Summary of Comments Received on the Revised Local Development

Eryri Local Development Plan

Summaries of comments received on the Revised Local Development Plan 2016-2031.

November 2017

General Comments on the Revised Eryri Local Development Plan

RespID RepsID First Surname Organisation Officer Summary name 008 001 Elfed Roberts Due to circumstances and plans in August, there was no time to report on the Deposit Version of the Local Development Plan, but is trusted and confident that the Park Authority would give the same protection and care to those elements that are valuable within its territory.

018 001 Catherine James Cyngor Sir Powys No Objections. County Council 021 001 Dewi Griffiths Dŵr Cymru General comments on the role of DC/WW LDP. Consider that there are no insurmountable constraints regarding the capability of our infrastructure to accommodate the proposed growth, or for the capability of any required infrastructure improvements to be delivered. The proposed Enterprise Zone employment sites represent a substantial area of land for development for which the water demand and foul sewage flow to be generated is unknown at present. It is essential that we understand these demands in order to allow us to assess the impact on our assets. It may be necessary for modelling assessments to be undertaken to establish how we would provide the connection to the water and/or sewerage network.

030 006 James Harland Cyngor Bwrdeistref Plan needs to recognise changes in national guidance particularly those with direct local implications, i.e. such as TAN 20 Sirol Conwy County and protecting the Welsh language, Active Travel Act/Plan. Borough Council

034 001 The Welsh The Welsh Government and Snowdonia Aerospace LLP would like to confirm their overall support for the proposed site- Government and specific policy for Llanbedr within the Deposit Plan, as detailed by Development Policy 27, as well as the redline boundary for Snowdonia the site as delineated on the LDP Proposals Map under reference PME/02. The Welsh Government and Snowdonia Aerospace LLP Aerospace LLP would also like to confirm their support for the following revisions to the Plan, on the basis that they provide a useful context for the SEZ and the associated designation of Llanbedr: • Modification to paragraph 1.57 (Ref#46); • Insertion of paragraphs 6.14 – 6.20 (Ref#171 – 178); • Insertion of paragraph 6.22 (Ref#180); • Insertion of paragraph 6.26 (Ref#184), and • Insertion of paragraph 6.28 (Ref#186). 036 001 Chris Jones Betsi Cadwaladr No significant impact on health services as a result of the proposed amendments has been raised, however we will use the University Health information for future planning purposes. Board 041 001 Angharad Wyn Cyfoeth Naturiol NRW objects to the plan and does not consider it meets Tests of Soundness 1 and Crump Cymru/ Natural 3. Two of the allocations PME/01 SEZ Allocation - Llanbedr and 31/06 Land adjacent Penyrhwylfa, Harlech do not comply Resources Wales with the requirements of TAN 15 as such NRW do not consider that either of these potential allocations can be delivered

RespID RepsID First Surname Organisation Officer Summary name during the plan period. NRW consider that revisions are required to the revised LDP to make the Plan sound and ensure that the Plan can deliver.

041 034 Angharad Wyn Cyfoeth Naturiol NRW advices that there is a need for all development to ensure the effective consideration of European Protected Site Crump Cymru/ Natural Conservation Objectives. The HRA of the plan will need to consider any allocations located within a protected site or an Resources Wales allocation located within a distance where it could have an impact. Consideration should also be given to flood defence consents or ordinary Watercourse Consent. NRW advise that Dŵr Cymru/Welsh Water is consulted to confirm that a public sewerage system is available to accommodate the proposed site allocations. There is also a need to ensure that all allocations have regard to National Park purposes. Consideration should also be made to landscape matters as well as ecological matters and protected species.

Introduction

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 032 001 Nia Davies Gwynedd 3 Change 1 (page 3 - Foreword) Council Welcome the reference to the low wage economy. Would like to note that the impact of low wages is wider than just young people leaving the area; we believe that responding to this challenge needs to be at the heart of all the policies of the Plan, including the National Park Management Plan. Believe that the Park's natural and cultural resources, the unique assets that exist within the Park - the Trawsfynydd Power Station and the Llanbedr Airfield area are specific - and the increasing availability of quality information technology infrastructure offers a golden opportunity to increase number/ rate of high value jobs within the Park area.

032 002 Nia Davies Gwynedd 13 1.10 Welcome the reference to the Historical and Industrial Qualities of the Park, and particularly the Council Slate industry. Suggest that this section should refer to the proposed World Heritage Site - Slate Industries of North Wales.

032 003 Nia Davies 14 1.12 Agree with what has been changed. Welcome reference to Environmental Qualities of the Gwynedd National Park, and reference to the Dyfi biosphere in particular. Council 032 004 Nia Davies Gwynedd 17 Either refer to the Gwynedd Single Integrated Scheme or refer to the Gwynedd and Môn Single Integrated Scheme. Both have replaced the Gwynedd Community Strategy. Council

032 005 Nia Davies Gwynedd 17 1.27 Agree with what has been written. Council 030 002 James Harland Cyngor 20 Conwy CB Council agree that a joint plan with SNP does not present a cohesive progression Bwrdeistref Sirol due to the many different issues faced by each area. Conwy County Borough Council

030 003 James Harland Cyngor 20 Conwy CBC and SNPA have liaised on joint issues throughout the whole LDP process. Bwrdeistref Sirol Conwy County Borough Council

030 001 James Harland Cyngor Bwrdeistref 21 For clarity, would like some sub-headings to be added to the list [in section 2] to identify specific Sirol Conwy County issues. Borough Council 4

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 032 006 Nia Davies Gwynedd 22/23 1.49/1.50 Agree with reference to low incomes as part of the associated challenge in securing affordable Council homes, but believe that there is a need for further emphasis on increasing the wealth of local residents alongside measures to increase the availability of homes / reduce cost.

027 001 Eileen Jones Cyngor Cymuned 24 1.57 Llanfihangel y Pennant Community Council considers that the Local Development Plan does not Llanfihangel- y- meet the test / soundness tests based on the following: Pennant 1. Access to the site is limited and inaccessible. Community 2. An unadopted and privately owned road means that its condition is rough, rocky and un- Council tarmacked. 3. The Village sewage system is at its highest and is at capacity; further development would make it unsustainable. 4. Rationale and analysis of the position set out in paragraph 1.57 means that the Plan is not robust based on: a) It is unlikely that any developments at Trawsfynydd and Llanbedr would result in the need for more houses in Abergynolwyn, due to the distance between them. b) There is no evidence that residents of Abergynolwyn earn a living from the business parks in Tywyn and in particular Dolgellau. Given the situation of the Business Park in Tywyn, many of the sites remain undeveloped, and where buildings have been built, many remain empty.

032 007 Nia Davies Gwynedd 24 1.55 Agree with what has been changed / written. Council 032 008 Nia Davies 24 1.57 Change 46 Gwynedd We welcome the emphasis on the Eryri Enterprise Zone sites, the Snowdonia Aerospace Centre Council and the Trawsfynydd Decommissioning Site, and recognize the role that both sites can play in developing the Meirionnydd economy. We are, therefore, very pleased to see the Snowdonia National Park Authority's support for its proper development, and look forward to working together in an effort to strengthen the area's economy.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 033 001 John Harold Snowdonia 26 1.66 Comment on National Park Objectives, with specific reference to the use of natural resources for Society renewable energy. In addition it is necessary to provide a more substantial and clearer framework of guidance for: • larger scale hydropower proposals, i.e. those with a capacity rating above 1 MW. • wind power proposals at the margins of size categories. • proposals for field-scale solar and larger wind schemes near the National Park boundary. This section requires a more robust and precautionary wording to make it clear that inappropriate developments will not be permitted.

032 009 Nia Davies Gwynedd 27 1.69 The reference to encouraging sustainable economic growth and supporting a rural economy offers Council employment and sustainable, vibrant communities is welcomed. The references to the support of outdoor tourism and recreation that maximize the local economic benefit are welcomed.

The Development Strategy

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 030 004 James Harland Cyngor Bwrdeistref 17 1.24 Section 1.24 needs to be updated to reflect the Well-being of Future Generations Sirol Conwy County (Wales) Act 2015. Borough Council

041 024 Angharad Wyn Cyfoeth Naturiol Cymru/ 31 A NRW welcome the additional criteria (xv) regarding the production of place plans. Crump Natural Resources Wales 030 015 James Harland Cyngor Bwrdeistref 32 There is no reference to the Carneddau HLF Project. Place planning is mentioned in Sirol Conwy County Strategic Policy A, this needs to be expanded upon and strengthened. Borough Council

034 003 The Welsh Government 33 Strategic Care should be taken with the interpretation of the wording of Strategic Policy B. There and Snowdonia B is potential for large-scale schemes to come forward on the Llanbedr site, which will Aerospace LLP bring much needed employment opportunities in the aerospace sector and associated industries. Given that development proposals at the site would be considered against Development Policy 27, Strategic Policy B, and other relevant Plan policies, it is therefore important that Strategic Policy B is closely aligned with Development Policy 27 so that it does not preclude larger development proposals at the site, which would help deliver the Plan allocation for Llanbedr, provided there are no adverse impacts on the National Park.

035 003 The Nuclear 33 Strategic It is important that Strategic Policy B is closely aligned with Development Policy 27 so Decommissioning B that it does not preclude larger development proposals at the site, which would help Authority and Magnox deliver the Plan allocation, provided there are no adverse impacts on the Limited National Park.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 032 010 Nia Davies Gwynedd Council 35 2.15 Change 56. The reference to the Eryri Enterprise Zone is welcomed. 032 011 Nia Davies Gwynedd Council 37 C Change 57 (page 37 - Strategic Policy C) The general direction of the policy and recognition of the opportunity to support employment development in each tier (although we believe there is scope to include reference to encouraging appropriate employment even in smaller settlements) and the special role of Dolgellau and Bala are supported.

033 002 John Harold Snowdonia 37 C Strategic Policy C: Spatial Development Strategy (C): Service Settlements (vi) Small scale Society general market and affordable housing for local needs – We would welcome the inclusion of a rationale for the proposed change. It would be useful to reference any evidence that inclusion of general market housing will not inadvertently lead to price inflation in key locations, to the detriment of local people.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 034 004 The Welsh Government 37 C It is the Welsh Government and the Snowdonia Aerospace LLP's view that the text on and Snowdonia ‘open countryside’ under Strategic Policy C should be amended so that the Policy Aerospace LLP provides support for development that may come forward within the Enterprise Zone. It is therefore suggested that an additional criterion be added as follows: xxvii: Economic development as part of the Snowdonia Enterprise Zone allocation.

035 004 The Nuclear 37 C It is the NDA and Magnox's view that the text on Decommissioning ‘open countryside’ under Strategic Policy C should be amended so that the Policy Authority and Magnox provides support for development that may come forward within the Enterprise Zone. It Limited is therefore suggested that an additional criterion be added as follows: xxvii: Economic development as part of the Snowdonia Enterprise Zone allocation.

013 001 Welsh Government 37 C The Welsh Government would welcome clarification on how the percentage targets Planning and ranges in Policy C (amended by Change 57) have been calculated including how they will be implemented and monitored. Clarification is also sought on how the ranges relate to the housing components proposed by Change 117.

030 009 James Harland Cyngor Bwrdeistref Sirol Greater emphasis on the intended use of Place Plans, especially the willingness to Conwy County Borough continue to collaborate on issues faced in shared settlements. Council

030 010 James Harland Cyngor Bwrdeistref Sirol Community Strategies: There’s a need to include the update and revision to the One Conwy County Borough Conwy strategy and the PSB information. Council

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 030 005 James Harland Cyngor Bwrdeistref Sirol There is no reference to the Rural Conwy Local Development Strategy 2014-2020, Conwy County Borough Conwy's Economic Growth Strategy 2017-2027, Destination Conwy Management Council Plan 2015-2018.

030 007 James Harland Cyngor Bwrdeistref Sirol Clarity of conforming to the Planning Act including stages and changes. Conwy County Borough Council

030 008 James Harland Cyngor Bwrdeistref Sirol Further mention of cross-boundary efforts especially for shared settlements and Conwy County Borough those issues faced especially the potential of development either side of the Council authority boundary. This should include all land use issues.

Protecting, Enhancing and Managing the Natural Environment

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 041 025 Angharad Wyn Cyfoeth Naturiol 45 Change 61 – Page 45 – Landscape. We welcome the inclusion of the text that confirms Crump Cymru/ Natural that Dark Landscapes can ‘contribute to Snowdonia’s night- time tranquillity and sense of Resources Wales wilderness and can lead to broader health and well-being benefits of both residents and visitors alike’.

033 004 John Harold Snowdonia 46 3.12 Illuminated sports pitches could create problems for the Dark Skies Reserve. Consider Society the use of the wording in PPW.

041 026 Angharad Wyn Cyfoeth Naturiol 46 3.11 NRW note that Carneddau do not fall into a Dark Skies Core Area despite sharing many Crump Cymru/ Natural characteristics of the areas which do form the Core Areas. Whilst development and new Resources Wales lighting along the Carneddau is highly unlikely, the lighting for example of new road schemes, residential and commercial development within the adjacent lowlands could give rise to adverse cumulative effects. The 3 core areas could create the impression that areas outside, but within the wider Dark Sky Reserve require less day to day consideration of the potential lighting impacts of planning proposals. We would therefore welcome some clarification either within the LDP policy text, or update of the SPG which gives planning weight to the conservation of night time Dark Skies of the Carneddau.

033 005 John Harold Snowdonia 47 3.20 Need to keep under review the scope of SPG. Other types of development, which are not Society currently covered by this guidance, could become significant e.g. Field-scale solar PV

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 041 027 Angharad Wyn Cyfoeth Naturiol Cymru/ 47 2 installations and polytunnels. NRW welcome the textual changes to Development Crump Natural Resources Wales Policy 2 to reflect the adoption of the Landscape Sensitivity and Capacity Assessment Supplementary Planning Guidance (SPG).

013 016 Welsh Government 47 2 The Authority should show spatially the Biosphere Reserve on the Proposals Map Planning in order to successfully implement the requirements of Policy 2.

037 001 Ben Lewis Barton Willmore 48 3.26 + 3.28 The representations seek amendments to the Deposit Revised LDP to reflect the context provided by the LDP background paper - the “Renewable Energy Assessment (May2017)” (REA). In relation to hydro power schemes, the REA states: • "This means that this assessment does not look into larger scale hydro (or pumped storage opportunities), where there may be no existing physical impediments in place." • "Hydropower opportunities may be greater than those presented in this report, as the data set used only looks at low head hydropower. High head hydropower and possibly pumped storage opportunities may also provide opportunities within Snowdonia."

In light of the above, the representations seek amendments to paras. 3.26 and 3.28 on the basis that the current text fails to reflect the fact that the REA acknowledges that there may be pumped storage opportunities within Snowdonia that have not been identified by the REA. The Plan should not foreclose the opportunity for such schemes to come forward.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 016 001 John Idris Jones Snowdonia Enterprise 49 3.29 The policy rightly recognises that both sites represent substantial opportunities for added Zone value job opportunities across different business sectors subject to their own unique characteristics and differing timescales. The Board is concerned with regards revision number 83 (page 49) (3.29) within the Written Statement. The Board considers this contrary to the EZ policy that has been developed to reflect the potential at the Trawsfynydd site and would ask if this statement could either be revised or removed. This policy inclusion can provide significant investor confidence and greater clarity around the scope for development, enhancing the attractiveness of both sites for both local, indigenous business and inward investors.

019 001 Paul Richardson Magnox 49 3.29 The Authority should reconsider revision number 83 (page 49) (3.29) to your plan. Trawsfynydd Suggest that the statement is revised, to allow individual reactor designs to be assessed on Power Station their merits.

032 029 Nia Davies Gwynedd Council 49 3.26 The recognition of the tradition of energy generation of water is welcomed, however, the reference is not clear in terms of the Park Authority's position on further developments.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 033 011 John Harold Snowdonia Society 49 3.26 Improve wording of policy and recognise limits to the deployment of renewable energy technologies in the National Park. Planning applications are largely restricted to the most extremely sensitive habitats in pristine landscapes.

033 012 John Harold Snowdonia Society 49 3.31 Regarding para 3.31 – ‘wind turbine developments. We would point out that the work on Landscape Sensitivity may need to be extended to other categories of development and their cumulative impacts and that this should be kept under review.

033 013 John Harold Snowdonia Society 49 3.31 Strengthen the wording to reflect the increasing number of near-boundary wind power developments in neighbouring Local Authority areas.

035 006 The Nuclear 49 3.29 Would like paragraph 3.29 to be amended - proposed changes underlined: Decommissioning “Trawsfynydd nuclear power station stopped generating in 1993 and is currently being Authority and Magnox decommissioned. The Authority considers that a further Nuclear Power Station would not Limited be acceptable in the National Park. New uses are being sought at the site, which include low carbon energy businesses and energy generation technologies as well as other employment uses in the ICT, Energy & Environmental sectors, and development proposals may come forward as decommissioning progresses.”

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 013 022 Welsh 49 3.31 Renewable Energy: propose a new criteria based policy to assess applications for renewable Government energy development either side of the 5MW threshold for different relevant technologies and Planning provide clarity on the relationship to local authority wide thresholds as outlined in National Policy.

039 001 Sioned E. Llanbedr and 49 3.29 Suggest reconsideration of number 83 (page 49) (3.29): Williams Trawsfynydd Overview "Trawsfynydd nuclear power station stopped generating in 1993 and is currently being Boards decommissioned. The Authority considers that a further Nuclear Power Station would not be acceptable in the National Park. Suggest to allow individual reactor designs to be assessed on their merits."

007 001 Rory Trappe Trawsfynydd Site 49 3.29 Consider rewording para 3.29 of the LDP which currently states that there will be no further (Magnox) Nuclear Power Generation at Trawsfynydd.

033 014 John Harold Snowdonia 50 3.34 3 Section 3.34 and Development Policy 3: Energy, are too permissively worded, particularly in Society relation to hydropower. Significantly they could also rapidly become too permissive in terms of wind power and solar PV developments, with only very small changes to the surrounding policy and incentives environment. ELDP policy should recognise the existence of the potential issues around scale of energy developments, numbers of schemes coming forward, and their cumulative and longer-term impacts on landscape, ecology and public enjoyment.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 035 005 The Nuclear 50 3.27 Request that paragraph 3.27 is removed as it contradicts elements of Development Policy Decommissioning 27. Authority and Magnox Limited 035 007 The Nuclear 50 3.32 Paragraph 3.32 is considered to be in conflict with Strategic Policy B and Development Decommissioning Policy 27, which would support low carbon energy generation schemes at the Trawsfynydd Authority and Magnox site (provided there are no adverse impacts on the National Park). As such, it is requested Limited that the text stating that “large scale energy power generation projects are incompatible with national Park status” should be removed.

035 008 The Nuclear 51 3 It is considered that Development Policy 3 should be amended to reflect the policy support Decommissioning for low carbon energy businesses and energy generation technologies at Trawsfynydd. As Authority and Magnox such, it is suggested that Development Policy 3 is amended by adding the following to the Limited end of the policy: "Low carbon energy businesses and energy generation technologies will be supported within the Snowdonia Enterprise Zone allocation at Trawsfynydd.”

033 009 John Harold Snowdonia Society 52 E Suggest a re-wording of the policy to include text from para. 3.41. "New permissions for mineral working must demonstrate an over-riding national (UK) interest."

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 033 010 John Harold Snowdonia 52 E Include a policy which supports the use of Prohibition Orders on dormant minerals sites. Society

033 008 John Harold Snowdonia 53 3.43 Supportive of the purpose behind this section, it may be useful to add in some clearer Society definitions e.g. what constitutes a ‘small’ quarry and a ‘short’ duration?

013 019 Welsh 53 Minerals - Policy E Minerals Safeguarding. For criterion (iii) of Strategic Policy E Minerals Government Safeguarding, we suggest the addition of ‘or sterilise the resource’ to be in line with national Planning policy (PPW, paragraph 14.7.3).

013 021 Welsh 54 4 Waste - Policy 4: contain a detailed framework against which to assess applications for new Government waste management facilities. As worded, policy does include assessment criteria on amenity, Planning transport and access amongst others. Authority should identify existing industrial sites it considers appropriate for such facilities and include a requirement for a Waste Planning Assessment to be submitted with applications for waste management facilities classed as disposal, recovery or recycling facilities.

032 012 Nia Davies Gwynedd Council 45 -46 3.8-3.12 The references to the Park's designation are welcomed as a Dark Sky Reserve and we recognize the opportunity to develop the visitors' offer of the area.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 033 003 John Harold Snowdonia 45 -46 3.10, 3.11 It's necessary to differentiate between the amount/spread of light pollution and the impacts of Society specific types of lighting. Policy needs to keep up to date with research in this area. Initial (limited) evidence suggests that there may be a trade- off between energy, landscape and wildlife here – as some more efficient and (to the human eye) less intrusive lighting may have proportionately greater negative impacts on wildlife.

032 013 Nia Davies Gwynedd Council 46 -47 3.15-3.18 The references to the Dyfi Biosphere Reserve are welcomed.

032 014 Nia Davies Gwynedd Council 49+102 3.29 27 Change 83 (pages 49 -3.29) & Change 187 (pg. 102 Policy 27). We object to this clause (3.29) in its present form. "Trawsfynydd's nuclear power plant has stopped producing electricity since 1993, and is now being decommissioned. The Authority considers that another Nuclear Power Station would not be acceptable in the National Park. "We believe that it is not consistent with the wording of Change 187 to Policy 27 which promotes low carbon businesses on the Trawsfynydd site. The possibility of nuclear power generation at the Trawsfynydd site should not be exempted in the future - we believe that the door should be kept open for any suitable development on the site.

033 006 John Harold Snowdonia 50 ,51 3.36,3.38,3.42 Recognise the existence and importance of National Policy to safeguard mineral resources. We Society therefore welcome some of the additional proposed wording in this section regarding the protection of the National Park's landscape as set out in PPW.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 032 015 Nia Davies Gwynedd Council 50 -52 3.36 E A specific reference should be included in these sections to consider the proposed Slate Industry World Heritage Site, particularly in relation to the design of waste slates.

040 001 Peter Moore General comments regarding the apparent proliferation of hydro schemes in Snowdonia and on National Trust land and the perceived damage they are doing to watercourses. The NT and SNP are doing harm to Snowdonia’s natural ecology!! The NT and the SNP within the wider political umbrella are defiling their Raison D’etre, that is:- “to conserve areas of natural beauty” “Forever for Everyone” (NT) Economic and social wellbeing does not mean manmade devices on these natural upland features. Would like for no more upland rivers polluted with hydro scheme dams.

015 001 David Woodford Concern expressed about the large number of hydro schemes being permitted in the National Park - The concrete dams, scarring pipe routes, interference to rivers, contradict the basic principle of National Parks.

013 020 Welsh Waste: RWPs (Regional Waste Plan) references should be deleted where appropriate. Government Planning

Protecting and Enhancing the Cultural and Historic Environment

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary 032 016 Nia Davies Gwynedd 50- 63 4.2 7 The references to protecting and enhancing heritage and cultural assets of the Council National Park area are welcomed. In particular we welcome the references to the proposed Slate Industry World Heritage Site.

032 017 Nia Davies Gwynedd 66 4.31-4.32 The reference to the possibility of restoration and / or redevelopment of buildings for Council employment uses is welcomed.

Promoting Healthy and Sustainable Communities

RespID RepsID First Surname Organisation Page No Paragraph Policy Officer Summary name No No 013 002 Welsh 72 5.4 The Authority should explain the implications (if any) of the latest 2014-based projections on the plan. Government Planning

013 003 Welsh 72+72,73 5.4+5.5 The Welsh Government does not object to the level of housing provision. We consider it necessary for Government the level of housing provision, plan requirement and a list of all the allocated housing sites to be Planning included in policy, not the supporting text.

013 008 Welsh 73 The contribution from windfall sites in Change 115 comprises small sites only. The Authority should Government explain why large windfall sites (of 5+ units) have not been included in the housing supply? The Planning Authority should consider whether the current windfall allowance is robust, and consider the need for an indicator in the monitoring framework to record the take-up of large windfall sites.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 013 007 Welsh 74 5.7 The planning status of some allocated sites is unclear in the housing components table e.g. land Government adjacent to Capel Horeb, and the Authority should ensure there is no double-counting between allocated, Planning completed and committed sites (Change 117).

013 004 Welsh 80 Of the 16 allocated sites listed (in Change 147), 11 are identified for 100% affordable housing, which Government accounts for almost 70% of all allocations in the plan; a figure well above that in the adopted LDP. The Planning Authority should robustly evidence the delivery of allocations for affordable housing. The flexibility afforded in para 5.19 to the release of 100% affordable housing sites for market dwelling should be explained and considered in the context of Strategic Policy G.

013 009 81 G Affordable Housing Viability - Affordable Housing Study and Site Viability. Welsh Government requires Welsh clarification on the viability of submarket areas when considered against benchmark land values. Also, Government the appropriateness of the thresholds in Policy G will need to be justified. The Authority should include a Planning density policy in the LDP.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 013 011 Welsh 86 5.33 The Authority should review the criteria in Policy 13 to ensure they are not overly restrictive. Criterion (i) Government does not accord with Welsh Government Circular 30/2007 (Annex B) and should be deleted. The criterion Planning is not considered to promote the equal rights of gypsy and travellers with all other citizens, as the requirement to ‘evidence need’ would not be a restriction placed on non-gypsy and travellers. Criterion (v.) should also be reconsidered in this respect.

013 010 Welsh 87 5.33 We note that a Gypsy Traveller Accommodation Needs Assessment (GTANA) has been undertaken by Government both Gwynedd and Anglesey (2016) and Conwy (2017) which covers the National Park. However, neither Planning GTANA’s cover the whole plan period up to 2031. The Authority should ensure that it has assessed the need for Gypsy and Traveller provision for the entire plan period up to 2031 and make appropriate provision.

Supporting a Sustainable Rural Economy

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 032 020 Nia Davies Gwynedd 66-100 6.13 27 Support of the development of Trawsfynydd and Llanbedr airport sites is a key factor in the Council development of the Meirionnydd economy. In this regard we welcome and support the significant revisions to the Plan to reflect this. Support the reference to developments that will maintain and improve the skills of the local population. (change 175)

032 021 Nia Davies Gwynedd 66-100 6.13 27 We suggest that the supporting text (change 181 - 183) could provide additional information about Council the possibility of a scheme to generate nuclear power at Trawsfynydd which would reinforce the reference to low carbon energy in the Policy text.

032 022 Nia Davies Gwynedd 66-100 6.13 27 We agree with the Authority's intention to secure appropriate Masterplans to inform development on Council sites (change 176).

032 023 Nia Davies Gwynedd 66-100 6.13 27 The Council also recognizes the wish of the Park Authority to ensure that new buildings of Council appropriate size and design (change 178) and that developments are not detrimental to the character of the area (change 178) or contrary to the special purposes / qualities of the Park (change 180). We are, however, concerned that these references are vague and open to interpretation in a way that could significantly hinder the development of the sites.

032 024 Nia Davies Gwynedd 66-100 6.13 27 We suggest that the Policy may benefit from the inclusion of an additional criterion to reinforce Council Development Policy 18. This is the suggested text: 'the proposal must incorporate appropriate mechanisms to mitigate any adverse effects of the proposed development on the Welsh language and culture or contribution will be made towards to mitigate those effects in accordance with Development Policy 18.'

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 032 018 Nia Davies Gwynedd Council 95-96 6.6 The reference to the Eryri Enterprise Zone and the Trawsfynydd and Llanbedr sites is welcomed in particular.

034 005 The Welsh 95-96 6.6 Would like for paragraph 6.6 to be amended - proposed changes underlined. Government and “The Welsh Government designated the site of the former nuclear power station at Snowdonia Trawsfynydd and the former Defence Evaluation Research Agency airfield at Llanbedr as Aerospace LLP the Snowdonia Enterprise Zone (SEZ) in 2012. The sites have been designated by the Welsh Government for business and employment uses, with a focus on development within the low-carbon energy, research and development (related to ICT, energy and environmental sectors), employment related training and education purposes, or aerospace sectors and emerging technologies. The Magnox power station is currently being decommissioned and the site remediated, however a number of new uses are being sought for the site and various studies have been undertaken. Llanbedr Airfield benefits from the granting of an application for a Certificate of Lawful Use for remotely piloted aerial systems (RPAS) testing and evaluation for the research & development, testing and evaluation of unmanned aerial vehicles (UAVS). Planning permission has also been secured for aircraft maintenance, repair and overhaul (MRO) including decommissioning / disassembly and parts recovery together with engineering training at the site. Other appropriate uses are also being sought at the Llanbedr site. The Authority is supportive of the development of the SEZ in line with Development Policy 27.”

035 009 The Nuclear 95-96 6.6 Would like paragraph 6.6 to be amended – proposed changes underlined. Decommissioning “The Welsh Government designated the site of the former nuclear power station at Authority and Magnox Trawsfynydd and the former Defence Evaluation Research Agency airfield at Llanbedr as Limited the Snowdonia Enterprise Zone (SEZ) in 2012. The sites have been designated by the Welsh Government for business and employment uses, with a focus on development within the low-carbon energy, research and development (related to ICT, energy and environmental sectors), employment related training and education purposes, or aerospace sectors and emerging technologies. The Magnox power station is currently being decommissioned and the site remediated, however a number of new uses are being sought for the site and various studies have been undertaken.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No Llanbedr Airfield benefits from the granting of an application for a Certificate of Lawful Use for remotely piloted aerial systems (RPAS) testing and evaluation for the research & development, testing and evaluation of unmanned aerial vehicles (UAVS). Planning permission has also been secured for aircraft maintenance, repair and overhaul (MRO) including decommissioning / disassembly and parts recovery together with engineering training at the site. Other appropriate uses are also being sought at the Llanbedr site. The Authority is supportive of the development of the SEZ in line with Development Policy 27.”

032 019 Nia Davies Gwynedd Council 96 H The purpose and intention of the policy and the adjustments to the proposed wording in terms of business development and current employment support are welcomed, but it is suggested that criterion (ix) should be amended, in order to avoid misunderstanding and ensure that the alternative location is consistent with the development plan strategy of neighbouring authorities.

013 013 Welsh 96 H The Authority may wish to consider a new safeguarding policy for key existing employment Government sites (e.g. Bala Enterprise Park) to protect and retain employment uses up to 2031. On such Planning sites, Policy H (Criteria vii-ix) would not apply.

013 014 Welsh 97 19 Employment - Safeguarding Policy and the Rural Economy: Policy 19 is overly restrictive in Government that it does not include the possibility of new build outside settlements. Planning

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 033 025 John Harold Snowdonia 98 We are supportive of job creation and of the National Park’s current and potential support Society and inspiration for appropriate enterprise. Creating the right conditions so that jobs are genuinely sustainable and contribute to the well-being of Snowdonia as a whole is not an easy task. There are questions about the nature of the developments which might emerge from the Snowdonia Enterprise Zone. The ELDP needs to adequately anticipate the possible outcomes and ensure that they do not compromise the statutory purposes of the National Park. The ELDP review provides a welcome opportunity to establish policy tailored to the Enterprise Zone. Such policy will allow National Park purposes to be put into effect. To do this successfully, policy must take account of the impacts of Enterprise Zone developments on neighbouring areas of the National Park which lie outside the Enterprise Zone. These impacts include direct environmental impacts such as light pollution, noise and traffic as well as the direct impacts of buildings and activities on the respective sites.

033 026 John Harold Snowdonia 98 6.17 Strongly support the proposed wording of Paragraph 6.17. Society 034 006 The Welsh 99 6.21 Would like for paragraph 6.21 to be amended - proposed changes underlined. Government and “The design, height, scale and siting of aviation and aerospace related buildings at the Snowdonia Llanbedr Site have to meet specific operational requirements. Due to its open nature, any Aerospace LLP new buildings on the Llanbedr site should generally be restricted to be no higher than existing buildings, to ameliorate their visual impact, unless there are exceptional or operational circumstances, in which case a clear evidenced justification will be required. The detailed consideration of design, height, scale and siting of development would be guided by the outline masterplan for the site and be informed by robust technical assessment in respect of landscape and visual impact.”

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 033 028 John Harold Snowdonia 99 6.2 Wording of paragraph 6.20 needs reinforcing to be meaningful. New buildings will need to Society exhibit a coherent design - it is extremely easy to think of examples where industrial buildings might fall short in this respect. The scale and nature of any new development must not detrimentally affect the character of the area. We have further specific questions about the Masterplan – who writes it, what does it contain, how is it scrutinized, how is it signed off and by whom.

033 029 John Harold Snowdonia 99 6.22 Paragraph 6.22 is supported. Society 035 010 The Nuclear 99 6.19 Would like for paragraph 6.19 to be amended - proposed changes underlined. Decommissioning “The Authority will expect an outline Masterplan to be in place before any significant new Authority and Magnox development commences on the sites. Having a clear strategic framework for the Limited development of the sites will be important in order to prevent inappropriate, piecemeal development and ensure that any new development is coherent and respects its location within the National Park. It should also allow greater certainty to any developer, and allow a quicker determination of planning applications as and when they are received. The Authority will work with the site owners and promoters to develop the outline masterplans following the adoption of the ELDP.”

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 035 011 The Nuclear 99 6.23 Would like to amend paragraph 6.23 - proposed changes are underlined: Decommissioning “This is a 50 hectare (123 acre) 774 hectare (1913 acre) site around the former Authority and Magnox Trawsfynydd nuclear power station, including Llyn Trawsfynydd. The extent of the site is Limited shown in Appendix 9 in the LDP Proposals Map, which corresponds with the SEZ designation. The site benefits from the legacy of its former use in that there is a source of cooling water from Wales’ largest man-made lake and a national grid substation that delivers a large and reliable electricity supply. The Authority recognises that the development of the site will be entirely dependent on progress with the site’s decommissioning programme. The LDP allocation corresponds with the SEZ designation as this recognises the importance of the lake as an integral part of the opportunity presented at the site, particularly for energy generation. The Authority does not anticipate that the lake will come forward for development and a However, development is anticipated to be focused on the area identified in the plan allocation, which extends to approximately 58.23 hectares. A broad development area has been defined which provides flexibility and scope for innovative development proposals to come forward which do not have a detrimental impact on the character of the area. Development is anticipated to be focused on the area identified in the plan allocation, which extends to approximately 135 hectares (334 acres).”

035 012 The Nuclear 99 6.24 Would like to amend the first sentence in paragraph 6.24 - proposed changes are underlined. Decommissioning “The National Park Authority expects to work closely with the site owners and Authority and Magnox promoters...” Limited 035 013 The Nuclear 99 6.25 Would like to amend paragraph 6.25 - proposed changes underlined. Decommissioning “The policy supports the on-going decommissioning, radioactive waste management, and Authority and Magnox site remediation process at Trawsfynydd – a process governed by national strategies which Limited are subject to regular review and consultation and recognised as a material consideration in planning decisions. Any works associated with decommissioning, and radioactive waste management and site remediation at the site will be supported by the Authority subject to compliance with the policies of the ELDP. The Authority is aware that the Environment Regulators have issued draft guidance1 which requires Magnox (and other Nuclear Site Licence holders) to review the site-wide waste management approach to identify

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No and deliver an optimised site end state. This includes consideration of site end state which may involve options for the in-situ disposal of existing sub-surface structures and the onsite disposal of any associated above ground portion, together with the approach to managing land contamination. The Authority will engage with Magnox during the plan period to keep updated on progress with decommissioning.”

041 003 Angharad Wyn Cyfoeth Naturiol 99 6.23 NRW wish confirmation as to the extent of the allocation at Trawsfynydd , there is currently a Crump Cymru/ Natural discrepancy between the proposed allocation plan and the text confirmed as change 181 as Resources Wales the proposed allocation area and the SEZ designation does not correspond. The SEZ allocations (PME/03) that forms part of the 'Proposals Map and Inset Maps' confirms that the allocation does not include Llyn Trawsfynydd. Provided the Lake is excluded, we are satisfied that the allocations falls outside the areas identified as flood risk. Should it be confirmed that the allocation area includes Llyn Trawsfynydd, which is located within C2 of the Development Advice Map (DAM) contained in TAN15, as previously confirmed we would suggest that only water compatible development should be located within the area of the lake. As such, we would recommend that the wording of Development Policy 27 is amended accordingly to reflect the uses that could be approved on the Lake given that it is located within a flood risk area.

041 017 Angharad Wyn Cyfoeth Naturiol 99 6.19 We note that Development Policy 27 criteria (v) confirms the need for development within both Crump Cymru/ Natural Enterprise Zones to be in line with an agreed outline Masterplan. For any Masterplan to Resources Wales provide a clear strategic framework to guide any development proposal, this can only effectively lead to an implementable scheme if the outline proposal is developed based upon full knowledge of the landscape, visual and environmental resource issues. There would be a need to scope potential adverse effects and then to positively address them in the outline Masterplan. We recommend that development guidelines including a Design Code and Landscape Strategy is produced.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No Given the location within the National Park, we strongly recommend that a landscape lead approach to developing the site Masterplan is undertaken. This should be a co-ordinated exercise, working alongside a range of potential employment and development options to test the capacity of the landscape to accommodate change. We consider that the policy wording needs to confirm this landscape led approach.

041 018 Angharad Wyn Cyfoeth Naturiol 99 6.21 We note that the new text confirms that ‘due to its open nature, any new building on the Crump Cymru/ Natural Llanbedr site should generally be restricted to be no higher than existing building to Resources Wales ameliorate their visual impact, unless there are exceptional or operational circumstances, in which case a clear evidenced justification will be required’.

033 027 John Harold Snowdonia 99+100 6.19+24+6.27 27 ‘The Authority will expect an outline Masterplan to be in place before any significant new Society development commences on the sites’. We support this statement and the rest of section 6.19, however it is not sufficiently robust. The Masterplan must: • be prepared before any significant development can occur • be compatible with and conform to National Park plans and policies • be approved by the National Park Authority • demonstrate regard for National Park purposes by taking account of the impacts of developments on neighbouring areas of the National Park which lie outside the Enterprise Zone. These impacts include direct environmental impacts such as light, noise and traffic as well as the direct impacts of buildings and activities on the respective sites.

033 030 John Harold Snowdonia 100 27 Development Policy 27. The use of the wording ‘will be supported’ and ‘will be accepted’ is Society likely to create confusion and could be seriously misleading. The wording creates the impression of being highly permissive and as such is unacceptable. In all cases it is necessary, as acknowledged elsewhere, to respond to proposals on a case by case basis. As such any wording which suggests a presumption in favour of permission is not acceptable. This is especially true given the wide range of possible and potential developments at these sites, including novel categories which will require considerable new work to reach a proper evaluation of their impacts on the immediate and surrounding areas of the National Park. 36

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No In place of ‘will be supported’ and ‘will be accepted’ we suggest ‘may be appropriate’ as a form of wording less vulnerable to misunderstanding or misinterpretation.

034 007 The Welsh 100 6.27 Would like changes to the Proposal Map of Llanbedr Enterprise Zone so that it 'comprises a Government and single redline boundary for the site'. In addition would like changes to the wording of para 6.27 Snowdonia in order to support the boundary of the site. These proposed changes can be seen below: Aerospace LLP For clarity and consistency, the LDP allocation for Llanbedr shows the area where the focus of development will be. A larger area has also been identified on the maps which corresponds with the SEZ designation, here development associated within the uses proposed for the site will be considered on a case by case basis in line with the requirements of the policy. The LDP allocation for Llanbedr corresponds with the SEZ designation in order to provide flexibility and maximise the site’s economic development potential, subject to technical consideration and where proposals do not have a detrimental impact on the character of the area. However, given known site constraints, including for example the existing runways, it is not anticipated that all of the site will be suitable for development. The Authority is aware that the site’s owners have undertaken some initial work to prepare a masterplan for the site and an area of approximately 35 hectares (86 acres) has been identified as the focus new development. The Authority recognises that there will be a need for small scale new development within the wider site for operational and safety reasons, but any significant new development and uses will be focussed within the North-eastern area of the site. The National Park Authority expects to work closely with the site owners to develop an outline masterplan to guide new development on the site. New development proposals will be subject to the criteria provided in Policy 27. Delivery of new uses on the site is anticipated during the first 10 years of the plan period – this will be monitored as part of the regular plan review process.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 034 008 The Welsh 100 27 Agree with the permitted uses set out in Development Policy 27 for Llanbedr. However, Government and would like to reconsider the wording in bullet point 2 to include and permit 'other local non- Snowdonia aviation and aerospace related industries to locate to the site.' With regards to Part A of the Aerospace LLP Policy, 'the Authority would wish to promote development of a high standard of design so that development proposals make a positive impact on the National Park.' Also, believes 'paragraph 6.18 stipulates that this is recognised through the policy (i.e. Development Policy 27), we are concerned that Criterion (i) is at odds with paragraph 6.18 and could have the potential to restrict some opportunities for the SEZ.' Changes to the wording of Part B are proposed as follows: “B. Llanbedr Within the wider Enterprise Zone area as identified on the proposals maps development associated with the uses below will be considered on a case by case basis. Within the Snowdonia Enterprise Zone allocation at Llanbedr, as identified on the proposals maps, the following uses will be accepted: o operations and uses associated with the aviation and aerospace industry, including those associated with airfield infrastructure and services and airspace management; o new uses including employment (B1, B2, B8) and other uses associated with research and development (including those related to aviation and aerospace industries); o employment-related training and education purposes; o other uses ancillary to the uses identified above including accommodation, catering and leisure. New development proposals will be guided by an outline masterplan for the site and will be considered against the requirements of this policy.”

034 010 The Welsh 100 In summary, the Welsh Government and Snowdonia Government and Aerospace LLP welcome the positive policy support provided within the revised LDP for Snowdonia existing and future development at the Llanbedr site. Aerospace LLP 035 018 The Nuclear 100 The NDA and Magnox welcome the positive policy support provided within the revised LDP Decommissioning for existing and future development at the Trawsfynydd Site. Authority and Magnox Limited

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 035 001 The Nuclear 100 The NDA and Magnox would like to confirm their support for the following revisions to the Decommissioning Plan, on the basis that they provide a useful context for the SEZ and the associated Authority and Magnox allocation for Trawsfynydd within the Plan: Limited •Modification to paragraph 1.57 (Ref#46); •Insertion of paragraphs 6.14 – 6.18 (Ref#171-176); •Insertion of paragraph 6.20 (Ref#178); •Insertion of paragraph 6.22 (Ref#180), and •Insertion of paragraph 6.28 (Ref#186).

035 014 The Nuclear 100 27 Agree with the permitted uses set out in Development Policy 27. However, with regards to Decommissioning Part A criterion (i) it must be acknowledged that design is a specific matter and will vary Authority and Magnox according to each development proposal which may come forward at either of the SEZ Limited sites, accordingly design should be appropriate to the scale, nature, location and context of each proposal. We are concerned that while para 6.18 stipulates this is recognised through Development Policy 27 that criterion (i) of the policy is at odds with para 6.18. The NDA and Magnox would not want overly prescriptive design criteria to foreclose potential development proposals coming forward.

035 015 The Nuclear 100 It is noted that Development Policy 27, Part C bullet policy 1 supports "works and uses Decommissioning associated with nuclear decommissioning". However for clarity and consistency, it is Authority and Magnox considered that the policy, Part C bullet point 1 should also explicitly support works and Limited uses associated with 'site remediation' and waste management' this would align with para 6.25.

035 016 The Nuclear 100 Given the request to amend the proposals map allocation for Trawsfynydd it is considered Decommissioning that Development Policy 27, Part C needs to be amended accordingly, therefore it is Authority and Magnox suggested that Development Policy 27 is amended as follows: C Trawsfynydd Limited

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No Within or immediately adjacent to the Snowdonia Enterprise Zone allocation at Trawsfynydd, as identified on the proposals map, the following uses will be accepted: o works and uses associated with nuclear decommissioning, site remediation, and waste management, in line with national strategies and policies for the management of waste (both radioactive and directive), o new uses including B1, B2, B8 and other uses associated with digital/ICT businesses, o low carbon energy businesses and energy generation technologies, o Research and Development (related to ICT, Energy & Environmental sectors), and o employment-related training and education purposes. New development proposals will be guided by an outline masterplan for the site and will be considered against the requirements of this policy.”

041 002 Angharad Wyn Cyfoeth Naturiol 100 27 We note that the Plan includes a new policy, Crump Cymru/ Natural Development Policy 27 Snowdonia Enterprise Zone which is a specific policy relating to Resources Wales development proposals within the Snowdonia Enterprise Zone – Trawsfynydd and Llanbedr. We see this policy as being an important policy to enable development within the enterprise zone and needs to provide a clear set of criteria that guides future development within the sites.

041 004 Angharad Wyn Cyfoeth Naturiol 100 27 Trawsfynydd EZ is located adjacent to SACs, SSSIs and an NNR, the Authority is reminded Crump Cymru/ Natural that they must not normally agree to any of the submitted allocations and the plan unless they Resources Wales are sure beyond all reasonable scientific doubt that any of the proposed allocations' will not adversely affect the integrity of a SAC, SPA or Ramsar sites. We note that criteria (iii) of DP 27 confirms the need for development proposals to have considered the requirements of the Habitats regulations and found to be compliant. We would wish to be involved in discussions with any potential developer of this site at the earliest opportunity with regards to any development that has the potential to affect the features of the above identified protected sites. We would also wish to be involved in the process of preparing a Masterplan for the site which we note forms a requirement under Development Policy 27.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 041 005 Angharad Wyn Cyfoeth Naturiol 100 27 Any future planning application to develop the site at Trawsfynydd will need to consider the Crump Cymru/ Natural impacts of the proposal on protected species and demonstrate that the proposal will not Resources Wales impact on the Favourable Conservation Status of European and Nationally protected species. Should surveys conclude the presence of protected species, then we would expect the application proposal to propose and deliver appropriate mitigation and/or compensation schemes, along with Reasonable Avoidance Measures, to ensure the favourable conservation status of the species is maintained.

041 006 Angharad Wyn Cyfoeth Naturiol 100 27 Geoscience - Trawsfynydd Site Crump Cymru/ Natural At planning application stage, NRW would wish for the submission to include details relating to Resources Wales the existing and historical uses of the site and follow the risk management framework provided in CLR11, Model Procedures for the Management of Land Contamination, when dealing with land affected by contamination. The developers’ attention should be drawn to Environment Agency document ‘Guiding Principles for Land Contamination’ for the type of information that NRW require in order to assess risks to controlled waters from the site. The Local Authority can advise on risk to other receptors, such as human health. NRW would also refer the developer to follow the guidance in the ‘Development of Land affected by Contamination: A Developers Guide, produced by WLGA and Environment Agency Wales’ as well as Groundwater protection: Principles and practice (GP3).

041 007 Angharad Wyn Cyfoeth Naturiol 100 6.27 Development Policy 27 Snowdonia Enterprise Zone. We are satisfied that Criteria A of the Crump Cymru/ Natural Policy provides the criteria that all development proposals within both Snowdonia Enterprise Resources Wales Zone areas needs to conform with including the need for development proposals to have considered the requirements of the Habitats Regulations and to offer a high standard of design that reflects the outstanding landscape setting and Special Qualities of the National Park. As currently set out, we consider that criteria B of Development Policy 27 is unclear in terms of providing a development criteria for development within the Llanbedr Enterprise Zone. NRW considers that two separate development criteria’ are required for development within areas PME/01 and PME/02 of the Llanbedr site.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No Both criteria need to confirm that all development proposals will need to demonstrate compliance with the criteria set out in Technical Advice Note 15 (TAN15).

041 012 Angharad Wyn Cyfoeth Naturiol 100 6.27 We note that Development Policy 27 criteria (v) confirms the need for development within the Crump Cymru/ Natural site to be in line with an agreed outline Masterplan. We confirm that we have had sight of the Resources Wales Masterplan referred to, ‘Llanbedr Aviation Centre & Enterprise Park – Masterplan Report January 2014’. The Masterplan (Figure 2) locates highly vulnerable development including residential uses within areas that have been confirmed in the SFCA as being at flood risk and unsuitable for development and therefore we do not consider that this Masterplan provides any basis for any future Masterplan that would provide a strategic framework for development as part of the Eryri LDP. We would wish for the LDP to confirm that NRW would wish to be part of the process of developing a new Masterplan that serves to guide future development within the site.

041 013 Angharad Wyn Cyfoeth Naturiol 100 Part of the Llanbedr site is within Morfa Dyffryn Site of Special Scientific Interest (SSSI) and is Crump Cymru/ Natural immediately adjacent to Morfa Harlech a Morfa Dyffryn Special Area of Conservation (SAC). Resources Wales The northern end of the site is also adjacent to Morfa Dyffryn NNR. As a competent authority for the purposes of the 2010 Regulations, your Authority must not normally agree to any of the submitted allocations and the plan unless you are sure beyond reasonable scientific doubt that any of the proposed allocations’ will not adversely affect the integrity of a SAC, SPA or Ramsar site. Referring to the outline mitigation options that have been considered in the SFCA’s that we have separately commented on, which includes options to raise parts of allocation area PME/01 to ensure that any development would remain dry during a flood event, although we have not commented on any formal mitigation proposals, we wish to confirm that any proposals to raise land levels will need to be assessed under the 2010 Regulations. In particular, further consideration will need to be given to possible coastal squeeze as a result of land raising. NRW will be able to provide further comment on this matter once we have engaged in further discussions with the SNPA and Welsh Government with regards to allocating this site.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 041 014 Angharad Wyn Cyfoeth Naturiol 100 We are aware that a suite of ecological surveys has been carried out for this site in Crump Cymru/ Natural 2015/2016/2017 by ARUP on behalf of the airfield and consider this to provide a useful Resources Wales baseline to confirm the protected species that make use of this site including assessment of potential effect on the features of the protected site. We consider that these surveys also provide a baseline to shape how much survey effort is required to inform any future development proposal on site. Any planning application will need to consider the impact of the proposal on protected species and demonstrate that the proposal will not impact on the Favourable Conservation Status of European and Nationally protected species. Should surveys conclude the presence of protected species, then we would expect any application to propose and deliver appropriate mitigation and/or compensation schemes, along with Reasonable Avoidance Measures, to ensure the favourable conservation status of the species is maintained.

041 015 Angharad Wyn Cyfoeth Naturiol 100 At planning application stage, we would wish for the application to include details relating to Crump Cymru/ Natural the historical uses of the site and include as a minimum a Preliminary Risk Assessment in Resources Wales line with CLR11 and the EA Guiding Principles for Land Contamination, 2010 (and adopted by NRW). The historical uses should include (but is not an exhaustive list) all fuel and oil storage and refuelling areas, aircraft and vehicle maintenance areas, onsite waste collections area and drainage and effluent treatment plant.

013 012 Welsh 100- 27 The plan allocations do not correspond with the Welsh Government’s EZ designation. Any Government 101 deviation from the Welsh Government’s designation will need to be clearly evidenced and Planning justified by the Park Authority.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 032 025 Nia Davies Gwynedd 102- 6.32- 29 Change 188 to 211 (pages 102 to 108 - 6.32 for Development Policy 29). Would like to see Council 108 references to cycling and events. We recognize the emphasis placed on the natural environment and landscape of the Park as the foundations for the local tourism industry. Would like to note that the unique culture and heritage of the area are also a special quality that increasingly contributes to visitors' enjoyment of the area. The Council believes that extending the availability of quality attractions that are not dependent on the weather is a key part of further developing the tourism industry. We agree with the emphasis of the Park Authority on maintaining and extending the availability of quality serviced accommodation, together with the emphasis on improving the quality of self-catering, camping and alternative accommodation provision.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No

041 028 Angharad Wyn Cyfoeth Naturiol 103 6.34 NRW welcome the inclusion of the additional text to reflect the publication of the two Crump Cymru/ Natural SPGs on landscape (Landscapes of Eryri and Landscape Sensitivity and Capacity Resources Wales Assessment) since the adoption of the LDP in 2011.

030 011 James Harland Cyngor Bwrdeistref 104 21 Need to define 'sustainable or eco-tourism' Sirol Conwy County • Does impact on biodiversity/environment need including as a criteria? Borough Council • (ii) ‘close to’ – needs to be defined • (iv) ‘quiet enjoyment’ ‘quality of life’ – needs to be defined • (vi) ‘…Snowdonia Dark Skies Reserve’ – in line with…?

041 019 Angharad Wyn Cyfoeth Naturiol 105 28 Policy 28. We are satisfied that the policy wording seeks to conserve landscape Crump Cymru/ Natural character and require development to be appropriately integrated. We note that a visitor Resources Wales accommodation SPG is proposed and we would welcome being consulted on this SPG at the appropriate time.

041 029 Angharad Wyn Cyfoeth Naturiol 105 6.39 NRW welcome the inclusion of the additional text to reflect the publication of the two Crump Cymru/ Natural SPGs on landscape (Landscapes of Eryri and Landscape Sensitivity and Capacity Resources Wales Assessment) since the adoption of the LDP in 2011.

030 012 James Harland Cyngor Bwrdeistref 106 22 Consider including 'environmental impact' to Development Policy 22. Sirol Conwy County Borough Council

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 041 030 Angharad Wyn Cyfoeth Naturiol Cymru/ 106 22 NRW notes the additional policy wording proposed and are satisfied that the Crump Natural Resources replacement of any static units with chalets or alternative accommodation units will only Wales be permitted where there is an overall improvement to the site and there is no unacceptable impact on the landscape. The word ‘on’ needs to be inserted into the additional text between ‘impact landscape’. NRW would however welcome the policy providing some clarification on how improvements to existing sites can be achieved.

033 015 John Harold Snowdonia 106 6.40 22 Static Caravans and Chalets. Support the proposed changes subject to the fact that Society the range of accommodation remains affordable to all. 6.40 ‘The Authority will support the replacement of static caravans with appropriately designed chalets if there is an overall improvement to the site and its impact on the surrounding landscape is reduced.’ Development Policy 22: Chalet and Static Caravan Sites (22) ‘The replacement of static units with chalets or alternative accommodation units will be permitted where there is an overall improvement to the site and there is no unacceptable impact [on] landscape.’ We recommend the two statements be made consistent with each other, for example by combining them: ‘…there is no unacceptable impact on landscape and there is an overall reduction in landscape impacts.’

030 013 James Harland Cyngor Bwrdeistref 107 23 Development Policy 23 Sirol Conwy County (i) ‘Reduction of its impact’ – needs to be defined Borough Council (iii) Delete ‘where appropriate’_ (iv) Add biodiversity (v) ‘in keeping with’ – needs to be defined

033 017 John Harold Snowdonia 107 23 Development Policy 23, strongly support this proposed change, which seems to align Society with our comments regarding para 6.42.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 033 016 John Harold Snowdonia 107 6.42 Support para 6.42 but it is incomplete, it should be amended to also prevent conversion of Society camping pitches to chalets or luxury lodges.

033 018 John Harold Snowdonia 107 6.43 Welcome the attention given to novel temporary accommodation types which have been Society inadequately covered by existing policy. Policy needs to accommodate both large-scale and small-scale applications in this category and needs to account for the potential detrimental impacts on the landscape, nature conservation or public enjoyment. Is there evidence for a particular pattern of development of these types of application. View is that small-scale sporadic developments are most likely, although policy clearly also needs to address the possibility of major field scale applications.

033 019 John Harold Snowdonia 107 6.43 Para 6.43 Pods, yurts, tepees, shepherds huts and wooden tents. This definition needs Society tightening to reflect likely impacts rather than just styles of accommodation. In our view ‘pods’ do not sit easily in this list or indeed under the heading of ‘low impact’ accommodation. We suggest therefore that the definition of the category be redrawn to reflect the nature and scale of likely impacts.

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No This might involve specifically excluding developments which would be directly connected to services. An alternative would be to specifically include pods and similar ‘plumbed in’ developments under the policy section for cabins or chalets. If well sited, well screened, and well managed, at an appropriate scale and in appropriate locations we can see a useful role for low impact accommodation to contribute to the mix. However, the suggestion in section 6.43 that these types of accommodation are ‘generally less intrusive’ seems to be based on assumptions about scale and siting for which we can see no direct evidence.

033 020 John Harold Snowdonia 107 6.44 The proposal that these types of development be restricted to agricultural diversification or Society existing tourist attractions is both too permissive and too restrictive and we strongly suggest that it be redrafted. It is too restrictive in that there is no logical reason why a well- sited application at an appropriate scale should not be given consideration simply because it is neither an agricultural diversification project nor attached to an existing tourist attraction. In all cases the likely impact of such developments on Dark Sky quality must be adequately assessed and evaluated. Suggest the following wording ‘Due to sensitivity of the landscape, such proposals will be considered only in locations where they will not have negative impacts on the landscape or natural environment.’

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 033 021 John Harold Snowdonia 107 6.45 6.45 – we strongly support the proposed change Society 030 014 James Harland Cyngor Bwrdeistref 108 29 Development Policy 29 Sirol Conwy County (i) ‘does not become’ – needs to be defined Borough Council (ii) Additional landscaping may be beneficial? (iii) . …landscape character or highway safety? (iv) Should ‘existing facilities’ read existing building

033 024 John Harold Snowdonia 108 29 Propose the following changes to Development Policy Society 29. Replace word 'permitted' with 'considered'. Delete criterion one and replace with the following; the proposed development does not include installation of electricity or water services or provision of drainage facilities for WC, showers and washing. Moreover, propose to delete - 'New sites which are not linked to an agricultural diversification scheme or an existing visitor attraction will not be permitted.'

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 041 020 Angharad Wyn Cyfoeth Naturiol 108 29 Policy 29 ‘Alternative Holiday accommodation’ Crump Cymru/ Natural We are satisfied that the policy wording seeks to conserve landscape character and require Resources Wales development to be appropriately integrated. 033 022 John Harold Snowdonia 108 6.46, 6.47 Pods are often installed with some degree of service connectivity which means they do Society not necessarily or comfortably fit the criteria of being ‘low impact’ and ‘temporary’ structures. We suggest that the definition of this category of accommodation needs further consideration to ensure clarity and exclude inconsistency.

033 023 John Harold Snowdonia 108 6.52 Paragraph 6.52 appears difficult to enforce. Society

013 015 Welsh 108 6.52 Paragraph 6.52 of the LDP should clearly state the occupancy restriction of 28 days Government applies to the occupant and not the ‘occupation’ of the accommodation. Planning

032 026 Nia Davies Gwynedd Council 109- 6.55 24 Support the Authority's intention to maintain the vitality of the commercial centres within 110 of the National Park area, as there are advantages to allowing the change of use of

RespID RepsID First Surname Organisation Page No Paragraph No Policy No Officer Summary name shops to alternative commercial uses.

Promoting Accessibility and Inclusion

RespID RepsID First Surname Organisation Page Paragraph Policy Officer Summary name No No No 032 028 Nia Davies Gwynedd Council 116- 7.13 26 Ensuring up to date telecommunications connectivity is an important key 117 to the future economic and social sustainability of the Park area. In this respect, there is a balance to be struck between maintaining the Special Qualities of the Park and making sure that businesses and residents have the most up to date standard of connectivity.

041 031 Anghara Wyn Cyfoeth Naturiol 116- 7.13 NRW note that the updated contextual information refers to the adoption d Crump Cymru/ Natural 117 of the Landscape Sensitivity and Capacity Study SPG which will aid the Resources Wales decision-making process for planning applications relating to the construction of mobile phone masts in the National park.

032 027 Nia Davies Gwynedd Council 118 Suggest that the Plan refers to the two Joint Local Transport Plans rather than the Regional Transport Plans.

Background Papers

RespID RepsID First Surname Organisation Background Officer Summary name Paper 038 001 Patricia Anne 6: Green Affordable Housing Exception Sites to include Green Wedges as per other LPA areas or a full review of green Owen Wedges wedge policy as per the Brecon Beacons National Parl LDP and Merthyr Tydfil County Borough Council LDP (2016- 2031) Green Wedge Background Paper.

013 005 Welsh 7: Housing The Authority should evidence the delivery of sites, any key infrastructure requirements and associated costs, Government together with an indication of key timings, phasing and funding mechanisms. This will be essential to ensure all Planning allocations are deliverable over the plan period.

017 002 Evan Owen Bywyd Cymru 7a: Housing The Gwynedd and Ynys Mon JLDP paper "Action Point S1/PG1 Local Housing Market Assessment (LHMA) has details of the need for Gwynedd which says in paragraphs 2.2.8 and 2.2.9 that Gwynedd has a need for 709 affordable dwellings per annum and the area outside the SNPA has a need for 592 per annum which leaves 117 per annum for the area of Gwynedd which is inside the boundaries of the SNPA. This is in addition to the need in Conwy BC. According to Arfon Hughes the Rural Housing Enabler the current need in the SNPA is: "Rhestr Tai Cymdeithasol": Yng Ngwynedd mae una 782 yn ardal y Parc ac yng Nghonwy mae yna 96! "Rhestr Tai Teg Gwynedd and Camau Cyntaf/First Steps Conwy": Yng Ngwynedd mae yna 92 wedi rhoi pentrefi a threfi yn y Parc fel dewis cyntaf ac mae yna 7 wedi rhoi dewis cyntaf ar restr tai cost isel/canolraddol Camau Cyntaf/First Steps yn Nghonwy. This indicates that the LDP may not be sound because the research is out of date.

RespID RepsID First Surname Organisation Background Officer Summary name Paper 017 001 Evan Owen Bywyd Cymru 7a: Housing The current JHLAS (July 2017) indicates a rapid decline in land availability over a 5 year period from 9.3 years to 5.4 years. Something needs to be done to counter this. The lack of housing is what causes the declining population. This indicates that the Plan is unsound because research is incomplete as far as Gwynedd is concerned so it doesn't fit with their LDP, because the actual figures are far higher than is assumed in SNPA documents.

013 006 Welsh 7a: Housing The land supply table in Appendix 2 must be calculated on the requirement of 770 dwellings with the associated Government graph totalling plan provision (of 810 units) to include flexibility. In essence a trajectory has two elements. One that Planning demonstrates flexibility over the plan period (graph) and one that demonstrates a 5 year supply linked to the housing requirement (supply table). A housing trajectory will greatly assist all parties to understand the delivery of sites over the plan period.

013 018 Welsh 9: Minerals Buffer zones should only exist around permitted and proposed sites, in line with national policy (MTAN 1, paragraphs Government 70 & 71). Planning

Inset Maps

RespID RepsID First Surname Organisation Settlement Officer Summary name 021 002 Dewi Griffiths Dŵr Cymru Aberdyfi Aberdyfi Former Primary School: a water supply can be provided to the site.

031 001 J Barrie Betws y Coed Would like land in Betws y Coed to be included within the housing development boundary.

031 002 J Barrie Betws y Coed Supports the inclusion of site ADSAF027 within the plan as an extension to the housing development boundary to provide an opportunity for a small scale housing development to meet the housing needs of the service centre and community.

006 001 Keith Bartlett Bryncrug Representation for a new site allocation for Local Self-Build Affordable Housing adjacent to Erw Goch, Bryncrug. This proposed development would improve the free flow of traffic in this area whilst providing a local self-build affordable housing site for my family to build on and remain in the local area.

026 001 Alison Cousins Capel Curig Capel Curig Would like more land to be available for Housing in Capel Curig - has suggested to include the land Community adjacent to the Dolydd Terrace Council Houses. Additional Papers with hard copy. Council

014 001 Alan Gayden Harlech Coed Can the inspector look into the problem of no footpath on the main Road (A496) as this is the likely access Pottery Ystymgwern point to the site. Nothing the difficulty in making a safe transit off and onto the site from A496. This I feel is a major drawback to the site. If solved will then not be a problem, but how will it be solved?

012 001 Charlene Sussums- Carter Jonas Coed Representation requesting inclusion of land for housing adjacent to Llwyn y Gog Coed Ystumgwern. Lewis LLP Ystymgwern The Site has been divided into three areas. Using the national housing density of 30 dwellings per ha, the following residential numbers could be achieved: Area 1 = 0.24ha (7 dwellings), Area 2 = 1.2ha (36 dwellings), Area 3 = 1.91ha (57 dwellings). The provision of good quality housing stock is needed to prevent occupants from leaving the village and migrating to the larger nearby settlements.

RespID RepsID First Surname Organisation Settlement Officer Summary name The development would also boost the pupil numbers in the local schools and therefore develop further welsh speakers. A viability study and sustainability appraisal have also been prepared, both of which conclude that the development of the site would lead to a sustainably located financially viable scheme.

021 003 Dewi Griffiths Dŵr Cymru Dinas Dinas Mawddwy - adj Lawnt y Plas: a water supply can be provided to the site. Mawddwy 021 004 Dewi Griffiths Dŵr Cymru Dolgellau Dolgellau - adj Wenallt Uchaf, 15 units: A water supply can be provided to the site.

011 002 Delwyn Evans Dolgellau Town Dolgellau Request the woodland be a Green Space for recreation. Council Planning Committee

011 001 Delwyn Evans Dolgellau Town Dolgellau A query regarding potential Housing Development at Old Factory at Coed y Pandy in Dolgellau. Council Planning Committee

021 005 Dewi Griffiths Dŵr Cymru Dolwyddelan Dolwyddelan - adj Glan Gors, 6 units: Further development in Dolwyddelan would require the upgrading of the existing water pumping station.

020 001 Rachel Johncock Dolwyddelan Strongly rejects the potential development for Candidate Site ADSAF064 in Dolwyddelan, and states the following reasons such as the land is outside the development boundary. The proposed land is an open scenic countryside, which should not be ruined by houses. The land is important for wildlife, and development also would create an unsightly view resulting in the ruin of the character of the village and the beautiful views. Moreover, the land has very poor access.

RespID RepsID First Surname Organisation Settlement Officer Summary name 023 001 A Roberts Dolwyddelan Rejects the potential development of Candidate Site ADSAF064 in Dolwyddelan as the lanes are inadequate to accommodate the increase in traffic, and parking is already a concern in the area. Moreover, the plot in question is an area of Natural Beauty.

001 001 J.F. Houston Dolwyddelan Agree with housing policy up to now in Dolwyddelan. However, consider Candidate Site ADSAF064 would open up to speculative development and would be unaffordable.

009 001 Clare Johncock Dolwyddelan Agree with rejection of Candidate ADSAF064 in Dolwyddelan. Object to any development on the fields for the following reasons: The site is outside the housing development boundary, the land is unspoilt open countryside and would stand out obtrusively. The site has poor access. New development would cause both noise and visual disturbance. New housing would disturb wildlife including bats. Parts of both fields are prone to water logging and would not be suitable for housing. The smaller of the two fields has a footpath which is used by locals. Question whether any new houses need to be built in Dolwyddelan. 50% of housing in the village is unavailable for locals. Housing associations should be buying up and modernising existing housing stock and not ruining historic villages by building out of character, modern new houses in the open countryside. Absentee landowners. The landowners live away and any development would have no impact on their daily lives, unlike the families that live around the proposed housing development, where there would be major impact. I trust the National Park will continue to uphold their objection.

RespID RepsID First Surname Organisation Settlement Officer Summary name 010 001 V. Ghazzali Dolwyddelan Regarding Candidate Site ADSAF064 in Dolwyddelan, the land is agricultural land and should only be built upon with an agricultural tie attached. The land is not within the current Local Development Plan which includes ample space at Glan-y-Gors for extra housing should a need arise. There is poor access already to the site, and any development of this land would be detrimental to the character and environment of the village.

005 001 H. Toft Dolwyddelan Understand that an application has been made to develop the land known as 'Aberbeinw Fields', candidate site ADSAF064 in Dolwyddelan, states that bats, badgers and barn owls have all been observed on the land, the land is outside the development boundary of the village, and that road access for the residents of Tan y Benar is already a difficulty.

002 001 E.M. Evans Dolwyddelan Consider that Candidate Site ADSAF064 in Dolwyddelan should be rejected for inclusion within the Housing Development Boundary, as there are enough houses in the village already without building more. Also, considers the land to have poor access, and no amenities.

003 001 Anna Johncock Dolwyddelan Agree with rejection of Candidate ADSAF064 in Dolwyddelan, as development on the site would stand out obtrusively having a serious detrimental impact on the visual aesthetics of the historic village. Also, there is no way of accessing the land with large vehicles and no way of accessing the land with smaller vehicles without creating a detrimental impact on a number of existing residents. Any new development on the proposed site would cause both audio and visual pollution to 17 immediate properties. Disturbance of 3 protected British wildlife species. The land is prone to water logging and is largely covered in boggy patches, not just during the winter and periods of heavy rain but throughout the year. The ground is also prone to saturation as a result of rising ground water. There is currently, to my knowledge, no mains water or mains electricity running to the land/existing derelict building. The land is also within the core zone of the dark sky reserve. If housing were to be built, light pollution from street lights and houses would negatively impact the Dark Sky Reserve. An existing development site within the village – a new, ‘affordable housing’ building plot has very recently been established at ‘Glan Gors’ within the village. It is questionable whether any new houses need to be built in the historic village of Dolwyddelan at all, even at ‘Glan Gors’.

RespID RepsID First Surname Organisation Settlement Officer Summary name 004 001 Iolo Hughes Dolwyddelan Considers that Candidate Site ADSAF064 in Dolwyddelan should be rejected as a Housing Development Boundary, as there is enough parking problems within the nearby houses already, and would cause traffic problems and negative social impacts should development occur.

021 006 Dewi Griffiths Dŵr Cymru Dyffryn Dyffryn Ardudwy - Adj Pentre Uchaf, 10 units: A water supply can be provided to the site. Ardudwy 021 007 Dewi Griffiths Dŵr Cymru Dyffryn Dyffryn Ardudwy - Tan y Foel/Capel Horeb, 5 units: A water supply can be provided to the site. Ardudwy 029 001 Claire Hancox Harlech Inclusion of Candidate Site ref ADSAF059, believes that it has been incorrectly identified within the settlement capacity study as having ‘some sections within a flood risk zone’. Would like the text in the settlement capacity study amended in recognition of this error.

041 023 Angharad Wyn Cyfoeth Naturiol Harlech The allocation ref 31/06 land at Penyrhwylfa, Harlech does not comply with the requirements of TAN Crump Cymru/ Natural 15. NRW considers the FCA should be amended to include a more detailed assessment of flooding Resources Wales elsewhere.

021 008 Dewi Griffiths Dŵr Cymru Harlech Harlech - Adj Penrwydfa, 24 units: A water supply can be provided to the site.

RespID RepsID First Surname Organisation Settlement Officer Summary name 021 009 Dewi Griffiths Dŵr Cymru Llanbedr Llanbedr - Adj Bryn Deiliog, 6 units: A water supply can be provided to the site.

021 011 Dewi Griffiths Dŵr Cymru Llanegryn Llanegryn - Tir Rhos Land, 8 units: A water supply can be provided to the site.

028 002 Estelle Patrick Llanfrothen The open space shown in this plan is not open (padlocked with animals grazing and stable erected) - would like to be open and additional access for the local residents.

021 012 Dewi Griffiths Dŵr Cymru Llanfrothen Llanfrothen - Adj Garreg Frech, 6 units: A water supply can be provided to the site.

028 001 Estelle Patrick Llanfrothen The potential development would increase the number of vehicles using the steep narrow Garreg Frech road and will be extremely dangerous for the occupants from Gallt y Ffrwd’s drive which is directly opposite the point of access on the bend in the road. Would like the Authority to reconsider.

021 013 Dewi Griffiths Dŵr Cymru Llanuwchllyn Llanuwchllyn - Adj Maes Padarn, 7 units: A water supply can be provided to the site.

021 014 Dewi Griffiths Dŵr Cymru Pennal Pennal - Adj Maes Teg, 6 units: A water supply can be provided to the site.

021 015 Dewi Griffiths Dŵr Cymru Trawsfynydd Trawsfynydd - Adj Bro Prysor, 10 units: A water supply can be provided to the site.

021 017 Dewi Griffiths Dŵr Cymru Trefriw Trefriw - Adj Ty Capel Peniel, 5 units: A water supply can be provided to the site.

022 001 M Harvey Trefriw Considers that land (72/01) in Trefriw should be included in the Local Development Plan.

024 001 Gary Morris Trefriw Would like for site (72/01) in Trefriw to be included within the Local Development Plan.

025 001 Catherine J. Trefriw Considers that land (72/01) in Trefriw should be included in the Local Development Plan. Westlake

021 018 Dewi Griffiths Dŵr Cymru Y Bala Y Bala - Adj Cysgod y Coleg, 10 units: A water supply can be provided to the site.

RespID RepsID First Surname Organisation Settlement Officer Summary name 021 019 Dewi Griffiths Dŵr Cymru Y Bala Bala - Rear of Red Lion, 55 units: A water supply can be provided to the site.

041 022 Angharad Wyn Cyfoeth Naturiol It is recognized that development proposals within the housing boundary and smaller settlement will be Crump Cymru/ Natural assessed on a cases by case basis at planning application stage. Resources Particular attention will need to be given to landscape matters. Wales

033 032 John Harold Snowdonia Not clear on what objective basis the housing allocation changes have been selected. Has there been any Society consultation on the process or the proposals including, most importantly, consultation with local communities on specific changes in their local area? Do any of the proposals represent parcels of land which local authorities wish to offload? The reason given for some of the proposed changes is ‘rounding off’. However it is unclear what logical and consistent process has been followed and applied. Would like greater clarity on the changes to the Housing Development Boundary in Aberdyfi.

Proposal Maps

RespID RepsID First Surname Organisation Proposal Officer Summary name Map 041 021 Angharad Wyn Cyfoeth Naturiol Area of In landscape character terms, it is likely that the proposals maps show an increase in areas perceived to Crump Cymru/ Natural Natural be natural and the area of conservation habitats. These are positive changes to natural beauty. In the Resources Wales Beauty context of forces for landscape change, the future direction of upland management and rural economy within the national park (relevant to the sustainable management of natural resources), it would be useful to investigate and set out the reasons behind this change within any update to the Eryri Management Plan.

033 031 John Harold Snowdonia Area Of Have changes to ANB boundary been consulted on? Would like to see rationale for the process of Society Natural identifying the proposed changes. Beauty

041 016 Angharad Wyn Cyfoeth Naturiol General There is a need to ensure that all allocations comply with your duty under Section 62 of the Environment Crump Cymru/ Natural Act 1995 which requires public bodies to have regard to National Park purposes when coming to Resources Wales decisions relating to or affecting land within a National Park.

033 007 John Harold Snowdonia Minerals High specification sandstones and igneous rocks occur in much of the high ground in Snowdonia despite Society Safeguarding being described as having a limited geographical extent. Area Puzzled by the inclusion of wind blown sand. These represent multi- designated nature conservation sites for example at Harlech and Dyffryn. These are not appropriate for inclusion as aggregates safeguarding sites and should be removed from the safeguarding map.

013 017 Welsh Minerals The Authority should safeguard both category 1 and category 2 mineral resources on the Proposals Map Government Safeguarding in accordance with the BGS Aggregates Safeguarding Map of Wales. Planning Area

RespID RepsID First Surname Organisation Proposal Officer Summary name Map 021 010 Dewi Griffiths Dŵr Cymru Snowdonia Snowdonia Aerospace Centre, Enterprise Zone: The proposed enterprise zone represents a substantial Enterprise area of land for development for which the potential demands are unknown at present. It is essential that Zone we understand these demands in order to allow us to assess the impact on our assets. It may be necessary for water and sewerage modelling assessments to be undertaken to establish how we would provide the water supply and where the proposed development could connect to the public sewerage system.

021 016 Dewi Griffiths Dŵr Cymru Snowdonia Trawsfynydd Site, Enterprise Zone: The proposed enterprise zone represents a substantial area of land for Enterprise development for which the potential demands are unknown at present. It is essential that we understand Zone these demands in order to allow us to assess the impact on our assets. It may be necessary for water and sewerage modelling assessments to be undertaken to establish how we would provide the water supply and where the proposed development could connect to the public sewerage system.

034 002 The Welsh Snowdonia Given that no Masterplan is currently available for the land, it would be considered premature to limit the site Government and Enterprise area to anything less than the designated SEZ boundary. The redline boundary for the Llanbedr site Snowdonia Zone (identified in the LDP Proposals Map under reference PME/02) delineates a site extending to 227.8 hectares Aerospace LLP (562 acres). Despite the flood risk identified to the northern area of the site, it is important that the redline boundary is not amended to exclude these areas, given that there are existing occupied buildings and uses within this area of the site which form an integral part of the site’s operation and should therefore remain within the identified redline boundary for the Enterprise Zone.

RespID RepsID First Surname Organisation Proposal Officer Summary name Map 035 002 The Nuclear Snowdonia Requests that the LDP Proposals Map allocation for Trawsfynydd be amended so that it comprises the Decommissioning Enterprise focus area for development as delineated by the ‘Snowdonia Enterprise Zone Allocation’ (under Authority and Magnox Zone reference PME/03, together with a redline boundary of the wider Trawsfynydd site. For clarity, the Limited allocation sought is shown on the attached site plan (reference GVA/SLP/02) submitted in support of this representation. It is considered that development can be suitably controlled within the wider Trawsfynydd site. Given known site constraints it is not anticipated that all of the site will be suitable for development. An outlined Masterplan for the site would provide a suitable control over development. New development proposals should be considered in a context of the existing built up nature of the site. New developments is expected to come forward within the extent of the site as shown in Appendix 9.

041 008 Angharad Wyn Cyfoeth Naturiol Cymru/ Snowdonia As previously confirmed, part of the ‘Snowdonia Enterprise Zone Allocation’ is located within Zone C1, Crump Natural Resources Enterprise as defined by the Development Advice Map (DAM) referred to under TAN15 Development and Flood Wales Zone Risk (July 2004). Our flood map which is updated on a quarterly basis, confirms that part of the site is within the extreme flood outline. It should also be noted that the DAM does not include any allowance for climate change. We confirm that we have recently provided advice on three versions of a ‘Strategic Flood Consequence Assessment’ for the Llanbedr Enterprise Zone which has been informed by a coastal flood modelling study. We note that these assessments of the flood risk associated with developing the site have not been formally included as part of the Deposit of the revised Eryri LDP consultation. We confirm that the Assessments that we have provided advice on has considered sea level rise to assess future flood risk. The Assessment confirms that parts of the ‘Snowdonia Enterprise Zone Allocation (PME/01)’ do not comply with the requirements of TAN15 and that certain parts are confirmed as being unsuitable for development under all circumstances. The Assessments have included mitigation options for parts of the allocation area (PME/01), which would include land-raising, that could potentially ensure that any development would remain dry during a flood event. However, we confirm that we have not commented on any formal mitigation proposals. NRW has significant concerns and objects to the ‘Snowdonia Enterprise Zone Allocation PME/01’ as the Assessment that we have reviewed has confirmed that parts of the allocation area is unsuitable for development in all circumstances and therefore does not comply with the requirements of TAN15.

RespID RepsID First Surname Organisation Proposal Officer Summary name Map The potential allocation boundary for PME/01 will need to be revised to reflect the findings of the assessment and to remove areas that have been confirmed as being unsuitable for development in all circumstances. In addition, Development Policy 27 needs to recognize the flood risks associated with developing the allocation area (excluding the areas confirmed as being unsuitable for any development) and confirm that development within this area is only acceptable subject to the LPA in consultation with NRW agreeing appropriate mitigation options that would ensure that the site remains dry during a flood event. We recommend that the Authority requests the submission of the latest assessment of the flood risk that NRW has commented on to inform the LDP process.

041 009 Angharad Wyn Cyfoeth Naturiol Snowdonia We refer you to the Shoreline Management Plan (SMP) which indicates that the plan for this area (Artro Crump Cymru/ Natural Enterprise Estuary South) will be managed realignment beyond the first epoch (2025 onwards). Paragraph 5.7.5 of Resources Wales Zone Planning Policy Wales (PPW) confirms that ‘In low-lying, undeveloped coastal areas, options for coastal defence may include a policy of managed set back. Shoreline management plans will establish long-term local policy frameworks for the management of coastal risk. The priorities contained within them should influence and inform the preparation of development plans’.

041 010 Angharad Wyn Cyfoeth Naturiol Snowdonia The site is within the Ardudwy Marsh Internal Drainage District and as such the area relies on flood defences Crump Cymru/ Natural Enterprise and associated structures to prevent tidal inundation. An IDD also suffers from problems with a water table Resources Wales Zone that is close or at ground level during times of prolonged rainfall events. The defences afford a degree of protection from tidal inundation but defences can overtop/fail if not maintained or when extreme events occur.

RespID RepsID First Surname Organisation Proposal Officer Summary name Map Our consent may be required for any works affecting any watercourse within the site. Part of the site is adjacent to a main river (East Drain) to which we may require access for maintenance purposes. There should be no development within 8m of a main river. Any works in, under, over or likely to affect a main river, may require a Flood Risk Activity Permit (FRAP) from ourselves.

041 011 Angharad Wyn Cyfoeth Naturiol Snowdonia As previously confirmed, parts of the ‘Snowdonia Enterprise Zone’ is located within Zone C1, as defined by Crump Cymru/ Natural Enterprise the Development Advice Map (DAM) referred to under TAN15 Development and Flood Risk (July 2004). Resources Wales Zone Given the flood risk associated with the ‘Snowdonia Enterprise Zone’ (PME/02), it is considered that Development Policy 27 should confirm the flood risk associated with the site and provide a clear definition of the types of development associated with the uses proposed for the Snowdonia Enterprise Zone Allocation that will be permitted within allocation area PME/02. We note that the policy as currently presented includes a list of the type of uses that may be acceptable following consideration on a case by case basis, however we would not be supportive of some of the uses defined including accommodation uses. We consider that the policy should also confirm that parts of the allocation area is within a flood risk area and thus may be unsuitable for development. We consider that the ‘Development Locations’ identified in the latest SFCA is in conflict with the vision of the Deposit LDP for the Llanbedr Enterprise Zone. We have recommended to the Welsh Government that they engage in further discussion regarding these revised ‘development locations’ with yourselves as they would involve developing outside the LDP’s ‘focus area’ and that further consideration is required to the implications of developing outside the focus area, including further consideration of possible landscape effects.

Sustainability Appraisal / Strategic Environmental Assessment / Habitats Regulations Assessment

RespID RepsID First Surname Organisation Officer Summary name 034 009 The Welsh With regard to the SA Report, the Welsh Government and Snowdonia Aerospace LLP note the assessment of the SEZ Government and allocation and the Authority’s stance that the allocation is deliverable. It is noted that the re-wording of DP 27 arising from the Snowdonia HRA acknowledges that the SEZ allocation will not have an adverse effect on the integrity of any European site. Aerospace LLP

035 017 The Nuclear With regard to the SA Report, the NDA and Magnox note the assessment of the SEZ allocation and the Authority’s stance Decommissioning that the allocation is deliverable. It is noted that the re-wording of DP 27 arising from the HRA acknowledges that the SEZ Authority and allocation will not have an adverse effect on the integrity of any European site. Magnox Limited 041 032 Angharad Wyn Cyfoeth Naturiol NRW note that as part of the Short Form Revision that the combined Sustainability Appraisal (SA) and Strategic Crump Cymru/ Natural Environmental Assessment (SEA) is also being reviewed. Resources Wales NRW acknowledged that the State of the Park Report (SoPR) characterizes the current state of the National Park’s environment and provides a baseline context.

NRW acknowledge that Section 3 of the SA Report provides a complete review of relevant Plans, Policies and Programmes. We are satisfied that the key sustainability issues and opportunities has been identified in Table 4.1.

NRW supports the recommendation set out in paragraph 7.3.2 of the SA Report, for the Deposit Version of the LDP to confirm a clear commitment to enhancement, rather than just protection.

With regards to table 5.1 which identifies the SA Framework, the reference to the ‘EA’ in row 2 needs to be changed to Natural Resources Wales (NRW).

With regards to the compatibility of the SA objectives and LDP objectives, as confirmed above NRW considers that the Plan is currently unsound as two of the proposed allocations does not conform with the requirements of TAN15. As such we consider that there is a conflict between the SA objective ‘Ensure that the location and design of new development is acceptable in terms of the potential consequences of flooding’ and the LDP Objective 2 Furthermore, we consider that there is a conflict between SA Objective ‘Ensure that the location and design of new development is acceptable in terms of the potential consequences of flooding’ with both Strategic Policy A National Park Purposes and Sustainable Development and Development Policy 1: General Development Principles (criteria xvi) and Development Policy 27 Snowdonia Enterprise Zone as the Plan proposes an allocation, the Llanbedr Enterprise Zone allocation which is within an area which is at risk from flooding. We are satisfied that the policy supporting text confirms the need for a new Masterplan to be prepared to guide new development on the sites.

RespID RepsID First Surname Organisation Officer Summary name Section 10 of the SA Report assesses the LDP Housing and Enterprise Zone.

Allocations. Table 10-1 includes an assessment of the sustainability summary and site specific mitigation for individual site allocations. For the Snowdonia Enterprise Zone the table does not recognize the flood risk associated with the site allocation. We acknowledge however that Volume 2 of the SA Report Appendices – Appendix F – Assessment of Site Allocation confirms that an FCA has been requested for Llanbedr Enterprise Zone by the Authority. As confirmed above NRW has provided comment on three versions of the SFCA and we have recommended that a final SFCA is submitted to inform the LDP review process. However, as confirmed above, NRW has significant concerns with the ‘Snowdonia Enterprise Zone Allocation PME/01’ as it does not comply with the requirements of TAN15.

With regards to table 12.1 Proposed Monitoring Framework, the reference to the ‘EA’ in row 2 needs to be changed to Natural Resources Wales.

041 033 Angharad Wyn Cyfoeth Naturiol We are satisfied as confirmed in paragraph 2.1.2 that the findings of the March 2009 HRA can be adopted by SNPA in Crump Cymru/ Natural respect of all other aspects of the LDP which are unchanged by the revision review and that the ‘Shadow’ HRA therefore Resources Wales focusses on the effects of the changes as outlined in points 1-10 of paragraph 2.1.1. We are satisfied with the changes confirmed in paragraph 4.1.2 that are taken forward for screening as they have been identified as potentially giving rise to effects which could conceivably undermine the conservation objectives for European Sites. We acknowledge that the revisions to the LDP drive by change 6 ‘To show the designation of the Snowdonia Enterprise Zone on the Proposals Map and introduce a new positive and enabling policy to manage new development within the zone’ has been identified as having a likely significant effect and is taken forward to appropriate assessment. We note that Section 6 of the ‘Shadow’ HRA includes an Appropriate Assessment of the Snowdonia Enterprise Zone at Trawsfynydd and Llanbedr Airfield.

- Trawsfynydd Enterprise Zone In terms of the bullet list provided under paragraph 6.2.2 we refer you to our specific comments on the Enterprise Zone potential allocations, and in particular the request for clarification as to whether the lake is to be included as part of the allocation in Trawsfynydd as it is located within Zone C2 of the Development Advice Map (DAM) contained in TAN15.

RespID RepsID First Surname Organisation Officer Summary name - Llanbedr Enterprise Zone Since the Shadow HRA was drafted, further assessment in the form of a SFCA has been prepared for the Llanbedr Enterprise Zone. It should be noted that the Assessment has included mitigation options for parts of the allocation area PME/01 which could potentially ensure that any development would remain dry during a flood event but we have not commented on any formal mitigation proposals. The mitigation options will need to be considered as part of the Shadow HRA in order to assess the potential effects of the proposed Llanbedr Enterprise Zone allocation on the conservation objectives of European Sites, including possible coastal squeeze. We note the confirmation in paragraph 6.2.2 that it must ‘be recognised that the level of detail provided in respect of the nature of the development proposals which might come forward through the LDP within the Enterprise Zone does not allow potential effects to be assessed in a meaningful manner. The LDP simply recognises the designation of the Enterprise Zone by the Welsh Government and provides an enabling policy’. We note that as confirmed in paragraph 6.2.2 that Development Policy 27 Snowdonia Enterprise Zone confirms that proposals for development within the Enterprise Zone which are in line with Parts B and C of the policy needs to also comply with the following criteria; - Development proposals have been considered in view of the requirements of the Habitats Regulation and found to be compliant. - Development on either site is in line with an agreed outline Masterplan for that site.

As confirmed in paragraph 6.2.15 we are satisfied that the publication of a Masterplan for the Enterprise Zone will be a ‘plan’ for the purposes of regulation 61 and that an assessment under the Habitats Regulation will be required. Furthermore, as confirmed by the criteria included as part of development policy 27, a project level HRA will also be required in respect of any development which will ultimately come forward under policy 27.