustainable Rural Economy; Development Policy 20: Agricultural Diversification; and Strategic Policy I; Tourism and Recreation). However, many of these policies make specific reference to the Special Qualities of the National Park and the need to protect the landscape from such development.
Economy Positive Policies in the LDP seek to allow employment
development in appropriate locations in settlements in the National Park but also allow rural diversification providing it will not adversely affect the National Park’s Special Qualities. This should offer cumulative benefits for the economy.
Section 6 of the LDP ‘Supporting a Rural Economy’
includes a series of policies addressing economic
development and rural diversification within the National
Park to benefit local communities and residents. A
recognised issue in the National Park is a lack of
employment opportunities which leads to out-migration of
younger people the National Park. Collectively, these
policies should provide benefits for the economy.
Furthermore, if more jobs are created in the long-term this
should benefit the vibrancy of local communities and also
Population,
human
health, living
environment
and
deprivation.
No mitigation measures
required.
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Mitigation
help to improve the viability of local services and
amenities e.g. shops and post offices. Economic
development is likely to be concentrated in the service
centres of Y Bala and Dolgellau. Whilst this could be
seen to be a fairly limited spatial distribution of the
benefits potentially offered by such employment, the
public transport links to these settlements are better than
to other settlements in the National Park and so the job
opportunities should also be available to those living in
other settlements. However, Development Policy 19: New
Employment and Training Development permits
employment in other settlements in the National Park and
also appropriate use of buildings in the open countryside
for economic purposes which should benefit the very rural
parts of the National Park The designation of the
Snowdonia Enterprise Zone necessitates the inclusion of
a new policy in the LDP – Development Policy 27.
However care must be taken as large-scale developments
could be potentially damaging to the “special qualities” of
the Snowdonia National Park. The siting of such
developments in a nationally important and highly valued
landscape could be controversial.
Critical to the economy of the National Park is tourism and
recreation providing a number of seasonal job
opportunities. However, critical to the success of this
industry is protecting and enhancing National Park.
Strategic Policy I:Tourism and Recreation along with
Development Policy 21: Tourism and Recreation;
Development Policy 28: New Build Serviced
Biodiversity,
flora and
fauna,
landscape,
soils, water
resources.
economy
transport
Care would be required to
ensure that any adverse
effects could be avoided,
mitigated or compensated
for.
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Receptor Topic Likely Cumulative Effect (positive, Negative, Neutral)
Commentary and Reference to LDP Policies Links to Other Receptor Topics
Mitigation
Accommodation; Development; Development Policy 22
Chalet and Caravan Sites; Development Policy 23: Touring
and Camping sites and Development policy 29: alternative
Holiday accommodation state that new tourist
development will be permitted providing a series of criteria
are are fulfilled including that they should not adversely
affect the Special Qualities of the National Park. This
should ensure that any such development within the Park
is appropriate and ensure that new tourist development is
sustainable in the long-term.
Housing Positive Cumulative benefits for the housing resource in the National Park, as the LDP focuses upon providing for and meeting the needs of local residents through the provision of affordable housing. Local incomes in the National Park are generally low and opportunities for higher paid employment limited. The combination of these factors creates difficulties for local people to access the housing market. The accessibility and affordability of housing is an essential factor in securing long- term sustainability of the rural communities in the National Park. The LDP includes a number of policies addressing housing (contained within the ‘Promoting Healthy and Sustainable Communities’ section) and recognises that owing to the high quality natural environment and the limited number of development sites available that, of the new housing to be provided over the plan period, at least 50% should be affordable The authority will also use Affordable Housing Supplementary Planning Guidance to guide affordable housing development in the National Park. Therefore, the policies should have cumulative positive impacts on addressing the housing needs of the National Park .
Deprivation
and living
environment,
human
health,
population
No mitigation required
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Receptor Topic Likely Cumulative Effect (positive, Negative, Neutral)
Commentary and Reference to LDP Policies Links to Other Receptor Topics
Mitigation
Deprivation and Living
Environment
Positive The focus of the LDP is upon meeting the needs of the population living in the National Park, whilst at the same time protecting the natural environment. Cumulatively, there should be benefits for quality of life. The LDP should help to improve the quality of life across
the National Park. The LDP includes a new settlement
strategy (Strategic Policy C: Spatial Strategy) that should
help to ensure that new development occurs in the most
appropriate locations across the National Park, providing
opportunities for an appropriate level of affordable housing,
employment development, retail and community facility
provision and also rural diversification where this is suitable.
The provision of this type of development is addressed in
Strategic Policy Ch: Social and Physical Infrastructure in
New Development, Strategic Policy G: Housing; Strategic
PolicyH: A Sustainable Rural Economy; Development
Policy 20: Agricultural Diversification and Development
Policy 23: Retail. Collectively, these policies collectively
should help to improve the vibrancy and vitality of
settlements in the long-term which could help to maintain
the viability of some rural services by ensuring a viable
population is maintained.
Accessibility to affordable housing is currently a significant issue affecting residents of the National Park and the clear emphasis upon the need for new housing to be affordable should help ensure that more affordable housing provision occurs within the National Park. The quality of the Natural Environment and accessibility to areas of open space are key factors affecting health and well-being. The Protecting, Enhancing and Managing the Natural Environment’ section of the LDP includes a number of policies addressing the protection and enhancement of the Natural Environment and so there are likely to be cumulative benefits for residents
Population,
human health,
housing,
material
assets, all
environmental
topics,
No specific mitigation
measures identified.
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Receptor Topic Likely Cumulative Effect (positive, Negative, Neutral)
Commentary and Reference to LDP Policies Links to Other Receptor Topics
Mitigation
living across the National Park.
Education and Qualifications Neutral Education provision and upskilling is not within the
remit of the LDP and it is considered unlikely that there will be cumulative effects on education facilities and educational attainment.
There are no specific areas of the LDP addressing
educational attainment in the National Park as education
does not fall within the remit of the SNPA. Improving
opportunities for understanding and education are
considered more likely to be realised through the
initiatives proposed as part of the NPMP. However, the
development of the local economy could provide a
greater number of employment opportunities and could
lead to upskilling and this is specifically addressed in the
‘Supporting A Sustainable Rural Economy’ Section of
the LDP. Strategic Policy H: Community Services and
Facilities also addresses the provision of educational
facilities which will be needed to support the proposed
provision of housing identified within the LDP.
There is a small risk that the development of new
housing sites could lead to increased pressure on
educational facilities in some settlements, conversely it
could also help to prevent some schools from closing.
The settlement strategy (defined in Strategic Policy C:
Spatial Strategy) is based upon a thorough evaluation of
service capacity and availability within settlements and
so no adverse effects should result
Population,
deprivation
and living
environment,
human health.
No mitigation measures
needed
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12 Monitoring Framework
12.1 Introduction
This section provides an outline monitoring framework and advice for monitoring the significant effects of implementing the LDP. Monitoring is an ongoing process integral to the implementation of the LDP, and can be used to:
• Determine the performance of the plan and its contribution to objectives and
targets.
• Identify the performance of mitigation measures.
• Fill data gaps identified earlier in the SA process.
• Identify undesirable sustainability effects.
• Confirm whether sustainability predictions were accurate.
12.2 Requirements of the SEA Directive
The activities relevant to monitoring that are stipulated in the SEA Directive are outlined in Box 5.
Box 5: SEA Directive Requirements Applicable to Monitoring
‘Member States shall monitor the significant environmental effects of the implementation of plans and programmes... in order, inter alia, to identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action’ (Article 10.1).
The Environmental Report should provide information on ‘a description of the measures envisaged concerning monitoring’ (Annex I (i)).
12.3 Approach
The monitoring framework has been developed to measure the impacts of implementing the LDP using indicators that are appropriate to the scope and potential impacts of the plan. A large number of beneficial effects have been predicted through the SA process and very few negative effects. Table 21-1 which presents the monitoring framework explains the effects that will be monitored and why.
As well as monitoring specific indicators linked to the implementation of the LDP, contextual monitoring of social, economic and environmental change has been included i.e. a regular review of baseline conditions in the National Park
In addition to undertaking monitoring specific to the SA process, annual monitoring will be undertaken for the LDP itself and the results published in an Annual Monitoring Report. This monitoring will be undertaken to determine whether policies are achieving their intended objectives or whether there are unexpected trends or significant changes that could lead to the need for an early partial review.
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The effects of the LDP policies will, therefore be subject to significant scrutiny on a regular basis.
12.4 Proposed Monitoring Framework
Table 12-1 provides a framework for monitoring the effects of the LDP and determining whether the predicted environmental effects are realised. The framework is based around the SA Objectives and includes the following elements:
• The potentially significant impact that needs to be monitored.
• A suitable monitoring indicator.
• An explanation of why that monitoring indicator has been used.
• The potential data source.
• The frequency of the monitoring.
The LDP will run until 2031 and this is a significant period of time over which the LDP will need to be monitored. Over this period new monitoring indicators may be identified and that it may be necessary for the monitoring framework to be updated to ensure that the most appropriate indicators are used. Likewise some monitoring indicators will change, or be removed. Reasons for this may be:
they are no longer considered to be fit for purpose
that the data is no longer collected by third parties,
monitoring the indicator is not possible as the information is not routinely
collected on the planning application form
they are considered to be more relevant to monitoring the National Park
Management Plan. The framework outlined in 12-1 should, therefore continue to be subject to regular review and update. The indicators have been developed based upon the findings of the SA and also suggestions from statutory consultees and good practice guidance.
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Table 12-1 Proposed Monitoring Framework
SA Objective Effect to be Monitored
Monitoring Indicator
Justification for Use of Indicator
Data Source Review Timescale
Manage the effects of climate change through mitigation and adaptation
The LDP includes a policy addressing adaptation to climate change (Strategic Policy E: Climate Change) and whilst it is considered that this will result in positive effects, it is recommended that a series of indicators are monitored to determine performance of the policy and the effectiveness of its implementation. New development in the National Park has the potential to increase energy consumption. However, this is not something that the LDP can entirely control as consumption of resources will be driven by individual habits and lifestyles. Adaptation to climate change also includes actions relating to the appropriate siting of new development e.g. ensuring it is not sited in floodplain and this can be monitored using the indicators for the SA Objective ‘Ensure that the location and design of new development is acceptable in terms of the potential
Ratio of renewable energy (solar, domestic wind and hydro project planning permissions granted against planning applications per year).
The LDP includes a policy addressing adaptation to climate change (Strategic Policy E: Climate Change) and whilst it is considered that this will result in positive effects, it is recommended that performance is monitored.
SNPA NRW
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consequences of flooding’. Retaining peatland soils will be particularly important and the loss of such soils will be monitored through the State of the Park Report
Ensure that the location and design of new development is acceptable in terms of the potential consequences of flooding
Strategic Policy E: Climate Change states that new development should be directed away from flood risk areas and so effects should be positive. However, the potential loss of floodplain, as a result of new development within the National Park, particularly within Dolgellau should be monitored. The extent to which the need for permeable surfaces and the use of SuDS is promoted in new development
Number of planning permissions contrary to EA advice on flooding. Number of new developments in flood zones. Number of new developments incorporating SuDS as a ratio of total planning permissions granted
The LDP and the application of its policies in planning decisions can affect whether development occurs in floodplain.
NRW SNPA
Annually
Promote the use of sustainable locally sourced material including energy
The effect of Development Policy 3: Energy leading to greater use of renewable energy technologies and energy efficiency in the National Park.
Number and type of renewable energy schemes with planning permission per annum. The number of new developments that use secondary and recycled construction materials. Number of new developments utilising recycled and secondary materials as a percentage of the total number of
The LDP and the application of its policies in planning decisions will affect whether sustainable energy and construction practices occur.
SNPA Annually
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planning applications granted each year. Number of developments granted planning permission achieving green design awards, as a percentage of the total number of planning applications granted each year.
Promote the use of sustainable transport modes and reduce the impact of cars, road freight and infrastructure
New development across the National Park needs to be sited near to public transport connections to reduce the likelihood of increased travel. The LDP includes policies and clauses addressing this issue and it will be important to monitor whether new development is sited close to public transport connections. The provision of transport connections is not the purpose of the LDP.
Distance of new developments from a public transport service. Journey to work by mode Average distance travelled to work Number of bus services running in the National Park
The first indicator will be the most important to monitor and the others will provide a context in relation to whether individual travel choices are changing.
SNPAGwynedd Council Conwy Council
Annually for the first indicator and every five years for all other contextual indicators
Protect and enhance landscape character and quality
The LDP includes specific policies and also clauses within other policies addressing the need to protect and enhance landscape character. No adverse effects are predicted. The Authority has adopted Supplementary Planning Guidance on the Landscape and Seascapes of Eryri and
Quantity of Outstanding and High value landscape as defined under LANDMAP’s five aspects: cultural, geological, landscape habitat and visual and sensory. Number of planning applications granted permission in areas of outstanding and high
Monitoring changes to the character and quality of the landscape of the National Park will be very difficult. However, it is envisaged that LANDMAP should be a useful tool to assist this process.
SNPANRW
Every five years
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Landscape Sensitivity and Capacity assessment
value as defined by LANDMAP. Extent of tranquil areas in the National Park
Protect and enhance air quality
It is not predicted that the LDP will result in adverse effects on air quality. However, some contextual monitoring could be undertaken to support other monitoring
Air pollutant levels in the National Park – based upon Air Quality Review and Assessments for Gwynedd and Conwy.
To provide background environmental information about the National Park
Gwynedd and Conwy Councils
When an update of the air quality review occurs.
Conserve the quality of soils through reducing contamination and protecting soil function
The new development promoted through the LDP could lead to the remediation of brownfield land.
Number of planning applications which include site remediation and the area of land remediated. Percentage of new developments granted planning permission on previously developed land.
To ensure that the most valuable soils in the National Park are protected from development and remediation occurs where appropriate
SNPA Annually
Safeguard National Park geology and geomorphology
There are policies in the LDP that address the protection of geodiversity and so effects should be positive. However, effects on the condition of sites of geodiversity value should be monitored, although it should be noted that the condition of such sites will be affected by more than just the policies in the LDP.
The condition of RIGS and SSSIs designated for their geodiversity importance in the National Park.
To monitor condition of RIGS and to better understand what affect their condition.
NRW RIGS Groups
Every 5 years
Protect and enhance biodiversity
There are a series of policies in the LDP that seek to protect biodiversity in the National Park and so effects are
Condition of Designated sites including SPAs, SACs, Ramsar, SSSI, NNR, LNR.
To monitor how the condition of designated sites is changing in the National Park and to understand the threats to
SNPANRW
Annually
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predicted to be positive. However, information should be collated in relation to the condition of sites to determine the effectiveness of the LDP policy. However, it is not just the LDP that will affect the condition and extent of key biodiversity resources in the Park but also the actions of other bodies.
Condition and status of LBAP species and habitats. Number of planning permissions affecting LBAP species and habitats Number of planning applications resulting in the loss of hedgerows and field boundaries (where this occurs the length of loss of details about species should be collated).
them to inform future planning decisions. To ensure that planning applications granted do not result in the loss of habitats and species.
Value and protect and enhance the historic environment including built heritage, archaeology and historic landscape
There are a number of policies in the LDP that seek to protect and enhance cultural heritage resources and so effects are predicted to be positive. It will be important to monitor the success of implementing these policies and whether enhancements are occurring, although it will only be possible to monitor the effects on condition of Conservation Ares once the management plans have been developed and condition assessments completed.
Condition of Conservation Areas and the extent to which new development is consistent with the Conservation Area Management Plans. Condition of Scheduled Ancient Monuments. Number of Listed Buildings at risk.
To ensure that planning applications help to protect the setting and condition of the heritage resource.
SNPACadw Gwynedd Archaeological Trust
Annually
Value and protect local diversity and distinctiveness
There are a number of policies in the LDP that seek to protect local diversity and distinctiveness. It will be
Condition of Conservation Areas and the extent to which new development is consistent with the
To ensure that new development complements and positively contributes to the townscape.
SNPACadw Gwynedd Archaeological Trust
Annually, although it will only be possible to monitor the effects on condition of Conservation Ares once the
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including townscape character
important to monitor whether new developments positively contribute to the quality of settlements and their townscape.
Conservation Area Management Plans. Number of new developments with design statements as a percentage of the total number of planning applications. Number of developments granted planning permission achieving green design awards as a percentage of the total number of planning applications granted each year.
management plans have been developed and condition assessments completed.
Conserve, promote and enhance Snowdonia’s cultural heritage and the Welsh language
Development Policy 18: The Welsh Language and the Social and Cultural Fabric of Communities, as well as the proposal within the LDP to try and encourage the retention of younger people through the provision of affordable housing could help to protect the use of the Welsh language within the National Park. However, the use of the Welsh language will not be influenced by the LDP alone, and the NPMP is likely to have an important role to play
Percentage of Welsh speakers in the National Park and their distribution
To determine whether the distribution of Welsh speakers in the National Park is changing and if the level of development in each settlement is affecting this distribution.
SNPA and Census
Every five years
To safeguard the quality and quantity of water resources
The LDP seeks to protect the quality of surface and groundwater resources. The availability of water resources falls within the
Percentage of Snowdonia’s rivers that are classified as High, Good, Moderate, Poor and Bad under the Water
To determine whether new development occurring in the National Park is affecting the quality of water resources.
NRW DC/WW Keep Wales Tidy
Yearly
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remit of Dwr Cymru/Welsh Water who is responsible for managing water supply and demand across Wales, although it is recognised that this will be affected by the levels of growth within the settlements. Indicators have been proposed to monitor water quality and the potential effects of new development. The LDP also promotes sustainable design and construction and so it will be beneficial to monitor water use in the LDP, although this is also affected by individual actions.
Framework Directive classification as set out in the relevant River Basin Management Plans Blue Flag and Green Coast Award beaches in Snowdonia Bathing and estuary water quality Estimated household water consumption (litres per head per day)
It is proposed that there will be a focus upon those watercourses that are designated or feed into sites designated for nature conservation purposes. However, the quality of watercourses could change as a result of multiple factors i.e. things outside the control of the LDP and so the causes for any changes will need to be discussed with Natural Resources Wales.
River Basin Management Plans are reviewed on a 6 yearly cycle
To promote mechanisms for waste minimisation, increased re-use and recycling.
New development across the National Park will increase waste. However, the extent to which recycling and re-use occurs will depend upon individual actions. However, Development Policy 4: Existing Waste Management Site and Small-Scale Sites for Household and Inert Waste permits new local recycling facilities and so the number that are established should be monitored. This could also be correlated with waste recycling facilities.
Number of sustainable waste management facilities granted planning permission in the National Park and their distance from settlements. Percentage of household and industrial/commercial waste recycling.
To monitor levels of recycling in the National Park and to determine if new facilities permitted are affecting recycling rates
SNPAGwynedd Council Conwy Council WG
Every 5 years
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Improve the quantity and quality of publicly open space
Policies in the LDP seek to protect open space and effects are predicted to be positive. However, the effectiveness of the implementation of the policy should be monitored.
Areas of open space lost to new development within the National Park.
To ensure that the LDP policies are effectively implemented.
SNPA Annually
To provide housing to meet local need
The LDP includes a number of policies promoting new housing which should positively contribute to housing needs
Affordable dwellings completed as a percentage of all new housing completion House price to income affordability ratio
To ensure that new housing developed meets the needs to the residents in the National Park and is meeting local targets.
SNPA Annually
To promote improved access to local services and amenities for all
The LDP includes a policy which addresses the provision of community services and so should have positive effects in the long-term
WIMD – Geographical Access to Services Deprivation Domain Number of new community facilities granted planning permission per annum and their proximity to public transport facilities.
The effects of this policy should be monitored to check that new facilities are being provided in the settlements that need them
To promote safe, healthy and sustainable communities
The policies in the LDP should collectively benefit communities by protecting and enhancing the natural environment and promoting new development in appropriate locations in the National Park. The health and safety of communities are determined by a wide range of factors and so determining whether the actions of the LDP are
Percentage of persons with long-term limiting illness in Snowdonia Percentage of persons whose health was ‘good’ over the last 12 months in Snowdonia WIMD – Health Deprivation Domain
To determine overall levels of health and perceptions of health and well-being in the National Park.
SNPAWAG
Every five years and for the WIMD data when it is updated by WAG.
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affecting health and well- being will be very difficult to determine.
To promote and facilitate improved community involvement
The LDP seeks to maintain and improve access to community facilities within the National Park and the effectiveness of such policies should be monitored.
WIMD – Geographical Access to Services Deprivation Domain Number of new community facilities granted planning permission in the National Park. The distance of new community facilities granted planning permission from public transport services.
To determine accessibility to community facilities
SNPA Annually
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12.5 Management and Responsibilities
The monitoring data needs to be collated in a structured manner so that patterns and trends can be identified and remedial action implemented. It is recommended that the data be collated in a tabular format and records the following:
• The SA Objective.
• The indicator being used.
• The data recorded.
• The trend i.e. is the situation improving or deteriorating.
• The need for remedial action.
• The remedial action to be taken.
• The date for the implementation of remedial action.
However, it is currently anticipated that remedial action will not be needed as there are no significant adverse effects anticipated as a result of the LDP strategic policies and development policies.
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13 Next Steps
Table 13-1 summarises the next steps in the production of the LDP and the SA Process.
Table 13-1 Next Steps in the SA Process Stage in the Process Target Date
Consultation on the revised SA Report and the Deposit version of
the LDP Summer 2017
Submission of the LDP and the representations received during the consultation to WG
Autumn 2017
Examination in Public for the LDP to be held by an independent Inspector appointed by the Planning Inspectorate.
Winter 2017
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