4 September 2018

Home , Cantref

APPENDIX A

Brecon Beacons National Park Authority

PLANNING, ACCESS, AND RIGHTS OF WAY

COMMITTEE 4 September 2018

PLANNING APPLICATIONS FOR DETERMINATION BY

THE PLANNING, ACCESS AND RIGHTS OF WAY

COMMITTEE

ITEM NUMBER: 1

APPLICATION NUMBER: 17/14934/FUL APPLICANTS NAME(S): Mr Colin Evans SITE ADDRESS: Upper Cantref Cantref Brecon LD3 8LR GRID REF: E: 305795 N:225772 COMMUNITY: Llanfrynach DATE VALIDATED: 26 October 2017 DECISION DUE DATE: 4 September 2018 CASE OFFICER: Donna Bowhay

PROPOSAL Change of use of agricultural land to accommodate the installation of a luge run incorporating bridges and a spectator footpath; toilet block and refreshment kiosk; ancillary building for queuing, shop, store, repair area; generator enclosure; drainage attenuation ponds; landscaping and a maize maze.

ADDRESS Upper Cantref, Cantref, Brecon

CONSULTATIONS/COMMENTS RECEIVED NP Planning Ecologist 16th Mar 2018 A. Additional Comments 1. Thank you for re-consulting me on the above application. The development proposals are for the construction of a luge run in an agricultural field. I provided comments in a Memorandum dated 17th November 2017 and have now received and reviewed the following additional information: o Cantref Luge - Environmental Statement Errata dated January 2018 o Cantref Luge - Construction Environmental Management Plan dated January 2018 o Cantref Farm, Brecon - Proposed Luge Development - Landscape and Ecological Management Plan by Haire Landscape Consultants dated September 2017 and updated February 2018 o Applicant's response dated 9 February 2018 - text in red in my Memorandum dated 17th November 2017 o Outline drainage for proposed luge run and maize maze for Cantref Farm by RPS dated February 2018 2. I welcome the submission of the additional information which appears to address most of the ecological issues previously raised and there is no ecological objection to the principle of constructing the Luge Run within what is already a regularly cultivated field. I offer the following comments on the amendments and additional information: 3. The Errata report now correctly refers to the Environment (Wales) Act 2016. 4. As previously stated, great crested newts are present at Cefn Cantref; this is 1.2km from the application site and I am still surprised that the information was not picked up in the 2km data search with BIS as the BIS records shared with the BBNPA clearly show their presence at Upper Cantref pond. I understand that the nearby pond was dry when the survey was originally undertaken and that a nearby breeding population was considered unlikely to be present, but I recommended that an appropriate mitigation strategy and precautionary approach would need to be adopted during the construction phase. During our site visit this week, the pond was full of water. Regarding this issue, the Construction Environmental Management Plan (CEMP) recommends a precautionary approach to site clearance and additional surveys prior to commencement of the development to confirm absence; however, there is limited detail of the precautionary approach. It is appreciated that the potential impact on great crested newts is mostly limited to the works to construct the attenuation ditch and connecting pipes i.e. the work closest to the ponds and that cross the hedgerow boundaries where foraging newts could be found. Now that it is clear that there is water in the pond, it would be appropriate for the surveys or for eDNA testing to be undertaken to confirm presence / absence or given that the pond itself is not affected, for more details of the precautionary approach to be provided. If great crested newts are present, an appropriate mitigation strategy will need to be forthcoming. 5. The management of surface water was identified as an issue during the previous application and additional information has been supplied to clarify drainage at the site. The Land Drainage Officer has confirmed that the scheme has capacity to address up to 1 in 100 year events and that it is acceptable. Provided that planning conditions are imposed as recommended, this aspect of the Test of Likely Significant Effects on the River Usk SAC can be completed by the BBNPA on that basis. 6. The Construction and Environmental Management Plan (CEMP) that has been submitted and demonstrates how negative impacts on the water environment can be prevented or mitigated during the construction phase of the development. Provided a planning condition is imposed to ensure that this is implemented, No Likely Significant Effects on the River Usk SAC are anticipated as a result of these development proposals. A formal TLSE can be completed in due course if the BBNPA is minded to approve this application. 7. In my previous comments I stated that the Phase 1 Habitat map should have included all the boundary hedgerows and the ditch along the northern boundary. The map has been amended and now shows the ditch along the western boundary, but still does not show the hedge-line and ditch along the northern boundary. Although these features should be shown on the map, it is acknowledged that they are not directly affected by the proposed development and they are shown on the landscaping plans. 8. The attenuation channel to be "constructed" across the hedgerows between the luge field and the drainage attenuation features will utilise a concrete pipe; the hedgerow will be retained or reinstated if there is a small impact. 9. I have previously advised that the "Maize Maze" is unlikely to be acceptable. As a maize crop, the area would need to be ploughed annually and would therefore contribute to surface water management issues; it would therefore be preferable to convert this area to permanent pasture with additional tree or shrub planting as landscaping and biodiversity enhancement at the site. However, the maize maze area is still being pursued, and a swale has been included to manage surface water. Whilst from an ecological point of view it would be preferable to have permanent pasture or woodland in this location, it is also appreciated that much of the field is currently ploughed annually and that a maize crop can be grown without needing planning permission. 10. The landscaping plan includes large areas of "disturbed areas to be seeded with hard- wearing grass mix". The applicants have clarified that this is because these areas will be disturbed during the construction process, but this doesn't really justify their long-term management in this way. It is a shame that the areas of wildflower meadow are still quite small, but the additional "non-rye grass" grassland areas that are to be managed as hay meadow are welcomed; it is anticipated that some of the wildflowers will spread into the grassland areas if they are managed n this way. The applicants have also clarified that the footpaths are to be surfaced with crushed stone. 11. The submission of the amended and detailed Landscape and Ecological Management Plan with appropriate measures for the long-term management of the habitats and biodiversity features at the site is welcomed. The proportion of beech proposed within the woodlands has been reduced and the other tree species have increased. The hedgerows along the southern and south-eastern boundaries of the luge field have been included in the Management Plan and will be allowed to grow taller, as recommended by NRW. Any hedgerow cutting should be undertaken in late winter to allow birds to forage available berries and seeds. Apart from this, the management prescriptions are appropriate and welcomed, and its implementation will need to be secured through an appropriately worded planning condition. 12. It is appreciated that the field in the north-east corner has been reduced in size, thereby increasing the area available for woodland planting and biodiversity enhancement. 13. The Landscape Masterplan also shows tree planting within the existing site at Upper Cantref. Following our site visit earlier this week, it is clear that much of this planting has already been undertaken but that there are some differences from the approved scheme and what has been undertaken. Some of the trees that were planted have subsequently died and therefore need to be replaced. 14. Confirmation has been provided that no external lighting is required. 15. Policy 1 of the LDP and Section 6 of the Environment (Wales) Act 2016 require the BBNPA to seek to maintain and enhance biodiversity. There will be opportunities to accommodate biodiversity enhancement measures at the site and the proposed invertebrate boxes and retention of 2 metre buffer strips are welcomed - the buffer strips are now shown on the landscaping drawing. The provision of just three bird boxes is minimal as enhancement for an application of this scale and I suggest that 6 bat boxes and 6 bird boxes are installed at the site. This can be secured through an appropriately worded planning condition.

B. Recommendations

The CEMP and surface water management details are acceptable, and the BBNPA is in a position to undertake a Test of Likely Significant Effects on the River Usk SAC as a result of these development proposals.

Great crested newt surveys or eDNA testing should be undertaken to confirm presence / absence or more details of the precautionary approach should be provided to demonstrate that newts will not be harmed during the construction phase. The applicant's consultants can contact me for clarification of what is required.

The LEMP requires minor amendment so that any hedge cutting is undertaken in the winter rather than autumn.

If the above issues can be clarified and resolved, I will be in a position to recommend appropriate planning conditions to secure the implementation of a landscaping and biodiversity mitigation and enhancement scheme as well as provision for long-term management of the site. This is in addition to the conditions required to secure the implementation of the drainage strategy and CEMP.

Reasons: o To comply with Section 5 of Planning Policy Wales (2016), Technical Advice Note 5 and Policies SP3, 1, 3, 4, 6, 7 and 12 of the adopted Local Development Plan for the BBNP o To comply with the Wildlife & Countryside Act 1981 (as amended), the Conservation of Habitats and Species Regulations 2017 and the Environment (Wales) Act 2016

NP Planning Ecologist 12th Mar 2018 Thank you for re-consulting me on the above application. I have started drafting my consultation response, but will delay submission until we have had opportunity to undertake our proposed site visit tomorrow.

Powys County Council Public Protection And Env Health 6th Aug 2018 Should planning permission be granted then the following conditions are recommended: The landscaping and construction period working hours and delivery times to be restricted as follows: All works and ancillary operations which are audible at the site boundary shall be carried out only between the following hours: 0800 - 1800 hrs Monday to Friday 0800 — 1300 hrs Saturday At no time on Sunday and Bank Holidays Deliveries to and removal of plant, equipment, machinery and waste, including soil, from the site must also only take place within the permitted hours detailed above. In addition the condition recommended in the Acoustics and Noise Limited report dated the 23rd May 2018 should be considered: To ensure that such rubber wheels are utilised, we suggest that a planning condition be imposed stating that the development shall not be brought into use until details of the wheel arrangement on the karts has been agreed in writing with the Local Planning Authority'.

Powys County Council Public Protection And Env Health 3rd May 2018 Thank you for your time on the phone earlier, as discussed an objector has provided an acoustic consultants report which raises a number of concerns in relation to the Paul Trew report which was submitted in support of the application.

A number of the challenges are connected to the operation of the track, ie. Additional noise from different wheels on the luge, extent to which luge runs will take place, public address system, noise from riders and spectators.

These challenges in the main relate to operation of the track and given that it would be the first in the uk, my knowledge of this type of operation is limited.

I would therefore recommend that challenges presented in the objector’s letter are put to the applicant for response.

Powys County Council Public Protection And Env Health 17th Nov 2018 Should planning permission be granted then the following conditions are recommended:

1. The landscaping and construction period working hours and delivery times to be restricted as follows: All works and ancillary operations which are audible at the site boundary shall be carried out only between the following hours:

0800 - 1800 hrs Monday to Friday 0800 - 1300 hrs Saturday At no time on Sunday and Bank Holidays

Deliveries to and removal of plant, equipment, machinery and waste (including soil) from the site must also only take place within the permitted hours detailed above.

2. The hours of opening to be restricted to the following:

0900 - 1800 hrs Monday to Friday 0900 - 1830 hrs Saturday 0900 - 1700 hrs Sunday and Bank Holidays

Powys County Council Land Drainage Department 22nd Feb 2018 Please accept my apologies for not responding earlier but with just two staff covering the whole of Powys, we are struggling with demand.

Based on the Outline Drainage Report for Proposed Luge Run and Maize Maze for Cantref Farm Dated February 2018 and associated Drawings Numbered Figure 4.8 Rev E, Figure 4.9 Rev F & Figure 4.7 Rev H, The Land Drainage Section can confirm that the applicant has suitably demonstrated that the drainage of the site can be managed and suitably discharged up to and including the 1 in 100 year storm event + 40%CC.

Sustainable Drainage Comment: No development hereby permitted shall be occupied until the sustainable drainage scheme for the site has been completed in accordance with the submitted details. The sustainable drainage scheme shall be managed and maintained thereafter in accordance with the agreed management and maintenance plan detailed in Appendix H of the Outline Drainage Report for Proposed Luge Run and Maize Maze for Cantref Farm Dated February 2018

I hope the above is of use but should you have any further queries then please do not hesitate to contact me.

Powys County Council Land Drainage Department 25th January 2018 Thanks for the opportunity to comment on this application. Having considered the information which has been submitted, along with a site visit, the Lead Local Flood Authority (LLFA) would make the following comments/recommendations:

Comment: The Authority holds no historical flooding information relating to this greenfield site.

Advisory: Any proposed alterations, interference or erection of any structure that affects an ordinary watercourse will require prior consent from Powys CC (as Lead Local Flood Authority), in accordance with Section 23 of the Land Drainage Act 1991 (as amended by the Flood & Water Management Act 2010). Further information can be sought at: http://www.powys.gov.uk/en/roads-transport-and-parking/ordinary-watercourses-applying-for- consent-for-works/

Advisory: It is presumed that Riparian rights and responsibilities exist in respect of the open watercourse (this will apply to any culverted sections of watercourse). The Applicant (or subsequent owners) are advised that they will be responsible to maintain any section of the watercourse that passes or abuts their property

Recommendation: No buildings, structures, fences, planting or changing of contours shall take place within 5 metres of the top of the bank of any watercourse, or 3 metres either side of any culverted watercourse (which would allow also allow for overland flows) without prior permission of the LPA

Observation: Records indicate that the site slopes towards the watercourse, the applicant would need to consider how surface water will be controlled from the site whilst interrupting drainage of the surrounding land and not exacerbating or creating any flooding problems.

Observation: The Lead Local Flood Authority would seek on site attenuation to the 1 in 100 year standard whilst limiting discharge to the existing 1 in 1 year Greenfield run-off for the connected impermeable areas.

Sustainable Drainage The Land Drainage Section are pleased to see the use of a SuDS scheme, however, we would ask that the design is able to show that the system is designed to meet the 1 in 100 year standard.

Comment: No development shall take place until details of the implementation, maintenance and management of the sustainable drainage scheme have been submitted to and approved by the local planning authority. The scheme shall be implemented and thereafter managed and maintained in accordance with the approved details. Those details shall include: i. a timetable for its implementation, and ii. a management and maintenance plan for the lifetime of the development which shall include the arrangements for adoption by any public body or statutory undertaker, or any other arrangements to secure the operation of the sustainable drainage scheme throughout its lifetime.

Comment: The Applicant is required to demonstrate where any exceedance flows are routed to ensure that any escaping water from the SUDS feature or similar will not cause or create a flooding nuisance to any third party or any publicly maintained Highway.

I hope the above is self-explanatory but if we can be of any further assistance then please do not hesitate to contact the Land Drainage Section.

Powys County Council Highways 21st August 2018 I refer to your re-consultation letter of 6th July 2018 concerning the above application. Powys County Council as highway authority offer the following observations and comments on the amendment: 1. The inclusion of information from Vision XS Limited provides background on figures included in the original submission. The company identifies a long-standing relationship with the applicant as well as engagement with a number of other similar Businesses of varying size. The data collected from these associations has been used to generate a potential growth scenario for Cantref. The suggested visitor figures with the Luge is indicated at 42,000p.a ±10% (37,800 - 46,200). At 42,000p.a this would be a growth of 8,000 visitors (24%) from the level in 2016 but a reduction from the peak in 2008 of 44,000,

2. The stated intention of the audience remains the younger family market, albeit with an extended age range for older siblings likely to be attracted by the inclusion of the luge;

3. The Supplementary Transport Statement provides additional information on the operation of the existing and proposed developments which assists in clarifying details included in the original submission;

4. The traffic survey undertaken on 24th August 2016 indicates 536 visitors in 188 vehicles with the maximum vehicles on site at any one time being 151 (Data from Section 2 and Table 1 refers). The data provided indicates that the peak day that year was 19th August 2016 with 967 visitors. Extrapolating this based on supplied data would suggest 339 vehicles through the site that day with around 270 on site at any one time. If a 24% growth rate is factored in for the projected impact of the luge these become around 1,200 visitors with 420 vehicles through daily and 342 vehicles on site at any one time;

5. The Draft Visitor Management Plan indicates that parking capacity is reduced to around 85% of measured capacity in current operational conditions (i.e. from 282 to c240). Using the Supplementary Transport Statement data (Section 2) this would suggest that currently parking issues will arise once visitor numbers reach around 850 per day (850 visitors / 2.85 vehicle occupancy rate x 0.8 factor for number of vehicles on site at any one time = 240). In 2016 visitors reached/exceeded this level on 3 days. This would seem to fit with more recent anecdotal information relating to overspill parking at the site;

6. The additional information recognises the impact on calculated parking capacity without some form of control with a suggested 85% capacity achievable in an uncontrolled environment. The benefit of managing flow around the car park is also recognised. The highway authority considers that even with proper line markings up to 5% of capacity may still be lost and therefore a figure of around 270 spaces would be more appropriate for a fully line- marked parking facility. Applying the same calculation in reverse as in 5. above would give a maximum daily visitor number of 962 (270 / 0.8 * 2.85). Adopting the methodology set out in the Draft Visitor Management Plan would likely generate figures between these limits (850 to 962 visitors and 240 to 270 vehicles). As indicated in 4. above if the 24% projected growth is applied then peak daily visitor numbers (based on 19th August 2016 data) could rise to 1,200 with 420 vehicles through daily and 342 vehicles on site at any one time. This clearly exceeds the proposed parking capacity on site,

7. The Vision XS Limited assessment estimates an increase in dwell time (time visitor stays on site) of about 1 hour. Calculations suggest this could increase maximum vehicle numbers on site at any one time by around 5% 8. Section 3 of the Supplementary Transport Statement considers access routes and identifies a number of provisions that could be made. Numbers using the Bailihelig Road approach from Brecon represent the minority of visitors but measures are required to ensure that this does not increase to a level where it becomes an issue as the road is narrow, with some limited visibility junctions and would not generally be considered appropriate as a means of access to the proposed site,

9. For the route from Llanfrynach a number of sites are identified for works to provide additional or formalise existing passing opportunities. This includes carrying out works to sites currently affected by verge overrun. Of particular concern on this route is the 150m section identified as Section A in the Supplementary Transport Statement and marked A1, A2 on the accompanying plan at Appendix 3 to the Statement where the width is stated to be generally at 3 metres.

10. Manual for Streets illustrates at paragraph 7.2 the various carriageway widths required to accommodate a selection of vehicle combinations. This shows, For 2 cars to pass 4.1m For 2 cars to pass comfortably 4.8m (width of 2 standard car parking bays) or LGV and car to pass For car and LGV to pass comfortably 5.5m or 2 LGVs passing

11. The Supplementary Transport Statement July 2018 Access Route Assessment (Appendix 3) suggests that around 50% of the route may fall below 4.1m in width and it is likely that only a very small percentage will achieve a 4.8m width.

12. There are likely to be many similar routes around the country which provide access to tourist and other venues experiencing higher volumes of traffic. It is considered that the proposed measures will assist users travelling along the route but that overall there will be increased delay or inconvenience compared with the current situation.

13. The proposals outlined in the Draft Visitor Management Plan are based around managing annual visitor numbers by post season monitoring. If the projected growth occurs pro-rata across the season then there will be potential impacts on the highway network before remedial action is implemented. These impacts will likely occur on existing peak days as well as increasing the frequency of days during the season when parking capacity and impact on the road network will become more apparent. On the basis of the current application proposal Powys County Council as highway authority would recommend refusal. The reasons for refusals are:- 1. There will be a sustained increase in visitor numbers which will impact on safe passage along the highway and lead to increased delays and inconvenience to road users (especially on peak days) 2. In-adequate on-site parking to deal with projected vehicle numbers (especially on peak days) which as a consequence will impact upon highway safety on the roads surrounding the site. If members are minded to grant consent then the highway authority would recommend that measures are put in place to effectively manage the projected increase in visitor numbers such that they are spread across the season rather than having an impact on attendance numbers on peak days or increasing the frequency of peak days where access/egress and parking provision will become issues. If consent is granted Powys County Council as highway authority would recommend that the following conditions be applied 1. A Visitor Management Plan be agreed in writing by the local planning authority to include a. A management regime to ensure efficient use of car parking provision b. Measures to cap daily visitor numbers by motor vehicle in line with on-site car parking provision based on calculations using parking capacity based on principles submitted on Parking Provision drawing (0990 101 A) included at Appendix 2 of the Supplementary Transport Statement July 2018

Car parking space efficiency ratio (non-marshalled parking) of 85% of capacity car parking space efficiency ratio (marshalled parking) of 90% of capacity car parking space efficiency ratio (line marked parking) of 95% of capacity vehicle occupancy rate of 2.85 (subject to periodic review based on data from Cantref site) c. Measures to be taken on the day in the event that visitors exceed the daily cap d. Measures to be taken to monitor visitor numbers throughout the season

2. A signing strategy to be approved in writing by the local planning authority to discourage the use of Bailihelig Road for access/egress by motor vehicles to/from the site promote use of the eastern access route from the Llanrfynach road

3. Highway improvements as outlined in the Supplementary Transport Statement including (locations and specifications to be approved in writing by the local planning authority) a. Formalising passing place A2 b. Surfacing field access B2 c. Improvements at 6 locations along section C where vehicles over-run existing verge d. Improvements at 8 locations along section D where vehicles over-run existing verge e. Improvements at 7 locations along section E where vehicles over-run existing verge f. Formalising passing places E2 and E3;

Reasons for Conditions In the interests of managing safe passage along the highway and safe operation of the site.

Informative Note Any works within the highway will require a licence which can be obtained from: Powys County Council, Street Works Section, County Hall, Llandrindod Wells, Powys, LD1 5LG

Powys County Council Highways 31st Jan 2018 Powys County Council as Highway Authority for county roads within Powys recommends that the application be refused on highway grounds on the basis that the application fails to take sufficient account of the potential impact on the existing highway infrastructure and its users. The key factors in reaching this conclusion are outlined below: 1. The proposal outlines the guidance to promote travel by public transport, walking or cycling, or to provide infrastructure or measures to manage traffic. It is recognised that the most likely means of travel in the short to medium term will continue to be by car or private bus. Consideration however should be given to providing facilities for other means of travel, such as bicycle or electrical vehicles, possibly through the provision of suitable infrastructure and charging points on-site. 2. In considering any potential impact on the highway network the submission is dependent upon on peak visitor numbers from a single year, 2008 (44,000) as providing a baseline for assessment. However, for the five year period 2011 to 2015 the figures show a more consistent attendance (c34,000). This peak is in-line with industry expectations of attendance, with attendance falling after initial interest before reaching a more sustainable rate. To note, attendance for 2016 was expected to be in-line with that for 2015. 3. Therefore, given a generally consistent pattern over the five year period 2011 to 2015, together with a indicative comparable figure for 2016, it is considered that the average over this period (c34,000) represents a more rational baseline against which to evaluate potential future impacts for highway users for any potential development. Yn agored a blaengar - Open and enterprising www.powys.gov.uk 4. Using the most recent period (2011 to 2016) attendance data to evolve a baseline, as opposed to a peak from 2008 will increase the likelihood that highway user safety concerns are identified and given appropriate consideration. This is important as in the context of the development the Design and Access statement (para 3.79) notes that there is a "poor road network serving the site". In addition the Transport Assessment (Appendix 6.1 para 3.9) identifies that the route between the site and Llanfaes via Balihelig Road "is considered to be unsatisfactory for traffic to and from Cantref Adventure Farm". We would concur with these qualitative assessments. 5. The Errata to the Transport Assessment (Appendix 6.1) corrects figures in relation to traffic movements. The calculations are based on the 2008 baseline and results in a projected 11% increase on the eastern (Cantref) side. The reference to "10% set by the EIA guidelines" should be remembered as guidance in relation to environmental impacts. The EIA guidelines also identifies that 5% variations would be of interest to the Department of Transport (in effect highway authorities) for operational and capacity criteria. Powys County Council and applicants have more recently considered variations of 2.5% as having the potential for significant impacts, thus requiring more detailed assessment. 6. However, using the 2016 recorded data as a baseline by comparison gives an increase between 24% (+77) and 47% (+151) depending on the contribution from the proposed mitigation on Balihelig Road (west side). The conclusion of the Errata submission that the "effect would be negligible or minor adverse and not significant" is not we believe valid against a 2016 baseline and supports the highway authority concerns. As identified in the Traffic and Access submission (para 6.70) pedestrians have concerns over sharing space with motor vehicles when flows are around 100 vehicles per hour. This figure may be reached during peak hours and could have a detrimental effect on pedestrian road users. 7. The traffic data supports our expectation that the traffic flows would peak around opening and closing times with lower flows in between these periods. The difference in flows at peak times and on peak days creates a wide variation in flows. 8. The proposed introduction of the luge has the potential to attract a wider and different user demographic to that already visiting the attraction. Currently the facilities are likely to attract a predominantly younger family age range, typically children of pre and primary school age. The luge is likely to appeal to older age ranges, probably secondary school and young adults, thus creating an audience of its own which may become significant and potentially make it the main attraction especially in the short term. 9. It is accepted by the applicant that the approaches from the west along Balihelig Road from Brecon present issues for access to the site. They are narrow with limited forward visibility and limited passing opportunities which will be exacerbated by vehicles in convoy situations as passing opportunities are generally limited to single vehicles with little opportunity for stacking waiting traffic. The applicant has taken steps to direct visitors via the A40 however it is inevitable that some visitors still access via Balihelig Road, presumably due to satellite navigation directions. Between Balihelig Road and Cantref there are two possible routes which are considered to require mitigation measures if the currently proposed mitigation measures prove ineffective. Yn agored a blaengar - Open and enterprising www.powys.gov.uk 10. The ability to deliver the proposed mitigation measures on Balihelig Road will be dependent upon Welsh Government as highway authority for trunk roads permitting additional signing. We understand that this proposal does not align with their current policy and practice. In addition we have concerns over the effectiveness of the signing. There appears to be no evidential support to the statement that the proposed mitigation "could remove around 90%" of traffic. We believe that this is unlikely to be the case and there will inevitably be a significant residual volume of traffic using this route. 11. The eastern access offers two alternative routes, albeit that current signing seeks to direct traffic along a single preferred route. Road widths along both routes have sections where free- flow two-way vehicle movements are constrained either by perception or actual width limitation. At lower traffic flows these situations do not present a significant problem. As flows increase, such as at peak times, problems will start to materialise particularly where convoys of vehicles have to wait to pass. 12. Damage has been observed along the route which is potentially linked with passing manoeuvres. Some of this damage appears likely to have been caused by agricultural vehicles, possibly because their familiarity with the area, driving skills and vehicle nature make it more likely that they will take the necessary action to pass. 13. Any increase in vehicle numbers will likely require improvement to the sites access and parking provision. In addition to parking capacity it is important that flow rates can be maintained at peak times to permit safe access and egress as well as reduce the likelihood of vehicles tailing back on to the public highway which could have a detrimental impact on emergency vehicles and other users. It appears that some of the parking is on grass standing which could impact access/egress rates during wet periods.

Powys County Council Highways 11th Apr 2018 I refer to your Re-Consultation in respect of the above application. Powys County Council as Highway Authority for county roads within Powys recommends that the application be refused on highway grounds. The reasons for refusal are The Transport Assessment fails to adequately consider the potential for growth in visitor numbers and the subsequent impact this may have on the existing minor road network in the vicinity on-site visitor car parking including access and egress.

Powys County Council Highways 12th April 2018 I refer to your Re-consultation Letter concerning the above application and in particular to the response from RPS in relation to the Highway Authority comments. With regard to their response Ref. PPS1087 we offer comments below. For convenience the paragraphs are numbered as per the original Highway Authority and RPS responses. 1. We would agree with RPS that the provision of facilities for other means of travel, such as bicycle or electrical vehicles could be secured by way of a conditioned Travel Plan. 2/3. The DfT's 'Guidance on Transport Assessment' paragraph 4.7 refers to trips which "….might realistically be generated…." from the existing permitted uses. We believe that our assessment of a baseline of c34,000 represents a realistic baseline for the current permitted uses.

There is no supporting information with regard to how the traffic generation estimate has been determined and therefore it is difficult to accept the figures. At paragraph 4.5 of the Transport Assessment it is stated that visitor numbers for every visitor attraction are limited by the number of people living in a certain travel time to the site. For Cantref Adventure Farm this is stated as a 40 minute drive time although no evidence has been provided to support this or how it relates to the stated traffic figure.

Printed promotional material for the existing development at Cantref is distributed beyond this 40 minute drive time, for example at Cardiff Bay Tourist Information Centre, a 70 to 80 minute drive time from Cantref. Looking at the potential for visitors from the Cardiff region as an example, it is accepted that there are comparable attractions closer to Cardiff and so visitor numbers may not be that high from this region. The proposed Luge appears to be a first for the UK and will likely attract visitors from a wider geographical area, such as Cardiff. Anecdotal evidence suggests that visitors would be prepared to travel over 2 hours for such an attraction.

Taking the route to Cardiff as an example it passes through a number of other local authority areas whose population densities are significantly higher than rural Powys.

Whilst journey times may be a deterrent to a higher proportion of visitors as the travel distance increases, this is likely to be balanced by the greater audience arising from the higher population densities. The 70 minute travel time to Cardiff is 30 minutes greater than the 40 minutes referred to in the Transport Assessment a 75% increase.

Taking a simplistic approach by discounting any effects of increased, population density and reduced take-up due to distance then this could result in a traffic estimate 75% higher. Based on the 2015 & 2016 (estimate) of 34,000 visitors this would translate to 59,500 visitors, 15,500 (35%) higher than that seen at the 2008 peak. At the stated vehicle occupancy rate (2.85) this equates to an additional 5,438 vehicles or 10,876 vehicle movements.

With regard to our incorrect assumptions about the level of visitors that should be expected at similar attractions we believe that our comments may have been misinterpreted. Our comments were intended to relate to the profile of visitor numbers over time rather than the actual volume that such a business may attract or may need to attract to remain viable. To this end for a set business standard we would expect to see a peak for a new attraction before dropping to a lower more consistent level.

Detailed comparable information has not been found to enable more detailed comparison. The Great Britain Day Visits Survey offers high level data for day visits to a range of attractions. This shows a comparable trend for 2012. The surveying organisation indicates that they cannot draw comparisons for other time frames as the survey questions changed for the 2016 survey.

Over this period the figures show a gradual decline. Cantref is fortunate that it has seen an increase in 2015 which it anticipated would continue in 2016. This would seem comparable with other similar attractions where some surveys report farm attraction visitor numbers performing better than other tourism sectors.

Personal Injury Collision (PIC) data for accidents in the Dyfed Powys Police area indicates that around 75% of PIC's occur on A and B class roads. In Powys only 20% of the road network is classified as A or B roads. The remaining 80% of the Powys road network comprises minor roads such as those in the immediate vicinity of Cantref. There is no reliable national or local data for non-PIC incidents and therefore other measures of conflict that could have a detrimental impact on the safety of highway users have to be considered. Where road widths prevent opposing vehicles from passing comfortably or where the lack of forward visibility and passing zones lead to conflict, evidence is often visible through damage to verges, structural failure of the highway edge or debris from vehicle collisions. In addition to the immediate safety concerns where users are in conflict, the resulting damage can give rise to more serious implications for subsequent users e.g. a vehicle mounting a soft verge can create a rut adjacent to the road edge that presents a greater hazard to cyclists/pedestrian etc or can cause water to flow onto the carriageway that can freeze during winter months. As set out in 2/3 above it can be seen that there is a realistic possibility of visitor levels increasing significantly (59,500 compared with the peak of 44,000) which will give rise to an increase likelihood of conflict which may lead to PIC's or less serious outcomes.

5. The document referred to is guidance. Given the differences of opinion in assessing a baseline and the lack of supporting evidence around projected visitor numbers it would seem sensible for a detailed environmental assessment for road traffic to be completed.

6. The figures are calculated using data in Table 6.8 of the Environmental Statement Erata using the 2016 Observed for Cantref Road and 2017 Post Development (No Mitigation and Mitigation) (397-320 = 77 = 24%) (471 - 320 = 151 = 47%).

The information provided in the Transport Assessment would appear to be mainly based around opinion rather than factual evidence of potential visitor numbers. It is accepted that assessments will often be very much opinion based however we believe that this proposal has significant potential to generate higher user volumes than are acknowledged in the Transport Assessment.

The bank holiday peaks will present the highest volumes of traffic and it is appropriate to carry out assessments around these peaks. Recent experience suggests that the use of web advertising and social media combined with fine weather can create user volumes significantly higher than have traditionally been experienced. This can lead to problems on the adjacent road networks, primarily due to inadequate parking at venues. The potential for such incidents needs to be considered and reasonable contingencies put in place to manage the situation.

Third parties have submitted photographic evidence of the overflow parking areas in use and possibly areas outside of the formal parking areas. It seems reasonable that such areas will come into play during unexpected peaks which we consider should not include days where higher than average levels of attendance are anticipated, such as Bank Holidays. Effective management of the core parking area is essential to ensure maximum parking capacity is achieved before the overflow parking comes into use and it we seem appropriate for the Transport Assessment to consider whether the layout and operational practices for the car park are appropriate. Poor access, layout, control and driver behaviour can all lead to delays in parking movements that can lead to traffic causing problems on the highway network. The potential increase in traffic volume that we believe could be achieved would require a review of parking provision to ensure that it remains adequate both in terms of capacity and access/egress arrangements.

8. The presence of the riding centre and bunkhouse were considered at the time the statement was made. We are still of the opinion however that the current uniqueness of the proposal has the potential to attraction significantly higher levels of visitors than the Transport Assessment forecasts.

9/10. A firm commitment by Welsh Government would be required for signing before further consideration could be given to appropriate means of reducing access along Bailihelig Road. 11/12/13 Accurately projecting user numbers is key to ensuring safe operation of the site for visitors as well as helping to identify necessary mitigation measures to prevent the introduction of additional risk for highway users. Within the applicants' response under 2) and 3) they state: "As long as we keep visitor numbers below where they were at the peak, then it should be acceptable in highway terms …." No proposal has been put forward to manage visitor numbers and it is difficult to see how such controls could be put in place. No significant evidence has been submitted to support the traffic generation figures stated in the Transport Assessment. The figures provided are based on an assumption of a 40 minute drive time which is considered to be an underestimate for the proposed new attraction. As a unique UK attraction the appeal is likely to be far wider and of interest to an audience that is more willing to travel greater distances. Additional user volumes will increase the potential for conflict where comfortable two way flows cannot be accommodated or where passing opportunities are insufficient or sighting distance to them insufficient. Whilst the applicant does not expect greater visitor numbers than were previously generated, we consider that the new attraction has the potential to generate higher levels. Paragraph 2.36 Table 1 of the Non-Technical Summary of the Environmental Statement indicates that 37,500 individuals are expected to go through the luge queuing and viewing educational areas. Assuming that 50% of these are additional users, i.e. not associated with current Cantref activities then 17,850 additional visitors would be generated per year. On top of the current c34,000 visitors this would provide a total number of visitors of 51,850 per year (52.5% increase).

Natural Resources Wales/Cyfoeth Naturiol Cymru 28th Feb 2018 Thank you for re-consulting Natural Resources Wales (NRW) regarding the above application on 13 February 2018. As you are aware, we did not object to the proposal in our letter dated 28 November 2017 (our ref: CAS-45400-B7B1) but raised significant concerns regarding landscape impacts. We have considered the further information submitted by the Applicant since that date, and continue to have significant concerns regarding the proposal. We recommend that planning permission only be granted if the scheme can meet the following requirement. We would object if the scheme does not meet this requirement. Requirement: mitigation to be provided as detailed in: the Landscape Masterplan (Figure 4.7 version H; dated 30 January 2018); the Landscape Mitigation / Planting Plan (Figure 4.9 version F; dated 01 February 2018); and the Landscape and Ecological Plan by Haire Landscape Consultants Ltd (dated September 2017, updated February 2018). We note that the Landscape and Ecological Plan, Landscape Masterplan and Landscape Mitigation/Planting Plan have been updated. We note that the hedgerow to the south-east boundary is to be allowed to grow up into a row of trees and that the paddock to the north east is to be reduced in size, with the area of woodland increased. Having considered the revised information, we recommend that planning permission should only be granted if the proposed mitigation is provided as per the above.

In response to your consultation regarding the 'Transport Objection' produced by Vectos (their ref: 151911/N03; dated February 2018), we note the concerns raised therein regarding increased traffic and parking provisions. Clearly, if the number of vehicles travelling to the site along the narrow, winding, rural lanes increases significantly, there is the potential for adverse impacts on the character of the lanes, through damage. There would also likely be an increased erosion of tranquillity. In addition, if the current parking provision proves to be inadequate, there is the potential for adverse landscape and visual impacts if new/increased areas of car parking are proposed for the site in the future; we note there is no increase in car parking proposed currently.

We are not in a position to advise on the adequacy of any transport assessment / parking provisions and therefore make no further comment on this matter. However, should the Applicant amend their application to increase parking provision, please re-consult us.

Campaign For National Parks 1st Aug 2018 Further to the email below and the attached re-consultation letter, I am writing to confirm that the previous comments we submitted in our letter of 29 November 2017 still apply. To summarise, we object to the application to install a luge run on agricultural land at Upper Cantref as it is in conflict with the statutory purposes of National Parks and is contrary to a number of the National Park Authority's planning policies, including those relating to appropriate development (policy 1) and the impacts of traffic (policy 59). We remain extremely concerned about the negative impacts of this proposal on the landscape and special qualities of the Brecon Beacons National Park even after considering the new information the applicant has provided on landscape. In addition, the new information on transport does nothing to address our concerns about the traffic impacts on minor roads in the area. The main solutions proposed appear to be surfacing some of the more informal passing places (which will have a negative impact on the rural character of these roads) and using brown tourists signs to reduce the use of unsuitable roads (with no consideration given to how effective these are at a time when most people use satnav). I would be grateful if you could confirm receipt of this email.

Brecon Beacons Park Society 9th Aug 2018 Thank for your letter of the 6th July informing the Brecon Beacons Park Society of the re- consultation. Having examined the further changes to the original proposal we do not think that they answer our objections, which we wish to maintain. We refer you to our original letter of 29th November 2017 and the further comments below.

1) Visual Impact We continue to be concerned about the negative impacts of this proposal on the landscape and special qualities of the Brecon Beacons National Park and feel that the mitigation that the proposed planting scheme are intended to afford may not be sufficient. Any mitigation is entirely dependent on the success of the proposed planting scheme. Previous experience on site suggests that there is no guarantee that the proposed planting will achieve the desired effect in the timescale suggested, not least because of the possibility of further drought years such as we are experiencing at present. In addition, we continue to believe that it is not acceptable for this special landscape to be disfigured for 10 to 15 years or even longer while the planting matures. There is also the probability that the deciduous nature of the planting would not form a sufficient screen in winter, even if it grew successfully.

2) Noise We continue to be concerned that the development would lead to a loss of tranquillity. It seems unrealistic to suggest that there would be no shouting in response to the thrill of the speed (Noise Rebuttal, Acoustics and Noise Ltd) and where groups are participating in time trials there is likely to be cheering and shouting from participants and spectators.

As stated before, the increased traffic that the scheme would attract would lead to increased noise and loss of tranquillity in the wider area around the site.

4) Access We continue to have concerns about the problems of increased traffic on the narrow lanes by which the site is accessed and do not consider that the proposal to surface three existing passing places (Supplementary Transport Statement, Acstro) will address the problems.

We continue to believe that the proposed luge, with its large expansion over the agricultural land of the Upper Cantref Farm, is not suited to this beautiful and tranquil area with its narrow roads. Nor does it seem necessary for the economic survival of the farm park, as is suggested by the applicant in justification for the proposal. The numbers visiting any new attraction may well diminish after the initial peak of interest but providing that the facilities are well maintained, the numbers should then reach a steady evel as new generations grow to the age to enjoy them. If new attractions are deemed necessary at Cantref we believe they should be accommodated within the existing site.

As we stated before, a development such as the proposed luge, should be sited near a main road and good public transport. We consider that the proposed development is contrary to the purposes and policies of the National Park, as detailed in our previous letter and we wish to maintain our objection.

NP Heritage Officer Archaeology 5th Mar 2018 Archaeological Comments: I am currently awaiting submission of an updated DBA for the proposed application, and will provide archaeological comments following submission and approval of this document.

NP Heritage Officer Archaeology 13th Mar 2018 National Policy Framework Planning Policy Wales (Edition 9: 2016): Welsh planning legislation and policy guidance outlines that the desirability of conservation of archaeological remains is a material consideration in the determination of a planning application (Planning Policy Wales, Chapter 6, Para. 6.5.5). 'The conservation of archaeological remains is a material consideration in determining a planning application, whether those remains are a scheduled monument or not. Where nationally important archaeological remains, whether scheduled or not, and their settings are likely to be affected by proposed development, there should be a presumption in favour of their physical protection in situ. It will only be in exceptional circumstances that planning permission will be granted if development would result in an adverse impact on a scheduled monument (or an archaeological site shown to be of national importance) or has a significantly damaging effect upon its setting. In cases involving less significant archaeological remains, local planning authorities will need to weigh the relative importance of the archaeological remains and their settings against other factors, including the need for the proposed development.'

This means that Local Planning Authorities in Wales have to take into account archaeological considerations and deal with them from the beginning of the development control process, and need to be fully informed about the nature and importance of archaeological remains, and their setting, and the likely impact of any proposed development upon them. Technical Advice Note 24 (May 2017): Paragraph 4.7. 'Where archaeological remains are known to exist, or considered likely to exist, and a study has not already been undertaken by the applicant, the local planning authority should ask an applicant to undertake a desk-based archaeological assessment and, where appropriate, an archaeological evaluation. These should be done by a qualified and competent expert to the appropriate standard. The reports of these investigations will form part of the planning application. Applicants should show they have modified their development proposals to minimise any negative impact on the identified archaeological remains, and how they intend to mitigate any remaining negative impacts'.

Development Plan Framework The adopted Local Development Plan sets out the Brecon Beacons National Park's policies and proposals to guide development in the National Park, including Policy SP3 f): 'All proposals for development or change of use of land or buildings in the National Park must demonstrate that the proposed development does not have an unacceptable impact on, nor detract from, or prevent the enjoyment of … archaeological features'.

Upper Cantref farm is a historic unlisted farmstead (CPAT69759), depicted on historic cartography, including the cantref Tithe of 1839. Historic maps depict a courtyard form of farm complex, associated buildings, surrounded by an orchard, woodland and field systems.

An archaeological Desk Based Assessment (DBA) has been produced and submitted in support of the application to provide more information on the archaeological potential of the site, and the archaeological impact of the proposed development (RPS, March 2018).

The DBA highlights that a number of designated heritage assets are located within a Ikm radius of the site, including five grade II listed buildings, and part of the essential setting of the Abercynrig Country House Registered Park and Garden. In addition, there are several scheduled monument within the wider landscape, including Coed Y Brenin enclosure, Coed Y Careau camp, Plas Y Gaer hillfort on the uplands to the south of the site, and Slwch Camp to the north.

No archaeological features are recorded on Historic Environment Records within the site boundary itself. However, the DBA highlights the rich archaeological context of the site, and the presence of a number of assets within a 1km radius, including three potential prehistoric burial sites, two potential enclosures, the Maesderwen Roman complex, and a number of Roman period entries within the study area, including coin findspots, and a number of coins, gold rings and other 'relicts of antiquity' discovered in 1824 around 400m to the west of the site.

Historic farmsteads and field systems testify to the later medieval and post-medieval agricultural character of the area, with evidence of relict field systems/boundary banks predating the modern layout of the farm's field systems noted from historic cartographic and remote sensing recourses within the application site itself.

Archaeological Impacts of the development The planning application is for a change of use of agricultural land to accommodate the installation of a 'luge run' with an ancillary building and the erection of a toilet block and kiosk, at Cantref Adventure Farm, Upper Cantref Farm, Brecon, Powys LD3 8LR.

The DBA highlights the archaeological potential of the landscape, from the prehistoric to the medieval period, and outlines that elements of the proposed development has the potential to impact upon previously unrecorded buried archaeological remains. It is considered that the greatest impacts will derive from groundworks and associated landscaping for construction of the luge track and also from construction of the new building, woodland planting, and excavations required for the attenuation pond and associated drainage (5.2). The DBA suggests that the steep topography of the luge field makes it an unlikely location of settlement, and the part of the site with the greatest potential for archaeological remains is considered to be the lower ground in the eastern part of the site, at the site of the proposed attenuation pond (5.4). However this will require confirmation via a programme of archaeological works designed to provide more information on the impact of the proposed development.

The DBA has also considered the potential impact of the proposed development on the settings of designated heritage assets. The DBA states that the application will have no effect on the significance of the nearest designated heritage asset to the site, the Grade II Lower Cantref (5.8.), or any other designated heritage asset, due to a combination of distance and/or lack of visibility from the proposed development site (5.11). The DBA also states that although elements of the site will be visible from the Brecon and Llangorse Registered Landscape of Special Historic Interest, the proposed development would result in no impact to the character of the registered landscape, or the ability to understand or appreciate its significance (5.12).

Archaeology The proposed development is located within an area of potential archaeological sensitivity. All proposals for development of land in the National Park must demonstrate that the proposed development does not have an unacceptable impact on, nor detract from, or prevent the enjoyment of archaeological features. The conservation of archaeological remains and their settings are a material consideration in determining a planning application.

It is therefore recommended that this application is not determined until the archaeological resource has been assessed through a programme of archaeological works in order to evaluate the nature, extent, preservation and significance of any archaeological deposits that survive on this site, and the impact of the proposed development on them.

It is recommended that this programme of works is undertaken as a staged programme: 1) The developer will ensure that a suitably qualified archaeological contractor is employed to carry out a programme of Geophysical Survey. The survey will be carried out in accordance with a written scheme of investigation which has been submitted by the applicant and approved in writing by the local planning authority and must meet the standards laid down by the Institute for Archaeologists in their Standard and Guidance for archaeological geophysical survey. A copy of the geophysical report shall be submitted to the Local Planning Authority for approval. The results of the programme of geophysical survey will assess the potential for archaeological remains and to inform the programme of archaeological trial trenching.

2) The developer will ensure that a suitably qualified archaeological contractor is employed to carry out a programme of archaeological trial trenching to evaluate the potential of the site and achieve an understanding of the nature of the archaeological remains and the likely impact of the proposed development. The evaluation will be carried out in accordance with a written scheme of investigation which has been submitted by the applicant and approved in writing by the local planning authority and must meet the standards laid down by the Institute for Archaeologists in their Standard and Guidance for archaeological field evaluation. A copy of the Evaluation report shall be submitted to the Local Planning Authority for approval. Following approval, the report will inform any further works necessary: determination of the application/ or whether further archaeological work is required.

An advice note for commissioning archaeological works within the Brecon Beacons National Park is attached above.

Settings of Scheduled Monuments The application is located within 2 kilometres from the perimeter of a scheduled monument, and has an area of 0.5ha or more. As such, Cadw should be consulted on any potential effect upon the setting of the scheduled monument(s), in accordance with the Town and Country Planning (Development Management Procedure) (Wales) (Amendment) Order 2016, and PPW, Paragraph 6.5.9. Settings of Listed Buildings The Conservation and Historic Buildings officer at the Brecon Beacons National Park will be commenting upon the effect on the proposed development on the settings of Listed Buildings, including the Grade II Listed Lower Cantref, and that information is not reproduced here.

NP Planning Ecologist 20th Nov 2017 C. Comments 1. Thank you for consulting me on the above application. The development proposals are for the construction of a luge run in an agricultural field. 2. I visited the site in 2015 as part of a pre-application enquiry and provided comments on the previous application for a luge run in a Memorandum dated 1st April 2016. I have reviewed the documents and drawings submitted with the application, which includes the following ecological information: o Preliminary Ecological Appraisal (PEA) (incorporating Extended Phase 1 Habitat Survey) by Arbtech dated May 2017 o Cantref Farm, Brecon - Proposed Luge Development - Landscape and Ecological Management Plan by Haire Landscape Consultants dated September 2017 3. I welcome the submission of an ecological report (PEA) with the application and I note that the site is predominantly an arable field. It is surrounded by hedgerows, although the hedgerow to the south has some gaps. The hedgerow along the northern boundary is tall (approximately 5m+), with trees towards the lower end. There is a ditch running along the hedge, which eventually joins the Afon Cynrig; this is a tributary of the River Usk SAC and becomes part of the designated site 400m downstream of the confluence of the ditch with the Cynrig. 4. The PEA report incorrectly refers to the Natural Environment and Rural Communities (NERC) Act 2006; in Wales this has been superseded by the Environment (Wales) Act 2016. 5. There is no ecological objection to the principle of constructing the Luge Run within what is already a regularly cultivated field, but a number of ecological issues were identified during the previous application; some of these issues have now been addressed, but some information that has been presented, including in the ecological report, needs to be amended and/or additional information provided to address these issues: 6. Great crested newts are present at Cefn Cantref; this is 1.2km from the application site and I am surprised the information was not picked up in the 2km data search with BIS. I understand that the nearby pond was dry when the survey was originally undertaken and that a nearby breeding population is unlikely to be present, but an appropriate mitigation strategy and precautionary approach would need to be adopted during the construction phase. 7. The management of surface water was identified as an issue during the previous application and does not appear to have been fully addressed within this application. I note that the Landscape Masterplan by Haire Landscape Consultants shows a drainage attenuation ditch and a drainage attenuation pond to the south of the site. It is welcomed that the hedgerow between them is to be retained in situ, with additional planting to enhance biodiversity. Detailed drawings of the design of these features have been provided, but there is no information on how the surface water is to be managed on the luge site and brought to the attenuation features or whether there is sufficient capacity within them. The proposed marginal and aquatic planting for the attenuation features is appropriate and welcomed. I understand that the attenuation pond is to be un-lined and is therefore unlikely to have permanent water. 8. In my previous comments I stated that the Phase 1 Habitat map should have included all the boundary hedgerows and the ditch along the northern boundary; this has not been addressed. 9. Please can it be clarified how the attenuation channel will be "constructed" across the hedgerows between the luge field and the attenuation features? 10. I have previously advised that the "Maize Maze" is unlikely to be acceptable. As a maize crop, the area would need to be ploughed annually and would therefore contribute to surface water management issues; it would be preferable to convert this area to permanent pasture with additional tree or shrub planting as landscaping and biodiversity enhancement at the site. If the maize maze is to be pursued, I recommend that surface water management features will need to be accommodated, such as swales. 11. The landscaping plan includes large areas of "disturbed areas to be seeded with hard- wearing grass mix". It is not clear why these areas would be particularly disturbed other than where the pedestrian access is to be provided and I recommend that some of this is replaced with additional wildflower areas. Please can it also be clarified whether all of the footpaths are to be surfaced or just mown paths? 12. The submission of a detailed Landscape and Ecological Management Plan with appropriate measures for the long-term management of the habitats and biodiversity features at the site is welcomed; its implementation will need to be secured through an appropriately worded planning condition. The proposed hedgerow and woodland planting specifications are broadly appropriate and welcomed. However, there is a high proportion of beech proposed within the woodlands (22%) which is not particularly typical of woodlands in this part of the National Park; I understand that this is partly because of the lack of availability of ash due to ash-dieback disease, but I recommend that the proportion of beech is reduced to about 10% and that the other tree species are all increased by 1-2%. The hedgerow along the south- eastern boundary of the luge field should be included in the Management Plan and should be allowed to grow taller, as recommended by NRW. 13. It is still disappointing that part of the field in the north-east corner has been removed from the application site, also reducing the area available for woodland planting and biodiversity enhancement. I endorse the NRW pre-application comments in relation to this. 14. The Landscape Masterplan also shows tree planting within the existing site at Upper Cantref; it would be helpful to have confirmation that all of this planting has been undertaken or when it is likely to do so. 15. It will be important to ensure that any external lighting is of an appropriate design and sensitively located to avoid light-spill towards bat roosting areas or wildlife corridors. I understand that no external lighting is currently proposed but it would be helpful to have confirmation of this. 16. Section 6 of the Environment (Wales) Act 2016 requires public authorities to seek to maintain and enhance biodiversity. There will be opportunities to accommodate biodiversity enhancement measures at the site and the proposed invertebrate boxes and retention of 2 metre buffer strips are welcomed. The provision of just three bird boxes is minimal for an application of this scale and I suggest that 6 bat boxes and 6 bird boxes are installed at the site. There will be opportunities to accommodate the provision of some of these features within the new structures. 17. The Wildlife Pond should also be reinstated as recommended in the ecological report. 18. A Construction and Environmental Management Plan (CEMP) will need to be prepared to show how negative impacts on the environment can be prevented or mitigated during the construction phase of the development. Provided this is secured and implemented, No Likely Significant Effects on the River Usk SAC are anticipated as a result of these development proposals. Although I previously advised that this could be secured by an appropriately worded planning condition, BBNPA officers have since received advice on the Habitats Regulations that this type of information is required in advance of determination of such planning applications or that the application would need to be subject to an Appropriate Assessment.

D. Recommendations

Further information and/or amendments are required regarding the following:

1. The proposed attenuation ponds: a. Detailed drawings of the proposed attenuation ponds to demonstrate sufficient capacity for surface-water flows from the site b. Details of how surface water is to managed from the luge run and maize maze 2. The proposed landscaping is generally welcomed but further details and some amendments will be required: a. Reduction of "disturbed area grassland" and an increase in wildflower areas b. Reduction of the amount of beech in the woodland mix c. Surfacing or otherwise of footpaths / pedestrian routes d. Management of the hedgerow along the south-eastern boundary of the luge field e. The "Maize maze" is not appropriate as landscaping in this location and does not provide any biodiversity benefits 3. Features for bats and birds that can be accommodated within the proposed new buildings. 4. A Construction and Environmental Management Plan (CEMP) will need to be submitted. 5. Confirmation that no external lighting is required.

Provided that the CEMP and surface water management details are acceptable, the BBNPA will be in a position to undertake a Test of Likely Significant Effects on the River Usk SAC as a result of these development proposals.

If the above issues can be clarified and resolved, I should be in a position to recommend appropriate planning conditions to secure the implementation of a landscaping and biodiversity mitigation and enhancement scheme as well as provision for long-term management of the site.

Reasons: o To comply with Section 5 of Planning Policy Wales (2016), Technical Advice Note 5 and Policies SP3, 3, 4, 6 and 7 of the adopted Local Development Plan for the BBNP o To comply with the Wildlife & Countryside Act 1981 (as amended), the Conservation of Habitats and Species Regulations 2010 (as amended) and the Environment (Wales) Act 2016

NP Heritage Officer Archaeology 12 Dec 2018 National Policy Framework Welsh planning legislation and policy guidance outlines that the desirability of conservation of archaeological remains is a material consideration in the determination of a planning application (Planning Policy Wales, Chapter 6, Para. 6.5.5). Planning Policy Wales (Edition 9: 2016): Paragraph 6.5.5. 'The conservation of archaeological remains is a material consideration in determining a planning application, whether those remains are a scheduled monument or not. Where nationally important archaeological remains, whether scheduled or not, and their settings are likely to be affected by proposed development, there should be a presumption in favour of their physical protection in situ. It will only be in exceptional circumstances that planning permission will be granted if development would result in an adverse impact on a scheduled monument (or an archaeological site shown to be of national importance) or has a significantly damaging effect upon its setting. In cases involving less significant archaeological remains, local planning authorities will need to weigh the relative importance of the archaeological remains and their settings against other factors, including the need for the proposed development.'

Technical Advice Note 24 (May 2017): Paragraph 4.7. 'Where archaeological remains are known to exist, or considered likely to exist, and a study has not already been undertaken by the applicant, the local planning authority should ask an applicant to undertake a desk-based archaeological assessment and, where appropriate, an archaeological evaluation. These should be done by a qualified and competent expert to the appropriate standard. The reports of these investigations will form part of the planning application. Applicants should show they have modified their development proposals to minimise any negative impact on the identified archaeological remains, and how they intend to mitigate any remaining negative impacts'.

Archaeological sensitivity and significance of the site The application site is located at upper cantref Farm, some 400m to the north of the historic settlement core of Cantref, as defined during a survey of historic settlements within the Brecon Beacons in 1993 and 2013 by the Clwyd Powys Archaeological Trust.

Cantref lies on the north bank of the Afon Cynrig, a small tributary of the Usk. The name recalls the medieval administrative unit known as the 'cantref' or ' hundred'. The early history and development of the church and any associated settlement is uncertain. The churchyard is polygonal in shape. However, Cantref House has a curving edge to its garden to the west, and it is possible that a semi-circular, potentially early enclosure could be located within this area (CPAT 2013). The earliest reference to the settlement dates from 1372. The Grade II listed church is thought to have been largely rebuilt in 1829 and restored in 1867 (Cadw 84819), but incorporates a tower which is believed to date from around 1600. In addition, the font is thought to be of 12th century origin (CPAT 2013). There is no evidence of a settlement developing around the church in the medieval era or after the Reformation, and the church today is accompanied only by a Grade II listed house (former vicarage) rebuilt c. 1780-1805 which shares the name (Cadw 84816) (CPAT40688).

Upper Cantref farm is a historic farmstead (CPAT69759), depicted on historic cartography, including the cantref Tithe of 1839. Historic maps depict a courtyard form of farm complex, associated buildings, surrounded by an orchard, woodland and field systems.

The farm is set within a historic landscape with the RCHMW recording earthworks east of Berllan comprising substantial field banks and possible rectangular enclosure (NPRN 300922) (CPAT623). Relict field systems, tracks and boundaries are clearly defined in remote sensing resources surrounding the proposed development area, with earthworks extending across the development plot. Prehistoric and Roman activity is well attested within the vicinity of the site (CPAT2386) (CPAT12393), including historic findspot of coins and metalwork to the west of the site (CPAT119436), and the site of the Maesderwen 'Roman Villa' bath house (CPAT610) and associated complex (CPAT17808) to the east.

In order to provide information on the impact of the proposed development, and demonstrate how any negative impact on identified archaeological remains or the settings of designated heritage assets can be mitigated, the applicants should undertake a program of archaeological assessment.

The applicant, or their agents or successors in title, need to secure the implementation of an archaeological Desk Based Assessment (DBA) and walkover survey to provide more information on the archaeological potential of the site, and archaeological impact of the proposed development. The DBA will be carried out in accordance with a written scheme of investigation which has been submitted by the applicant and approved in writing by the local planning authority and must meet the standards laid down by the Institute for Archaeologists in their Standard and Guidance for historic environment desk-based assessment.

A copy of the DBA shall be submitted to the Local Planning Authority for approval. Following approval, the report will be submitted to the National Park Archaeologist and the local Welsh Archaeological Trust for inclusion in the Regional Historic Environment Record (HER).

This programme of archaeological assessment will provide more information on the archaeological potential of the site, and inform any potential requirement for further archaeological work.

NP Heritage Officer Archaeology 20th Nov 2017 National Policy Framework Welsh planning legislation and policy guidance outlines that the desirability of conservation of archaeological remains is a material consideration in the determination of a planning application (Planning Policy Wales, Chapter 6, Para. 6.5.5). Planning Policy Wales (Edition 9: 2016): Paragraph 6.5.5. 'The conservation of archaeological remains is a material consideration in determining a planning application, whether those remains are a scheduled monument or not. Where nationally important archaeological remains, whether scheduled or not, and their settings are likely to be affected by proposed development, there should be a presumption in favour of their physical protection in situ. It will only be in exceptional circumstances that planning permission will be granted if development would result in an adverse impact on a scheduled monument (or an archaeological site shown to be of national importance) or has a significantly damaging effect upon its setting. In cases involving less significant archaeological remains, local planning authorities will need to weigh the relative importance of the archaeological remains and their settings against other factors, including the need for the proposed development.'

The proposed development is located within an area of potential archaeological sensitivity. All proposals for development of land in the National Park must demonstrate that the proposed development does not have an unacceptable impact on, nor detract from, or prevent the enjoyment of archaeological features. The conservation of archaeological remains and their settings are a material consideration in determining a planning application. In order to provide information on the impact of the proposed development, and demonstrate how any negative impact on identified archaeological remains or the settings of designated heritage assets can be mitigated, the applicants should undertake a program of archaeological assessment.

This programme of archaeological assessment will provide more information on the archaeological potential of the site, and inform any potential requirement for further archaeological work.

NP Sustainable Tourism Manager 31st Oct 2017 Without any knowledge of site based issues, I can comment that our area has relatively few attractions for families and that Cantref does perform a useful function for visitors, particularly staying families, a segment we are trying to encourage. I therefore welcome this proposal on tourism development grounds. The tourism strategy specifically supports private sector investment in new tourism focused facilities.

NP Heritage Officer Building Conservation 23rd Nov 2017 POLICY CONTEXT Planning Policy Wales (Edition 9: November 2016): Paragraph 6.5.11 recognises the importance of protecting the historic environment and states that: "There should be a general presumption in favour of the preservation of a listed building and its setting, which might extend beyond its curtilage. For any development proposal affecting a listed building or its setting, the primary material consideration is the statutory requirement to have special regard to the desirability of preserving the building, its setting or any features of special architectural or historic interest which it possesses."

Technical Advice Note 24: The Historic Environment (May 2017) Setting of Historic Assets in Wales (May 2017)

Brecon Beacons National Park Local Development Plan (December 2013)

Policy 1: Appropriate Development in the National Park All proposals for development or change of use of land or buildings in the National Park must comply with the following criteria, where they are relevant to the proposal: i) the scale, form, design, layout, density, intensity of use and use of materials will be appropriate to the surroundings and will maintain or enhance the quality and character of the Park's Natural Beauty, wildlife, cultural heritage and built environment; …..

Policy 17: The Settings of Listed Buildings:

Development proposals which would adversely affect the setting of a listed building will not be permitted.

ASSESSMENT These comments are written with regard to the heritage and conservation aspects of the proposal.

There are four listed buildings in the vicinity of the site for the proposed luge run and associated facilities. Whether or not there is an impact on the setting of the listed buildings is a factor to be considered in assessing this development proposal.

Cantref House and St. Mary's Church are located to the south west of Upper Cantref, just over 500 metres from the nearest edge of the site. Cantref House is a former vicarage which was re-built 1780-1805 and has a late Georgian character. It is grade II listed. The Church of St Mary is grade II listed and is of medieval origin. The church now has a 19th century character since it was re-built in 1829 and heavily restored in 1867. The church is surrounded by its churchyard with numerous graves. There are mature trees within the churchyard and enclosed by a thick belt of trees to the south east side and partly around the north east and south west boundaries. Lower Cantref, a late Georgian Farmhouse which is also grade II is approximately 350 metres to the north east. Maesderwen (grade II) is found approximately 800m to the east

The setting of a listed building can extend beyond its property boundary into the surrounding landscape. The possibility that the site of the proposed development forms part of the setting of the listed buildings referred to above therefore has to be considered. In the case of these buildings, the landscape features in their immediate environment contains the extent of the area that can be regarded as their primary setting. In addition, the distances involved and the intervening landscape features limit any visual connection between the site and the listed buildings.

The setting of listed buildings is not necessarily confined to the visual connection between the building and its surroundings. Other sensory elements can also affect setting, including noise. The activities proposed in relation to this development are acknowledged in the Environmental Statement as potentially generating additional noise. The sound assessment states that the nearest sound sensitive receptor is Lower Cantref. The assessment goes on to outline the measures that will be introduced to reduce noise levels. The impact of additional noise on setting is relevant given the relatively tranquil rural environment.

CONCLUSION It is concluded that there will be very minimal impact on the setting of the listed buildings in terms of any visual impact. The increase in noise levels as a result of the development could have an impact on the setting of the listed buildings, particularly Lower Cantref. The applicant is proposing measures to reduce the impact of noise from the activities and it is important that that it is demonstrated to the Authority's satisfaction that these measures are sufficient.

NP Strategy And Policy 30th Nov 2017 The development plan for the area is the Brecon Beacons National Park Local Development Plan 2007-2022 (hereafter LDP) which was adopted by resolution of the National Park Authority on the 17th December 2013.

My observations relate to the proposals compliance with the strategy and policy of the LDP.

Proposal The application seeks consent for the changes of use of agricultural land to accommodate the installation of a luge run with ancillary building and erection of a toilet block and kiosk.

Local Development Plan Policy Context The proposal is located in an area of open countryside as defined by the LDP Proposals Map. The LDP defines countryside locations as areas unsuitable to accommodate future development in accordance with the Environmental Capacity of the National Park. In these areas there is a presumption against development with the exception given to those development forms where there is a defined essential need for a countryside location.

Policy CYD LP1 Enabling Appropriate Development in Countryside Locations sets out the forms of development that are acceptable in a countryside location. Criterion 5 of this policy enables proposals for tourist attractions which by evidenced necessity require a countryside location as essential to their function.

This position is further supported by policy SP14 which states:

The NPA will enable proposals for sustainable tourism development which promote opportunities for the enjoyment and understanding of the National Park, whilst ensuring that the natural beauty, wildlife and cultural heritage is conserved and enhanced.

The LDP at para 7.8.8 goes on to state that the overriding principle in the consideration of all proposals for tourism or enjoyment uses is to ensure that the pursuit of the second purpose and the duty of the National Park does not conflict with pursuit of the first. The second statutory purpose of the National Park is to promote opportunities for the understanding and enjoyment of the special qualities of the National Park by the public. This proposal would go some way to contributing towards this purpose.

The principle considerations therefore are twofold, firstly, is a countryside location necessary and essential to the proper functioning of the tourism attraction and secondly, whether the development has any adverse impact on the special qualities of the National Park.

To address the first point, the proposal would form an extension of an existing tourism business 'Cantref Adventure Farm', which offers a variety of indoor and outdoor activities and camping accommodation. The existing site is relatively large and the extension to the business is proposed into a field of approx. 2.5 hectares. Given the scale of the proposal and the relationship with the existing tourism business, it is difficult to envision that such a development would be able to be accommodated within a settlement location.

With regard to the second point, I refer you to the 'Landscape and Development Supplementary Planning Guidance' which includes Landscape Character Assessment for the National Park area. The site in question is located within Landscape Character Area 6 Middle Usk Valleys. This area is defined as:

'…an area of transitional landscape, connecting the uplands of the Central Beacons with the lower and more settled Usk Valley. It is visually dominated by the high northern scarps of the Central Beacons which form a dramatic southern backdrop to the area. A generally pastoral agricultural landscape of green fields divided by hedgerows, its character is also locally influenced by upland heath, designed parklands, urban development, valley floodplain and transport routes. A landscape of historical strategic importance, it contains defensive sites from the Iron Age, Roman and Medieval periods, and as well as recent military use.'

The overall strategy for this area is:

'To retain and enhance the area's special qualities, in particular its views and historic features, ensuring that any new development is sensitively designed and accommodated within its landscape setting. Agriculture is viable, with farmers encouraged to use traditional land management techniques to retain and enhance landscape features and biodiversity. Iconic views to and from the Central Beacons are protected and enhanced, and historic sites, buildings and features are in good condition. The landscape impacts of new developments and military use are minimised. Visitors and local people are encouraged to enjoy the landscape through a wide variety of recreation opportunities, but without detriment to the area's special qualities.' The proposed development has the potential to impact on the Park's special qualities as experienced through landscape character. Chapter 5 of the Environmental Statement (Non- Technical Summary) submitted in support of the application provides a summary of the environmental effects of the proposed development. The assessment of effects on users of the local transport network is provided and a full Transport Assessment has been prepared and submitted. I note from the application file that the relevant Highway Authority has been consulted and I trust they will be able to address transport issues.

A sound assessment has been carried out and while the conclusion provided in the Non- Technical Summary of the Environmental Statement states that there will be no significant sound effects during the operation of the development, I note from the file that the Public Protection and Environmental Health Department have been consulted and trust they will be able to provide an opinion.

With regard to the potential impact of the proposal on Landscape and Visual elements, Tables 4.9 and 4.10 of the Landscape and Visual Assessment provides a summary of effects on landscape and visual receptors within the Park. It is noted that the assessment at the construction phase and at Year 15 that the vast majority of impacts are either not significant or negligible.

As such it is considered that the development has no significant lasting adverse impact on the Natural Beauty of the National Park. I will leave it to relevant consultees to consider the potential for impact from increased traffic movements and sound.

I trust you will also give due consideration to Policy 1 'Appropriate Development in the National Park' when determining the proposal.

Recommendation The Strategy and Policy Team have no objection to the proposal.

Natural Resources Wales/Cyfoeth Naturiol Cymru 6th July 2018 We have received a re-consultation for the above application, dated 6 July, due to an amendment. We are no clear to what amendment this relates. The latest information uploaded on your website was on 12 June. Please could you advise the nature of the amended information submitted?

Natural Resources Wales/Cyfoeth Naturiol Cymru 28th Nov 2017 As you are aware, we have commented on a previous application for this proposal (your ref: 15 12959 FUL) on 29 March 2016 (our ref CAS- 166140C9D3), and commented in response to a Statutory pre-application consultation from the applicants under the Town and Country (Development Management Procedure) (Wales) (Amendment) Order 2016 (our ref: CAS- 34738-G0M6 dated 11 July 2017). We have significant concerns with the proposed development as submitted. We would recommend that planning permission only be granted if the scheme can meet the following requirement. We would object if the scheme does not meet this requirement. Requirement: mitigation to be provided as detailed in the Landscape Masterplan (Figure 4.7 version F dated 09 October 2017) and the Landscape Mitigation / Planting Plan (Figure 4.9 version D dated 16 September 2017). We provide further comments and recommendations regarding landscape below, as well as foul drainage and the Usk Special Area of Conservation.

Brecon Beacons National Park The proposal site is located within the Brecon Beacons National Park, and the area of the proposal site is identified in the Brecon Beacons National Park Landscape Character Assessment as LCA6 Middle Usk Valleys.

In LANDMAP the site falls within the Glyn Tarrell & Cynrig Valley Visual & Sensory aspect area (BRCKNVS148), assessed as being of High value. Adjacent Visual & Sensory aspect areas include Brecon Beacons (BRCKNVS833), evaluated as Outstanding, and Usk Valley East of Brecon (BRCKNVS735), evaluated as High value.

The site also lies within the 'Libanus' Historic Landscape aspect area (BRCKNHL525), evaluated as High value.

The landscape is one of rolling pasture and arable fields with hedgerows, trees and woodland, and the area is noted for its tranquillity, peaceful pastoral quality and sense of timelessness. The proposal site is visible from elevated land to the south, where footpaths and open access land lead up to the main peaks of the Brecon Beacons, and there is some visibility from local lanes, footpaths and houses on the edge of Llanfrynach. Existing trees and woodland currently screen the site from a number of views, particularly in the summer months and including from the nearby listed church and rectory. However, during the winter months there would be greater visibility.

We consider that there are likely to be some significant adverse landscape and visual effects resulting from the proposed development in the short to medium term, up to approximately 10 years. We consider that after 15 years there should be no significant adverse landscape and visual effects, providing the proposed mitigation is effective.

We have the following observations regarding the Landscape Visual Impact Assessment, and proposed mitigation.

Landscape Visual Impact Assessment The applicants have submitted a Landscape Visual Impact Assessment (LVIA) for their proposals produced by Mike Haire Landscape Consultants Ltd, found in chapter 4 of the Environmental Statement. This is the same LVIA we were provided with when we were consulted on the Statutory pre-application consultation, and therefore our comments remain largely the same. We have amended some comments due to the updated mitigation proposals set out in the Landscape Masterplan (Figure 4.7 version F dated 09 October 2017) and the Landscape Mitigation / Planting Plan (Figure 4.9 version dated 16 September 2017).

We have the following comments regarding the LVIA. (1) We consider that the LVIA has underestimated the adverse effects to some extent and that there are likely to be some significant adverse landscape and visual effects resulting from the development in the short to medium term, up to approximately 10 years. (2) We note that in Table 4.8 it states that a Medium effect on a High sensitivity receptor is substantial rather than significant. We consider Moderate and greater significance of effects to be significant in EIA terms. (3) Regarding Table 4.4, we consider High value and Medium susceptibility results in High- Medium sensitivity, not Medium sensitivity as stated. (4) For Table 4.5 we consider recreational users in a National Park, appreciating the landscape and scenery, to be of High sensitivity rather than Medium-High, and users of rural minor roads in a National Park to be Medium-High sensitivity (e.g. walkers, cyclists, horse riders), and drivers on these roads to be of Medium sensitivity. (5) We consider the site and the Glyn Tarell & Cynrig Valley Visual & Sensory aspect area to be of Medium-High sensitivity. We consider that there would be substantial (significant) adverse landscape effects on the site in the construction phase due to the degree of earthmoving and re-grading; these effects would reduce to slight adverse effects by year 15 after the development (as opposed to moderate reducing to negligible). (6) We believe there would be slight adverse effects from the attenuation ponds at construction, becoming slightly beneficial at year 15 (as opposed to slight adverse and not significant). (7) With regards to the special qualities identified in the National Park Management Plan and LCA6 Middle Usk Valleys, high scenic quality and strong sense of place have been identified. Sensitivity includes the introduction of visually intrusive features into views from the central Beacons. In section 4.184 of the LVIA it states that there would be limited effect on this special quality (negligible in the medium to long term) and that sense of place would not be affected. We consider that the effect on scenic quality is highly dependent on the success of the proposed mitigation and the effects are likely to be greater for a longer period. (8) In section 4.190 of the LVIA it states that there would be limited effects on the peaceful pastoral quality and sense of timelessness and emphasises noise from minor roads, farms and aircraft. We agree with the National Park findings that the peaceful quality and sense of timelessness here is strong and of a special quality, and consider that this quality would be eroded to some extent throughout the life of the development. (9) We do not agree with Table 4.10 where it values BRCKNVS833 Brecon Beacons as of low susceptibility- we consider that due to outstanding value and high susceptibility it is of High sensitivity (not medium). We consider that there would be Moderate adverse visual effects on receptors from F3 & 4 until the mitigation takes effect around year 10, when the effects would reduce to slight adverse. (10) We agree that there would be limited views from residential properties due to intervening landform/vegetation or distance involved. However, it would take some time for the mitigation planting to mature, so where there are views e.g. from Llanfrynach (H5), they will be more noticeable in winter and will last for a much longer period than just the construction period. It is likely to be year 10 before the mitigation begins to take on the appearance of a woodland. This also applies to views from minor roads (R1, 2 & 5) and footpaths (F2, 3 & 4). It should be noted that the current development is highly visible from F3 & 4 (Cefn Cyff & Rhiw) and stands out as incongruous from the surrounding landscape and draws the eye, despite being an element in a panoramic view. The buildings, luge run, bridges, and people on the site will be highly visible for some time. Overall, we consider that there would be Moderate adverse visual effects on receptors at viewpoints H5, R2, R5, F2, F3 & F4. (11) We consider that there would be some adverse landscape and visual cumulative effects resulting from the increased intensity and spread of leisure development over a considerably larger area. In the short-medium term these are likely to be moderate adverse, reducing to slight adverse in the long term, with mitigation.

Mitigation The proposals would involve re-grading of the landform, new buildings and the hard surfacing and embankments of the luge run. These features would be incongruous and would not help to conserve or enhance the natural beauty of the National Park, or the peace and tranquillity of the locality. The landscape assessment has underestimated the adverse effects to some extent, and that there are likely to be some significant adverse landscape and visual effects resulting from the development in the short to medium term, up to approximately 10 years.

However, we consider that in the long term, after 15 years, there should be no significant effects, providing the proposed mitigation set out in the Landscape Masterplan (Figure 4.7 version F dated 09 October 2017) and the Landscape Mitigation / Planting Plan (Figure 4.9 version D dated 16 September 2017) is provided and effective.

The proposed woodland planting has been enhanced since the previous application (your ref: 15/12959/FUL), with more extensive tree planting and an improved balance between woodland and open glades within the luge run field. Advance planting has been included to the south west boundary, along with allowing the existing hedge to grow out. The hedgerow previously marked for translocation in the water attenuation area is now marked for retention, with wildlife habitat planting in this area. Areas of cut and fill are intended to be graded out to more gentle gradients. The proposal includes some areas of wildflower meadow and non-Rye grassland to be managed as Hay Meadow. A Landscape and Ecological Management Plan has been submitted.

We therefore do not object to the application, provided the mitigation proposed is provided as set out in the following Landscape Masterplan (Figure 4.7 version F dated 09 October 2017) and Landscape Mitigation / Planting Plan (Figure 4.9 version D dated 16 September 2017).

Further advice We recommend that the hedgerow to the south-east boundary is allowed to grow up, to help provide mitigation in the early years and be subsequently managed at a height of 2-3m. Rather than changing the field pattern with additional hedgerows and paddock, we recommend the inclusion of woodland/pasture in the north-east area.

We recommend increasing the areas of wildflower meadow (e.g. in some of the non-Rye grassland areas).

Foul drainage With respect to the discharge of effluent to ground or surface water, the Applicant will need to apply for an environmental permit, prior to commencement of work on site. Please note that further information may be required as part of that application and the Applicant is therefore advised to hold pre-application discussions with our Permitting Team on 0300 065 3000 at the earliest opportunity to try to ensure that there is no conflict between any planning permission granted and the permit requirements. More information, including a step by step guide to registering and the relevant application forms, are available on our website. Where private sewage treatment/disposal facilities are utilised, they must be installed and maintained in accordance with British Standards 6297 and Approved Document H of the Building Regulations. We also refer the Applicant to Pollution Prevention Guideline 4 which provides further information.

Other matters Our comments above only relate specifically to matters that are included on our checklist Natural Resources Wales and Planning Consultations (March 2015) which is published on our website: https://naturalresources.wales/planning-and-development/planning-and- development/?lang=en .

We have not considered potential effects on other matters and do not rule out the potential for the proposed development to affect other interests, including environmental interests of local importance. The applicant should be advised that, in addition to planning permission, it is their responsibility to ensure that they secure all other permits/consents relevant to their development.

If the applicant requires guidance on matters within our remit then this can be found on our website at www.naturalresourceswales.gov.uk

Llanfrynach Community Council 15th August 2018 Referring to 17/14934/FUL Llanfrynach Community Council reiterates it's former comments and adds that, construction and heavy goods traffic is too big for Cantref's narrow lanes, and secondly the issue of excessive noise should have further measures to deal with it.

Llanfrynach Community Council 4th Dec 2017 Llanfrynach Community Council is cognisant of the statutory purposes of the National Park as set out in Section 61 of the Environment Act 1995 :- First Purpose: to conserve and enhance the natural beauty, wildlife, and cultural heritage of the National Park; Second Purpose: to promote opportunities for the understanding and enjoy of the special qualities (of National Parks) by the public. The Community Council is equally mindful of the National Park Authorities duty under Section 62(1) of the Environment Act 1995: Duty: In taking forward the National Park purposes, to seek to foster the economic and social well-being of local communities within the National Park. The original planning application, reference 12/08328FUL was granted with conditions 11 and 12 being pertinent to this current application: Condition 11 - the development herby permitted shall remain ancillary and subservient to the primary use of the premises namely pony trekking centre, bunk house and adventure farm, the development shall not become the primary or separate use at any time and shall not be operated independently or during the hours the pony trekking centre is not in use.

Condition 12 ¬- the attraction shall only be used by persons using Cantref Riding Centre and Adventure Farm and shall not be offered as a separate attraction.

With these purposes, duty and conditions in mind the Community council has facilitated two meetings with the residents of Cantref and the other wards in the Llanfrynach Community Councils area.

The first meeting held at Cantref and Llanfrynach Village Hall on 10th July 2017 and was a public meeting when approximately 20 residents attended. At this public meeting the Applicant gave a presentation of the history and future proposals for the development of Cantref Adventure Farm; he listened to objections and addressed these issues undertaking to answer the real and genuine concerns of the residents.

The second meeting was an Extraordinary meeting of the Council held in public and as such was not a public meeting, it allowed the Council to listen to the concerns and objections of the residents: 25 residents and interested parties attend on 27th November 2017 at Cantref and Llanfrynach Hall.

The Community Council recognises the concerns and objections of the residents and believes them to be real and consequential.

The Community Council also acknowledge the benefits that the Applicant's enterprise brings to the community being the largest employer of staff (particularly of young people).

Following the initial consultation with the BBNPPA the applicant has addressed issues concerning noise (sound); landscape and the visual impact of the development which may well satisfy the planning authority. However the residents have strong reservations that the noise levels will not be reduced to an acceptable level particularly in such a sensitive area. The fundamental objection raised by the residents and an objection supported by the Community Council concerns the access to the site and the number of traffic movements over unclassified narrow country lanes.

Unless these issues can be addressed then the Council cannot support application reference 17/14934/FUL

Notwithstanding whether the application is granted or not the Community Council will support the Applicants requests to Powys County Council for better signage to the site from the A40 southerly route and for prohibitive notices to be placed on the Llanfaes route.

Llanfrynach Community Council 4th Dec 2017 I have just realised that I was expected to send this comment in earlier in the week. I had not realised that I was to post it off to you. I hope you can accept it as nearly the whole community has contributed to it. (NOTE from ADMIN: No further comment received)

Campaign For National Parks 29th Nov 2017 Campaign for National Parks has been campaigning for over 80 years to protect and improve all the National Parks of Wales and England. Our mission is to inspire everyone to enjoy and look after National Parks - the nation's green treasures.

We object to the application to install a luge run on agricultural land at Upper Cantref as it is in conflict with the statutory purposes of National Parks and is contrary to a number of the National Park Authority's planning policies. We discuss each of these concerns in more detail below.

Conflict with National Park purposes National Parks are the finest landscapes which have been granted the highest level of protection. The statutory purposes of National Parks are: To conserve and enhance the natural beauty, wildlife and cultural heritage of the National Parks. To promote opportunities for the public understanding and enjoyment of the special qualities of the National Parks. In pursuing these purposes, National Park Authorities (NPAs) also have a statutory duty to seek to foster the economic and social well-being of communities living within the National Park. The Environment Act 1995 also states that in those cases where there is a conflict between the purposes and reconciliation proves impossible, the first purpose should tak precedence. We note that Natural Resources Wales (NRW) has already raised concerns about the 'significant adverse and visual effects resulting from the proposed development in the short to medium term, up to approximately 10 years.' NRW have also noted significant shortcoming with the Landscape Visual Impact Assessment (LVIA), for example, some of the landscape and visual effects of the proposal have been underestimated, as have the potential impacts on recreational users of the area.

In addition, the proposal will have a negative impact on the natural beauty and special qualities of the Brecon Beacons National Park both during construction and throughout the lifetime of the development. The presence of new buildings, the changes to the landform and the inclusion of embankments and hard surfacing to form the luge run all add up to a development which will be extremely intrusive in this location. There will be additional noise disturbance both during construction and when in operation from users of the luge and vehicles and other associated activities. The development would be visible from the peaks and ridges of the Brecon Beacons and will have a negative impact on the tranquillity of the area. All of this could have a detrimental impact on the economy of the National Park if it deters tourists from visiting the area.

It is clear that this proposal would cause significant harm to the landscape and is therefore completely inappropriate in a protected landscape.

National Park Authority planning policies The proposals are contrary to a number of the policies in the Brecon Beacons National Park Authority Local Development Plan 2007-2022. These include:

SP1: National Park Policy. This policy makes it clear that development in the Park must comply with the statutory purposes and duty. As set out above, this proposal is clearly contrary to the statutory purposes. Policy 1: Appropriate Development in the National Park. The scale, form and design of this proposal are completely inappropriate to its surroundings and will not maintain or enhance the National Park. SP17: Sustainable Transport. This states that proposals that will result in transport impacts which cannot be satisfactorily mitigated should be refused. As access to this site is via narrow lanes and it is reasonable to assume that it would attract large numbers of visitors at peak times (if it is to commercially viable), this will lead to significant problems of congestion and road safety. Policy 59: Impacts of Traffic. It is not possible to provide appropriate access to this site as set out above. Development of this nature which is intended to attract large numbers of visitors should be located near a main road and wherever possible, in locations which are easily accessible by public transport. Allowing such a development to go ahead in this location will lead to pressure for increased road capacity in the future as the existing roads are not appropriate for the anticipated level of traffic. This will further increase the negative impacts on the special qualities of the National Park. We object to this application for the reasons set out above and urge the National Park Authority to refuse planning permission for it.

Brecon Beacons Park Society 30th Nov 2017 I am writing on behalf of the Brecon Beacons Park Society which is an independent organisation with over 800 members that exists to further the enhancement, protection, conservation and enjoyment of the Brecon Beacons National Park. We have the following concerns relating to the planning application cited above.

1) Visual Impact

As a development in Brecon Beacon National Park this proposal must comply with the National Park purposes and statutory duty (LDP SP1) and with LDP Policy 1, Appropriate Development in the National Park.

The proposed development is located close to the main peaks of the Brecon Beacons and the north running ridges extend towards the site. We are concerned that the proposed development will be very visible from the peaks and ridges of the Beacons, particularly from Cefn Cyff and Rhiw, and be an intrusion into the landscape. Because of the sloping nature of the site, it will also be very visible from the recreation ground in Llanfrynach and nearby houses, from the footpath that runs from the recreation ground to towards Abercynrig Mill, from the footpath running south from Cantref Church and from the Three Rivers Ride. This is made clear by the Viewpoint Photography in the EIA Volume 2. The two proposed new buildings will be isolated from the main farm buildings and will therefore stand out more. The bitmac luge track and other paths and bridges will be an alien intrusion into this rural landscape. The proposed planting scheme would in time go some way to screening the development but we consider that it would be 10 years at least before the planting would be effective and feel that this is too long to have this important area of the National Park disfigured.

We therefore consider that the proposed development is contrary to LDP SP1 as it does not "Conserve and enhance the Natural Beauty, wildlife and cultural heritage of the Park". Nor does it "Provide for, or support, the understanding and enjoyment of the special qualities of the National Park in a way that does not harm those qualities." The enjoyment of the luge will be due to the thrill of speed, not the special qualities of the National Park. For the same reasons it does not comply with SP14 Sustainable Tourism.

We also consider that the proposal is contrary to Policy 48 of the Local Development Plan, as we do not believe that: "the applicant has demonstrated to the satisfaction of the NPA that the proposed development is fully integrated into the landscape by virtue of topography or surrounding land uses, particularly when viewed from public routes and vantage points from outside the site;".

2) Noise The proposed development is in open countryside in a very rural situation. The noise from the generator, motorised vehicles and customers using the luge is difficult to assess as there are no similar developments to compare it with. However it seems likely that such a development together with the other activities on the farm will lead to a loss of tranquillity. Furthermore the predicted 45% increase in traffic (see below) approaching from the east will also lead to loss of tranquillity and is likely to affect the quiet enjoyment of the area. 3) Light pollution Even a fairly modest amount of lighting would affect the sense of tranquillity and remoteness of the area and affect the appreciation of the night skies by residents and visitors to the area and would therefore be contrary to LDP SP1a). Should this application be permitted we request that conditions be imposed so that it complies with LDP Policy 12. 4) Access The site is located in open countryside and the vast majority of the access will be by private car. Access to the site, whether approaching from Brecon or the Llanfrynach direction is via narrow lanes. Any increase in this traffic is likely to lead to congestion, disturbance to this peaceful area and problems of safety. Therefore the proposed development is contrary to LDP SP17c and Policy 59. Improved signage may ensure that most traffic will approach from the East. However this route from the A40 is also very narrow in places and crosses the C18 11* listed river bridge (Lock Road Bridge) which is single track and vulnerable to damage. Even if one accepts the applicant's suggestion that visitor numbers will not be greater than the 2008 peak, the diversion of 52% of the projected number of cars from the western approach would result in a 45% increase in traffic from the east above current levels. Table 6.8 on page 6.27 of the EIA Chapter 6: Traffic and Access, is incorrect in this respect. If 79 (52%) cars approach from the east instead of from the west, this would result in a total of 576 approaching from the east (not 497). This is a 45% increase in the daily traffic on the road from the east as a result of the development, not the 3% suggested in paragraph 6.108. Having made this mis-calculation, it is then concluded that, as this increase is under the 10% set by the EIA guidelines (see 6.27 - 6.30 ), the impacts of the proposal are imperceptible and further consideration of this matter is screened out of the assessment. The above errors invalidate such a conclusion and we therefore disagree with the statement in Chapter 6 of the EIA that the development is acceptable in highway terms. We consider that the development may well be contrary to LDP SP17 c) and Policy 59 a) because of its likely impact on traffic levels at peak times.

The proposed expansion of the Activity Centre by nearly five hectares will greatly increase the area of the site covered by unsightly features. The development of new buildings, a considerable distance away from the main grouping of the farm, will exacerbate this (as well as being contrary to LDP Policy 38(e) Farm Diversification). The new development would be likely to attract large numbers of visitors, and is not suited to this beautiful and tranquil area with its narrow roads. Such a development does not require this very rural location and would be better sited near a main road and public transport.

The society therefore wishes to object to the proposed development.

CADW Ancient Monuments 6th Apr 2018 Having carefully considered the information provided with the planning application, our records show that there are no scheduled monuments or registered historic parks and gardens within the vicinity of the proposed development. We therefore have no comments to make on the proposed development.

NP Strategy And Policy 26th Apr 2018 I refer to the above application that was previously brought to the attention of the Strategy and Policy Team for comment.

I note since comments were provided from this department that you have received an assessment of the landscape impacts from Simon White Associates. Given that this assessment concludes that there will be demonstrable visual impacts arising from the development for a significant period of time, I am minded to provide a supplementary comment on behalf of the Strategy and Policy Team.

Whilst I would maintain that the general principle of the development is acceptable, it must be noted that this cannot be at the expense of the special qualities of the National Park. To this end, by reason of its detrimental impact on the landscape, it is considered that the proposal would fail to comply with the following LDP Policies: o SP1 National Park Policy o Policy 1 Appropriate Development in the National Park o SP2 Major Development in the National Park o SP3 Environmental Protection o CYD LP1 Enabling Appropriate Development o SP14 Sustainable Tourism

Recommendation To this end, the Strategy and Policy Team objects to the above development by reason of its potential to have a significant impact on the landscape. The proposal is considered to be contrary to the policies of the Adopted Brecon Beacons National Park Local Development Plan listed above.

Please do not hesitate to contact me should you require any further information.

Dwr Cymru Welsh Water - Developer Services 16th Nov 2017 We refer to your planning consultation relating to the above site, and we can provide the following comments in respect to the proposed development.

SEWERAGE

As the applicant intends utilising a septic tank facility we would advise that the applicant contacts Natural Resources Wales who may have an input in the regulation of this method of drainage disposal. However, should circumstances change and a connection to the public sewerage system/public sewerage treatment works is preferred we must be re-consulted on this application.

Our response is based on the information provided by your application. Should the proposal alter during the course of the application process we kindly request that we are re-consulted and reserve the right to make new representation.

If you have any queries please contact the undersigned on 0800 917 2652 or via email at [email protected]

Please quote our reference number in all communications and correspondence.

Natural Resources Wales/Cyfoeth Naturiol Cymru 18th Apr 2018 Thank you for re-consulting Natural Resources Wales (NRW) regarding the above application on 21 March 2018.

As you are aware, we did not object to the proposal in our previous letters dated 28 November 2017 (our ref: CAS-45400-B7B1) and 28 February 2018 (our ref: CAS55385-T5M6) but raised significant concerns regarding landscape impacts.

Following a visit to the site and giving consideration to the recommendations of the report by Fiona Cloke Associates submitted by third party objectors (Revision 1 dated March 2018), we continue to have significant concerns regarding the proposal.

As such, we recommend that planning permission should only be granted if the scheme can meet the following requirement. We would object if the scheme does not meet this requirement.

Requirement: mitigation to be provided as detailed in o the Landscape Masterplan (Figure 4.7 version H; dated 30 January 2018); o the Landscape Mitigation / Planting Plan (Figure 4.9 version F; dated 01 February 2018); and o the Landscape and Ecological Plan by Haire Landscape Consultants Ltd (dated September 2017, updated February 2018), with further amendments to be agreed, as explained below. In our letter dated 27 November 2017 we stated that, in our opinion, after 15 years there should be no significant effects, providing the proposed mitigation set out in the Landscape Masterplan and the Landscape Mitigation / Planting Plan is provided and is effective. However, having visited the site and assessed the recent nearby planting ourselves, we agree with the report by Fiona Cloke Associates titled 'Review of Landscape & Visual Impact Assessment' dated March 2018 (Revision 1) that there may be a limited number of significant visual effects remaining at Year 15, possibly longer, depending on how the planting matures. We agree that the Year 15 visualisations produced by the applicant may be optimistic, showing trees at 6-7m height based on an assumed growth rate of 400-500mm per year (planted at 600mm). They do not take account of the elevated nature of the site, low growth rates in the first two to three years of establishment, or years of poor growing conditions. The length of time before the planting matures and provides effective screening is dependent on numerous factors, not least the care given to maintenance and ongoing management. We therefore recommend that the Landscape and Ecological Plan is further amended to include a commitment to provide annual monitoring reports on the planting to your Authority for approval, together with proposals to replace/increase planting if the monitoring work indicates this is necessary.

Natural Resources Wales/Cyfoeth Naturiol Cymru 2nd Aug 2018 Thank you for re-consulting Natural Resources Wales (NRW) regarding the above application on 06 July 2018. As you are aware, we did not object to the proposal in our previous letters dated 28 November 2017 (our ref: CAS-45400-B7B1), 28 February 2018 (our ref: CAS-55385-T5M6) and 18 April 2018 (our ref: CAS-58926-N9N0) but raised significant concerns regarding landscape impacts. We recommended that mitigation should be provided as detailed in o the Landscape Masterplan (Figure 4.7 version H; dated 30 January 2018); o the Landscape Mitigation / Planting Plan (Figure 4.9 version F; dated 01 February 2018); and o the Landscape and Ecological Plan by Haire Landscape Consultants Ltd (dated September 2017, updated February 2018), amended to include a commitment to ongoing monitoring reports and proposals to replace/increase planting on an annual basis and that reports are submitted to the local authority. We have reviewed the Supplementary Landscape Statement by Haire Landscape Consultants Ltd (dated July 2018). The Supplementary Landscape Statement provides some assurance that the proposed mitigation would be successful in providing adequate mitigation of the proposals within a 15 year timeframe, if: o the Applicant confirms annual monitoring will take place; o the size of the initial planting stock is increased from 60-90cm to 90-120cm; o failed plants are replaced; and o the construction of Bridge 2 and part of the path network is delayed until sufficient landscape cover has become established. We therefore continue to have significant concerns about the proposal. If you are minded to grant planning permission for the proposals then we repeat the recommendations of our letter dated 18 April 2018, and refer you to our comments above regarding the Supplementary Landscape Statement.

NP Planning Ecologist 3rd Aug 2018 Thank you for re-consulting me on the above application. I am satisfied that Bridgit Symons' recommendations still stand (16th March 2018). I notice that the CEMP and LEMP have been revised to accommodate her recommendations and I am satisfied with them. With regards to access (ref: Supplementary Transport Statement (Issue 4, July 2018 - acstro) I would require full details of what measures are to be put in place for the following sections: o Section C - There are a number of locations (approximately 6) where there is evidence that vehicles are regularly using the verge to pass. There are opportunities to improve some of these passing places. o Section E - Opportunities also exist to improve and formalise passing places E2 and E3.

Clarification on the suggested improvements to be made and construction methodology as well as long-term management measures is required. I hope this is of help - please let me know if I can assist you further.

NP Heritage Officer Archaeology 6th Jul 2018 National Policy Framework Planning Policy Wales (Edition 9: 2016): Welsh planning legislation and policy guidance outlines that the desirability of conservation of archaeological remains is a material consideration in the determination of a planning application (Planning Policy Wales, Chapter 6, Para. 6.5.5). 'The conservation of archaeological remains is a material consideration in determining a planning application, whether those remains are a scheduled monument or not. Where nationally important archaeological remains, whether scheduled or not, and their settings are likely to be affected by proposed development, there should be a presumption in favour of their physical protection in situ. It will only be in exceptional circumstances that planning permission will be granted if development would result in an adverse impact on a scheduled monument (or an archaeological site shown to be of national importance) or has a significantly damaging effect upon its setting. In cases involving less significant archaeological remains, local planning authorities will need to weigh the relative importance of the archaeological remains and their settings against other factors, including the need for the proposed development.'

Archaeological sensitivity and significance of the site The application site is located at Upper Cantref Farm, some 400m to the north of the historic settlement core of Cantref, as defined during a survey of historic settlements within the Brecon Beacons in 1993 and 2013 by the Clwyd Powys Archaeological Trust. Upper Cantref farm is a historic unlisted farmstead (CPAT69759), depicted on historic cartography, including the cantref Tithe of 1839. Historic maps depict a courtyard form of farm complex, associated buildings, surrounded by an orchard, woodland and field systems. An archaeological Desk Based Assessment (DBA) has been produced and submitted in support of the application to provide more information on the archaeological potential of the site, and the archaeological impact of the proposed development (RPS, March 2018).

Archaeology All proposals for development or change of use of land or buildings in the National Park must demonstrate that the proposed development does not have an unacceptable impact on, nor detract from, or prevent the enjoyment of archaeological features. Consultation of the regional HER, and the Desk Based Assessment produced in support of the application have indicated that the proposed development is located within an archaeologically sensitive landscape.

A staged programme of archaeological field assessment has been required in order to inform determination of this application. To date, a programme of geophysical survey has been completed, which aimed to provide information on the nature and character of the detectable archaeological resource within a specified area, and to inform the programme of trial trenching. The survey has failed to identify definite archaeological remains on the site - although the alignment of a probable former field boundary has been highlighted.

Studies have highlighted that geophysical survey, whilst a good technique for identifying substantial features and enhanced soils, is less reliable at detecting subtle or ephemeral archaeological remains such as settlement remains, posthole structures and isolated pits (particularly of prehistoric and earlier medieval origin). The absence of features identified by geophysical analysis cannot therefore be taken to indicate an absence of potential archaeological remains (Hay and Lacey 2001), and does not remove the requirement for archaeological evaluation to assess the impact of the proposed development.

However, given that the geophysical survey has failed to identify definite evidence of archaeological activity, it is recommended that the customary 5% sample can be reduced to a 3% sample - the minimum sample size recommended to provide an adequate assessment of the site to meet planning requirements and form the basis for designing a mitigation strategy (Hay and Lacey 2001, 50). The evaluation should be undertaken in a standard grid array, with some modification of the plan to target the identified linear geophysical anomaly.

It is customary for archaeological evaluation to be undertaken prior to determination of any application. However, if in this case the planning officer considers it desirable to utilise a pre- commencement planning condition to ensure appropriate assessment of the archaeological implications of the development and the subsequent mitigation through preservation in situ or by record, the following condition would be a suitable to use:

No development shall take place until the applicant, or their agents or successors in title, has secured the implementation of a programme of archaeological work. This will comprise: i) The developer will ensure that a suitably qualified archaeological contractor is employed to carry out an Archaeological Evaluation. The archaeological evaluation will be carried out in accordance with a written scheme of investigation which has been submitted by the applicant and approved in writing by the local planning authority and must meet the standards laid down by the Institute for Archaeologists in their Standard and Guidance for archaeological field evaluation. A copy of the Evaluation report shall be submitted to the Local Planning Authority for approval. Following approval, the report will inform further works necessary. The approved report will be submitted to the National Park Archaeologist and the local Welsh Archaeological Trust for inclusion in the Regional Historic Environment Record (HER). ii) Following on from the evaluation, any safeguarding measures required to ensure preservation in situ of important archaeological remains and/or further archaeological investigation, recording and reporting shall be implemented. These works will be undertaken in accordance with a specification which has been submitted to and approved in writing by the Local Planning Authority.

Reason: To ensure appropriate assessment of the archaeological implications of the development and the subsequent mitigation through preservation in situ or by record.'

An advice note for commissioning archaeological works within the Brecon Beacons National Park is attached above.

NP Heritage Officer Archaeology 12th Jun 2018 National Policy Framework Planning Policy Wales (Edition 9: 2016): Welsh planning legislation and policy guidance outlines that the desirability of conservation of archaeological remains is a material consideration in the determination of a planning application (Planning Policy Wales, Chapter 6, Para. 6.5.5). 'The conservation of archaeological remains is a material consideration in determining a planning application, whether those remains are a scheduled monument or not. Where nationally important archaeological remains, whether scheduled or not, and their settings are likely to be affected by proposed development, there should be a presumption in favour of their physical protection in situ. It will only be in exceptional circumstances that planning permission will be granted if development would result in an adverse impact on a scheduled monument (or an archaeological site shown to be of national importance) or has a significantly damaging effect upon its setting. In cases involving less significant archaeological remains, local planning authorities will need to weigh the relative importance of the archaeological remains and their settings against other factors, including the need for the proposed development.'

A programme of geophysical survey has been undertaken in support of the application. However, the report concludes that no anomalies indicative of definitive archaeological interest were identified within the site boundary. A weak linear feature identified has been interpreted as probably relating to a former field boundary. The remainder of features were interpreted as either of natural origin, deriving from ploughing, or resulting from modern magnetic disturbance (Sumo, June 2018). Archaeological Impacts of the development The planning application is for a change of use of agricultural land to accommodate the installation of a 'luge run' with an ancillary building and the erection of a toilet block and kiosk, at Cantref Adventure Farm, Upper Cantref Farm, Brecon, Powys LD3 8LR.

Archaeological recommendations: Archaeology All proposals for development or change of use of land or buildings in the National Park must demonstrate that the proposed development does not have an unacceptable impact on, nor detract from, or prevent the enjoyment of archaeological features. Consultation of the regional HER, and the Desk Based Assessment produced in support of the application have indicated that the proposed development is located within an archaeologically sensitive landscape. A staged programme of archaeological field assessment has been required in order to inform determination of this application. To date, a programme of geophysical survey has been completed, which aimed to provide information on the nature and character of the detectable archaeological resource within a specified area, and to inform the programme of trial trenching. The survey has failed to identify definite archaeological remains on the site - although the alignment of a probable former field boundary has been highlighted. Studies have highlighted that geophysical survey, whilst a good technique for identifying substantial features and enhanced soils, is less reliable at detecting subtle or ephemeral archaeological remains such as settlement remains, posthole structures and isolated pits (particularly of prehistoric and earlier medieval origin). The absence of features identified by geophysical analysis cannot therefore be taken to indicate an absence of potential archaeological remains (Hay and Lacey 2001), and does not remove the requirement for archaeological evaluation to assess the impact of the proposed development.

However, given that the geophysical survey has failed to identify definite evidence of archaeological activity, it is recommended that the customary 5% sample can be reduced to a to a 3% sample - the minimum sample size recommended to provide an adequate assessment of the site to meet planning requirements and form the basis for designing a mitigation strategy (Hay and Lacey 2001, 50). The evaluation should be undertaken in a standard grid array, with some modification of the plan to target the identified linear geophysical anomaly.

The second stage of the archaeological field assessment is now required. 2) The developer will ensure that a suitably qualified archaeological contractor is employed to carry out a programme of archaeological trial trenching to evaluate the potential of the site and achieve an understanding of the nature of the archaeological remains and the likely impact of the proposed development. The evaluation will be carried out in accordance with a written scheme of investigation which has been submitted by the applicant and approved in writing by the local planning authority and must meet the standards laid down by the Institute for Archaeologists in their Standard and Guidance for archaeological field evaluation. A copy of the Evaluation report shall be submitted to the Local Planning Authority for approval. Following approval, the report will inform any further works necessary: determination of the application/ or whether further archaeological work is required. An advice note for commissioning archaeological works within the Brecon Beacons National Park is attached above.

Settings of Listed Buildings The Conservation and Historic Buildings officer at the Brecon Beacons National Park will be commenting upon the effect on the proposed development on the settings of Listed Buildings, including the Grade II Listed Lower Cantref, and that information is not reproduced here.

NP Heritage Officer Building Conservation 21st Aug 2018 POLICY CONTEXT Planning Policy Wales (Edition 9: November 2016): Paragraph 6.5.11 recognises the importance of protecting the historic environment and states that: "There should be a general presumption in favour of the preservation of a listed building and its setting, which might extend beyond its curtilage. For any development proposal affecting a listed building or its setting, the primary material consideration is the statutory requirement to have special regard to the desirability of preserving the building, its setting or any features of special architectural or historic interest which it possesses."

Technical Advice Note 24: The Historic Environment (May 2017)

Setting of Historic Assets in Wales (May 2017)

Brecon Beacons National Park Local Development Plan (December 2013)

Policy 17: The Settings of Listed Buildings:

Development proposals which would adversely affect the setting of a listed building will not be permitted. ASSESSMENT These comments are written with regard to the heritage and conservation aspects of the proposal.

Built Heritage comments have previously been provided within a memorandum dated 23.11.2017 and an email dated 11.05.2018. To summarise, it was considered that due to distance and intervening landscape features, the impact on the setting of the listed buildings closest to the site (Church of St Mary, Cantref House, and Lower Cantref) would be little changed in terms of visual connectivity. However, the comments went on to point out that other sensory elements also affect setting. In this case, the noise likely to be generated by the proposal, including the operation of the luge run and additional vehicles accessing the attraction has the potential to harm the setting of the nearby listed buildings.

Since the built heritage comments were provided, further information has been submitted for consideration. The additional information regarding the noise likely to be generated by the proposal is contained within the Noise Rebuttal Report, supplementing the sound assessment in the Environmental statement Cadw's guidance 'Setting of Historic Assets in Wales' (2017) provides advice on assessing the impact of development. The document states 'The setting of a historic asset includes the surroundings in which it is experienced and appreciated, embracing present and past relationships to the surrounding landscape.' The heritage assets referred to above are currently understood within the context of a rural landscape which is made up of a scatter of farmsteads, small hamlets, individual buildings / dwellings, set within a gently rolling landscape of agricultural fields, hedgerows, tree groups, woodland and narrow 'country lanes. Historic mapping shows that this area has changed little since the late 19th century and in spite of modern farming methods, the landscape is much the same. The landscape within which the listed buildings are experienced and appreciated has therefore been fairly constant for a considerable period. The countryside surrounding the listed buildings is tranquil and relatively remote since only accessed by narrow lanes. Any new sounds that are unexpected in this context have the potential to be experienced more acutely. Cadw's guidance is clear that when considering the impact of development on a historic asset, it is not only views to and from that are relevant: 'Although views to and from a historic asset are often the most obvious factors, other sensory elements can also affect setting'. The impact of sound on the setting of the listed buildings as a result of the proposed development is therefore an important consideration in the assessment of this application.

The Noise Rebuttal Report defends the sound assessment provided in the Environmental Statement. In terms of the accuracy of the assessment of anticipated sound arising from the Luge, the views of consultees with expertise in this area are deferred to. However, it is pointed out that although the test track runs at Upper Cantref provide a measurable basis for the predicted sound emissions from the Luge run, the assessment on the likely sound levels related to spectators and ride users is less robust. The Luge is likely to be a high adrenaline ride and as the applicant's supporting information points out, there is no comparable attraction in Europe. The predicted sound levels from spectators and ride users seem to be speculative and not sufficiently backed up by evidence other than the author's personal experience (Noise Rebuttal Report). In addition, during a site visit to Upper Cantref on Wednesday 8th August a loud speaker was in use intermittently and was loud enough to be intrusive, even from a distance. The Noise Rebuttal report states that they are not aware that the applicant intends to install a public address system. However, this would appear to be no means certain based on current observations.

From a heritage perspective the additional sounds arising from the Luge is therefore still of concern. As stated above, an element of the setting of the listed buildings close to the Luge site is the peace and tranquillity offered by their rural surroundings. Some sounds arise from agricultural activity but this is integral to the predominant land-use in the area and is not unexpected. In comparison, the sounds potentially generated by the operation of the Luge run, spectators and ride users are more alien and unexpected in this rural location. As such, the understanding of the agricultural character of the landscape associated with the historic assets would be diminished. Although some assessment of the impact on the setting of the listed buildings has been provided in the Historic Environment Desk-Based Assessment produced by RPS, this primarily focusses on the visual relationships and only provides a brief reference to noise generated by the proposal.

The other sound issue is related to the additional traffic likely to be generated by the Luge attraction. This includes vehicles on the road network and vehicles manoeuvring to park within the site. In terms of the accuracy of predicted visitor numbers and increase in traffic, again I defer to other consultees with expertise in these areas. Any noticeable increase in the number of vehicles using the lanes leading to Upper Cantref as a result of the proposed visitor attraction will have a negative impact on the tranquillity of the area and therefore harm the setting of the listed buildings.

The applicant is not currently including any additional area for parking to cope with increased visitor numbers. It is understood from the information supplied in the application that the current parking areas accommodate up to 282 spaces. This is referred to as car park A and car park B although I was unable to identify these areas on the submitted plans. Any additional parking area on the field to the south west (where overspill car parking has been observed in the past) would be in close proximity to St Mary's Church and Cantref House and would feature in views to and from these buildings. This would change the way these heritage assets are experienced and have an adverse impact on their setting

CONCLUSION The information in the application does not provide sufficient assurance that sounds related to the Luge development will not be detrimental to the setting of the listed buildings. Although a sound assessment has been produced as part of the Environmental Statement, none of the supporting information considers in sufficient detail how sound might affect the setting of the listed buildings.

In terms of the accuracy of the applicant's assessment of the anticipated noise likely to be generated by the Luge, the views of consultees with expertise in this area are deferred to. However, based on the current available information which is considered to be incomplete, it remains a concern that the sounds / noise generated by the proposal will detract from how the listed buildings are experienced and understood, in turn harming their setting. Therefore from a heritage perspective, the objection to this proposal stands.

NP Heritage Officer Building Conservation 11th May 2018 I have looked through the case file and the application does not seem to include information about the siting of additional parking to serve the luge run attraction. The red line identifying the application site does not include the land shown in the photographs that you forwarded which I understand are from a third party. If additional parking is required, we would need to know where the parking would be located, the level of infrastructure required, and design details such as landscaping and materials. The setting of listed buildings would be one of the considerations but there would also be other issues to consider, including impact on ecology and landscape. At the moment from a heritage perspective I can only comment on the content of the application as presented. Depending on the location of parking there could be a harmful impact on the setting of listed buildings; however, until the applicant provides information on location and detailed design I cannot comment any further.

In my comments dated 23.11.17 I raised the issue of increased noise levels as a result of the development potentially having an impact on the setting of the listed buildings. To be clear, this includes noise generated from additional traffic as well as noise generated from use of the luge run.

I refer to the email dated the 15th August 2018 from Jane Pashley in respect of additional third party representation received by the BBNP.

Having regard to the correspondence dated the 10th August 2018 from Hunter Acoustics I note their comments in respect of the following:

'No assessment of the clanks or bumps as carts transfer onto the power rails has been undertaken by Acoustics & Noise Ltd. It is our opinion that this should be assessed as it has the potential to cause annoyance at nearby noise sensitive receptors'.

'Acoustics & Noise Ltd were not made aware of the installation of any public address system and they confirm that this would need to be assessed, if used for purposes other than emergency use. It is our opinion that this has to be assessed given the annoyance currently being caused by PA systems in operation at the Cantref Adventure Farm to surrounding noise sensitive receptors'.

'The current application has significantly underestimated the potential visitor numbers the luge is likely to attract. The cumulative effect of this, is that noise from road traffic is underestimated in the applicant's noise chapter of the Environmental Statement, and the number/regularity of LAmax,F events from shouting and laughing, which already cause annoyance to the local community, is likely to significantly increase. It is our opinion that this should be assessed as it has the potential to cause annoyance at nearby noise sensitive receptors'.

I would suggest that the applicant has the opportunity to consider and respond to the above comments by providing an additional noise impact assessment.

CONTRIBUTORS Andrew And Heather Hornung, Rhiwiau, Cantref BreconMr Andrew Bevan, 2A High Street , CrickhowellMrs P Herring, 14 Penfan Road, BreconVeronica Sullivan, Bailyhelig Farm, Bailyhelig RoadUrsula Sullivan, Bailyhelig Farm, Bailyhelig RoadMr Colin Herring, Bailyhelig Farm,, Bailyhelig RoadMiss LARA JENKINS, 25 st david's park, llanfaesMr Rob Jenkins, Camp Cynrig, CantrefVeronica Sullivan And Pam Colin Herring, Bailyhelig Farm, Bailyhelig RoadDP, M And BWD Davies, Pencaefadog Farm, CantrefMr John Griffiths, The Forge, CantrefSheila Jenkins, Cantref House, CantrefMr Bernard Aronson, Lower Cantref, CantrefAG And JM Davies, Berllan Farm, CantrefShania Jones, Berllan Bungalow, CantrefAndrew And Stella Phillips, Tylebrythos, CantrefChris Davies MP, Chris Davies MP, House Of CommonsJane Walters, Pannau Farm, CantrefMr And Mrs P And W Jones, Berllan Bungalow, CantrefMr Andrew Hornung, Rhiwiau, U0544 From South West Of Pen-Yr-Heol To Junction With Road To RhiwiauMr Alexander Isaac, 32, North Worple WayStella Owen, , Susan Brooks, Old Crofftau, CantrefJCP Solicitors, Registered Office, Venture CourtMr And Mrs MHL Lewis, Glan Usk, Llanfrynach

OFFICER’S REPORT This application was originally presented to the PAROW Committee meeting on 15th May 2018, but withdrawn from consideration by the Chairman in order to allow time for the applicant to address matters of concern that have been raised about the proposed development.

The report is the same as previously presented but has been updated where necessary to include the additional information that has been submitted, any additional responses received and consideration of these matters.

NEIGHBOUR/THIRD PARTY RESPONSE SUMMARY This application has been advertised through a press notice, the erection of a site notice and neighbour notification, which was repeated in respect of the additional information submitted. As a result of this publicity, 20 responses have been received raising the following objections:-

Policy - contrary to national and local planning policy, contrary to Sandford Principle, purposes of the national park, query whether should be a departure, duty of BBNP to protect, promote, conserve and enhance special qualities of natural beauty, wild life and cultural heritage as a basis of tourism industry, does not conserve natural beauty as defined in the Sandford Principle, not compatible with SP16 and SP1and many other policies -Policy 38e, 59, SP1, sustainable tourism, with previous developments at site and in wider locality development incompatible with primary purpose of the park

Landscape/Visual - Adverse impact on special landscape, impact significant extending beyond 15 years, does not have positive impact on characteristics of LCA 6 in accordance with SPG on Landscape, cumulative impact on rural character, eyesore- detrimental visual impact from places such as Pen - Y Fan, adverse landscape impacts cannot be mitigated, destroy natural beauty of landscape when viewed from such places as Pen Y Fan, detrimental visual impact, be an eyesore, race track will form prominent engineering feature.

Natural beauty Harm existing character, rural location and natural beauty and quiet enjoyment, change rural character of area, spoil it, create a theme park which is inappropriate, will have opposite effect on local surroundings, people, way of life and tourism in locality.

Amenity, peace, tranquillity, noise -Noise impacts for residents and others enjoying peace and tranquillity - cannot be mitigated , impact on social wellbeing of people, disturbance, undermine quality of lives for community and environment in Cantref, wish area to remain quiet, safe and calm, use is likely to generate noise from generator and users and spectators of luge run, noise pollution from loud speakers, racing activities and disco music on occasions, use of flood lights, speakers, additional noise will cause disturbance and distress to sheep and livestock and noise pollution, noise levels difficult to assess until development is complete, peace, quiet and tranquillity and for adjacent tipi village, noise of existing site will be exacerbated, detrimental to residential amenity, peace and tranquillity, noise from increase in traffic and users of luge, with use of tannoy system likely to be regular, health and safety, screaming and shouting.

Scale - Existing adventure farm has plenty of amenities and is big enough, when will it stop, not ancillary to existing use, doubling of size, national scale, cannot be accommodated on site without causing significant harm, scale unsuitable, inappropriate scale not proportionate or ancillary to existing adventure farm, existing site big enough with plenty of facilities, represents a major tourist attraction - an adrenaline based activity involving people racing downhill on luge carts which would normally be found at an amusement park rather than a National Park, should be sited in a more appropriate location in terms of the transport network and environmental nuisance, away from residential areas, Merthyr or Cardiff, initial permission stated that adventure farm should not overtake pony trekking business which it has, development would be in breach of conditions 11 and 12 of original permission 12/08328/FUL and the maize maze is unauthorised, community given assurances that scale of site would be carefully controlled by conditions to ensure scale ancillary to farm, concern will develop into a theme park the scale of Oakwood or Alton Towers , beginnings of a theme park unacceptable, countryside should be protected from this luge which resembles a formulae one track, with bridges for spectators in beautiful countryside.

Visitor Numbers New concept for Wales and UK will attract large numbers of visitors, attractions and theme parks get bigger and bigger which is alien in a national park, such a significant investment would surely need to attract tens of thousands of visitors, would attract different age group of visitor - teenagers and young adults resulting in more cars and people visiting the area.

Access/Highways /Traffic Present position -traffic from existing adventure farm having negative impact on local residents and nearby businesses, present access and parking facilities inadequate, congestion and efficient movement of existing tourist and agricultural traffic, growth of site has often seen road gridlocked, coach convoys and increased traffic causing increased community safety concerns, inability of emergency vehicles, insufficient parking at peak times, BBNP considered Bailyhelig Road substandard and incapable of increase in vehicular activity when determining application 10/04668/FUL - no improvements made except more traffic generated, traffic ignores traffic signage, accidents and near misses have occurred but not reported to police, minor collisions not reported, parking already occurs outside sit e boundary, on lanes and adjacent to listed house and church, lots of buses already block lanes.

Bailihelyg Road - an ancient green lane is not capable of increase in vehicular traffic - majority single track with limited passing and traffic in Llanfaes for 4 miles, already heavy at school start and end times, use of LLanfaes route unsatisfactory, lack of passing bays, unsafe to allow more traffic to pass Llanfaes CP School, with narrow footpath between church hall.

Proposals will cause traffic congestion, conflict with highway users, damage to highway verges, existing traffic problems will be exacerbated, will increase traffic to unacceptable levels, existing roads with twists and blind turns, steep parts and in poor condition not suitable for volume of traffic predicted and buses, inadequate existing capacity of country lanes/class C roads causing inconvenience and danger to farmers, residents and other visitors on a regular basis, additional cars, buses and commercial vehicles visiting and servicing site, additional traffic on roads without capacity causing hazards and congestion for local residents, farming community, emergency vehicles, tourists, holiday makers, walkers, cyclists and horse riders.

Cumulative impact - increase in traffic created over time due to increase in activity from holiday conversions, campsites, housing development and Cantref Adventure Farm, walkers and cyclist, this will compound problem, development of camp site due to be completed next year will cause more traffic

Signage should be placed at the Tarell roundabout to direct people to A40 and via Llanfrynach route, rather than via Bailyhelig from LLanfaes, (this route is already congested) although satellite navigation takes people via Cefn Cantref.

Concur with Highway Authority's recommended refusal.

Existing Economy Summer busy for local farmers who constantly use lanes with machinery, sheep and livestock on daily basis and large number of visitors will cause stress and prevent this work, will jeopardise small key tourism in vicinity Needs and opinions of established community of Cantref should not be ignored in favour of tourism, would be detrimental to small tourism businesses in area, need tourism but not at expense of social well-being of community, distress and inconvenience to nearby farmers and livestock, promotion of large scale tourism should not be at expense of local people and way of life, upsetting the balance, harm to efficient and productive nature of business, conflict with existing agricultural traffic, conflict with low impact tourism businesses.

Detrimental impact to local listed buildings due to noise, visual impact, and extension of development for parking.

Pre App - No response or changes made in relation to objections made during pre- application consultation process.

Enforcement matters raised in relation to existing site which may have impact of validity of proposed development, the maize maze needs permission, and there are failures and growth rates of previous mitigation planting subject to enforcement action.

Third Party Reports

Vectos Transport Objections for JCP Solicitors dated Feb 2018 No evidence to support level of visitor numbers Rationale for limiting catchment to 40 minute drive flawed Unsustainable location Local roads unsuited to significant increases in traffic causing highway safety issues Existing parking provision inadequate

Review of LVIA by Fiona Cloke Associates dated March 2018 Area of attraction 80% larger than present Development not dependant on countryside location LVIA underestimated severity of adverse landscape and visual effects- with open site, elevated and forming part of important views of Central Beacons with landscape and viewers very sensitive to changes of scale and nature proposed o Consider mitigation planting insufficient and estimates of growth rates higher than expect for elevated site o There would be more significant adverse landscape and visual effects than shown in submitted LVIA - sensitivity of landscape underestimated and severity of effects, particularly the cumulative effects within existing farm park. Not clear whether winter effects considered which would be more severe as mitigation largely dependent on deciduous planting. o The luge development would not result in positive impacts on the defined characteristics of LCA6 and would have significant adverse effects on the special qualities of the National Park and contrary to LDP policies SP1, SP3 and CYD LP1.

Independent review of Farm Park's Visitor potential by TVAC dated April 2018 o Visitor numbers are based on a 40 minute drive time where typically a 1 hour drive time is considered and up to 2 hours for unique and larger attractions ( Luge will be unique in Wales and UK) o A 60 minute drive time is used then potential market much higher o Comparable toboggan style ride attractions in Wales have attracted far more visitors and led to other linked development o Visitor estimates expected to be at least 50,000 to 60,000 visitors a year-and potentially up to 80,000 or 90,000 as would be first such attraction in UK (with press and social media interest) and age demographic will change.

Noise Report by Hunter Acoustics o Considers that the application has underestimated the potential visitor numbers and therefore noise from road traffic o The PA system is not assessed o Current activities causing unacceptable disturbance and luge would increase impact o Noise sources of screaming, shouting, PA system, out of character with National Park.

One letter of support has been received making the following comments:- o Cantref Adventure Farm plays an important part in the tourism and economy fulfilling a popular visitor destination where there are few attractions for families in the area o Small expansion will enhance the attraction and bring it up to date and blend into the landscape o Further job creation is an additional benefit of the expansion o Proposal fits in with the tourism strategy

Following PAROW meeting on 15th May, and further publicity, the following additional responses have been received:- Third Party Reports:- Heritage Impact Statement: Summary Review of Supplementary Landscape Statement Noise Comments Transport Objection

In addition, further letters have been received raising the following comments:-

Proposal is damaging to community and local environment Increased traffic on roads not built for heavy traffic especially in holiday season Cars already use overflow car park Safety of walkers and horse riders Effect on St Mary’s church Peace and tranquillity destroyed Question whether trees planted to hide luge Support response from PCC Highway Authority Local farming business already adversely affected Any further traffic will be a significant concern Adverse impact continuing expansion will have on landscape, inappropriate eyesore Additional information has not addressed previous concerns Minor amendments has not changed significant concerns of noise, traffic, landscape and environment Proposals do not adhere to the two purposes of the National park Should be sited in more appropriate location in terms of transport network and environmental nuisance Photographs provided showing traffic on narrow stretches of road resulting in traffic delays Local business already constantly adversely affected by traffic associated with adventure farm – photo provided of bank holiday traffic Already an eyesore in the landscape and application inappropriate in National Park None of the Bailihelig Road issues have been addressed by recent additions- where there is a further increase in traffic due to Cefn Cantref camp site opening Fully support BBNP planning and PCC Highway in rejecting application Increased noise, (pa sound system) residential amenity, landscape character degradation and traffic levels are of concern. Not compatible with objectives of a national park No reasons provided to overcome previous reasons for refusal of the proposed development which does not accord with national or local planning policy

INTRODUCTION This application seeks full permission for the change of use of agricultural land to accommodate the installation of a luge run incorporating bridges and a spectator footpath;; ancillary building for queuing, shop, store, repair area; generator enclosure; drainage attenuation ponds; landscaping and a maize maze, together with a toilet block and refreshment kiosk.

The site relates to land at and adjoining Cantref Adventure Farm, Upper Cantref Farm, Brecon, LD3 8LR.

The application is being reported to the Planning Access and Rights of Way Committee as it constitutes a 'major' development.

SITE DESCRIPTION The site is irregular in shape and measures approximately 5 ha on land which comprises agricultural land adjoining and to the north and land within the existing adventure farm at Upper Cantref Farm, which lies approximately 3.5km south east of Brecon town centre and 1.5km to the west of Llanfrynach.

The site lies on a south east facing slope, is orientated east to west and the ground slopes steeply down from 225m AOD on the western boundary down to 180m AOD on the eastern boundary. The land falls a further 20m towards the Afon Cynrig, which is a tributary of the River Usk.

The northern boundary comprises of an overgrown hedgerow with trees on its lower eastern part and a small watercourse. The eastern, western and southern boundaries comprise of trimmed hedgerows with very occasional trees. The southern boundary has gaps in the hedgerow due to grazing from animals.

The existing adventure farm comprises of a field with a central "green" with various attractions around it. There is a track around the perimeter used for farm tractor rides and a wildlife pond at the south eastern corner of the site.

The buildings at the site comprise of a mixture of traditional stone and modern steel framed buildings, grouped at the site. The original stone built farmhouse lies at the eastern edge some 40m from the main group of buildings and at a lower level. The camping site occupies land at the southern edge of the farm.

A planting scheme was carried out in 2013/2014 as part of the development of the camping site in order to integrate the development into the landscape.

The access to the site is along a 250m long private drive from Cantref Road a minor Class C public road. The site benefits from brown tourist signs from the A40 trunk road to the east at Cefn Brynich which directs traffic along the B4558 and Cantref Road avoiding the centre of Llanfrynach. The alternative route to the west joins Bailyhelig Road to Llanfaes, Brecon. There is no public transport serving the site. Parking facilities exist within the site and additional parking spaces and an overflow car parking area were granted in 2013 (12/08328). Access within the site is pedestrian only which are Equality Act standard.

The existing adventure farm is open in the summer from 10:30 to 17:30 hours from first day of school Easter holidays until the end of the school Autumn half term break and in the winter is open during weekends, Christmas holidays and Spring half term between 10:30 to 17:00 hours (closing at 16:00 hours on Christmas Eve and New Year's Eve. It is closed on Christmas Day, Boxing Day and New Year's Day.

In ecological terms the site consists mainly of improved grassland used for sheep grazing. The western section of the site is fenced off and cropped with maize. Hedgerows form the site boundary and provide habitat connectivity to the surrounding woodlands and open arable/grazing pasture. There are no trees or buildings on the application site.

The closest ecological designation is the Afon Cynrig, approximately 200m to the east of the site, which is connected to the River Usk approximately 350m downstream, which is designated as a Site of Special Scientific Interest SSSI and a Special Area of Conservation (SAC).

In the vicinity of the site are scattered dwellings or farmsteads. Nearby is the historic St Mary's church and associated rectory and Cantref House which are all Grade II listed buildings.

There are two public footpaths in close proximity to the site. One follows a field boundary to the west of the site within a sunken lane, linking Cantref with Tir-y-Groes farm and the other leads south from Cantref church and crosses the Afon Cynrig.

The site lies within flood zone A for the purposes of TAN 15.

The site is located outside the Middle Usk Valley: Brecon and Llangors Landscape of Outstanding Historic Interest. The site lies within Landscape Character Area 6 Middle Usk Valleys, as defined in the BBNP Landscape Character Assessment and SPG.

The site lies within the Brecon Beacons Dark Skies Reserve but outside the core or buffer zone.

PROPOSED DEVELOPMENT

Background Upper Cantref Farm comprises of approximately 56ha (140acres) with an additional 14ha (36 acres) in Llanddew approximately 6 miles away. The land is predominantly used for agricultural purposes, comprising permanent pasture stocked with 250 Welsh Mule breeding sheep and 70 horses.

In 1993 the farm diversified into education and tourism, initially starting with a caravan site and progressing into pony trekking and farmhouse bed and breakfast.

In 2003 the farm diversified further into an educational farm-based visitor attraction providing improved facilities such as café, shop, covered play, educational area and ancillary facilities to the riding centre. The activities being provided include a range of animals including alpacas, donkeys, horses, sheep, pigs as well as rabbits, guinea pigs which children can handle and sledge rides, paddle boats, outside play area and equipment, picnic areas. This area represents 6ha of the site or 9% of the total area.

The existing uses at the site were regularised by a partly retrospective planning permission, 12/08328/FUL dated 14th August 2013 for "Retrospective composite planning application for the change of use of land and buildings to provide A) A boating ride, B) Pony paddock, C) Animal/play area, D) Tractor ride, E) Play area, I) Overflow car park, J) Static caravans, incorporating improvement to education visitor centre by providing 16 camping pitches, toilet and shower block ( including washroom accessible to physically disabled visitors). To include associated engineering works to facilitate the specific uses detailed herein, including proposed car park for campsite.

The proposed development is seeking to further the farm diversification of the land at Upper Cantref Farm. The applicant is proposing this new visitor experience in order to regenerate visitor numbers which have been falling since a peak level of approximately 44,000 in 2008. It is also intended to prolong visitor stays. The expected visitor numbers are 42,000. Without this investment, to sustain visitor numbers, then it is anticipated that the visitor attraction at Cantref will decline and will ultimately bring into question its viability.

The existing adventure centre employs some 8 full time and 36 part time/seasonal employees. The introduction of the luge run is anticipated to increase the number by up to 2 full time and 12 part time employees or 6 full time equivalent staff.

Components of the development Luge track The luge track comprises of a 3m wide bitmac surfaced track which follows a 526m long curved route down the slope before returning up the slope via a 262m straight section to reach the start. The track follows a designed average gradient which is 1:16.5 which would be generally cut into the upper slope and filled on an embankment within the lower parts, with ground disturbance along the track up to a maximum width of approximately 40m and a height of 5m. The side dimensions of the slopes would be generally be 1:2, 1:3 but some profiles have a more natural profile. The landform would be created using materials won on the site as part of a cut and fill exercise.

The luge is a free-wheeling low level cart with one seat for one rider, 4 small rubber wheels, handlebars for steering, a bumper at low level and a braking mechanism. It would be fitted with a GPS system and cameras to record each individuals experience and to provide timed competitive racing.

The luge has been designed and engineering for all able bodied persons over 93cm tall and a photograph of the prototype has been provided. Luges for less able bodied riders are proposed to be incorporated during the operation of the luge.

It is anticipated that it would take a rider between 4 and 7 minutes to traverse down the track and a small electric motor (powered by batteries) would power the luge back to the top of the track. A back-up diesel generator is proposed to be installed adjacent to the reception building to be used as necessary.

Spectators would be able to use the paths and bridges over the luge track. The paths would be constructed of crushed stone a maximum of 2m wide and the two proposed bridges a maximum of 2.0m above the proposed ground levels, constructed of timber with 1.1m high timber fencing.

Entrance/Exit building and storage workshop This a single storey building within the south western corner of the site. It would measure an approximate maximum size of 20m x 11.7m x 5.2m high to the asymmetrical ridge and 3.3m and 2.2m down to the eaves and would be finished externally in timber cladding with dark grey profiled metal roofing.

Toilet and refreshment block This is proposed within the western part of the existing central green of the adventure farm. It would be located on an existing hard-core base. It is a single storey building which would be finished externally in timber cladding with dark grey profiled metal roofing. It would measure approximately 10m x5m x 3.3m high to the asymmetrical ridge and 2.3m and 2.0m down to the eaves.

The maize maze This is sited within the north western part of the site. It would be a maize crop which would be planted in May/June, used as a maize once the crop has attained a suitable height (mid to end July) and then harvested in late autumn.

Water supply, drainage and flood risk A new single attenuation pond and ditch would be created at the south eastern lower part of the site to collect surface water run-off from the proposed track and roof water of the ancillary building via existing and new piped drains. The existing ditch would also be intercepted and directed into the pond. The pond would be fenced to allow the marginal areas to develop into wildlife habitat. Disposal of roof water from the toilet/refreshment kiosk would be discharged through soakaways. The drainage strategy is provided in more detail within the Outline Drainage Report.

The site would be served by a private water supply and all foul water discharges would be to the existing septic tank which was installed in 2013.

Landscape Strategy The landscape strategy comprises of additional planting including tree belts and hedges. It involves planting the embankment areas with native woodland species, planting of woodland belts to subdivide the field, grassland management to increase biodiversity and visual diversity, planting of new hedges to contain the proposed paddock at the eastern lower part of the site and the provision of wildlife habitat around the attenuation ponds.

All components of the proposed development are shown on Figures 8 Rev A, 4.7 Rev H, 4.8 Rev E, 4.9 Rev F and the landscaping scheme is shown on Figure 4.14. Sections 4.10 Rev C, 4.11 Rev C and 4.12 Rev C also show the landscape mitigation measures.

Ecological Enhancements The ecological enhancements include a 2m wide strip of rough grass which would be created on the site perimeter where possible, installation of biodiversity features including 3 bat boxes, a minimum of 3 bird boxes on existing trees within the northern corridor, underground bumblebee box and 3 insect hotels.

The landscape and ecological management plan aims to manage existing trees and vegetation to enhance the landscape, visual and wildlife value of the site, promote speedy establishment of new trees, shrubs, hedges and grassland, encourage ecological diversity and to manage the new grassland and planting scheme.

Access and parking No additional parking provision is proposed or modifications to the existing access. It is proposed to install additional signage at the A40/A470 roundabout to the south west of Brecon to further promote the appropriate route to the site, rather than the Llanfaes route. It is also proposed to develop and implement a travel plan to minimise the traffic impact of the development. Additional footpaths would be constructed within the site to the same standard as exists within the existing site.

Lighting and Tannoy system Both new buildings would have external lighting at the entrances to each building by low level shielded fixtures to prevent light spill, controlled by motion sensors to minimise light pollution. No other lighting is proposed for the development. A localised tannoy system is proposed along the luge track for health and safety and emergency reasons.

Construction The indicative construction programme is approximately 12 weeks from 07;00 to 19:00 hours Monday to Friday , 07:00 to 13:00 hours on Saturday and at no time on Sundays or on bank and public holidays. The key elements of the construction work would be to upgrade an existing access track located away from the visitor area, construct the drainage and attenuation ponds, construct the main earthworks for the luge track, construct the luge track and lift, paths and bridges and erect the buildings.

The site would be fenced and a number of temporary facilities would be required such as temporary welfare facilities, storage areas for materials, fuels, plant and equipment and topsoil management areas.

The peak periods for construction traffic movements are anticipated to be 07:00 to 08:00 hours and 15:00 to 16:00 hours. It is not expected that any abnormal loads would be required.

Construction activities would be implemented in accordance with a Construction Environmental Management Plan which sets out the control measures for managing the potential environmental effects of construction, pollution prevention measures and limiting disturbance.

Supporting Documentation The details of the proposed development is fully detailed within the submitted plans and documentation. The supporting documentation is listed below:-

Pre-Application Consultation Report

Design and Access Statement

Environmental Statement

The Environmental Statement presents the assessment of likely significant effects on the environment in terms of landscape and visual impact, highway impact and noise impact, in accordance with the scoping opinion. It assesses the effects based on the existing baseline conditions of the existing adventure farm.

Since the original submission, a number of pieces of additional information and amendments have been made to the application which are reflected in new and amended documentation details as follows:- o An Errata to the Environmental Statement received 18.01.2018 o Response to Highway Authority comments received 08.02.2018 o Outline Drainage Scheme received 09.02.2018 o Historic Environment Desk Based Assessment dated Feb 2018 o Landscape and Ecological Management Plan - dated Feb 2018 - and revised March 2018 Construction Environmental Management Plan dated Jan 2018 and updated March 2018 o Revised plans to show site location plan, new block plan, landscape masterplan, attenuation ponds, landscape mitigation/planting plans and bridge plans to replace previous versions o Additional cross sections through the luge track to supplement original drawings o New plan showing the construction traffic route o Revised drawings of the design of proposed pedestrian bridges o Historic Environment Desk-Based Assessment dated March 2018 o Response to Vectos Transport Objections - letter dated 15 March 2018 o A Programme of archaeological works - ongoing

Since the PAROW meeting on 15th May 2018, the following documents have been submitted :- o Supplementary Landscape Statement July 2018 o Supplementary Transport Statement dated July 2018 o Draft Visitor Management Plan o Visitor Management Plan produced for Hobbledown Surrey – for information o Technical note from Vision XS Ltd o Comments on the Third Party Hunter Acoustics Review by Acoustics and Noise Ltd o Geophysical Survey Report

PLANNING HISTORY

15/12959/FUL - Screening Opinion dated 24.03.2016 determined that the proposed development is EIA development and that an Environmental Statement is required to accompany the planning application.

15/12959/FUL - Scoping Opinion dated 02.06.2016 determined that the Environmental Statement should include the following significant matters - landscape and visual impact, highway impact and noise impact.

15/12959/FUL - Change of use of agricultural land to accommodate the installation of a luge run with ancillary buildings and the erection of a toilet block and refreshment kiosk. Withdrawn 27.11.2016.

12/08328/FUL for "Retrospective composite planning application for the change of use of land and buildings to provide A) A boating ride, B) Pony paddock, C) Animal/play area, D) Tractor ride, E) Play area, I) Overflow car park, J) Static caravans, incorporating improvement to education visitor centre by providing 16 camping pitches, toilet and shower block (including washroom accessible to physically disabled visitors). To include associated engineering works to facilitate the specific uses detailed herein, including proposed car park for campsite. Permitted 14th August 2013.

11/07315/FUL Installation of photovoltaic panels on two roofs and associated connection to electricity national grid. Approved 21.10.2011

11/06933/FUL Improvement to educational visitor centre by providing 20 camping pitches, toilet and shower block (inc. disabled washroom). Change of use of land to accommodate these proposals. Approved Retrospectively 13.07.2011

07/01331/FUL Retention of ground based slide and kiosk for storage. Approved 11.09.2007

07/00966/FUL Extension to form additional catering facilities with store and staff room under. Approved 10.04.2007

P18148 Conversion and alterations to farm buildings to form cafe, shop lecture area, staff accommodation & covered play/educational area for children, as ancillary facilities to riding centre. Approved 10.01.2002 K12670 Full planning permission for change of use and conversion of redundant agricultural buildings to bunkhouse accommodation. Approved 10.06.1992 K12628 Full planning permission for extension to existing farm waste facilities. Approved 15.05.1992 K14734 Certificate of lawfulness for an existing use or operation relating to bunkhouse accommodation at farm. Approved 04.03.1996 K12454 Full planning permission for construction of open air collecting area at riding school. Approved 03.02.1992 P21438 Engineering works and development of 2no. slides, erection of kiosk and creation of associated footpaths. Approved K11667 Full planning permission for c/u of certain agricultural buildings grouped in farm yard to pony trekking establishment. Approved 29.10.1990

POLICY CONTEXT

Brecon Beacons Local Development Plan 2013 Policy 1 Appropriate Development in the National Park Policy 3 Sites of European Importance Policy 4 Sites of National Importance Policy 6 Biodiversity and Development Policy 7 Protected and Important Wild Species Policy 10 Water Quality Policy 11 Sustainable Use of Water Policy 12 Light Pollution Policy 22 Areas of Archaeological Evaluation Policy 38 Farm Diversification Policy 48 New or Extended Outdoor Activity Centre Policy 56 Water and Sewage Supply for New Development Policy 58 Sustainable Drainage Systems Policy 59 Impacts of Traffic Policy 60 Provision for cycling and walking Policy CYD LP1 Enabling Appropriate Development in the Countryside Policy SP1 National Park Policy Policy SP3 Environmental Protection - Strategic Policy Policy SP4 Climate Change Policy SP12 Economic Wellbeing Policy SP14 Sustainable Tourism Policy SP17 Sustainable Transport

SPG's Landscape and Development (October 2014) Obtrusive Lighting and Light Pollution (March 2015) Farm Diversification (BBNPA March 2015). Biodiversity and Development (Sep 2016) Joint SPG : Enabling Sustainable Development in the Welsh National Parks (March 2015)

In the determination of a planning application, regard should also be given to the requirements of National Planning Policy which are not duplicated in the Local Development Plan. The following Welsh Government Planning Policy is relevant to the determination of this planning application:-

Planning Policy Wales (PPW) Edition 9 Nov 2016 Chapter 4 - Planning for Sustainability, Chapter 5 - Conserving and Improving Natural Heritage and the Coast, Chapter 6 - Conserving the Historic Environment, Chapter 8 - Transport, Chapter 11 - Tourism, Sport and Recreation Chapter 12 - Infrastructure and Services, Chapter 13 - Minimising and Managing Environmental Risks and Pollution.

Planning Policy Wales Technical Advice Notes TAN 5 - Nature Conservation and Planning, TAN 6 - Planning for sustainable rural communities, TAN 11 - Noise, TAN 12 - Design, TAN 15- Development and Flood Risk, TAN 18 -Transport, TAN 23 - Economic Development, TAN 24 - The Historic Environment.

MATERIAL CONSIDERATIONS The main material planning considerations for a proposal of this nature are the following matters:- o Principle of the development, o Character and appearance of the area, o Highway infrastructure, o Ecology/biodiversity and protected species, o Archaeology, o Drainage infrastructure, flood risk and pollution control and o Amenities of nearby residents.

APPRAISAL

Principle of the development Overarching Strategic National Policy SP1 of the LDP requires development to conserve and enhance the natural beauty, wildlife and cultural heritage of the Park, and/or development which provides for, or supports the understanding and enjoyment of the special qualities of the National Park in a way that does not harm those qualities; and fulfils the two purposes above and assists the economic and social well-being of local communities.

The proposed development site is located within the open countryside as shown on the LDP Proposals Map, and lies adjacent to the existing tourist attraction at Upper Cantref Farm. The LDP defines countryside locations as areas unsuitable to accommodate future development in accordance with the Environmental Capacity of the National Park. In these areas there is a presumption against development with the exception given to those development forms where there is a defined essential need for a countryside location.

The LDP at para 7.8.8 goes on to state that the overriding principle in the consideration of all proposals for tourism or enjoyment uses is to ensure that the pursuit of the second purpose and the duty of the National Park does not conflict with the pursuit of the first. It also states that activities will be regulated by legal agreements where appropriate to control the impact of enjoyment and recreational activities so that no harm will be caused to the special qualities of the National Park.

Policy 48 d) allows for extensions to existing outdoor activity centres in the countryside if it can be demonstrated that there is no significant detrimental impact on the surrounding landscape character and the necessity for a countryside location is proven necessary.

Para 3.32 of the JSPG "Enabling Sustainable Development in the Welsh National Parks" states that while planning policy on tourism development varies from Park to Park, it is generally likely to be permitted if it contributes to the sustainable development of the Parks by promoting the understanding and enjoyment of the Parks' special qualities, provides accessibility to all who wish to experience the Parks' special qualities, and safeguards the tranquillity and views of the Parks to enhance visitor experience and maintain local residents' quality of life.

Policy 38 -Farm Diversification permits proposals for farm diversification where: a) the proposed diversification will be of an intensity of use appropriate to the environment and setting within the National Park and will have no significant detrimental effect on the vitality and viability of any adjacent town or village, either in its own right or through cumulative impact; b) functioning of surrounding agricultural land is not prejudiced; c) adequate provision for the storage of materials/equipment is maintained; d) adequate parking provision is made to serve the needs of the diversified scheme; and e) Any new buildings or conversions or existing buildings that form part of the proposal lie within or immediately adjacent to the group of existing buildings which make up the farm complex and are in accordance with Policy 23.

A business/management plan should demonstrate the necessity of the diversification to support the future viability of the farm and demonstrate the sustainability of the future proposal, as set out in accordance with the requirements of para 4.4 of the Farm Diversification Supplementary Planning Guidance (BBNPA March 2015).

Policy 1- Appropriate Development in the National Park sets out criteria to ensure that development does not impact on the National Park's ability to deliver its statutory purposes and duty.

PPW advises at Para 11.1.7 that in rural areas, tourism-related development is an essential element in providing for a healthy, diverse, local and national economy. It can contribute to the provision and maintenance of facilities for local communities. Here too development should be sympathetic in nature and scale to the local environment and to the needs of visitors and the local community. Para 11.3.1 advises that local planning authorities need to consider the impact of proposals on the environment and local community. They may seek to reduce the impact of development using arrangements for traffic and visitor management.

TAN 23 deals principally with Businesses Classes but recognises that the whole economy contribution to economic growth (jobs and income) is important. Section 2 outlines the criteria-based approach to balance economic benefits against any social or environmental damage.

Consideration The main considerations in relation to the principle of the proposed development is whether it is justified given its location within the open countryside and whether it would have any adverse impact on the special qualities of the National Park.

Justification in open countryside The proposed development would form an extension to the existing outdoor activity centre, which offers a variety of indoor and outdoor play and educational activities, riding, camping and bunkhouse accommodation. Given the length of the proposed luge track and its requirement for a sloping site, it is difficult to envisage that it could be accommodated within a settlement location. Whilst it is accepted that a luge track is not dependent on a rural setting, given the proposed close relationship with the existing tourist facility, it is considered that a countryside location is justified in this case. In addition, by providing a family orientated facility, accessible to all and open throughout the year, the proposed development would support the aims of the Sustainable Tourism Strategy. On this basis the Sustainable Tourism Officer has raised no objection to the development.

In terms of farm diversification, the supporting information states that the proposed development is an integral part of a farm diversification project that is necessary for its continued economic success. Clarification has been received from the applicant's agent that the existing farmland of Upper Cantref comprises of 71.3ha of which 6.29ha is taken up by the existing recreational and educational purposes. The installation of the luge run and associated development would increase that area to 11.29ha, which would represent 15.9% of the total farm area. The development has been designed not to interrupt the existing farming activities, which comprise the stocking of 250 sheep and 70 horses and which would remain the primary use of the farm.

It appears from a number of site visits by the case officer that adequate provision for the storage of materials/equipment exists at the site and this would be unaffected by the proposed development. The development would give rise to the provision of additional buildings, but these are considered to be reasonably necessary for the development, are of a scale and character in keeping with the existing agricultural buildings found at the wider site and would be located within or adjacent to the existing group of existing buildings. The proposed development would therefore seem to complement the existing farm business and would not disrupt or prejudice the functioning of the existing agricultural operations.

Without the new investment and added new attraction of the proposed luge and associated development to sustain visitor numbers the applicant's agent has stated that it is anticipated that the visitor attraction at Cantref will decline and will ultimately bring into question its viability. The introduction of the luge run is also anticipated to increase the staff number by up to 2 full time and 12 part time employees or 6 full time equivalent staff compared to the existing adventure centre employs some 8 full time and 36 part time/seasonal employees.

The proposed development is therefore considered in principle to be justified in its countryside location, in terms of being associated within an existing tourism facility, forming an integral part of a farm diversification project which does not appear to prejudice the functioning of the existing agricultural operations. It would also bring some economic benefit in terms of additional employment at the site. The development would therefore make a small but valuable contribution to the local economy and social viability.

Impacts on the special qualities of the National Park In view of the scale of the development, being an EIA development, the proposed development has the potential to have an adverse impact on the special qualities of the National Park in terms of its natural beauty, wildlife and cultural heritage, peace and tranquillity.

The Environmental Statement which accompanies the application has considered the significant matters of landscape and visual impact, highway impact and noise impact and has concluded that there would be no significant adverse impacts on the environment, in the long term. In addition, no significant impacts have been shown to effect local ecology or biodiversity matters or cultural heritage resources. However, following consideration of consultee responses and representation it has been concluded, as set out in the individual topics within the report below, that the proposed development would be likely to cause significant adverse impacts in relation to the key environmental impacts of landscape character and visual impact and highway impact. In addition, it has not yet been determined whether the proposed development will have any impact on cultural heritage in terms of unrecorded archaeological resources within the site.

Revised comments have been received from the Strategy and Policy Team that whilst the general principle of the development is acceptable, this cannot be at the expense of the special qualities of the National Park. By reason of its detrimental impact on the landscape, it is considered that the proposal would fail to comply with the policies of the Adopted Brecon Beacons National Park Local Development Plan, namely SP1 National Park Policy, Policy 1 Appropriate Development in the National Park, SP3 Environmental Protection, CYD LP1 Enabling Appropriate Development and SP14 Sustainable Tourism.

In conclusion, as it is considered that the proposed development would have significant adverse impacts on the special qualities of the National Park, in terms of safeguarding its natural beauty and also cultural heritage. The proposal would therefore be contrary to the provisions of policies SP1, SP3, SP14, CYD LP1, 1, 38 and 48, of the LDP.

Update following PAROW on 15.05.2018

Following consideration of the further consultee responses and representation received it is still considered that the proposed development would be likely to cause significant adverse impacts in relation to the key environmental impacts of landscape character and visual impact and highway impact. However, having considered further archaeological field assessment it has been determined that the proposed development would be unlikely to have any impact on cultural heritage in terms of unrecorded archaeological resources within the site. The proposed development is therefore considered to comply with SP3 f) of the LDP.

It is therefore considered that the proposed development would have significant adverse impacts on the special qualities of the National Park, in terms of safeguarding its natural beauty. The proposal would therefore be contrary to the provisions of policies SP1, SP14, CYD LP1, 1, 38 and 48, of the LDP.

Impact on the character and appearance of the area Policy 1 of the LDP is an overarching policy, criterion (i) of which seeks to ensure that the scale, form, design, layout, density, intensity of use and use of materials of any development, including a conversion, would be appropriate to the surroundings and will maintain or enhance the quality and character of the Park's natural beauty, wildlife, cultural heritage and built environment. Criterion (ii) seeks to ensure that developments are integrated into the surrounding landscape through planting and appropriate management of native species and creation of appropriate boundary features as necessary.

SP14 enables proposals for sustainable tourism development which promote opportunities for the enjoyment and understanding of the National Park, whilst ensuring that the natural beauty, wildlife and cultural heritage is conserved and enhanced.

Policy SP3 Environmental Protection - Strategic Policy All proposals for development or change of use of land or buildings in the National Park must demonstrate that the proposed development does not have an unacceptable impact on, nor detract from, or prevent the enjoyment of; a) the special qualities of the National Park as identified in the National Park Management Plan.

SPG - Landscape and Development (October 2014) Landscape Character Assessment Middle Usk Valleys. Para 5.1.5 states that the National Park Authority will only be able to support applications which result in positive impacts on the defined characteristics of an LCA. Para 5.2.4 states that where detailed landscape and visual assessment are considered necessary, applicants are advised to consult best practice guidance as provided in Guidelines for Landscape and Visual Impact Assessment (Third Edition), Landscape Institute and Institute of Environmental Management and Assessment (2013)

Appraisal Policies in the LDP seek to ensure that any development should be appropriate to the surroundings and maintain or enhance the quality and character of the National Park's natural beauty. This reflects the primary purpose of the National Park which is to conserve and enhance its natural beauty. The principle policies of relevance are Policy CYD LP1, Policy 1, Policy SP3 and Policy SP14. In addition, the SPG -Landscape and Development (October 2014) states that the Authority will only support applications which result in positive impacts on the defined characteristics of the Landscape Character Areas.

The application is accompanied by a Landscape and Visual Assessment (LVIA) which has assessed the effects of the construction phase, year one operation and at year 15.

The LVIA has been reviewed by NRW and by Specialist Landscape advisers (White Consultants) who were commissioned by the Authority to consider and evaluate the details set out in the ES as well as the potential impact of the proposed development on the protected landscape of the National Park. The LVIA has also been reviewed by Fiona Cloke Associates submitted by a third party objector. The key issues and concerns raised are set out below.

Whilst it is considered the LVIA broadly complies with current best practice, it is considered to have underestimated the landscape and visual effects resulting from the development. The LVIA acknowledges the prominence of the site and the contribution it makes to the wider setting, but it understates the sensitivity of the site being a prominent lower valley slope which is visible from elevated land, local lanes, footpaths and dwellings as well as from the outskirts of the settlements of Llanfrynach and Llangorse. The LVIA also does not take into account that the existing adventure farm park is not typical of the area or its characteristics. It is not agriculture in character and the visual clutter of the elements such as the animal pens and enclosures, garden sheds, other buildings and experience attractions, parked cars and tents are not well screened at present.

The LVIA is considered to understate the significance of the landscape and visual effects, which the independent landscape consultant considers would be significant adverse for up to 15 years. NRW (in updated comments dated 18.04.2018) consider that there may be a limited number of significant visual effects remaining at Year 15, possibly longer, depending on how the planting matures. It is clear that the proposed development relies entirely on the proposed planting to establish and become effective to integrate the development into the landscape.

The LVIA addresses the effect on the special qualities of the Middle Usk Valleys Landscape Character Assessment (LCA). The LVIA recognises that the development would have adverse effects in the short term. However, it is considered that adverse effects would continue in the short to medium term and would be contrary to the special qualities of the LCA, for the following reasons.

There would be adverse effects on the scenic quality and sense of place by the introduction of visually intrusive features on the slope which is seen in views of the Cynrig valley and the Beacons backcloth and the top of the site is on a local skyline in some views.

In terms of landscape quality and integrity there are likely to be adverse effects, as the character of the landscape will be altered and the proposed woodland planting may not be as effective as proposed, if past planting and management practices are continued into this site. NRW concur that the effect on scenic quality is highly dependent on the success of the proposed mitigation.

Regarding perceptual qualities, the LCA area is stated as having a peaceful pastoral quality away from towns and main roads. The LVIA suggests that the site is in a relatively busy area being 2 km from the A40 (T) and 1.5km from Llanfrynach. This overstates these developments. The surrounding area is relatively peaceful and movement on the site would be detrimental to this peaceful quality and the site is a more exposed location than the adjacent existing site. NRW consider that the peaceful quality would be eroded to some extent throughout the life of the development.

In terms of visual effects the LVIA considers a series of viewpoints to be representative of a number of different receptors. The most significant effects are from the houses at the edge of Llanfrynach, at 1100m distance, (H5), the PROW west of the village (F2), at 1000m, near Abercynrig Mill, the minor roads south of Pannau (R4 and R5) at 750m distance, and the PROW running along Rhiw (F4). However, the significance of effect identified in the LVIA is not agreed to be moderate but likely to be significant adverse, up until year 15+.

From viewpoints to the east of the site, from the village at Llanfrynach, PROW and minor road to the north, at F2,H5,R1 and R2 the site would be more visible than the existing development at the adventure park, particularly the development in the top part of the field.

Similar effects are also likely from viewpoints to the south of the site, from the minor road south of Pannau, including the Three Rivers Ride, viewpoints R4 and R5, where the top part of the development would be visible forming an incongruous feature on the valley side. The maize field would be visible as an irregular shape contrasting with the surrounding rectilinear field boundaries. The planting would not be established but would create patches of irregular shapes within the site. At year 1 the development would form an incongruous feature on the valley side, which would likely be significant adverse from the village and the PROW.

From further afield, from open access land at F3 and F4 (Cefn Cyff and Rhiw) the whole application site is visible from these elevated positions. At year 1 the development would be apparent as a minor feature forming an incongruous feature on the valley side. The effect is likely to be borderline significant adverse.

At year 15 + the woodland planting once established would effectively screen the luge and the paths. Though the pattern would be different from the adjacent pastoral fields, the effect is not considered significant.

The LVIA addresses cumulative effects and states that when seen from a distance much of the existing site is indistinguishable from normal paraphernalia associated with farming and that the planting will assimilate the existing features as the existing planting takes effect.

However, this seems to understate the existing character of the site which is not agriculture in character and the planting is not well maintained, is growing slowly and some has not been implemented in accordance with the approved planting scheme. In addition, the LVIA underestimates the speed at which the proposed planting will grow. NRW concur that the Year 15 visualisations may be optimistic as they do not take account of the elevated nature of the site, growth rates and the need for maintenance and ongoing management.

It is considered that the cumulative effect of the development with the existing adventure park and camping site would be likely to be slightly greater than the effects of the development on its own from the east, and significant overall from the south and from the open access land, appearing as a large incongruous group of buildings and uses at odds with the surrounding landscape pattern.

Conclusions The site is a prominent, sloping lower valley side within the open countryside. It is open to views from at least the east and south and there are a variety of visual receptors, including users of PROW's, open access land and local roads, and there is the scattered rural settlement of Llanfrynach which will have views of the development.

The proposed development will diverge from the pattern of the pastoral enclosed landscape and appear as an incongruous feature on the valley side. Most views are at a distance.

The proposed woodland planting has been designed to screen the development, create the effect of woodland and to try to reinforce the enclosure pattern.

There are likely to be significant landscape and visual adverse effects in the short/medium term until the planting is sufficiently established to screen most of the activity on the site, although from some angles parts of the site will remain apparent. As the applicant has a mixed track record of implementing and maintaining planting there is doubt about how long it will take to effectively screen the development. Furthermore, the growth rates provided within the visualisations, cross sections and LVIA are considered optimistic.

Overall, the development in the short/medium term is considered to be contrary to the special qualities of the LCA, including scenic quality, sense of place, landscape quality and integrity and perceptual qualities. In the longer term, i.e. 15+ years, it is considered that it may integrate into the landscape if the planting establishes.

It is concluded that, as the site is a prominent, sloping lower valley side within the open countryside, there are likely to be significant landscape and visual effects and detrimental effects on the special qualities of the LCA in terms of scenic quality, sense of place, landscape quality and integrity and perceptual qualities in the short/medium term, and would not be sympathetic in nature and scale to the local environment. The proposed development therefore does not comply with the provisions of Policy CYD LP1, Policy 1, Policy SP3 and Policy SP14 nor the SPG -Landscape and Development (October 2014).

Update following PAROW on 15.05.2018 A Supplementary Landscape Statement dated July 2018 was submitted with the aim of addressing landscape issues raised above. It provides further information about planting rates, offers to undertake planting prior to commencement of earthworks, increase the size of planting stock, to delay implementing the construction of Bridge 2 and part of the footpath network and to submit yearly monitoring reports.

NRW have reviewed the Supplementary Landscape Statement and have advised that it provides some assurance that the proposed mitigation would be successful in providing adequate mitigation of the proposals within a 15 year timeframe, if: · the Applicant confirms annual monitoring will take place; · the size of the initial planting stock is increased from 60-90cm to 90-120cm; · failed plants are replaced; and · the construction of Bridge 2 and part of the path network is delayed until sufficient landscape cover has become established.

NRW however advise that they continue to have significant concerns about the landscape impacts of the proposal and that planning permission should only be granted if it is undertaken in accordance with the previously submitted landscape mitigation plans and the above measures are secured.

Nevertheless, it remains the case that, even with the additional mitigation measures, it is considered that there will be some significant landscape and visual effects as a result of the proposed development up to a 15 year timeframe. On this basis it is considered that the original conclusions as set out above are still valid and that the development would not comply with the provisions of Policy CYD LP1, Policy 1, Policy SP3 and Policy SP14 nor the SPG -Landscape and Development (October 2014).

Impact of the setting of nearby listed buildings and heritage assets Policy 17 The Settings of Listed buildings - states that development proposals which would adversely affect the setting of a listed building will not be permitted.

There are 4 listed buildings in the vicinity of the site, namely St Mary's Church and Cantref House located to the south west of Upper Cantref, just over 500 metres from the nearest edge of the site, Lower Cantref approximately 350 metres to the north east and Maesderwen approximately 800m to the east. These are all Grade II listed buildings.

The significance and implications of the proposed development on the setting of the nearby listed buildings has been undertaken within the archaeological Desk Based Assessment (DBA) submitted with the application.

In respect of the nearest asset, Lower Cantref, the DBA states that there would be glimpsed winter views of elements of the proposed development in winter, at least until the proposed new woodland planting has matured. There would also be an increase in noise as a result of the use of the luge, but the emergency generator and luge return lift are located as far as possible from Lower Cantref and the noise assessment has assessed that the noise increase at Lower Cantref would be very low. The DBA states the changes within the setting would not affect the ability to understand and appreciate this Grade II listed building and any changes would reduce as the new woodland planting matures. The DBA therefore concludes that the application proposals will have no effect on the significance of the nearest asset, Lower Cantref, or any other designated heritage asset.

The DBA has also concluded that due to topography and existing vegetation there is no intervisibility between the site and the defined essential setting of the Grade II Registered Park and Garden of Special Historic Interest in Wales at Abercynrig, to the north east of the site.

The National Park's Senior Heritage Officer has agreed that due to the distances involved and the intervening landscape features any visual connection between the site and the nearby listed buildings is limited. However, the use of artificial lighting and additional noise are seen as issues which have the potential to have an impact on the setting of the listed buildings, particularly Lower Cantref, the nearest listed building. The Heritage Officer has therefore advised that any external lighting will need to be designed to ensure there are sufficient measures in place to avoid light spill and that measures should be undertaken to reduce the impact of noise from the proposed activities, given the relatively tranquil rural environment.

No heritage objection is therefore raised to the proposed development on the grounds of setting issues, subject to any external lighting and noise reduction measures being acceptable. These matters could be secured by condition, were the development to be considered otherwise acceptable.

It is therefore considered that the proposed development would be consistent with policy 17 of the Local Development Plan as well guidance set out in PPW and TAN 24.

Update following PAROW on 15.05.2018 The National Park's Senior Heritage Officer has provided revised comments dated 21.08.2018, as detailed above, raising concern that the information submitted to accompany the application does not provide sufficient assurance that the operation of the Luge development will not be detrimental to the setting of the nearby listed buildings. In summary, the concerns relate to the following matters:-

Any noticeable increase in the number of vehicles using the lanes leading to Upper Cantref as a result of the proposed visitor attraction will have a negative impact on the tranquillity of the area and therefore harm the setting of the listed buildings.

Any additional parking area on the field to the south west (where overspill car parking has been observed in the past) would be in close proximity to St Mary’s Church and Cantref House and would feature in views to and from these buildings. This would change the way these heritage assets are experienced and have an adverse impact on their setting.

The predicted sound levels from spectators and ride users seem to be speculative and not sufficiently backed up by evidence other than the author’s personal experience (Noise Rebuttal Report).

Whether the proposals include the use of a public address system. The Noise Rebuttal report states that they are not aware that the applicant intends to install a public address system. However, this is not certain based on observations at a recent site visit, when a loud speaker was in use intermittently which was loud enough to be intrusive, even from a distance.

A heritage objection has therefore been raised due to the insufficient information submitted to show that the operation of the Luge development will not be detrimental to the setting of the nearby listed buildings, in terms of increased noise, traffic and views of any additional parking provision.

In consideration of the above comments, it is shown in the Highway Section of the report, that there is likely to be a sustained increase in visitor numbers to the site, which on peak days is likely to result in the use of the overspill parking area (especially on peak days). It is therefore considered that the proposed development would be likely to result in an adverse impact on the setting of nearby listed buildings, in terms of loss of tranquillity and additional noise from the increase in visitor numbers and traffic. Further, the use of the overspill parking area would have an adverse impact on their setting. In addition, there are also outstanding concerns in relation to predicted sound levels from spectators and ride users and whether the proposals include the use of a public address system. The proposed development is therefore considered to be contrary to the provisions of policy 1, policy 17 of the Local Development Plan as well as guidance set out in PPW and TAN 24.

Impacts on archaeology Para 6.5.1 of PPW outlines the desirability of preserving archaeological remains and their setting is a material consideration in the determination of planning applications.

TAN 24 advises at Para 4.7 that where archaeological remains are known to exist, or considered likely to exist, and a study has not already been undertaken by the applicant, the local planning authority should ask an applicant to undertake a desk-based archaeological assessment and, where appropriate, an archaeological evaluation. These should be done by a qualified and competent expert to the appropriate standard. The reports of these investigations will form part of the planning application. Applicants should show they have modified their development proposals to minimise any negative impact on the identified archaeological remains, and how they intend to mitigate any remaining negative impacts.

Local Development Plan Policy SP3 f) requires all development proposals to demonstrate that they do not have an unacceptable impact on, nor detract from or prevent the enjoyment of … archaeological features. Policy 22 requires that where important archaeological remains are known or may exist within an area for archaeological evaluation, the archaeological implications of development proposals shall be evaluated by qualified and independent archaeologists before planning applications are determined.

The Local Planning Authority therefore has to take into account archaeological considerations from the beginning of the development control process, and needs to be fully informed about the nature and importance of archaeological remains, and their setting and the likely impact of any proposed development upon them.

The application site is located some 400m to the north of the historic settlement core of Cantref, and Upper Cantref farm is a historic farmstead consisting of a courtyard form of farm complex, associated buildings, surrounded by an orchard, woodland and field systems, and set within a historic landscape.

An Archaeological Desk Based Assessment (DBA) has been undertaken to provide more information on the archaeological potential of the site and archaeological impact of the proposed development. No archaeological features are recorded on the Historic Environment Records within the site, but there are many assets within a 1km radius. The DBA highlights the archaeological potential from the prehistoric to the medieval period and outlines the elements of the development which could impact upon unrecorded remains.

The BBNP Archaeologist has advised that a programme of archaeological work should be undertaken prior to determination to evaluate the nature and extent of any archaeological deposits on the site and the impact of the proposed development on them. This piece of work is presently in the process of being undertaken to enable a decision to be made regarding the likely impact of the development, in accordance with PPW 6.5.6 and TAN 24, para 4.7.

The site is located just over 2km of the nearest Scheduled Ancient Monument, to the south- south-east of the site, including Coed Y Brenin enclosure and Coed Y Caerau camp of iron age and Plas Y Gaer hillfort Cadw, approximately 2.7km to the south west of the site. The DBA states that the development will have no effect on the significance of any designated heritage assets due to a combination of distance and/or lack of visibility from the site. Cadw have been consulted on the application and have advised that they have no comments to make on the proposed development.

It is therefore considered that as there is an outstanding matter in relation to the determination of the archaeological resource that survives on the site and any impact of the proposed development on them. The proposed development therefore, at the present time, would not be consistent with policy SP3 f) of the Local Development Plan as well as guidance set out in PPW and TAN 24.

Update following PAROW on 15.05.2018

A staged programme of archaeological field assessment, in the form of a geophysical Survey Report has been completed which did not identify any definite archaeological remains on the site. The BBNP Archaeologist has provided updated comments dated 03.07.2018 which has advised that whilst the absence of features cannot be taken to indicate an absence of potential archaeological remains, in this instance a pre- commencement condition could be imposed on any consent to secure the implementation of a programme of archaeological work and the subsequent mitigation through preservation in situ or by record.

It is therefore considered that the proposed development, would be consistent with policy SP3 f) of the Local Development Plan as well as guidance set out in PPW and TAN 24. Previously recommended refusal Reason 4 has therefore been deleted.

Impacts on ecology/biodiversity and protected species To comply with Planning Policy Wales (2016), section 5.5 and also Technical Advice Note (TAN) 5, biodiversity considerations must be taken into account in determining planning applications. Planning permission should be refused if the proposals will result in adverse harm to wildlife that cannot be overcome by adequate mitigation and compensation measures.

The Local Development Plan includes a number of policies regarding ecological issues and safeguarding biodiversity as set out in the report above.

The application is supported by the following ecological information:- o Preliminary Ecological Appraisal incorporating Extended Phase 1 Habitat Survey Report dated May 2017 o Cantref Luge - Environmental Statement Errata dated January 2018 o Cantref Luge - Construction Environmental Management Plan (CEMP) dated January 2018 and updated March 2018 o Cantref Farm, Brecon - Proposed Luge Development - Landscape and Ecological Management Plan (LEMP) by Haire Landscape Consultants dated September 2017, updated February and March 2018 o Applicant's response dated 9 February 2018 - text in red in my Memorandum dated 17th November 2017 o Outline drainage report for proposed luge run and maize maze for Cantref Farm by RPS dated February 2018

It is noted that the site consists predominantly of an arable field which is surrounded by hedgerows. A ditch running along the northern and eastern boundary of the site eventually joins the Afon Cynrig, which is a tributary of the River Usk SAC.

No ecological objection has been raised in principle to the proposed development by the National Parks Planning Ecologist although a number of ecological issues have been identified to be addressed.

Great Crested Newts are present at Cefn Cantref, which is 1.2km from the site. The potential impact on great crested newts is mostly limited to the works associated with the construction of the attenuation ditch and connecting pipes in near proximity to a nearby existing pond. Further details of an appropriate mitigation strategy and precautionary approach during the construction phase was requested and an updated CEMP dated March 2018 was received on 09.04.2018. The updated CEMP includes a precautionary approach to site clearance, including provision for a finger-tip search of the section of hedgerow affected, by a qualified ecologist, prior to the works commencing. The surrounding habitat will be maintained as grazed or mown grassland and is largely unsuitable for reptiles or amphibians. The development should therefore be implemented in accordance with the updated CEMP.

The management of surface water was identified as an issue and information has been provided showing the design of the drainage attenuation features including an unlined attenuation pond with marginal and aquatic planting. The Outline Drainage Report dated February 2018 shows how the surface water will be managed and that there is sufficient capacity provided within the system. The Land Drainage Officer of Powys County Council has confirmed that the drainage scheme is acceptable. The CEMP demonstrates how negative impacts on the water environment can be prevented or mitigated during the construction phase of the development and planning conditions could be imposed to ensure that this is implemented. On this basis the National Park's Planning Ecologist has advised that the Test of Likely Significant Effects on the River Usk can be completed.

No objections have been raised to the provision of the maize maze by the National Park's Planning Ecologist but it would be preferable to convert this area to permanent pasture with additional tree or shrub planting as landscape and biodiversity enhancement. However, it is appreciated that the planting of a maize crop could be grown without planning permission.

The amended detailed Landscape and Ecological Management Plan (LEMP) includes a 2m buffer strip adjacent to hedgerows, hedgerows to be cut annually in the winter, the seeding of hard wearing grass mix for areas disturbed by the construction process, areas to be managed as hay meadow, the reduction in proportion of beech planting, the hedgerows along the southern and south-eastern boundaries to be allowed to grow taller, as recommended by NRW, the reduction in size of the field in the north-east corner, thereby increasing woodland planting and biodiversity enhancement, together with long term management. The LEMP is therefore considered appropriate and its implementation will need to be secured by planning conditions

The provision of 3 bird boxes is considered minimal for an application of this size and the National Park's Planning Ecologist has suggested that 6 bat boxes and 6 bird boxes are installed at the site, which could be secured through condition.

In conclusion, no ecological objection has been raised to the development from NRW or the National Park's Planning Ecologist, subject to the imposition of a number of conditions, to secure the above mitigation and enhancement measures, as set out above. It is therefore concluded that ecological issues and safeguarding of biodiversity within the proposed development can be appropriately accommodated. The proposed development is therefore considered to be consistent with policies SP3, policies 3, 4, 6, 7, 9 and 12 of the Local Development Plan.

Update following PAROW on 15.05.2018

The Supplementary Landscape Statement includes revisions to the CEMP and LEMP. The BBNP Ecologist has provided revised comments dated 02.08.2018 which advises that these documents have been revised to accommodate original recommendations dated 16.03.2018 and that she is satisfied with them. With regards to any passing places improvement works, as set out in the Supplementary Transport Statement (, July 2018) the BBNP Ecologist has requested full details of what improvements are to be made and construction methodology as well as long-term management measures. However, as the proposed passing places improvement works would involve the surfacing of existing highway verges, within the existing highway land, there should not be significant ecological implications and the details could be secured as part of any planning approval.

The proposed development is therefore considered to be consistent with policies SP3, policies 3, 4, 6, 7, 9 and 12 of the Local Development Plan.

Impacts on drainage infrastructure, flood risk and pollution control Policy 56 of the LDP requires development to have adequate water and mains sewerage infrastructure and that conditions should be imposed to ensure adequate services are available to serve the development.

Supplementary Planning Guidance within the Sustainable design and construction and climate change context states that development proposals in the Parks can help to meet this objective by avoiding areas which are at risk from flooding now or are predicted to be at risk in the future and by constructing sustainable drainage systems (SUDS).

Chapter 12 of PPW advises that development proposing the use of non-mains drainage schemes will only be considered acceptable where connection to the main sewer is not feasible. Non-mains sewage proposals, such as septic tanks and surface water drainage schemes, included in development applications should be the subject of an assessment of their effects on the environment, amenity and public health in the locality…

Chapter 13 of PPW advises that the planning system has an important role in avoiding or minimising the adverse effects of any environmental risks on present or future land use, minimising risk from land contamination and that development does not increase the risk of flooding or surface water run-off.

An outline drainage strategy dated February 2018 accompanies the application which describes the existing drainage of the site and has identified a sustainable solution for surface water drainage for the proposed development site.

At present surface water run-off either discharges to ground or flows above ground and eventually discharges to the Afon Cynrig at an unrestricted greenfield rate. Site investigation has identified that the use of soakaways would be suitable for this site. The proposed surface water system is a surface water attenuation system which will collect surface water within the luge track area via filter drains and from the maize maze area by a network of 300mm diameter pipes to connect to a drainage ditch and a drainage attenuation pond towards the southern part of the site. This network is considered to have sufficient capacity to convey flows allowing for climate change.

In terms of flood risk the site is located within flood zone A for the purposes of TAN 15 and therefore at very low risk of flooding and a flood risk assessment is not required to support the application.

Dwr Cymru Welsh Water have raised no objections to the proposed development as the applicant proposes to utilise an existing septic tank facility as the method of foul drainage disposal.

Powys County Council Land Drainage have been consulted as the Lead Local Flood Authority regarding the application. The Authority advised originally that it had no historical flooding information relating the site and the proposed development would require to attenuate surface water drainage to ensure that it does not exceed existing greenfield run- off. The use of SuDS scheme was welcomed and following the receipt of an outline Drainage Report and associated drawings Powys County Council Land Drainage Section has confirmed that the applicant has suitably demonstrated that the drainage of the site can be managed and suitably discharged up to and including the 1 in 100 year storm event + 40%CC.

Powys Land Drainage Section have recommended that a condition is imposed on any consent to ensure that the development is not occupied until the sustainable drainage scheme for the site has been completed in accordance with the submitted details and the sustainable drainage scheme is managed and maintained thereafter in accordance with the agreed management and maintenance plan detailed in Appendix H of the Outline Drainage Report

The CEMP demonstrates how negative impacts on the water environment can be prevented or mitigated during the construction phase of the development and planning conditions could be imposed to ensure that this is implemented.

It is therefore considered that the drainage provisions, flood risk and pollution control measures of the proposed development, subject to the imposition of conditions, are considered to be acceptable and comply with policy 56 of the LDP and the provisions of PPW.

Impacts on highway infrastructure Policy 59 of the LDP specifies that development will only be permitted where appropriate access can be achieved commensurate with the level of development proposed.

Policy 60 encourages the provision of cycle paths and walkways.

Policy SP17 of the LDP seeks to ensure that opportunities are taken to improve and promote accessibility and to reduce the need to travel by private car.

A Transport Assessment accompanies the application. It includes an analysis of the baseline environment, a traffic survey coinciding with the high season for the site to represent a period of peak traffic generation for the site. A seven day traffic volume survey was also undertaken on the public highway to the west and east of the site, as agreed with the Highway Authority. Comparisons have also been made to current visitor numbers and historic peaks in visitor numbers.

The baseline environment shows that the site is accessed from an unnamed county highway that leads west from Llanfrynach from a simple priority junction. The road continues west past the site eventually meeting Bailyhelig Road that links to the Llanfaes area of Brecon. The site benefits from brown tourist attraction directional signs from the A40 trunk road at Cefn Brynich, directing traffic along the B4558 and the unnamed county highway to avoid the centre of Llanfrynach. The assessment states that this route is generally some 5m wide and able to accommodate two way traffic, apart from some narrower sections where traffic is single file, but there are passing places to assist. The route to the west is narrower, predominantly only single file width and considered to be unsatisfactory for traffic to and from the site.

The survey revealed that some 95% of traffic generated by the site is car traffic, which reflects its location and limited alternative modes of traffic. Some 79% of arrivals and 86% of departures travel along the preferred eastern route to and from the site. This accounted for 83% of all the traffic on the route. Use of the western route accounted for some 51% of all traffic on the route. There were 536 visitors to the site on the surveyed day equating to an average of 2.85 people per arriving vehicle. At current visitor numbers (34,000) per annum (77% of the 2008 peak) this would generate 11,930 vehicle arrivals or 23,860 vehicle movements, and an average of 65 movements per day. Using the same method, the assessment has calculated that the 2008 peak in visitor numbers (44,000), would have generated 15,439 vehicle arrivals (30,878 vehicle movements) over the year or an average of 85 vehicle movements a day. It is assumed that the distribution would be in similar proportions, and represents the baseline traffic generation of the existing permitted use of the site.

The seven day survey undertaken at the end of August shows that an average daily traffic flow of 404 vehicles to the east of the access to the site and 172 vehicles to the west, peak hour traffic volume of 23 vehicles to the west and 54 vehicles to the east. The 85th percentile traffic speed was recorded as 23mph.

The historic injury accident records have been reviewed from 1999 to 2016 and two slight severity accidents are recorded with the most recent being in 2006, and none during the peak years of 2008 to 2010. It is therefore concluded that there is no evident deterioration in road safety since the opening of the adventure farm in 2003.

An assessment of the proposed operations has been undertaken. It is considered that there would be no foreseeable material changes to the baseline conditions. This is because the applicant has forecasted, based on datasets from numerous UK farm attractions, that the additional investment and improved offer will increase visitor numbers to approximately 42,000 (95% of the 2008 peak) and that the traffic volume would reflect this, accounting in 23 daily fewer traffic movements compared to the 2008 peak.

Mitigation measures are proposed in order to reduce the volume of traffic travelling to and from the west of the site by erecting additional signage at the A40/A470 roundabout and at the Newgate Street/Bailyhelig Road junction to advise drivers to travel via the existing signposted route at the A40 Cefn Brynich junction. This is assumed to remove around 90% of the attraction's traffic from the western route. It is proposed that annual surveys would be undertaken to gain an understanding of the volume, type and direction of traffic generated by the proposed development. A Travel Plan will also be implemented in order to minimise traffic, promote the eastern access route to all staff and suppliers, promote car sharing and cycling by staff and rationalise deliveries/suppliers and which will be updated to reflect the results of the surveys.

The construction works are likely to last 12 weeks and be undertaken during the hours of 07:00 to 19:00 hours Monday to Friday, 07:00 to 13:00 on Saturday. Construction traffic would use the existing access from the public highway and use a dedicated non-visitor traffic route to enter the site, endeavouring to avoid commuter peak periods. Estimated construction movements have been provided for staff and hgv vehicles which would result in a maximum addition of 62 daily vehicle movements or approximately 8 movements per hour, or 10 - 15% above existing traffic levels. This is considered a minor impact in terms of highway safety and over a short term duration. A Construction Environmental Management Plan would be undertaken in order to implement measures to control and manage the environmental effects of the construction and limiting disturbance from construction activities.

An assessment of cumulative effects has considered the camp site at Cefn Cantref (15/12500) granted in March 2016 for a maximum of 30 or 90 people at any one time between March and October. However, it is assumed that the majority of the camp site's traffic would use the most convenient route to the site along Bailyhelig Road and therefore there would be negligible impact along the signposted route to Cantref Adventure Farm from the A440. In addition, improved signage will remove further traffic from the Bailyhelig route.

Powys County Council Highway Authority has considered the proposed development and recommends that the application is refused on highway grounds. In an original response dated 31.01.2018 objections were raised on the basis that the application fails to take sufficient account of the potential impact on the existing highway infrastructure and its users. Following a response from the applicant's agent on 08.02.2018, the consultation response was amended on 11.04.2018 to state that the application fails to adequately consider the potential for growth in visitor numbers and the subsequent impact this may have on the existing local highway network and on site visitor car parking and access and ingress.

The Highway Authority have provided the following key factors in reaching its conclusion.

It is considered that a baseline attendance of 34,000 (an average of attendance for the five year period 2011-2015) represents a realistic baseline for the current permitted uses against which to evaluate potential future impacts rather than the peak visitor numbers from a single year, 2008 of 44,000. There is no supporting information regarding how the traffic generation estimate has been determined and therefore it is difficult to accept the figures. The proposed luge appears to be a first for the UK and will likely attract visitors from a wider geographical area than the existing operation which could generate up to 59,500 visitors or an additional 5,438 vehicles at the stated occupancy rate of 2.85.

Use of a realistic baseline attendance will increase the likelihood that highway user safety concerns are identified and given appropriate consideration. The applicant's agent refers to a lack of accidents on the roads leading to the site during the peak years as evidence that the roads can safely accommodate up to 44,000 per annum. However, the Highway Authority state that there is a realistic possibility that visitor numbers will increase significantly which will give rise to an increase likelihood of conflict which may lead to personal injury collisions or less serious outcomes. Furthermore, there is no reliable national or local data for non- personal injury collision data for accidents in the Dyfed Powys Police area and other measures of conflict should be considered. This would be apparent in damage to verges, structural failure of highway edges or debris from vehicle collisions, which can present hazards to users and greater hazards to cyclists and pedestrians.

It is considered that the potential increase in traffic volume requires a review of parking provision to ensure that it remains adequate both in terms of capacity and access/egress arrangements. The Transport Assessment should consider whether the existing layout and operational practices are appropriate, as poor access, layout, control and driver behaviour can lead to delays in parking movements that can lead to traffic causing problems on the highway network.

The introduction of the luge has the potential to attract a wider and different user demographic compared to the existing visitors and therefore to attract significantly higher levels of visitors than the Transport Assessment forecasts.

It is accepted by the applicant that the approaches to the site from the west along Bailyhelig Road from Brecon present issues for access to the site. They are narrow with limited forward visibility and limited passing opportunities. The applicant proposes to direct visitors via the A40, however, some visitors inevitably will still access via Bailyhelig Road. Between Bailihelig Road and the site there are two possible routes which require mitigation measures if the currently proposed mitigation measures prove ineffective.

The ability to deliver the proposed mitigation to remove traffic from the west from Brecon along Bailyhelig Road would be dependent on Welsh Government permitting additional signage. In addition there are concerns over the effectiveness of signage to support the mitigation claims of removing "around 90% of traffic" with no evidential support. A firm commitment by Welsh Government would be required for signing before further consideration could be given to appropriate means of reducing access along Bailyhelig Road.

There are two alternative routes from the east albeit that current signing seeks to direct traffic along a preferred single route. Free-flow two-way traffic movements along both routes are constrained, passing opportunities are insufficient or sighting distances insufficient. At lower traffic flows these situations do not cause a significant problem, but as flows increase, such as peak times problems will materialise particularly where convoys of vehicles wait to pass and damage has been observed along the route.

Increases in vehicle numbers is likely to require improvements to the sites access and parking provision. Parking capacity and free flow of traffic is important to be maintained at peak times to reduce the likelihood of vehicles tailing back on to the public highway to the detriment of emergency and other users. Parking on grass standing could impact access/egress rates during wet periods. The applicant has responded stating that the proposed development is not expected to result in greater visitor numbers than during its peak, which operated safely. Accurately projecting user numbers is key to ensuring safe operation of the site and to identifying necessary mitigation measures to prevent the introduction of additional risk for highway users. No significant evidence has been submitted to support the traffic figures which are based on an assumption of a 40 minute drive time which is considered an underestimate for the proposed new attraction. Whilst the applicant does not expect greater visitor numbers, it is considered that the new attraction has the potential to generate higher levels. Table 1 of the Non-Technical-Summary indicates that 35,700 individuals are expected to go through the luge queueing area, assuming 50% of these are additional users, then 17,850 additional visitors would be generated per year, which would be a 52.5% increase and provide a total number of visitors of 51,850.

The applicant's agent has submitted some additional evidence in relation to projected visitor numbers. This sets out that the potential increase in attendance would be no more than 42,000 visitors due to the location of Cantref, in relation to nearby population concentrations, the normal driving time of 40 minutes for such attractions and likely new visitors in relation to additional capital spend. It also states that the proposed increase in attendance would usually occur over a 3 year period with no increase thereafter. The added attraction of the luge would result in an average increase in stay of 30 minutes and lengthen the time people stay by approximately 1 hour. It is also considered that the luge would broaden the age appeal from children aged 1-6+families to children aged 1-12. It would not have the pulling power to attract teenagers and people in their twenties and is aimed at existing attendees plus slightly older families.

Powys County Council Highway Authority has considered the additional information and met with the applicant's agent. In the meeting much of the discussion centred on getting a reliable and justified estimate of potential visitor numbers for the type of attraction proposed but signage on the trunk road and through Brecon to encourage traffic away from Bailihelig Road and the need for more information around how the existing car parking operates was also discussed. The applicant's agent is likely to provide additional supporting material and Members will be updated verbally if this is the case.

Whilst originally raising concerns about the lack of facilities to encourage sustainable means of travel such as bicycle or electrical vehicles, Powys County Council Highway Authority has accepted that such facilities and other means of sustainable travel such as staff car sharing could be secured by the imposition of a conditioned Travel Plan.

Many representations have expressed concern regarding the inadequacy of the existing local highway network to cope with additional traffic generation, particularly the access from the west, comprising of rural narrow lanes with limited visibility and passing places. However, the claims by the third party Highway Report for visitor numbers which are based on Skyline Luges in other parts of the world would seem to be exaggerated. Concern has also been expressed about the adequacy of the existing car parking provision on the site.

In conclusion, in view of the concerns raised and the consultation response from Powys County Council who consider that the application fails to adequately consider the potential for growth in visitor numbers and the subsequent impact this may have on the existing local highway network and on site visitor car parking and access and ingress, the proposed development would not comply with policy 59 of the LDP.

Update following PAROW on 15.05.2018 The Supplementary Transport Statement provides additional information on the existing and proposed parking demand and capacity, the route to the site and availability of passing opportunities and proposals for additional consistent signage. The technical note from Vision XS provides background figures relating to visitor attendance and the Draft Visitor Management Plan provides proposals to manage annual visitor numbers by monitoring.

Powys County Council Highway Authority has considered the additional information and provided detailed comments above dated 21.08.2018.The additional information has assisted in clarifying the likely visitor numbers and the parking capacity on the site. However, a number of concerns are still raised. There is considered to be an incapacity to cater for peak daily visitor numbers, based on the projected growth figures, which would exceed the proposed parking capacity on the site despite the proposals to manage the parking facilities. Whilst the proposals provide additional or formalise existing passing opportunities along the route from Llanfrynach, there is concern regarding the width of this route, particularly a 150m section, identified as Section A in the Supplementary Transport Statement where the width is stated to be generally at 3m. There would still be increased delay or inconvenience compared with the existing situation, and measures are still considered necessary to deter use for the minority of visitors using Bailihelig Road. There is also concern about the proposals outlined in the Draft Visitor Management Plan whereby there would be potential impacts on the highway network on existing peak days, as well as increasing the frequency of days when parking capacity and impact on the road network will be more apparent before remedial action is implemented.

In view of the above concerns the Highway Authority recommends that the application is refused on highway grounds for the following two reasons. Firstly, there will be a sustained increase in visitor numbers which will impact on safe passage along the highway and lead to increased delays and inconvenience to road users (especially on peak days). Secondly, there is inadequate on-site parking to deal with projected vehicle numbers (especially on peak days), which as a consequence will impact upon highway safety on the roads surrounding the site. Nevertheless, if Members are minded to grant consent then the Highway Authority have recommended conditions are imposed in order to:- effectively manage the projected increase in visitor numbers so that they are spread across the season; secure a signing strategy to promote use of the eastern access and discourage the use of Bailihelig Road; and to secure a number of highway improvements involving formalising passing bays and improvements to passing places at numerous locations where vehicles over-run the existing highway verge.

Third party responses have made representation about the inadequacy of the existing highway network to cope with the existing and proposed traffic, particularly along Bailihelig Road, conflict with other highway users, inadequacy of on- site parking at peak times and inadequate signage to promote the eastern access. In conclusion, in view of the response form the Highway Authority which are also reflected in the third party highway concerns, it is considered that the proposed development would not comply with policy 59 of the LDP.

Impacts on amenities of nearby residents

Para 3.1.7 of PPW states that the planning system does not exist to protect the private interests of one person against the activities of another. Proposals should be considered in terms of their effect on the amenity and existing use of land and buildings in the public interest, and it is therefore valid to consider the effect of a proposal on the amenity of neighbouring properties.

Para 11.3.3 of PPW states that Authorities need to consider the effects of sport and recreation on neighbouring uses in terms of noise, light emissions, traffic generation and, in the case of larger developments, ease of access and the safety of residents, users and the public (sections 13.13 to 13.15).

Para 13.15 of PPW states that noise can be a material consideration and in some considerations a technical noise assessment will be necessary. Conditions can be attached regarding the design and operation of lighting systems.

Policy 12 of the LDP requires light pollution to be sympathetic in order to not significantly effect a number of criteria including the character of the area and local residents.

The application site lies in the countryside and in near proximity to residential properties. The proposed construction phase and future use of the luge development therefore has the potential to have an effect on the nearby residential amenity in terms of noise, light emissions, traffic generation and the enjoyment of peace and quietness of the area and the special qualities of the National Park.

A Noise Impact Assessment (NIA) accompanies the application. It has assessed the existing noise conditions based on a typical three day period with weather conditions suitable for sound surveys. The assessment has not been able to measure sound emissions at an existing luge facility as the proposed luge would be the first of its kind in Europe. The sound emission level has therefore been determined from a series of measurements during the operation of a prototype luge with a test track at Upper Cantref Farm. This consisted of a 30m test track with a suitable slope on rough tarmac which represented a worst-case surface as the proposed surface would be a smooth bitmac surface and with socially engaged spectators located in close proximity, whereas they are likely to be grouped in smaller numbers distributed throughout a wider area.

The assessment is based on a worst case approach and modelled the anticipated peak figures for the number of people using the proposed development. Therefore, at any one time it is assumed that there are 35 people waiting at the start of the luge, 50 people using the maize maze and 23 people (15 spectators plus 8 luge riders returning via the lift) at the finish of the luge ride.

A number of mitigation measures have been designed into the project to minimise noise impacts. These include housing the emergency generator in an acoustic enclosure, and locating the luge return lift close to the existing adventure farm away from the closest residential dwelling.

Two sound sensitive receptors (SSR) were identified at Lower Cantref, to the east, at approximately 320m distance and the public right of way located to the south-west, at approximately 600m distance to the nearest construction works. The assessment of the construction period which would be carried out over a period of 12 weeks has been undertaken based on a worse case approach, considering the impact from activities taking place at the extent of the site located nearest to each SSR and based on all the plant operating concurrently. For both receptors the predicted worst case construction noise levels would be at or below the World Health Organisation guideline criteria values for annoyance during the daytime.

The assessment of operational effects has included the prediction of sound from the operation of the emergency generator, the luge travelling down the track and being pulled back to the start using an electric motor and spectators using the luge and maize maze facility. The assessment concludes that for both sound sensitive receptors the magnitude of impact would be negligible or no change to the ambient sound levels and therefore not significant.

The noise assessment states that due to the relatively low predicted noise emissions from the proposed development, no long term post development monitoring is proposed based on the anticipated visitor numbers.

There is also an assessment of the additional noise associated with the predicted increase in traffic levels of the proposed development. This is based on the traffic assessment and compares the predicted increase in traffic compared to the baseline peak traffic flows in 2008. The proposed development proposes to use the existing access to the Cantref Adventure farm and is intending to prolong visitor stays and reverse the decline in visitor numbers. The Traffic Assessment predicts that traffic to the west of the site will reduce by 52% resulting in a 3dB reduction in noise level or moderate beneficial impact and traffic to the east will increase by 3% resulting in an increase of less than 1dB or negligible impact.

No cumulative impact is expected as a result of the operation of the development with the nearby Cefn Cantref camp site, (15/12500) which was granted in March 2016 for camping in tents for 90 persons only occupied from March to October. This is due to it being located approximately 1.5km to the west of the site and having no significant sound sources.

An updated Construction Environmental Management Plan (CEMP) dated March 2018 accompanies the application. This indicates the approach to manage environmental aspects of the development including how construction will be managed on site to reduce noise, dust and disturbance. The measures include restricting working hours to 0700 to 1900 hours Monday to Friday, 0700 to 1300 hours on Saturday and no working Sunday, public or bank holidays.

In respect of nearby residential amenity, representation has been received raising concerns about noise, lighting and disturbance, as a result of the operation of the luge, external lighting, use of loud speakers and from construction activities.

The submitted noise report concludes that that there would not be adverse noise impacts to the nearest property at Lower Cantref, which is located over 320m distance. This distance, coupled with the presence of significant areas of intervening mature vegetation should ensure that there would not be a significant adverse impact on residential amenity. There would be no external lighting other than on the proposed buildings and the details of these could be secured by means of a condition to avoid light spill in accordance with the BBNPA SPG on Light Pollution.

Powys County Council Environmental Health Service have raised no objection to the proposed development. The Environmental Health Officer has advised that the noise assessment and noise guidance used is appropriate for the purposes of environmental protection. The World Health Organisation guidelines for community noise suggest that to protect the majority of people from being seriously annoyed during the daytime the LAeq at outdoor living areas should not exceed 55dB. Noise from construction activities will be of a transient nature and the predicted noise levels at both of the sound sensitive receptors are stated to be at or below the WHO guidance criteria. From table 5.5 of the NIA the 55dB level is indicated to reach this level during week 9 only. Conditions have been recommended in order to limit the landscaping and construction working hours to the daytime period only (0800 - 1800 Mon to Fr, 0800-1300 Sat and at no time on Sunday and Bank Holidays) and to limit the hours of opening of the luge run to be restricted to the hours of 0900-1800 Mon to Fr, 0900-1830 Sat and 0900 -1700 Sunday and Bank Holiday.

Overall, no objections have been raised from the Environmental Health Officer of Powys CC, subject to the imposition of conditions to limit the hours of working and delivery times and to limit the hours of opening of the proposed development. It is also considered that conditions should be imposed to secure compliance with the CEMP and to control the use of the proposed public address system.

Following the receipt of the third party noise report the Environmental Health Officer of Powys CC has provided additional comments seeking clarification regarding the operation of the luge track in terms of additional noise from different wheels on the luge, extent to which luge runs will take place, public address system, noise from riders and spectators. The applicant’s agent is likely to provide additional supporting material and Members will be updated verbally on this matter, if this is the case.

Overall based on the formal response from the Environmental Health Officer of Powys CC to date, it is considered that the effects of the proposed development can be adequately controlled such that there would not be a significant detrimental effect on the amenity of nearby residents in terms of dust, noise, disturbance, light pollution or loss of privacy and is acceptable in terms of residential amenity.

Update following PAROW on 15.05.2018

A report by Acoustics and Noise Limited has been submitted as a rebuttal to the third party noise report prepared by Hunter Acoustics. The report has clarified the type of wheels to be used, the type of flow of carts, and use of an incline and a rail system to direct the carts, racing discouraged by the spacing of the riders, and that they are not aware of the installation of any public address system.

Powys County Council Environmental Health Officer has been re-consulted on this document and has advised that to ensure that rubber tyres will be used, as was used on the prototype, a condition should be imposed to secure the details of the wheel arrangement.

Additional third party representation dated the 10th August 2018 from Hunter Acoustics, raises concerns regarding the noise impact at nearby noise sensitive receptors of the carts being transferred onto the power rails, use of any public address system and the sound levels from spectators and ride users from events, which already cause annoyance to the local community.

In response to these concerns it is considered that the predicted sound levels from spectators and ride users seem to be speculative and not sufficiently backed up by evidence other than the author’s personal experience, as stated within the Noise Rebuttal Report. The Noise Rebuttal report states that they are not aware that the applicant intends to install a public address system. However, this is not certain based on observations at a recent site visit, when a loud speaker was in use intermittently which was loud enough to be intrusive, even from a distance.

The Environmental Health Officer, had advised in a response dated 20.08.2018, that the applicant should provide an additional noise impact assessment to cover these matters.

Overall, whilst it is considered that the hours of operation, construction phase and lighting should be able to be adequately controlled such that there would not be a significant detrimental effect on the amenity of nearby residents, there remains outstanding noise matters in relation to predicted sound levels from spectators and ride users and whether the proposals include the use of a public address system. The Environmental Health Officer of Powys CC has requested an additional noise impact assessment to cover these matters.

It is therefore considered that, as there is insufficient information accompanying the application in relation to outstanding matters in relation to the noise implications of the proposed development, the proposed development, at the present time, would not be consistent with policy SP3 of the Brecon Beacons National Park and PPW.

Overall Conclusions It is considered that the proposed development would have a significant detrimental impact upon a number of material considerations as set out above.

The application is therefore recommended for refusal for the reasons set out below.

RECOMMENDATION: Refuse

Reasons

1. It is considered that the proposed development would have significant adverse impacts on the special qualities of the National Park, in terms of safeguarding its natural beauty, cultural heritage, peace and tranquillity and would not be sympathetic in nature and scale to the local environment. It would therefore be contrary to the provisions of policies SP1, SP3, SP14, CYD LP1, 1, 38 and 48, of the Brecon Beacons National Park Local Development Plan.

2. The proposed development is considered to be contrary to the provisions of Policy 59 of the Brecon Beacons National Park Local Development Plan which specifies that development will only be permitted where appropriate access can be achieved commensurate with the level of development proposed, for the following reasons:- i)there will be a sustained increase in visitor numbers which will impact on safe passage along the highway and lead to increased delays and inconvenience to road users (especially on peak days) and ii) there is inadequate on-site parking to deal with projected vehicle numbers (especially on peak days), which as a consequence will impact upon highway safety on the roads surrounding the site.

3. As the site is a prominent, sloping lower valley side within the open countryside, there are likely to be significant landscape and visual effects and detrimental effects on the special qualities of the Landscape Character Area of Middle Usk Valleys, in terms of scenic quality, sense of place, landscape quality and integrity and perceptual qualities in the short/medium term. The proposed development therefore does not comply with the provisions of Policy CYD LP1, Policy 1, Policy SP3 and Policy SP14 of the Brecon Beacons National Park Local Development Plan LDP nor the SPG -Landscape and Development (October 2014).

4. It is considered that the proposed development would result in an adverse impact on the setting of nearby listed buildings, in terms of increased noise, traffic and parking provision and would therefore be contrary to the provisions of policy 1, policy 17 of the Brecon Beacons National Park Local Development Plan as well as guidance set out in PPW and TAN 24.

5. It is considered that, as there is insufficient information accompanying the application in relation to outstanding matters in relation to the noise implications of the proposed development, the proposed development, at the present time, would not be consistent with policy SP3 of the Brecon Beacons National Park Local Development Plan and PPW.