Neath County Borough Council Local Development Plan 2011 –2026

Climate Change & Flooding Topic Paper August 2013

www.npt.gov.uk/ldp Contents

1 Introduction 1 2 Background 3 3 Policy Context: National, Regional & Local 7 3.1 National Policy Context 7 3.2 Regional Policy Context 14 3.3 Local Policy Context 20 4 Current Situation and Trends 23 5 Summary of Consultation Responses 33 6 Issues to be Addressed 35 7 Objectives 39 8 Strategic Policy Development 41 9 Detailed Policy Development 47 Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) Contents eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit 1 . Introduction

1 Introduction

1.0.1 This topic paper is one of a range of papers prepared to offer more detailed information and provide an explanation of the approach taken in the Local Development Plan (LDP) in relation to different topics and issues affecting the County Borough.

1.0.2 At the Pre-Deposit consultation stage in September 2011 the topic papers published included two separate papers, one on 'Climate Change and the Environment' and one on 'Flooding'. This has now been changed and to accompany the Deposit Plan consultation there is an Environment topic paper and this paper relating to Climate Change and Flooding.

1.0.3 This paper specifically considers Climate Change and Flooding.

1.0.4 The Pre-Deposit consultation was the first statutory stage of the LDP and set out the Council's overall Preferred Strategy. Following the consultation, the comments received have been taken into account and the topic papers have been amended accordingly.

1.0.5 The Deposit Plan consultation is the second statutory stage of the plan and allows a further period of formal public consultation. Comments received at this stage will be considered by an Independent Planning Inspector who will hold an Examination in Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) Public into the Plan. If the Inspector considers the Plan to be 'sound' it will be recommended for adoption and once adopted it will supersede the current Unitary Development Plan (UDP) and be the primary document for use in the determination of planning applications.

1.0.6 This topic paper can be read in isolation or in conjunction with the other topic papers and background papers that have been prepared to give a full picture of Neath Port Talbot(1).

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1 The information contained within this Topic Paper is correct as of the date sent to print. 1 . Introduction eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit

2 2 . Background

2 Background

2.0.1 There is now a general consensus that the global climate is changing, that it will continue to change over the coming century and that much of this change is due to increased concentrations of greenhouse gases produced by human activities. The Planning system has a key role to play in addressing climate change, across the full range of topic areas. This paper is intended to address climate change as an overarching theme, acknowledging that it is addressed in some way by most of the individual topics, and to explain the linkages and the approach taken by the LDP as a whole.

2.0.2 Planning Policy Wales identifies two fundamental aspects that need to be addressed in dealing with climate change:

The causes of climate change; and

The consequences of climate change.

2.0.3 In relation to the causes of climate change, The Climate Change Act 2008 provides the statutory framework for the reduction of greenhouse gas emissions in the UK, requiring Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) a reduction in net UK greenhouse gas emissions of 80% by 2050, and of CO2 emissions by at least 34% by 2020 - against a 1990 baseline.

2.0.4 In relation to the consequences of climate change, the impact of the changes in the climate that are already locked into the climate system as a result of past emissions must be taken into account in all planning proposals. This will result in short and long-term challenges, but it will also present new opportunities that should be maximised.

2.0.5 For Neath Port Talbot, one of the most significant predictable impacts of climate change is likely to be the increased risk of flooding. Parts of the developed area of the County Borough are currently in flood risk areas and the risk is expected to increase and affect wider areas in the future. The main developed areas have grown up on the coastal plain and valley floors, and as a result of climate change both tidal and fluvial flooding are likely to increase in depth and extent. These constraints limit the potential locations for new development.

2.0.6 Because of the overarching nature of the topic, this paper has a rather different format to the other LDP topic papers. It aims to identify the main issues facing Neath Port Talbot in relation to climate change and the approaches that are being taken across all topic areas of the LDP to address these issues. Climate Change Background 3 2.0.7 The latest predictions based on the UK Climate Projections 2009 indicate:

Average UK summer temperature is likely to rise by 3-4°C by the 2080s. In general, greater warming is expected in the southeast than the northwest of the UK, and there may be more warming in the summer and autumn than winter and spring. 2 . Background

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Average summer rainfall across the UK may decrease by 11% to 27% by the 2080s. While this is the average, there will be a big change in rainfall between the seasons, with winters becoming wetter and summers drier.

Sea levels are expected to rise. The central estimate (taking into account land movement) highlight sea level is projected to rise by 36cm in London by the 2080s.

Extreme weather events are likely to become more common.

2.0.8 Planning Policy Wales (PPW) indicates that Wales is likely to experience the following changes to the climate and impacts arising from climate change:

Increase in winter rainfall and in the frequency of intense rainfall;

Increase in the length of the growing season;

Rising sea levels;

More extreme weather, such as severe storms;

Hotter average temperatures;

An increase in the number of hot and dry summers and an increase in the number of extremely hot days; and

Milder winters and a reduction of snowfall;

2.0.9 The anticipated impacts include:

An increase in flash flooding due to heavy rain and an increase in river and coastal flooding and erosion;

Increased pressure on sewer systems;

Increase in winter storm damage;

Change in habitats and species;

Changes to the landscape; 4 Summer water shortages and increased incidence of low flow rivers; Increased risk of subsidence in subsidence prone areas;

Increased thermal discomfort in buildings; and

Health problems in summer, including heat related deaths linked to high air pollution. 2 . Background

2.0.10 PPW states that a twin-track approach is needed to tackling climate change, recognising:

A. The causes of climate change: the need to cut emissions of greenhouse gases that cause climate change; and

B. The consequences of climate change: the need to address the impact of the changes in the climate that are already locked into the climate system which will occur as a result of past emissions.

Flooding

2.0.11 Because of the topography of the area and the historic pattern of development, there have been extensive flood protection works in parts of the County Borough for many years. These works and any maintenance implications form part of the context for flood management and the LDP.

2.0.12 The responsibility for flood management is shared between Natural Resources Wales (NRW) (which has an overseeing role and leads on main rivers and tidal flooding) and the County Borough Council. Both organisations have programmes of work for

maintaining and providing defences against flooding. The Flood and Water Management Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) Act requires that an integrated approach is set out in Flood Water Management Plans.

2.0.13 The LDP's role is to integrate the flood consequences and management proposals into the LDP's spatial strategy and detailed allocations where development will be supported. It will protect areas that are required to accommodate floods and ensure that new development does not take place in inappropriate areas.

2.0.14 In relation to flooding, this document sets out the current situation, summarises how flooding issues have influenced the LDP and its allocations and policies and summarises the findings of the Strategic Flood Consequences Assessment, a document prepared in order to inform the LDP preparation process.

5 2 . Background eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit

6 3 . Policy Context: National, Regional & Local

3 Policy Context: National, Regional & Local

3.1 National Policy Context

Wales Spatial Plan (2008) Update: People, Places, Futures

3.1.1 A number of actions are identified to tackle climate change, but also promote a healthy and enjoyable environment in which to live and work, by:

Encouraging more walking and cycling as part of people’s daily lives;

Providing safe and clean open spaces with more opportunities to enjoy wildlife;

Improving air quality, for example through an integrated approach to traffic management;

Managing waste, water and soils more sustainably, with Spatial Plan partners;

Enabling the development of enhanced provision for the re-use and recycling of waste. Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) 3.1.2 Reducing the need to travel by co-locating jobs, housing and services, and changing behaviour in favour of ‘greener’ modes of travel, such as car sharing, public transport, walking and cycling are also identified.

Planning Policy Wales Edition 5 (2012)

Planning to Minimise the Causes of Climate Change

3.1.3 Decisive action is required to move towards a low carbon economy through:

Proactively reducing the demand for energy;

Facilitating the delivery of new and more sustainable forms of energy provision;

Minimising emission of greenhouse gases to the atmosphere.

Planning for the Consequences of Climate Change

3.1.4 Climate change impacts need to be planned for to reduce the vulnerability of our natural environment and built environment. LDPs should take a sustainable approach to flooding, involving the avoidance of development in flood hazard areas and where possible 7 the encouragement of managed retreat, the creation of wash lands and flood plain restoration.

Key Policy Objectives

3.1.5 The key policy objectives in relation to climate change include: 3 . Policy Context: National, Regional & Local

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Promotion of resource-efficient and climate change resilient settlement patterns that minimise land-take, area of impermeable surfaces, and urban sprawl through preference for the re-use of suitable previously developed land wherever possible avoiding development on greenfield sites;

Locate developments so as to minimise the demand for travel, especially by private car;

Move towards a low carbon economy. This includes facilitating development that reduces emissions of greenhouse gases in a sustainable manner, provides for renewable and low carbon energy sources at all scales and facilitates low and zero carbon developments;

Minimise the risks posed by, or to, development on, or adjacent to, unstable or contaminated land and land liable to flooding including building resilience into the natural and built environment.

Play an appropriate role to facilitate sustainable building standards (including zero carbon) that seek to minimise the sustainability and environmental impacts of buildings;

Ensure that development contributes to tackling the causes of climate change (by reducing greenhouse gas emissions) and to effective adaptation to the consequences of climate change through good design.

Strategic Sites

3.1.6 Strategic sites should be assessed to identify opportunities to require higher sustainable building standards (including zero carbon) to be required. In bringing forward standards higher than the national minimum, local planning authorities should ensure that what is proposed is evidence-based and viable.

3.1.7 Particular attention should be given to opportunities for minimising carbon emissions associated with the heating, cooling and power systems for new developments, for example by utilising existing or proposed low and zero carbon energy supply systems (e.g. district heating systems).

Natural Heritage and the Coast

3.1.8 The adaptation needs of biodiversity should be considered including identifying the scope for minimising or reversing the fragmentation of habitats and improving habitat connectivity through the promotion of wildlife corridors. Local Planning Authorities (LPAs) 8 should ensure that development minimises impact within areas identified as important for the ability of species to adapt and/or to move to more suitable habitats.

3.1.9 The development of networks of statutory and non-statutory sites and of the landscape features which provide links from one habitat to another can make an important contribution to the conservation and enhancement of biodiversity and the quality of the local environment, including enabling adaptation to climate change. 3 . Policy Context: National, Regional & Local

3.1.10 The need to minimise the production of greenhouse gases and to allow for and require adaptation to the consequences of climate change is stressed by PPW in relation to all topic areas.

Flood Risk

3.1.11 Local Planning Authorities should ensure that, as well as not being at risk itself, development does not increase the risk of flooding elsewhere. The continued construction of hard engineered flood defences to protect development in defined areas of flood hazard is unlikely to be sustainable in the long term.

3.1.12 In areas of flood plain currently unobstructed, where water flows in times of flood, built development should be wholly exceptional and limited to essential transport and utilities infrastructure. Such infrastructure should be designed and constructed so as to remain operational even at times of flood, to result in no net loss of floodplain storage, to not impede water flows and to not increase flood risk elsewhere. It will be inappropriate to locate certain types of development such as schools, hospitals, residential development and emergency services within some areas defined as being of high flood hazard.

Technical Advice Notes (TANs) Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) 3.1.13 As with PPW, the need to address climate change is a theme that runs through all the TANs. However, the following TANs put a particular emphasis on the topic.

TAN 8 Planning for Renewable Energy (2005)

3.1.14 Local Development Plans should promote high standards of energy efficiency, energy conservation and the use of renewable energy as a part of the national and international response to climate change, and this should be reflected in the strategy of development plans. LPAs should consider the local availability of renewable energy resources and develop suitable policies that promote their implementation. Additionally, local planning authorities should consider the specific requirements of individual renewable energy technologies, outlined in this TAN, which are likely to come forward during the Plan period.

TAN 15 Development and Flood Risk (2004)

3.1.15 TAN 15 covers dealing with the likelihood of flooding and the likely increases in flooding due to climate change through factors such as sea level rise, increased storms and rainfall.

3.1.16 The general approach is to advise caution in respect of new development in areas at high risk of flooding by setting out a precautionary framework to guide planning 9 decisions. The overarching aim of the precautionary principle is to: 3 . Policy Context: National, Regional & Local

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Direct new development away from those areas which are at high risk of flooding; and Ensure that where development has to be considered in high risk areas, only those developments which can be justified on the basis of certain tests are located within such areas.

3.1.17 The operation of the precautionary framework is governed by:

A Development Advice Map (DAM) containing three zones (A, B and C with subdivision into C1 and C2) which should be used to trigger the appropriate planning tests; and Definitions of vulnerable development and advice on permissible uses in relation to the location of development and the consequences of flooding.

3.1.18 The table below describes the composition and use of these zones to control and manage development.

Table 3.1 : Flood Risk Zones

Description of Zone Zone Use within the Precautionary Framework

Considered to be at little or no risk of A Used to indicate that justification test is not applicable and fluvial or tidal/coastal flooding no need to consider flood risk further.

Areas known to have been flooded in B Used as part of a precautionary approach to indicate where the past evidenced by sedimentary site levels should be checked against the extreme (0.1%) deposits flood level. If site levels are greater than the flood levels used to define adjacent extreme flood outline there is no need to consider flood risk further.

Based on Environment Agency extreme C Used to indicate that flooding issues should be considered flood outline, equal or greater than 0.1% as an integral part of decision making by the application of (river, tidal or coastal) the justification test including assessment of consequences

Areas of the floodplain which are C1 Used to indicate that development can take place subject developed and served by significant to application of justification test, including acceptability of infrastructure, including flood defences consequences

Areas of the floodplain without significant C2 Used to indicate that only less vulnerable development flood defence infrastructure should be considered subject to application of justification test, including acceptability of consequences. Emergency services and highly vulnerable development should not be considered.

Source: WG (2004) TAN 15: Development & Flood Risk

3.1.19 National policy states new development should be directed away from zone C 10 and towards suitable land in zone A, otherwise to zone B, where river or coastal flooding will be less of an issue. In zone C the tests set out below will be applied. However, highly vulnerable development and Emergency Services in zone C2 should not be permitted.

3.1.20 Highly vulnerable development is defined as all residential premises and public buildings, together with especially vulnerable industrial development such as power stations and waste disposal sites. 3 . Policy Context: National, Regional & Local

3.1.21 All other new development should only be permitted within zones C1 and C2 if determined by the planning authority to be justified in that location. Development, including transport infrastructure, will only be justified if it can be demonstrated that:

Its location in zone C is necessary to assist, or be part of, a local authority regeneration initiative or a local authority strategy required to sustain an existing settlement; or

Its location in zone C is necessary to contribute to key employment objectives supported by the local authority, and other key partners, to sustain an existing settlement or region; and

It concurs with the aims of Planning Policy Wales and meets the definition of previously developed land; and

The potential consequences of a flooding event for the particular type of development have been considered, and found to be acceptable. Deposit LDP - Climate Change and Flooding Topic Paper (August 2013)

11 3 . Policy Context: National, Regional & Local

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Map 3.1 Development Advice Map

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3.1.22 Whilst the DAM identifies land that is at risk from flooding, Natural Resources Wales also produces flood risk maps for main rivers (an NRW responsibility) and smaller watercourses (a local flood authority (NPTCBC) responsibility). 3 . Policy Context: National, Regional & Local

TAN 22 Planning for Sustainable Buildings (2010)

3.1.23 The TAN covers sustainable building standards; sustainable building design solutions; Low and Zero Carbon Design Solutions and gives further guidance on the selection of strategic sites for higher sustainable building standards.

Environment Strategy for Wales & Environment Strategy Action Plan

3.1.24 The Plan sets out the long term strategy for the Welsh environment. The five main themes of the Strategy are:

Addressing climate change;

Sustainable resource use;

Distinctive biodiversity, landscapes and seascapes;

The local environment; and

Environmental hazards. Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) 3.1.25 The Strategy and Action Plan set out the Welsh Government's approach to these themes.

Flood and Water Management Act (2010) and Flood Risk Regulations (2009)

3.1.26 The Flood and Water Management Act received Royal Assent on 8 April 2010. The main significant provisions that may affect the LDP process relate to the designation of third party assets, provisions for Sustainable Drainage Systems (SuDS), and the requirement to prepare Local Flood Risk Management Strategies.

3.1.27 The Flood Risk Regulations (2009) transpose the EU Floods Directive into UK legislation and include requirements for Preliminary Flood Risk Assessments (PFRA), flood hazard maps, flood risk maps, and flood risk management plans.

3.1.28 The Act and Regulations divide responsibilities between the NRW and lead local flood authorities (unitary authorities). NRW has responsibility for flooding from the sea, main rivers and reservoirs, while lead local flood authorities have responsibility for other watercourses and water bodies, surface water and ground water flooding.

3.1.29 The Regulations require PFRA to be published by the end of 2011, with a first review completed by the end of 2017. The PFRA has been published and Neath is identified 13 as one of two flood risk areas in the West Wales River Basin District - Swansea is also identified as such.

3.1.30 Flood hazard maps and flood risk maps must be published by the end of 2013 and reviewed by the end of 2019 and flood risk management plans must be prepared by the end of 2015 and then reviewed by the end of 2021. Flood risk Management plans will need to reflect the LDP strategy and policies and will feed into the LDP preparation process. 3 . Policy Context: National, Regional & Local

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit 3.1.31 The Act requires each lead local flood authority to develop, maintain, apply and monitor a strategy for local flood risk management and coastal erosion risk management in its area. In addition, in relation to third part assets, the Act gives legal powers for authorities to formally designate assets or features which affect flood or coastal erosion risk. Once a structure is designated, it cannot be altered, removed or replaced without the permission of the responsible authority. This will address local problems and flooding risk concerns, but also has the potential to constrain development.

3.1.32 In relation to SuDS, the Act requires most types of rain-water drainage systems to be approved and adopted (where relating to more than one property) by an approving body (the unitary authority). National standards for the design, construction and maintenance of drainage systems are being finalised. In effect this provision means that in future, surface water drainage systems will have to be designed to be sustainable, ensuring that their final discharge is clean and restricted to greenfield run-off volumes.

3.2 Regional Policy Context

Lavernock Point to St Ann's Head Shoreline Management Plan

3.2.1 The Shoreline Management Plan (SMP2)(2) is prepared by the Swansea and Carmarthen Bay Coastal Engineering Group (including representatives from coastal local authorities, NRW and Welsh Government) and identifies policy areas affecting Neath Port Talbot. The SMP provides a large-scale assessment of the risks associated with coastal erosion and flooding at the coast. It also presents policies to help manage these risks to people and to the developed, historic and natural environment in a sustainable manner.

3.2.2 The SMP covers the shoreline between Lavernock Point (Vale of ) in the east and St Ann’s Head (Pembrokeshire) in the west. The table below describes the policies contained within the SMP for managing the shoreline.

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2 and Carmarthen Bay Shoreline Management Plan 3 . Policy Context: National, Regional & Local

Table 3.2 : Policy Options, Shoreline Management Plan Lavernock Point to St Ann's Head (July 2010)

Policy Option Description Non-Technical Description

Hold the This policy means that existing defences are maintained, or Keeping the shoreline in line(HTL) replaced, along their current alignment. Typically this will result the same place. in an increased risk of coastal flooding due to future sea level rise. If a significant number of assets are at risk it may be justifiable to upgrade existing defences (raise and strengthen) to reduce this risk.

Advance the New defences are built seaward of the original defences, in Creating more land by line (ATL) order to create new land. This policy is restricted to places where moving coastal defences significant land reclamation is considered. into the sea.

Managed This policy allows the shoreline to move backwards with Letting the shoreline move Realignment management to control or limit movement (such as reducing backwards in a controlled (MR) erosion or building new defences on the landward side of the way. original defences).

Managed realignment has been assigned to all dune areas since it is not sustainable to artificially fix a line of dunes. Although dune areas will generally be allowed to evolve Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) naturally, a policy of managed realignment means that management techniques could be used, if necessary.

No Active This policy means that there is no investment in coastal Letting nature take its Intervention defences or operations. Where there are currently no defences, course on the shoreline this policy means that the shoreline will continue to evolve once defences (if present) naturally. fail.

However, where the shoreline is currently defended, any existing defences will not be maintained and will be allowed to fail. This means that areas inshore would be at increased risk of flooding and coastal erosion in the future.

3.2.3 The coastline of Neath Port Talbot is divided into seven policy units, each having an individual preferred policy and approach to managing the coastline. The proposed SMP Policies are shown on the maps below:

15 3 . Policy Context: National, Regional & Local

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Map 3.2 Crymlyn Burrows to Port Talbot Docks, Shoreline Management Plan

16 3 . Policy Context: National, Regional & Local

Map 3.3 Port Talbot Docks to Sker Point, Shoreline Management Plan Deposit LDP - Climate Change and Flooding Topic Paper (August 2013)

3.2.4 . The proposed management is :

Port Talbot Steelworks – hold the line (green); Port of Port Talbot (including ) – hold the line (green); Port Talbot Docks to Baglan Burrows ( Beach) – hold the line (green); Baglan Burrows – managed realignment (yellow); Neath Estuary – hold the line (green); Crymlyn Burrows ( to the former BP tank farm) – managed realignment 17 (yellow); and Former BP tank farm – hold the line (green). 3 . Policy Context: National, Regional & Local

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Catchment Flood Management Plans

3.2.5 The Ogmore to Tawe Catchment Flood Management Plan (CFMP)(3) prepared by NRW identifies policy areas affecting Neath Port Talbot. The CFMP considers all types of inland flooding, from rivers, groundwater, surface water and tidal flooding, but not flooding directly from the sea (coastal flooding) – this is covered by the Shoreline Management Plan (SMP).

3.2.6 The role of the CFMP is to establish flood risk management policies which will deliver sustainable flood risk management for the long term.

3.2.7 The Ogmore to Tawe CFMP is divided into a total of 12 distinct sub-areas which have similar physical characteristics, sources of flooding and level of risk (see map 3.4). In each of these sub-areas the most appropriate approach to managing flood risk is identified and a generic flood risk management policy allocated. Five of the sub-areas fall within Neath Port Talbot and the generic flood risk policies include:

Upland Rivers (including the upland reaches of the Rivers Tawe, Neath and Afan) – areas of low to moderate flood risk where Natural Resources Wales and partners are generally managing the flood risk effectively; Tawe Valley (from Trebanos to Ystalyfera and beyond) – areas of moderate to high flood risk where Natural Resources Wales and partners can generally take further action to reduce flood risk; Upper Neath (including the area covered by the Neath Valley spatial area) – areas of low, moderate or high flood risk where Natural Resources Wales and partners are already managing the flood risk effectively but where there may be a need to take further actions to keep pace with climate change; Lower Neath (including the dense urban area of Neath) – areas of low, moderate or high flood risk where Natural Resources Wales and partners are already managing the flood risk effectively but where there may be a need to take further actions to keep pace with climate change; and Port Talbot (including the dense urban area of Port Talbot and ) – areas of moderate to high flood risk where Natural Resources Wales and partners can generally take further action to reduce flood risk.

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3 Catchment Flood Management Plans (Natural Resources Wales(NRW)) 3 . Policy Context: National, Regional & Local

Map 3.4 Sub-Areas in the Ogmore to Tawe CFMP. Source: Ogmore to Tawe Catchment Flood Management Plan Summary Report (January 2010) Deposit LDP - Climate Change and Flooding Topic Paper (August 2013)

3.2.8 Nearly all of Neath Port Talbot CBC area is covered by the Ogmore to Tawe CFMP (with the exception of the Upper Swansea and Amman Valleys). The plan identifies key locations considered to be at risk currently and those likely to be at risk by the end of the century. These include Pontardawe (100-500 properties at risk from flooding during a 1% Annual Exceedance Probability (AEP) flood event), Neath (500-1000 properties) and Port Talbot (>1000 properties). Of particular concern is Glynneath, where the number of properties at risk is predicted to increase from 25-50 currently to 100-500 by 2100 and Resolven where an increase from less than 25 to 500-1000 is predicted.

3.2.9 In the Lower Neath sub area, the main sources of flood risk identified are from tidal influences and overtopping of the Tennant Canal. Future increases in tide levels will result in tidal flood risk extending further upstream. Neath, Briton Ferry and Jersey Marine are identified as being at risk, together with parts of the Fabian Way corridor and the main Swansea – London railway line.

3.2.10 The Port Talbot sub area is characterised as a high density urban area with fast responding rivers and a risk of overtopping defences of Afon Afan and Ffrwd Wyllt. A large 19 number of properties are at risk from the 1% AEP flood event (currently 3840, rising to 5790 in the future), located in Aberafan and central Port Talbot. Parts of and Cwmafan are also at risk. In addition there are surface water flooding issues. 3 . Policy Context: National, Regional & Local

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Catchment Abstraction Management Strategies and Water Resources Management Plan

3.2.11 In relation to Neath Port Talbot, the relevant Catchment Abstraction Management Strategies(4) indicate that there is generally no water available for additional abstractions from local water courses in the relevant catchments of the County Borough. It is indicated that careful management will be necessary in order to continue to meet demand taking into account the likely effects of climate change. However, the majority of the public water supply to the Neath Port Talbot area is drawn from the Afon Tywi in Carmarthenshire. Dwr Cymru/Welsh Water's draft Water Resources Management Plan (5)indicates that there are no anticipated problems in water supply in the Tywi Conjunctive Use System Water Resource Zone and that there is adequate 'headroom' for anticipated future demand.

3.3 Local Policy Context

Neath Port Talbot Community Plan (2010-2020) 'Greater Opportunity For All'

3.3.1 The Community Plan sets out the target that by 2014 "...our carbon footprint is significantly reduced because we are reducing the contributory factors, as well as adapting to the effects of climate change. Energy resources are also used efficiently with actions to reduce the impact of climate change being implemented to include rapid responses to flooding and flood risk".

Single Integrated Plan (SIP): Neath Port Talbot Working in Partnership (2013-2023)

3.3.2 Incorporating the vision and guiding principles of the Community Plan, the Single Integrated Plan (SIP) sets out the Council's vision for Neath Port Talbot and the steps the Council will take together with partners to protect and improve local services and support communities. The Council's vision is 'Creating a Neath Port Talbot where everyone has an equal opportunity to be healthier, happier, safer and prosperous'.

3.3.3 Outcome 3 that the SIP aims to achieve is that 'Neath Port Talbot's communities and environment are sustainable'. In doing so, the Council will seek to:

Develop communities that are strong and sustainable through meeting housing needs across all tenures;

Ensure environmental sustainability by living within our limits and ensuring healthy and clean air, land and water;

Protect, enhance and conserve our natural and built environment;

20 Develop sustainable transport;

4 The Tawe, Loughor and Gower Catchment Abstraction Management Strategy (EAW 2007);The Neath, Afan and Ogmore Catchment Abstraction Management Strategy (EAW Consultation Document 2005) 5 Revised draft Water Resources Management Plan (Dwr Cymru/Welsh Water Oct 2011) 3 . Policy Context: National, Regional & Local

Reduce waste and move towards maximising recycling; and

Support opportunities for the building of safe, resilient, economically viable and sustainable communities.

Preliminary Flood Risk Assessment

3.3.4 As discussed in National Policy Context above, the Local Authority has a duty, as part of the requirements of the Flood and Water Management Act 2010, to publish a Preliminary Flood Risk Assessment (PFRA). Neath Port Talbot County Borough Council published the PFRA in 2011 and Neath is identified as one of two flood risk areas in the West Wales River Basin District - Swansea is also identified as such.

3.3.5 A map below illustrates the Indicative Flood Risk area: Deposit LDP - Climate Change and Flooding Topic Paper (August 2013)

21 3 . Policy Context: National, Regional & Local

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Map 3.5 Indicative Flood Risk area in Neath Port Talbot, Preliminary Flood Risk Assessment.

22 4 . Current Situation and Trends

4 Current Situation and Trends

Causes of Climate Change

4.0.1 Neath Port Talbot (NPT) is important as an employment base nationally and within Swansea Bay, with some long established heavy industries (e.g. the steel industry). As a result, levels of emissions within NPT are high, but while new industrial processes may increase emissions, they may be beneficial in delivering wider sustainability improvements (e.g. reducing imports or displacing more damaging processes elsewhere).

4.0.2 Transport is a major contributor to greenhouse gas emissions, and the M4, A465 and local traffic all contribute. The County Borough contains some 62,000 dwellings and a whole variety of industrial, business and extractive activities. Both new development and the performance of existing buildings and activities are increasingly under scrutiny in respect of climate change impacts.

(6) [1] CO2 Emissions

4.0.3 Neath Port Talbot has the highest per capita emissions of CO2 in Wales. Between

2005 and 2007, per capita CO2 emissions increased from 55.4 tonnes to 60.8 tonnes, but Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) then decreased to 44.4 tonnes by 2009. This high level of emissions appears to be mainly due to heavy industry, in particular steel production. Investment by Tata Steel in BOS gas recovery technology has resulted in a reduction in CO2 emissions of 250,000 tonnes per annum, and this is partly reflected in the above figures.

4.0.4 There are significant amounts of carbon stored / locked up within the County Borough area, for example in soils (especially peat), trees, woodlands and forests, which may be released as a result of land use changes or development. This needs to be taken into account and protected where possible.

[2] Gas Use(7)

4.0.5 There appears to have been a fall in domestic gas use in recent years, which may be due to improved domestic insulation and boiler efficiency.

23

6 Local Authority Carbon Dioxide figures - Department of Energy and Climate Change 7 Local Authority Carbon Dioxide figures - Department of Energy and Climate Change 4 . Current Situation and Trends

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Figure 4.1

4.0.6 There has also been a general reduction in CO2 emissions from the use of commercial gas since 2000, although there was an upward trend in 2005/2006.

[3] Electricity Use(8)

4.0.7 Emissions from domestic electricity use have fluctuated over recent years, but there was a notable reduction in 2009.

Figure 4.2

24

4.0.8 Industrial and commercial figures indicate a similar pattern, with a gradual decline in emissions becoming more pronounced in 2009.

8 Local Authority Carbon Dioxide figures - Department of Energy and Climate Change 4 . Current Situation and Trends

[4] Transport

4.0.9 Improvements are continually being made to vehicle design, improving efficiency and developing the potential of alternative fuels. However, growth in traffic and vehicle use may still result in a greater impact overall.

Figure 4.3 Deposit LDP - Climate Change and Flooding Topic Paper (August 2013)

4.0.10 Figures for road transport indicate a general decline in emissions in 2008 and 2009 which may be partly as a result of the above improvements, but are likely to be affected also by the economic slowdown.

4.0.11 The LDP will play a particular role in reducing transport emissions, in relation to the location of new development, its accessibility by a range of transport options and reducing the need to travel. There is potential for the electrification of the main line railway to London, which could result in a significant improvement in emissions, depending on the means used for electricity generation.

[5] Buildings

4.0.12 New development (housing and other buildings) will be increasingly required to improve their environmental performance through planning and building regulations. The design and layout of sites can also deliver significant gains through attention to building orientation and exposure. Consequences of Climate Change 25 4.0.13 In relation to the anticipated impacts of climate change set out in paragraph 2.0.9, including increased winter storm damage, changes in habitats and species, summer water shortages and increased thermal discomfort, there is little specific information available at present to reliably extrapolate any trends. The relevant Catchment Abstraction 4 . Current Situation and Trends

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Management Strategies(9) indicate that there is generally no water available for additional abstractions form local water courses in the relevant catchments of the County Borough. It is indicated that careful management will be necessary in order to continue to meet demand taking into account the likely effects of climate change. However, the majority of the public water supply to the Neath Port Talbot area is drawn from the Afon Tywi in Carmarthenshire. Dwr Cymru/Welsh Water's draft Water Resources Management Plan (10)indicates that there are no anticipated problems in water supply in the Tywi Conjunctive Use System Water Resource Zone and that there is adequate 'headroom' for anticipated future demand.

4.0.14 The main information available in relation to the consequences of climate change relates to flood risk.

[1] Flood risk

4.0.15 Most of Neath Port Talbot’s population live in areas along the coast or along valley floors. Natural Resources Wales' (NRW) Flood Map shows flood zones, some flood defences, areas benefiting from flood defences and flood storage areas. Flood Zone 3 is the best estimate of the areas of land with a 1% (1 in 100), or greater, chance of flooding each year from rivers, or with a 0.5% (1 in 200) chance, or greater, of flooding each year from the sea and Flood Zone 2 is the best estimate of the areas of land between Zone 3 and the extent of the flood from rivers/from the sea/from rivers and, or the sea with a 0.1% (1 in 1000) chance of flooding in any year.

26

9 The Tawe, Loughor and Gower Catchment Abstraction Management Strategy (EAW 2007);The Neath, Afan and Ogmore Catchment Abstraction Management Strategy (EAW Consultation Document 2005) 10 Revised draft Water Resources Management Plan (Dwr Cymru/Welsh Water Oct 2011) 4 . Current Situation and Trends

Map 4.1 Natural Resources Wales Flood Map Deposit LDP - Climate Change and Flooding Topic Paper (August 2013)

27 4 . Current Situation and Trends

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit 4.0.16 The Map 4.1 identifies that significant areas of the coastal belt and the urban areas of Neath and Port Talbot are at risk of flooding. They are at risk of both fluvial and tidal flooding and also in combination effects. Locations along the main rivers and watercourses are also identified as flood risk areas with the Swansea Valley, Neath Valley and Pontardawe particularly vulnerable.

4.0.17 The Welsh Government also issues development advice maps in conjunction with the advice in TAN15 which identify areas at risk from flooding. These zones (zones B, C1 and C2) include significant areas that are centres of population. Indications are that flooding events will become more frequent in the future as a result of climate change. Map 3.1shows the Development Advice Map covering Neath Port Talbot.

4.0.18 Information issued in connection with the review of the Shoreline Management Plan(11) indicates likely significant changes to the coast such as:

Greater frequency of storms;

Increased wave heights;

Increased erosion;

Fluctuating rainfall; and

Increasing river flows.

4.0.19 A key risk along the shore will be future changes in tidal surges, winds and storms. The combination of high tides and strong westerly and south-westerly winds, increasing wave height and tidal surges is a significant threat in terms of future coastal erosion and flooding. However, UKCP09 concludes that in most locations, the trend in storm surge levels cannot be clearly distinguished from natural variability. Natural Resources Wales recommends that climate change impacts on tidal inundation should be considered over a 100 year lifetime of development for residential properties and other highly vulnerable development and 75 years for other developments.

4.0.20 Changes in precipitation patterns could have implications for river flows which could affect meandering patterns, alignment of intertidal channels, development and breaching of sand spits, fluvial discharge and flood risks. Any effects on shoreline evolution are considered likely to be localised.

4.0.21 The Catchment Flood Management Plan (CFMP) analyses future flood risk using the assumptions that peak rivers will increase by 20%, sea level will rise a total of 28 one metre by 2100 and there will be a 10% decrease in forestry coverage, increasing flows in the upper reaches of affected catchments. In addition, increases in the incidence of extreme and stormy weather are expected. These changes have the potential to have a significant impact on the coastline of the UK, including the low lying coastline of Neath Port Talbot and have a significant impact on the frequency of flooding events generally.

11 Swansea Bay and Carmarthen Bay Shoreline Management Plan Review (Swansea and Carmarthen Bay Coastal Engineering Group) 4 . Current Situation and Trends

4.0.22 The CFMP identifies key locations within the County Borough that are considered to be at risk currently and those likely to be at risk by the end of the century if measures are not taken to manage the increasing risk. Areas at risk by 2100 include Pontardawe (100-500 properties at risk from flooding during a 1% Annual Exceedance Probability (AEP) flood event, Neath (500-1000 properties) and Port Talbot (> 1000 properties). A large number of properties are identified as being at risk in Aberafan, central Port Talbot and also areas of Taibach and Cwmafan. In Glynneath and Resolven the number of properties at risk is predicted to increase to 100-500 by 2100. Furthermore, the CFMP identifies that future increases in tide levels will result in tidal flood risk extending further upstream with Neath, Briton Ferry, Jersey Marine, parts of the Fabian Way corridor and the main Swansea-London railway identified as being at risk.

Maintenance of Flood Defences

4.0.23 There are a number of flood defence schemes which are in operation in Neath Port Talbot which seek to protect areas of the County Borough from flooding.

4.0.24 These defences are located in the Neath Valley, Swansea Valley, Pontardawe and Port Talbot spatial areas:

Ystalyfera: along river bank adjacent to Glan yr Afon; Deposit LDP - Climate Change and Flooding Topic Paper (August 2013)

Resolven: Along the canal between Abergarwed and Resolven;

Resolven: Clydach Brook adjacent to A465;

Glynneath: along river bank adjacent to Craig Nedd and Pentre Street;

Glynneath: adjacent to Canal Place;

Port Talbot: along both banks of the River Afan from Velindre through the town centre to Water Street.

29 4 . Current Situation and Trends

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Map 4.2 Location of Flood Defences, Neath Port Talbot

30 4 . Current Situation and Trends

4.0.25 Natural Resources Wales are responsible for maintaining the flood defences and have a programme of investment to manage and maintain these assets. In addition to 'hard' flood defences, areas of the County Borough are protected from flooding by natural floodplains, for example, the tidal estuary of the river Neath.

4.0.26 The Shoreline Management Plan identifies that the areas of dunes within the County Borough (Crymlyn Burrows and Baglan Burrows) will be subject to the policy approach of managed realignment - this policy approach will allow the shoreline to move backwards and evolve naturally although management techniques could be used if necessary. This will not affect areas of population but may result in a change in the coast line.

4.0.27 The remaining shoreline areas will be supported by a 'Hold the line' Policy which means that existing defences are to be maintained, or replaced, along their current alignment. Typically this will result in an increased risk of coastal flooding due to future sea level rise. If a significant number of assets are at risk it may be justifiable to upgrade existing defences (raise and strengthen) to reduce this risk.

Implementation of SuDS

4.0.28 The Flood and Water Management Act 2010 encourages the uptake of Sustainable Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) Drainage Systems (SuDS) by removing the automatic right to connect to sewers and providing for Councils to adopt SuDS for new developments and redevelopments.

4.0.29 The purpose of SuDS is to reduce the potential impact of new and existing developments with respect to surface water drainage discharges and to retain the greenfield run off rates.

4.0.30 The Construction Industry Research and Information Association (CIRIA)(12) define SuDS as a 'sequence of management practices, control structures and strategies designed to efficiently and sustainably drain surface water, while minimising pollution and managing the impact on water quality of local water bodies. These systems are more sustainable than conventional drainage methods because they:

Manage runoff volumes and flowrates, reducing the impact of urbanisation on flooding; Protect or enhance water quality; Are sympathetic to the environmental setting and the needs of the local community; Provide a habitat for wildlife in urban watercourses; Encourage natural groundwater recharge (where appropriate).

4.0.31 The Local Authority is the sustainable drainage approving body (SAB) and has the responsibility for the approval of proposed drainage systems in new developments 31 and redevelopments.

12 CIRIA are running a specific project designed to disseminate and promote good practice in the implementation of SuDS and their website contains a wealth of information 4 . Current Situation and Trends

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit 4.0.32 The design and implementation requirements of SuDS needs to be considered by developers early on in the application process. There are a range of techniques that can be implemented which will be determined by the specific site requirements for example site layout, current drainage issues and topography. If designed to a high standard then SuDS can serve a dual purpose and provide important areas for biodiversity and greenspace.

32 5 . Summary of Consultation Responses

5 Summary of Consultation Responses

5.0.1 This section of the paper summarises the main issues and comments raised following:

The formal Pre-Deposit Consultation (September / October 2011); and

The informal Emerging Deposit Plan Proposals Consultation (September / October 2012).

5.0.2 The Pre-Deposit Consultation was the first of two formal consultations on the LDP and focused on the Authority's vision, strategic options, preferred strategy and key policies. Previous Topic Papers were published alongside the Pre-Deposit Plan.

5.0.3 The Emerging Deposit Plan Proposals were discussed at a series of informal meetings with a variety of stakeholder organisations. These included representatives of the many interest and community groups in the County Borough. At the same time all of the information presented at the stakeholder meetings was made available on the Council's website and anyone or organisation that is interested in the future development of Neath

Port Talbot was invited to comment. Deposit LDP - Climate Change and Flooding Topic Paper (August 2013)

5.0.4 The Deposit Plan Proposals Report (Sept’12) set out the emerging picture both in terms of the overall strategy for the LDP and the various topic based policies that will be included. The report was accompanied by the emerging Proposals Map which showed the geographical location of the emerging policies and proposals.

5.0.5 Full details of comments received and the Council's responses to those comments are set out in the Initial Consultation Report(13). The comments are summarised below.

[1] Strategy & Policies

It is not clear how the LDP will address the impacts of climate change, reduce pollution and the creation of greenhouse gases. This needs to be supported with strategies and objectives.

It is not clear how the proposed policies address the climate change strategy.

The strategy to address flood risk needs to be strengthened.

The Pre-Deposit LDP fails to adequately address flooding issues. A Strategic Flood Consequences Assessment should be produced to support and justify the approach of the Deposit Plan considering the number of potential development sites within the 33 flood zones. Site specific Flood Consequences Assessments will be required to support any proposed developments within flood risk areas

13 LDP Initial Consultation Report (August 2013). 5 . Summary of Consultation Responses

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit [2] Habitats and Species

Adaptation to climate change should seek to include novel and inventive ways to assist natural habitats and species to build resilience.

[3] Coed Darcy

It is indicated that Coed Darcy is to be promoted as an 'exemplar' of sustainable development but no details are given of what techniques / developments are proposed that justify this description.

[4] Flood Risk

A number of schemes are proposed that appear to be located in flood risk areas. It is important to ensure that future development is in line with the objective to avoid vulnerable development in areas of flood risk.

The Plan will need to provide clear evidence of how flooding policy has been considered in the development of the preferred strategy and strategic site selection.

34 6 . Issues to be Addressed

6 Issues to be Addressed

6.0.1 Having considered (1) the requirements of National / Regional policy and guidance, (2) the matters that have emerged from the evidence base and (3) the responses received to the formal Pre-Deposit stage consultation (Sept'11) and the more informal emerging Deposit Plan Proposals consultation (Oct'12), this section of the paper considers in more detail the issues that the LDP has to address.

Requirements Arising from National Policy and Guidance

6.0.2 National policy and guidance indicates that the following matters relating to climate change should be addressed in the development of the LDP:

Biodiversity and Climate Change - Local Planning Authorities (LPAs) must address biodiversity issues, insofar as they relate to land use planning, in both development plans and development control decisions. LPAs should consider how they might accommodate a response to climate change as part of their overall approach towards meeting biodiversity objectives. Ways in which the adaptation needs of biodiversity could be considered include identifying the scope for minimising or reversing the fragmentation of habitats and improving habitat connectivity through the promotion of wildlife corridors. Deposit LDP - Climate Change and Flooding Topic Paper (August 2013)

Wind Energy Developments - the need for wind energy is a key part of meeting the Welsh Government’s vision for future renewable electricity production. An integrated approach should be adopted towards planning renewable and low carbon energy developments and additional electricity grid network infrastructure.

Opportunities to Co-locate Major Developments to Optimise Renewable and Low Carbon Energy - LPAs should seek to maximise the opportunities for district heating and generation schemes in their development plan by co-locating new proposals and land allocations with existing developments and heat suppliers and users.

Appropriate Renewable / Low Carbon Energy Developments - LPAs should guide appropriate renewable and low carbon energy development by undertaking an assessment of the potential of all renewable energy resources and renewable and low carbon energy opportunities within their area, and include appropriate policies in development plans.

Opportunities for Higher Sustainable Building Standards on Strategic Sites - LPAs should assess strategic sites to identify opportunities to require higher sustainable building standards (including zero carbon) to be required. 35 A sustainable approach to flooding - Development in flood hazard areas should be avoided and where possible managed retreat, the creation of wash lands and flood plain restoration should be encouraged 6 . Issues to be Addressed

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Issues Arising from the Evidence Base

6.0.3 The following summarises the issues arising from the information relating to the current situation and trends.

6.0.4 In relation to the Causes of Climate Change:

Greenhouse Gas Emissions - the primary issue emerging from the data is carbon dioxide emissions. Currently the County Borough has the highest per capita emissions

of CO2 in Wales. Although this is likely to be due mainly to the County Borough's heavy industry and therefore not something that the LDP is likely to be able to affect significantly. It will be important however that all measures possible are taken to reduce emission levels.

Carbon Storage - significant amounts of carbon are 'locked up' within the County Borough because of the extensive areas of peat, woodlands and forests etc.

6.0.5 The LDP can affect greenhouse gas emission levels in a number of ways:

Settlement Pattern - emissions need to be reduced through the development of more sustainable settlements and settlement patterns, reducing the need to travel for access to services and facilities.

Transport - reducing traffic levels and traffic congestion and encouraging more sustainable travel patterns including encouraging use of alternatives to the private car.

Building Emissions - improved standards of building efficiency, including insulation standards and heating and cooling system efficiency.

Power Generation - need to make the County Borough's appropriate contribution to green energy generation

6.0.6 In relation to the Consequences of Climate Change:

Flood Risk - the topography and location of the County Borough means that significant areas and populations are vulnerable to increased flooding from both the sea and from streams and rivers. The risk of flooding therefore constrains and limits the availability of sites for development. 36 6 . Issues to be Addressed

Health Effects - a warming climate may exacerbate problems of poor air quality, but may also bring health benefits.

Habitats and Species - climate change is likely to put ecosystems and consequently habitats, species and ecosystems services under increasing pressure. Some species may be lost to the UK, arrival of invasive non-native species may pose a threat to native species and there may be a decline in habitats which develop in a cool, wet climate.

Key Issues

6.0.7 The Pre-Deposit Plan identified the following key issues which were linked to climate change:

Due to the topography of Neath Port Talbot, tidal and river flooding pose particular threats. Significant areas of the County Borough near to the coast fall within Flood Zone C2(14), together with large areas of the valley floors. This constrains and limits the availability of sites for development.

Vehicle ownership is increasing within Neath Port Talbot. This is leading to a rise in Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) greenhouse gas emissions.

6.0.8 In order to improve clarity for the Deposit Plan and as a result of an improved understanding of an up-to-date evidence base, the issue for the Deposit Plan has been amended as follows(15):

The causes and consequences of climate change will need to be addressed, including the increased risk of flooding.

37

14 Areas of the floodplain without significant flood defence infrastructure: TAN 15 (2004). 15 The Pre-Deposit Plan identified a total of 29 key issues. The Deposit Plan is now better informed by a strengthened identification of just 18 key issues. 6 . Issues to be Addressed eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit

38 7 . Objectives

7 Objectives

7.0.1 The objectives are at the centre of the LDP, they emerge from the vision and key issues and form the basis for future policy development.

7.0.2 The Pre-Deposit Plan identified a number of objectives, the following are relevant to climate change (the numbering follows the numbering in the Pre-Deposit Plan):

[8] Manage the effects of climate change including the need to avoid vulnerable developments in areas that are at risk from flooding or that may increase the risks of flooding elsewhere.

[12] Reduce greenhouse gas emissions and promote the use of renewable energy resources and maximising opportunities presented by its production.

7.0.3 In order to better reflect the revised key issue and improve clarity for the Deposit Plan, the following specific objective is proposed:

Minimise the causes and consequences of climate change through reduced

greenhouse gas emissions and adapt to climate change through consideration Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) of its effects in the design and location of new development.

39 7 . Objectives eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit

40 8 . Strategic Policy Development

8 Strategic Policy Development

8.0.1 At the Pre-Deposit stage, the overall Preferred Strategy was underpinned by a number of topic based and area based strategies.

8.0.2 Having considered the issues and objectives outlined in previous chapters, this section of the paper sets out how the strategy has evolved since the Pre-Deposit stage. Where appropriate, amendments and additions to the strategies are highlighted and explained.

Pre-Deposit Strategy

8.0.3 The Pre-Deposit Plan included the following topic based strategy for climate change:

Create communities and development that address the impacts of climate change (e.g. Stormier winters, drier summers, increased risk of flooding) and ensure that there is a greater resilience to these effects.

Ensure the efficient use of land and natural resources. Deposit LDP - Climate Change and Flooding Topic Paper (August 2013)

Guide development away from land that is at risk from flooding or environmental pollution (noise, air quality, instability).

Reduce carbon emissions and energy use. Promote the use of low carbon energy generation including district heating networks and renewable energy schemes. Identifying key sites where there is the potential for achieving higher carbon capture standards.

Co-locate facilities and encourage the joint use of facilities to reduce the need to travel.

Promote a more sustainable pattern of settlements through the location of, and integration of, new development to support active travel.

Provide facilities to reduce waste generation and promote recycling.

Apply the proximity principle to developments and cluster those with similar needs.

Through the Green Space strategy protect existing green areas within urban areas and provide areas of green space in new developments. 41 Use settlement limits and Green Wedges to define urban areas, encourage resource-efficient development, avoid the fragmentation of habitats and maintain continuity. 8 . Strategic Policy Development

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit Deposit Plan Strategy

8.0.4 A number of comments were received at the Pre-Deposit stage which contended that the strategy did not establish a baseline for successful implementation and treated the issue in a superficial way. Furthermore, it was argued that it did not give an indication of what measures will be looked for and how and when they will be sought in relation to the Preferred Strategy.

8.0.5 Taking these comments into account and in order to reflect the overall importance of climate change and its central role in the development of planning policies, the following specific overarching strategic policy has been developed for the Deposit Plan.

8.0.6 Overarching strategic policies are those relating to matters considered to be of primary importance for the whole County Borough and they set out measures that will be implemented through all the themes and topic areas of the LDP.

8.0.7 Strategic Policy: Climate Change

Climate Change

The causes and consequences of climate change will be addressed by implementing the following measures.

In relation to the causes of climate change:

1. The efficiency and sustainability of the County Borough's settlements will be enhanced through developing more cohesive and efficient settlements and settlement patterns, and consequently more sustainable travel patterns;

2. Greenhouse gas emissions from transport will be minimised through encouraging freight/commercial transport by alternatives to road (e.g. rail or sea);

3. Dependence on the private car and the need to travel in general will be reduced through promoting alternative means of transport and more efficient use of existing facilities, co-location and joint use of facilities;

4. Provision will be made for the County Borough's appropriate contribution to renewable and low carbon energy generation.

In relation to the consequences of climate change: 42 8 . Strategic Policy Development

1. Likely increased flood risk will be taken into account and addressed by ensuring that there is greater resilience, including by guiding development away from land that is at risk from flooding or locations that could increase the risk of flooding elsewhere;

2. The fragmentation of habitats will be minimised and opportunities made for habitat and species change and migration where possible.

8.0.8 Climate change is likely to affect the environment and future development of Neath Port Talbot in a range of significant ways, some of which are not fully predictable at present. It is also necessary to reduce greenhouse gas production as far as reasonably possible in order to minimise the causes of climate change. These issues are considered to be of fundamental importance to the LDP, and have influenced every aspect of the Plan's development. Climate change is consequently seen as an overarching matter to be addressed by all topic areas.

8.0.9 The measures outlined in the climate change strategic policy have therefore fundamentally influenced the development of the Plan, and are addressed and implemented through all its policies and proposals. Development allocations have been selected in Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) accordance with sustainable development principles to be in locations that minimise as far as possible dependence on the private car and can benefit from local services and facilities, while encouraging the provision of locally based facilities in order to address the causes of climate change. At the same time, the effects of a changing climate (for example flood risk) have been taken into account as far as possible in all the Plan allocations and policies.

Flood Risk

8.0.10 In order to ensure that the Plan allocations are in acceptable locations in relation to flood risk and that the LDP meets the requirements of TAN15: Development and Flood Risk, a detailed Strategic Flood Consequences Assessment (SFCA) has been undertaken. This document is available as part of the LDP Background Papers.

8.0.11 The SFCA provides a strategic plan making assessment of flood consequences within Neath Port Talbot County Borough Council. The document provides detailed information on the following:

Identification of the various relevant sources of flooding; Identification of existing flood defences and flood management regimes Identification of the areas of the county borough that have been identified for growth 43 and development over the LDP period that may be vulnerable to any type of flooding; Assessment of the likely consequences of flooding in relevant areas and assess whether these can be managed or mitigated Further investigation including detailed technical modelling of certain sites being considered within flood risk areas. 8 . Strategic Policy Development

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit 8.0.12 As identified in chapter 3 large areas of urban Neath and Port Talbot are vulnerable to flooding as are significant tracts of the main rivers and watercourses in the Valleys. Flood risk concerns and constraints have therefore been considered during the development of the strategy and have influenced the areas identified for development and the proposed allocations.

8.0.13 As is discussed in detail in the SFCA the Plan has sought to avoid, as far as possible, development within flood risk areas and an assessment of flood risk has been considered as part of the methodology of assessing the proposed housing and employment allocations and as part of the settlement limit boundary review.

8.0.14 The SFCA consists of three stages:

Stage 1 consisted of compiling information about flood risk, including from indicative flood maps (principally the Welsh Government Development Advice Maps and NRW's Flood Map), records of historic flooding incidents, sewer records, flood defence information and local flood levels. From this information, proposed development sites at risk of flooding could be identified. Stage 2: Sites most at risk were removed, and those not within any flood zone identified. The remaining sites were considered at Stage 2 in relation to the justification test in TAN 15. This further refinement led to the identification of those that were acceptable in terms of the test, and those where further analysis was required. Stage 3: Where stages 1 and 2 did not fully satisfy the requirements of TAN 15 due to the lack of available data regarding flooding consequences at particular sites (but where the sites were otherwise in sustainable locations and important for delivering the Plan strategy), specific sites were considered at Stage 3. This included more detailed analysis of flooding mechanisms and consequences.

Residential Allocations

8.0.15 Following the above process, five sites were identified that required detailed analysis at Stage 3. These sites are listed in Table 8.1 below.

Table 8.1 LDP Residential/Mixed-Use Allocations Requiring an SFCA Stage 3

DAM Flood Site Ref Name Settlement Comments Zone

H1/17 Harbourside Port Talbot A/C1/C2 Parts of site within flood zones

Afan Lido and land to Sandfields Included due to possible impacts H1/18 the rear of Tywyn A of Climate Change 44 School Purcell Avenue Sandfields Included due to possible impacts H1/20 A of Climate Change

Tir Morfa Road Sandfields Included due to possible impacts H1/22 A of Climate Change

H1/23 Park Avenue Glynneath A/B/C2 Parts of site within flood zones 8 . Strategic Policy Development

8.0.16 In relation to these sites, further investigation has been undertaken and they have been subject to a more detailed 'stage 3' analysis. Full details are in the SFCA document. In summary, the Stage 3 analysis made the following conclusions:

H1/17 Harbourside

8.0.17 Harbourside is allocated as a Strategic Regeneration Area mixed use development under reference SRA 2 of the Deposit Plan. Residential development is allocated under reference H1/17, but specific sites for housing are not identified within the LDP. The SFCA has assessed in detail the residential development sites shown in the Harbourside Masterplan, and reaches the following conclusions:

Henshaw Street (SA2)

8.0.18 The site passes the justification test, it can be developed with levels raised by approximately 400mm which will minimise flooding during a 1000 year fluvial event to the 600mm prescribed by TAN15. At this level it will not flood during the 1 in 100 year plus climate change fluvial event or the 1 in 200 year tidal event. There is a suitable route for access and egress to the west of the site which will remain dry in all flood events.

Gas Works Site (SA 3) Deposit LDP - Climate Change and Flooding Topic Paper (August 2013)

8.0.19 This site should be deemed as passing the justification test and can be developed at its current approximate elevation with localised regrading to prevent excessive flooding during the 1 in 1000 year fluvial flood events. There is a suitable route of access and egress from the north which would be open in all flood events up to and including the 1 in 100 year plus climate change fluvial and 1 in 200 year tidal event.

Harbourside (SA4)

8.0.20 There are large areas on this site with no flooding issues (Zone A) that are currently shown as residential use and could be developed without further flooding consideration provided that the associated infrastructure was designed to allow for emergency access and egress which appears eminently possible due to the swath of Zone A that runs up to the new Peripheral Distributor Road to the north. Areas within zone C will be developable subject to detailed investigation through site specific Flood Consequence Assessments and the provision of appropriate mitigation measures.

H1/18 Afan Lido and Land to the rear of Tywyn School, Aberafan

8.0.21 There do not appear to be any areas local to this site that would be affected were this site to be developed. The proposed development site is suitable for development in accordance with TAN 15. 45

H1/20 Purcell Avenue

8.0.22 There do not appear to be any areas local to this site that would be affected were this site to be developed. The proposed development site is suitable for development in accordance with TAN 15. 8 . Strategic Policy Development

eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit H1/22 Tir Morfa Road

8.0.23 There do not appear to be any areas local to this site that would be affected were this site to be developed. The proposed development site is suitable for development in accordance with TAN 15.

H1/23 Park Avenue

8.0.24 The majority of the site lies within Flood Zone A and B which is deemed to be developable based on the requirements of TAN 15. The smaller part of the site classified as zone C2 which covers the brownfield part of the site should be considered in more detail during the site specific FCA but this area can be excluded from the developed part of the site as appropriate.

46 9 . Detailed Policy Development

9 Detailed Policy Development

9.0.1 Climate change is one of the most fundamental issues that the LDP will need to address and a response to the challenges posed is embodied in all parts of the Plan. As a consequence, there are no detailed policies in the Deposit Plan that deal specifically with climate change. Moreover, the various elements of the climate change strategy are addressed and implemented through a range of topic based strategic and detailed policies. Policy for dealing with proposals for development within areas of flood risk are contained within national policy (Planning Policy Wales and TAN 15).

Causes of Climate Change

9.0.2 Efficiency and sustainability of settlements are addressed under the 'Settlement' topic and strategy(16).

9.0.3 Greenhouse gas emissions from transport are addressed under the 'Transport' topic and strategy(17).

9.0.4 Greenhouse gas emissions from buildings are addressed under the 'Renewable and Low Carbon Energy' topic and strategy(18). Deposit LDP - Climate Change and Flooding Topic Paper (August 2013) 9.0.5 Power generation is addressed under the 'Renewable and Low Carbon Energy' topic and strategy(19).

Consequences of Climate Change

9.0.6 Flood risk is addressed in detail by the 'Strategic Flood Consequences Assessment' (SFCA)(20).

9.0.7 Health effects are addressed under the 'Environment' and 'Health' topics and strategies(21).

9.0.8 Habitat and species issues are addressed under the 'Environment' topic and strategy(22).

47

16 Deposit Settlement Topic Paper (August 2013). 17 Deposit Transport Topic Paper (August 2013). 18 Deposit Renewable & Low Carbon Energy Topic Paper (August 2013). 19 Deposit Renewable & Low Carbon Energy Topic Paper (August 2013). 20 Strategic Flood Consequences Assessment (August 2013). 21 Deposit Environment Topic Paper (August 2012); Deposit Health Topic Paper (August 2013). 22 Deposit Environment Topic Paper (August 2013). 9 . Detailed Policy Development eoi D lmt hneadFodn oi ae Ags 2013) (August Paper Topic Flooding and Change Climate - LDP Deposit

48 Local Development Plan Cynllun Datblygu Lleol

August 2013 ENVT1549 www.npt.gov.uk/ldp