Site Alternative Deliverability Report SALT 004 Castle Road, Llangynidr Resubmission: Undeliverable

Local Development Plan Site Alternative Deliverability Report

Brecon Beacons National Park Authority

SALT 004 Castle Road, Llangynidr

Resubmission: Undeliverable

SALT 004 Castle Road, Llangynidr Llangynidr (Llangynidr) Existing use Agriculture Proposed use Residential Previous CS/DBR Number CS18

Previous site survey Taken from LDP Settlement Assessment: Llangynidr

Candidate CS18 Land South West of Castle Farm

Field access off Castle Road at NW corner of site

Rear of Church Close Development

Filed access and ROW stile into field

Looking NE towards NE boundary and field access into site. View of Castle lane looking SE from west of site

View within site looking towards South

View of Western Boundary looking south from within site. Note wild flowers within site and overgrown hedgerow. Note View from NW corner looking towards Eastern extent landscape context.

View from Eastern Boundary looking towards development at Church close

View within site looking towards Eastern Boundary, note landscape context Overgrown area adjacent to Southern Extent of site. Image taken looking North

CS ID no CS18 Site Name Land South West of Castle Farm

Current use of area Agriculture—Hay meadow at time of visit

Proposed use Residential development—no of units not specified. Site would accommodate up to 38 dwellings working at 30 dwellings per hectare density.

Are there natural Constraints Relatively flat site bounded on all sides by mature and overgrown hedgerow—mature trees within site preventing development

Are there any other constraints No current access, field access exits field onto Castle Road, minor and narrow road serving Cwmcrawnon area of preventing development of the site Llangynidr North. Immediate impressions suggest there would be capacity issues with servicing size and extent of development area proposed at prudent land use levels. Feasibility of access subject to appropriate assessment from Powys Highways Authority. ROW runs diagonally across site from NW to SE corner. Development on site would have possible Backland and amenity issues for adjoining properties at Castle Close Development immediately adjacent? Predominately surrounded by agricultural land. Castle road runs parallel with NE boundary. Eastern boundary abuts rear of Church Close Modern Housing estate. Impact on settlement if development Site Description: Located at the Western extent of Llangynidr South. Site is a relatively flat area accessed off Castle were to proceed lane, development would extend out the current form of the village along castle road.

Landscape Impact: Despite its relative adjacency to developed form of Llangynidr south area feels remote from main village nucleus and represents area of open space with good public access at the edge of village at point where development gives way to rural agricultural landscape. Landscape setting is predominately rural to the West, South and East affording views out towards Mynydd Llangattock. Area affords sense of open valley setting. Development at this point would extend developed form illogically into open countryside, presenting an urban clump at pronounced and definite edge of village.

Other issues: Potentially rich area for biodiversity from wildflower cover (wild orchids seen within field) Impact on area of access into open countryside.

Recommendation Area is illogical extension out of keeping with settlement character, impacting on important open space which serves also to frame the village within landscape setting. Recommend area retain current use as agricultural land during LDP period.

DEPOSIT Key Stakeholder Responses No previous consultation – site failed capacity stage.

SALT Key Stakeholder Responses Consultee Score Comment Dwr Cymru Welsh Water Sewerage Foul and surface water flows should be on separate systems. Development of these sites may be constrained by the performance of our public sewerage network for which there are no planned improvements within our current capital investment programme. Should this land be allocated for development then we would request that the allocation be released in the latter part of your Plan to allow us the time to undertake improvements or alternatively developers may need to fund the works in advance of our Regulatory requirement. Sewerage Treatment Our Waste Water Treatment Works for this area has limited capacity to accommodate all of the planned growth without further improvement. Dependant on the scale and rat of development, there will ultimately be a time where improvements to our asset is required. These improvements will form part of our Regulatory Capital Investment Programme which is agreed in 5 yearly cycles. Water A water supply can be made available to service the proposed development site. However, this would require off-site mains to be laid to the proposed development to ensure customer service standards is maintained Highways Castle Road is too narrow for two vehicles to pass, has poor horizontal alignment and has very limited visibility to the south-west at its junction with Church Close. This means of access is totally unsuitable for any residential development, especially on the scale possible on the size of the plot outlined CCW The supporting documentation submitted in support of the proposed allocation does not include a sustainability assessment of the site or any assessment against the Plan’s SA Objectives, and as such we do not consider that the proposed allocation meets the requirements of the SEA Regulations. Notwithstanding the above, the following points should also be taken into consideration when considering the allocation of this site: Llangynidr is identified as a ‘Level 4: Limited Growth settlement’ in the BBNPA Deposit LDP, where it has been determined that growth would significantly impact on the Special Qualities of the National Park, and/or, development is constrained by external pressures which are irresolvable without significant impact on the special qualities of the National Park (para. 3.10.1.2, BBNPA Deposit LDP). The proposal therefore appears to be inconsistent with the LDP strategy. Given the scale of the proposal, allocation and subsequent development of this site would lead to a significant westward extension of the village into the open countryside, leading to significant sprawl, particularly when viewed from Buckland Common to the north. Although a Right of Way runs diagonally across the site from North West to the South East corner of the site, no information is provided as to how it will be protected / incorporated into any development. Finally, our records indicate that the site consists of Lowland Meadows, a Priority Habitat in the UK Biodiversity Action Plan (BAP). As surveys at this site were undertaken more than 10 years ago, should the LPA/Inspector be minded to proceed with this allocation, an up to date survey of the site should be undertaken Brecon Beacons Park Society Llangynidr is a large village which has reached environmental capacity. Development of Salt 004 would be an unacceptable extension into open countryside and SALT 085 would be an urban intrusion into the centre of the village which at present has an open rural feel. The beauty of the canal, river and surrounding countryside attract many visitors. The membership of the Brecon Beacons Park Society includes many walkers and the village car park is often used as the starting point for walks. Both these developments would affect the character of the village. They would also be visible from the surrounding hills and would adversely affect the special landscape character of the NP. This would be against the aims of the NP Management Plan, which states that part of its vision is that “the Park’s irreplaceable historic settlement patterns and buildings are conserved” (Page 76 MP). It would also conflict with Planning Policy Wales, which states the aim in section 4.4.2. “to minimise land-take and urban sprawl”. In section 4.5.4 it states “Countryside…must be conserved and enhanced for the sake of its ecological and agricultural value and for its landscape and natural resources”. This village has no bus service and lacks any major source of employment. It is therefore not a sustainable location so these developments would conflict with the Wales Spatial Plan. (C1, C2, C3, C4)

Crickhowell & District Civic Society Llangynidr Applications - We wish to support the local community council but consider the major problem with both applications is the massive expansion of the community curtilage. Brecknock Wildlife Trust The site is listed as semi improved neutral grassland on CCW’s Phase 1 habitat maps. I would like to recommend further survey of this site before it gets into the LDP to ensure that a Biodiversity Action Plan priority habitat is not lost.

Llangynidr Community Council Llangynidr Community Council objects to both the above site alternatives.

The Council is happy with the designation of the village as a Level 4: Limited Growth Settlement, given in the Deposit Local Development Plan. We also consider that this designation accords with the wishes of the vast majority of the inhabitants as evidenced by the community consultations that were undertaken as part of the preparation for the Plan.

(i) Environmental Capacity In general it is felt that there has been enough, if not too much, development over the last five decades and that the village has reached environmental capacity. Future housing should be restricted to a small number of affordable houses for evidenced local need. The sewerage system is inadequate for more development.

The historic character and vernacular nature of the village have been threatened by the development that has occurred in recent years. We do not want further open market development which would turn a pleasant rural village into an urban dormitory. Development of these two sites would alter the village form and lead to urban sprawl. This would be against the aims of the NP Management Plan, which states that part of its vision is that “the Park’s irreplaceable historic settlement patterns and buildings are conserved” (Page 76 MP). It would also conflict with Planning Policy Wales, which states the aim in section 4.4.2. “to minimise land- take and urban sprawl”. In section 4.5.4 it states “Countryside…must be conserved and enhanced for the sake of its ecological and agricultural value and for its landscape and natural resources”. Llangynidr has historically consisted of two separate parts, Upper and Lower Llangynidr. The community is particularly keen that the fields separating them should not be built on as this would diminish the open rural feel that is a special feature of the village and this is a particular reason for opposing development of SALT 085. SALT 004 is not a logical extension of the village and would result in a further spread into agricultural land.

Tourism is an important source of employment in the village, with the attractions of the canal, the River Usk, the historic bridge and the views of the surrounding mountains drawing walkers, cyclists, canoeists and people using barges on the canal. Development of these two sites would create an urban feel and seriously diminish the special qualities, the peace and tranquillity, the sense of place and cultural identity, the outstanding natural beauty and intimate sense of community which are what attract visitors to the area and which the National Park designation and the NP Management Plan seek to protect. (M.P. Section 7.1.5.). In Section 7.3.1. Strategic Objective 7. (page 133) is to “Realise fully the tourism potential of the Monmouthshire and Brecon canal whilst its attractive settings are conserved and enhanced.

The above points show that the inclusion of these two sites in the LDP would be at variance with the policies of PPW and the BBNP Management Plan and would therefore cause it to fail the consistency tests C1, C2 and C4.

(ii) Sustainability Further development in Llangynidr would be against the policy of sustainability. Llangynidr has no adequate bus service (one bus a day to Brecon in school term only), so access to most services and employment is by private car. Moreover Llangynidr has road infrastructure restrictions. Llangynidr Bridge is an important historical structure. Any further developments in Llangynidr (and in villages to the north of Llangynidr such as Bwlch, Llangorse and Talgarth) will place additional pressure on Llangynidr Bridge and roads around Llangynidr. The bridge is being repeatedly damaged by the increasing volume of traffic. The road east to Crickhowell and west to Talybont (B4558) is narrow with many sharp bends. In places it is not possible for the school buses or lorries to pass cars. There have been numerous accidents on these roads over the past 10 years. An increase in traffic, which development would generate, would worsen the situation. The mountain road to the south (B4560) to Beaufort and the Heads of the Valleys road has a very poor vehicle accident record including fatalities in recent years. Moreover accidents to sheep on the unfenced section cause considerable losses to farmers.

Castle Road is a particularly narrow lane and would not be suitable as access to a development the size of SALT 004. The road is an ancient lane and we would be opposed to any destruction of the ancient walls and hedges.

Due to the limitations of the road infrastructure, Llangynidr has very little prospect of new employment. Further housing development will result in the village being used as a dormitory town with residents travelling long distance by car to reach employment.

The concept of sustainability underpins the Wales Strategic Plan, Planning Policy Wales and the NP Management Plan. According to the Hub and Cluster approach to development promoted in the Wales Spatial Plan, developments of this size should be concentrated in the primary key settlement, or the key settlements so that people live near their employment and services. PPW states “development should be located to minimise the need to travel” (4.4.2) and “In rural areas the majority of new development should be located in those settlements which have relatively good accessibility by non-car modes” (4.6.7). The BBNP Management Plan Strategic Objective for Transport 1 states “Reduce the need for transport by controlling the location and design of development.” (7.3.5). In the section on Planning and Development (7.3.4) it states “Planning is the principle process for achieving sustainable development in the Park” and Strategic objective 4 states “ … encourage a better link between the provision of employment and housing.”

The development of SALT 085 and Salt 004 would not be sustainable and would therefore fail the consistency tests C1, C2, C3 and C4.

For all the above reasons we do not think that the inclusion of SALT 085 and SALT 004 in the LDP would be sound.

Deliverability Assessment

Is the site deliverable? No Unachievable access. Unacceptable intrusion into open countryside.

Local Development Plan

Site Alternative

Assessment against LDP Strategy

Brecon Beacons National Park Authority

SALT 004

Castle Road, Llangynidr

Not Compliant with Strategy

Is the site located within a community where No there is a defined need for growth? Pre-Deposit consultation with Llangynidr Community Council details preference for limited growth options to meet affordable housing / local needs housing only.

Is the site located in a sustainable location? Yes

Llangynidr meets sustainability criteria relating to role, function and relationship with key settlements.

Is there a current allocation within the Deposit No LDP? No suitable development options were identified for Llangynidr during pre-deposit assessments.

Results from Deliverability Assessment Access to the site has been identified as unsuitable for residential use, the supporting road network does not have capacity to accommodate development of the scale proposed.

The Site does meet deliverability criteria.

Officer Recommendation Site Site is not considered suitable as a development option for the National Park Community.

No change to the LDP as a result of deposit allocation representation.

Site to remain as countryside during LDP period (subject to findings of any subsequent review)

Officer Recommendation Settlement No alteration to Llangynidr Settlement Assessment.