Neath Port Talbot County Borough Council Local Development Plan 2011 –2026

Environment Topic Paper August 2013

www.npt.gov.uk/ldp Contents

1 Introduction 1 2013) 2 Background 3

3 Policy Context: National, Regional & Local 5 (August 3.1 National Policy Context 5 Paper

3.2 Regional Policy Context 14 opic T 3.3 Local Policy Context 16 4 Current Situation and Trends 25 Environment 4.1 Built Environment and Historic Heritage 25 -

4.2 Countryside and the Coast 32 LDP

4.3 Biodiversity and Geodiversity 35 Deposit 4.4 Environmental Protection 43 5 Summary of Consultation Responses 51 6 Issues to be Addressed 55 6.1 Built Environment and Historic Heritage 55 6.2 Countryside and the Coast 58 6.3 Biodiversity and Geodiversity 63 6.4 Environmental Protection 65 7 Objectives 69 8 Strategic Policy Development 71 8.1 Built Environment and Historic Heritage 71 8.2 Countryside and the Undeveloped Coast 74 8.3 Biodiversity and Geodiversity 77 8.4 Environmental Protection 79 9 Detailed Policy Development 83 9.1 Built Environment and Historic Heritage 83 9.2 Countryside and the Undeveloped Coast 87 9.3 Biodiversity and Geodiversity 92 9.4 Environmental Protection 93 Contents Deposit LDP - Environment T opic Paper (August 2013) 1 . Introduction

1 Introduction 2013) 1.0.1 This topic paper is one of a range of papers prepared to offer more detailed

information and to provide an explanation of the approach taken in the Local Development (August Plan (LDP) in relation to different topics and issues affecting the County Borough. Paper 1.0.2 This paper specifically considers the Environment. opic T 1.0.3 The 'Environment' topic covers a broad range of issues including:

Built Environment and Historic Heritage; Environment - Countryside and the Coast; LDP Biodiversity and Geodiversity; and Deposit Environmental Protection.

1.0.4 Previously, two topic papers, one entitled 'Climate Change and the Environment' and the other entitled 'Community Safety', were published at the Pre-Deposit stage in September 2011. 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 For the Deposit Plan consultation stage however, the decision has been taken to (1) prepare two separate papers, one covering 'Climate Change'(1) and the other 'Environment'; and (2) to amalgamate and incorporate the main planning matters addressed in the previous 'Community Safety' topic paper into this 'Environment' topic paper.

1.0.6 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 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 Neath Port Talbot Unitary Development Plan (UDP) and be the primary document for use in the determination of planning applications.

1.0.7 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 (2) Port Talbot . 1

1 Deposit Climate Change Topic Paper (August 2013). 2 The information contained within this Topic Paper is correct as of the date sent to print. 1 . Introduction Deposit LDP - Environment T opic Paper (August 2013)

2 2 . Background

2 Background 2013) 2.0.1 The Environment as a topic covers a range of issues relating to the existing natural

and built infrastructure of the area, the framework and inter-relationships between these (August factors and the services that are supplied by the natural ecosystem (such as clean air, water and productive soil). Paper opic 2.0.2 The Planning system has a key role in addressing environmental issues, ensuring T new developments and the urban form enable residents to reduce their overall 'Ecological Footprint', avoiding and reducing significant impact where possible. Where adverse impacts on the environment are unavoidable, it should be ensured that mitigation or compensation Environment measures are put in place. There are a number of challenges which the County Borough -

will face over the coming years, including addressing the impacts of climate change, LDP preventing further loss of biodiversity and integrating policies and strategies to promote and deliver sustainable development. Deposit 2.0.3 This paper will cover the following areas:

Built Environment and Historic Heritage - including historic heritage (Conservation Areas, Listed Buildings, Canals), design, community safety and gateways;

Countryside and the Coast - including Green Wedges, Special Landscape Areas and the developed and undeveloped coast;

Biodiversity and Geodiversity - including European, national, regional and local designations and priority habitats and species; and

Environmental Protection - including soils, contamination, air quality, water quality, noise and light.

2.0.4 Climate change is now covered in a separate topic paper(3), which gives an overview of the impact of all aspects of planning and the LDP on the causes of climate change (and measures being taken to reduce this) and the ways in which the consequences of climate change will be taken into account and addressed. Community safety matters, previously covered in a separate topic paper, are now addressed as part of the design considerations under the Built Environment element of this topic area.

2.0.5 It should be noted that flooding issues are dealt with in the 'Strategic Flood Consequences Assessment'(4) and 'Climate Change Topic Paper' respectively.(5).

2.0.6 It should also be highlighted that the Deposit LDP has been the subject of a 'Sustainability Appraisal (incorporating Strategic Environmental Assessment)' [SA(SEA)] 3 which addresses in detail the anticipated impact of the Plan on a range of environmental, social and economic issues. The key findings are presented in the SA Report(6).

3 Deposit Climate Change Topic paper (August 2013). 4 Strategic Flood Consequences Assessment (SFCA) (August 2013). 5 Deposit - Climate Change Topic Paper (August 2013). 6 Sustainability Appraisal (August 2013). 2 . Background Deposit LDP - Environment T opic Paper (August 2013)

4 3 . Policy Context: National, Regional & Local

3 Policy Context: National, Regional & Local 2013) 3.1 National Policy Context (August Wales Spatial Plan (2008) Paper 3.1.1 One of the key priorities for the Swansea Bay Waterfront and Western Valleys opic Area, in which Neath Port Talbot lies, is to ensure that environmental protection and T enhancement are fully integrated. This includes protecting and enhancing the biodiversity of the area and managing the risks of the disconnection and isolation of habitats from changes in land use and climate. Environment - 3.1.2 The Wales Spatial Plan (WSP) recognises that the natural environment underpins the success of the area and is central to the quality of life of residents, visitors and LDP employees and is vital in ensuring that we retain jobs, attract inward investment and diversify our local economy. Deposit

3.1.3 In terms of the built environment, the WSP states that the quality of design of buildings and public spaces in the area’s city, town centres and smaller settlements needs to be high, giving places wherever possible a distinct sense of identity, fostering a sense of civic pride and community. The overall aim of the Plan is to create a network of settlements with real character which complement each other and add strength to the attractiveness of the city-region as a whole.

3.1.4 It recognises the importance of the environment for its intrinsic value and for the economy and quality of life. The safeguarding and enhancing of the natural environment will attract people and retain them and preserve the foundations for the future. The Plan identifies a need to understand better how Wales’ great environmental assets can be used to benefit people and the economy. Furthermore, it is stated that mitigation and adaptation to climate change can give opportunities for environmental gain including biodiversity enhancements and habitat improvements.

Planning Policy Wales Edition 5 (2012)

3.1.5 Planning Policy Wales (PPW) identifies a number of broad objectives which reflect the sustainable development agenda and Welsh Government (WG) priorities:

Promote resource-efficient and climate change resilient settlement patterns that minimise land-take (and especially extensions to the area of impermeable surfaces) and urban sprawl, especially through preference for the re-use of suitable previously developed land and buildings, wherever possible avoiding development on greenfield sites. 5 Locate developments so as to minimise the demand for travel, especially by private car. 3 . Policy Context: National, Regional & Local

Deposit Guide renewable and low carbon energy provision as part of an integrated approach including the location and design of new development, identify strategic sites to deliver

LDP enhanced standards, and ensure that public buildings (including major renovations) fulfil an exemplary role. - Environment Support the need to tackle the causes of climate change by moving 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 T opic energy sources at all scales and facilitates low and zero carbon developments. Paper Minimise the risks posed by, or to, development on, or adjacent to, unstable or

(August contaminated land and land liable to flooding. This includes managing and seeking to mitigate the consequences of climate change by building resilience into the natural and built environment. 2013)

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

Play an appropriate role in securing the provision of infrastructure to form the physical basis for sustainable communities (including water supplies, sewerage and associated waste water treatment facilities, waste management facilities, energy supplies and distribution networks and telecommunications), while ensuring proper assessment of their sustainability impacts.

Contribute to the protection and improvement of the environment, so as to improve the quality of life, and protect local and global ecosystems. In particular, planning should seek to ensure that development does not produce irreversible harmful effects on the natural environment and support measures that allow the natural heritage to adapt to the effects of climate change. The conservation and enhancement of statutorily designated areas and of the countryside and undeveloped coast; the conservation of biodiversity, habitats, and landscapes; the conservation of the best and most versatile agricultural land; and enhancement of the urban environment all need to be promoted. This can include the use of local designations such as Green Wedges and Special Landscape Areas.

Help to ensure the conservation of the historic environment and cultural heritage, acknowledging and fostering local diversity.

Maximise the use of renewable resources, including sustainable materials (recycled and renewable materials and those with a lower embodied energy). Where it is judged necessary to use non-renewable resources they should be used as efficiently as 6 possible. The use of renewable resources and of sustainably produced materials from local sources should be encouraged and recycling and re-use levels arising from demolition and construction maximised and waste minimised. 3 . Policy Context: National, Regional & Local

Encourage opportunities to reduce waste and all forms of pollution and promote good

environmental management and best environmental practice. Waste arising from 2013) demolition and construction should be minimised, and opportunities to recycle and re-use this waste promoted. (August

Ensure that all local communities - both urban and rural - have sufficient good quality Paper housing for their needs, including affordable housing for local needs and for special opic needs where appropriate, in safe neighbourhoods. T

Promote access to employment, shopping, education, health, community, leisure and sports facilities and open and green space, maximising opportunities for community Environment

development and social welfare. -

Foster social inclusion by ensuring that full advantage is taken of the opportunities to LDP secure a more accessible environment for everyone that the development of land and

buildings provides. This includes helping to ensure that development is accessible Deposit by means other than the private car.

Promote quality, lasting, environmentally-sound and flexible employment opportunities.

Contribute to the protection and, where possible, the improvement of people’s health and well-being as a core component of sustainable development and responding to climate change. Consideration of the possible impacts of developments - positive and/or negative - on people’s health at an early stage will help to clarify the relevance of health and the extent to which it needs to be taken into account.

Development Plans need to provide a framework to stimulate, guide and manage change towards sustainability. They should secure a sustainable settlement pattern which meets the needs of the economy, the environment and health, while respecting local diversity and protecting the character and cultural identity of communities.

3.1.6 Further information and explanation of these objectives is provided in the various chapters of PPW including:

Chapter 4: Planning for Sustainability.

Chapter 5: Conserving and Improving Natural Heritage and Coast - which includes biodiversity, conservation and coastal areas.

Chapter 6: Development Plans and the Historic Environment - which includes conservation areas, areas of archaeological interest and listed buildings. 7 Chapter 12: Infrastructure and Services.

Chapter 13: Minimising and Managing Environmental Risks and Pollution - which includes flood risk, contaminated land, air, water and noise quality. 3 . Policy Context: National, Regional & Local

Deposit Technical Advice Note (TAN) 5: Nature Conservation and Planning (2009)

LDP 3.1.7 TAN 5 sets out the key principles of planning for nature conservation, including biodiversity and geodiversity. It is indicated that biodiversity conservation and enhancement -

Environment is an integral part of sustainable development, with the planning system having a central role to play, while the geology of Wales is visually impressive, of great scientific importance and provides opportunities for lifelong learning, recreation and tourism. The importance of geodiversity is identified as the basis for landscapes, rocks, minerals, soils and other T

opic superficial deposits. Geodiversity is important because it underpins biodiversity with soils being the link between them. The TAN also: Paper

Identifies the legislative requirements, including the National Environment and Rural (August Communities Act 2006, Countryside Act 1968, the Wildlife and Countryside Act 1981, and the specific requirements of regulations concerning European Wildlife Sites; 2013) Provides advice about the preparation and review of development plans, including the relevant statutory requirements;

Addresses nature conservation in development control procedures;

Deals with the conservation of internationally and nationally designated sites and habitats and also covers local sites; and

Deals with the conservation of protected and priority habitats and species.

3.1.8 Detailed advice is given about the appraisal of development plans under the Habitats Regulations, involving assessing the likely effects of the Plan on any 'European Site', including Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and Ramsar sites.

Technical Advice Note (TAN) 8: Planning for Renewable Energy (2005)

3.1.9 In relation to renewable energy, TAN 8 indicates that design, infrastructure and site layout are key to achieving energy efficient development by optimising passive solar gain and that the standards established under the Eco-Homes scheme for residential development and BREEAM scheme for non-residential development form a useful framework for energy efficiency consideration. Furthermore, developers need to consider the use of low and zero carbon energy sources as part of their approach to reducing carbon emissions associated with developments. 8 Technical Advice Note (TAN) 11: Noise (1997) 3.1.10 TAN 11 indicates that noise policies may apply to the Plan area as a whole but that area specific noise policies may be useful in some circumstances with relevant boundaries illustrated on the Proposals Map. It is highlighted that it will generally be inappropriate for a Proposals Map to show detailed noise contours as noise emissions may change significantly over time. 3 . Policy Context: National, Regional & Local

3.1.11 It is suggested that Plans should contain an indication of any general policies which the local planning authority proposes to apply in situations where it is particularly 2013) difficult to separate noise sensitive development from noisy activities. Noise Exposure Categories (NECs) are set out to assist local planning authorities in their consideration of (August planning applications for residential development near transport related noise sources. Paper Technical Advice Note (TAN) 12: Design (2009) opic T 3.1.12 TAN 12 recommends that flexibility should be built into building design so that the buildings are adaptable and can respond to social, technological, economic and environmental conditions / changes over time to minimise the need to demolish and rebuild. Environment

For example, in mixed-use developments consideration should be given to how the - proposed density and mix will encourage different uses by various sectors of the community which will require an anticipation of potential changes in the make up and needs of LDP occupiers. Deposit 3.1.13 TAN 12 states that development plans and supplementary planning guidance should provide a clear context for design requirements in the local area and should include clear robust policies on design which address local issues and should be based on relevant evidence. They should not repeat national policy and should set out the planning authority’s design expectations without imposing architectural styles or tastes. Furthermore, strategic, generic and cross cutting design policy may be required for LDPs. Plans may incorporate targeted design policies for major areas of change or protection, strategic sites or for certain types of development.

3.1.14 Detailed advice is given on the following design issues:

Inclusive Design;

Transport & Movement;

Landscape;

Biodiversity;

The Historic Environment;

Urban Regeneration;

Rural Areas; Public Buildings; 9 The Public Realm;

Public Art;

Signs & Advertisements; 3 . Policy Context: National, Regional & Local

Deposit Housing Design & Layout;

LDP Employment & Commercial Areas; -

Environment Environmental Sustainability; and

Design & Public Safety. T opic 3.1.15 It is stated that 'Designing Out Crime' requires full consideration by everyone

Paper involved in the design of development and attention should be given at the outset of the design process. It is also noted that the 'Safer Place and Secure by Design Initiative' (August provides recognised standards that have been shown to reduce crime (particularly residential burglary) and the impact of crime upon neighbourhoods. 2013) Technical Advice Note (TAN) 15: Development and Flood Risk (2004)

3.1.16 TAN 15 indicates that planning and building standards have a complementary role in flood management and the use of flood damage resistant and mitigation measures will be required as part of ensuring that consequences of flooding are acceptable. Simple design features such as raising floor levels, while ensuring that appropriate access is maintained for disabled people, or keeping electrical circuits above levels likely to be affected by flooding, can enable buildings to resist and cope with flooding better.

3.1.17 In relation to mitigation measures, TAN 15 states that built development, such as roads, pavements and roofing, tends to increase the surface area of impermeable ground, thus reducing percolation and increasing surface run-off and indicates that 'Sustainable Urban Drainage 'schemes (SUDs) can perform an important role in managing run-off from a site and should be implemented, wherever they will be effective, in all new development proposals, irrespective of the zone in which they are located.

Technical Advice Note (TAN) 18: Transport (2007)

3.1.18 TAN 18 emphasises the critical importance of the layout and detailed design of development in providing genuine alternatives to car travel and achieving quality in the environment as a whole. Transport infrastructure should contribute to a sense of place and community within a development and the design of streets has a crucial role in this regard.

3.1.19 Careful consideration should be given to location, access arrangements and design to encourage walking as a prime means for local journeys.

10 Technical Advice Note (TAN) 22: Sustainable Buildings (2010)

3.1.20 TAN 22 states that design guidance on delivering sustainability and in meeting sustainable building standards can usefully be addressed through supplementary planning guidance. Furthermore, the scale and mix of a development can provide opportunities to 3 . Policy Context: National, Regional & Local

deliver localised energy solutions (e.g. higher densities and mixed use developments will often be best for community heating, cooling and power supplied by low / zero carbon 2013) technologies).

3.1.21 Local Planning Authorities can set local requirements on strategic sites that (August exceed the standards set out in national policy. It is the aspiration of the Welsh Government Paper for all buildings built from 2011 onwards to be zero carbon hence the Local Authority needs opic to maximise opportunities to meet higher sustainable building standards. T

Welsh Office Circular 16/94: Planning Out Crime

3.1.22 Although published prior to devolution and some joint responsibility for Home Environment - Office functions, this circular is still in force. LDP 3.1.23 It states that "layouts should aim to reassure the public by making crime more

difficult to commit, increase the risk of detection and provide people with a safer, more Deposit secure environment".

3.1.24 Planning can address crime and disorder prevention as part of an overall strategic approach to community safety and, where appropriate, crime prevention can be a material consideration in a planning application.

3.1.25 Planning can affect community safety and crime and disorder prevention at three different levels:

Land use – avoiding the juxtaposition of land uses that could give rise to conflict and the creation of passive surveillance at all times of day;

Layout of individual developments; and

Individual design of buildings and landscapes - so as to avoid sterile and unattractive areas and places to hide and the management of public space.

3.1.26 Many of these measures will not only reduce crime, but will also reduce the fear of crime especially for vulnerable groups such as women and the elderly.

3.1.27 A constant theme is the reconciliation of potentially competing objectives and how a balance might be achieved between them. For example, the need for security measures during certain times of day or night with the creation of an attractive and welcoming environment that creates its own level of security. Environment Strategy for Wales (2006) 11 3.1.28 The Strategy provides a framework within which to achieve an environment which is clean, healthy, biologically diverse and valued by the people of Wales. It sets out the Welsh Government's strategy until 2026, providing the context, the challenges, the Welsh Government's Vision for the environment and how change will be enabled under the following five key environmental themes: 3 . Policy Context: National, Regional & Local

Deposit Addressing climate change;

LDP Sustainable resource use; -

Environment Distinctive biodiversity, landscapes and seascapes;

Our local environment; and T

opic Environmental hazards. Paper 3.1.29 The Environment Strategy for Wales indicates that in order to deliver high quality (August places for people to live, a high quality built environment is required, with opportunities to access green space and biodiversity, where environmental nuisances are minimised and

2013) where flood risk is understood and managed.

3.1.30 New decisions, policy and programmes will need to give specific consideration to how they can deliver the outcomes in the strategy.

3.1.31 The Environment Strategy specifically considers Biodiversity and provides outcomes for 2026.

Topic Based Policy

[1] Design

Manual for Streets (2007)

3.1.32 The manual indicates that better designed streets contribute significantly to the quality of the built environment and play a key role in the creation of sustainable, inclusive, mixed communities consistent with the policy objectives of PPW.

3.1.33 It is important that designers place a high priority on meeting the needs of pedestrians, cyclists and public transport users, so that growth in these modes of travel is encouraged.

3.1.34 The way streets are laid out and how they relate to the surrounding buildings and spaces has a great impact on the aesthetic and functional success of a neighbourhood.

3.1.35 The importance of inclusivity is stressed, and the need for good design and high-quality construction, followed by good management and maintenance. 12 [2] Pollution Environment Act (1995) (as amended)

3.1.36 Part IV of the Act requires Local Authorities to review air quality in their areas and to declare air quality management areas (AQMAs) where standards or objectives are not being met. 3 . Policy Context: National, Regional & Local

Pollution Prevention and Control Act (1999) 2013) 3.1.37 The Act implements European Directive 96/61/EC concerning integrated pollution prevention and control. It sets out powers for local authorities and Natural Resources Wales (NRW) (formerly the Environment Agency) to regulate pollution (emissions and (August waste production) from installations through regulation, permitting and monitoring. Paper opic

Air Quality Strategy for England, Scotland, Wales and Northern Ireland (DEFRA T 2007)

3.1.38 The Strategy sets out air quality standards and objectives to be achieved; introduces a new policy framework for tackling fine particles; identifies potential new Environment - national policy measures to give further health benefits. LDP Environmental Noise (Wales) Regulations (2006) Deposit 3.1.39 Specific requirements for Noise Action Plans are identified in the European Noise Directive. The Swansea and Neath Port Talbot conurbation is defined as an agglomeration for the purposes of the Directive and Regulations, and Noise Action Planning Priority Areas (NAPPAs) and Urban Quiet Areas (UQAs) within the agglomeration are being defined. These will need to be taken into account in the development of LDP policies and allocations.

EU Water Framework Directive (Directive 2000/60/EC)

3.1.40 Establishes a framework for the protection of inland surface waters, transitional waters, coastal waters and groundwater, requiring the establishment and maintenance of good chemical and ecological status of water bodies.

EU Thematic Strategy for Soil Protection (COM(2006)231)

3.1.41 Emphasises the protection and sustainable use of soil, with restoration of degraded soils where possible.

Environmental Permitting (England and Wales) Regulations (2010) (as amended)

3.1.42 Puts in place a single regulatory framework, streamlining and integrating:

Waste Management Licensing;

Pollution Prevention and Control;

Water Discharge Consenting;

Groundwater Authorisation; and 13

Radioactive Substances Regulation. 3 . Policy Context: National, Regional & Local

Deposit Draft Clean Air for Port Talbot Short-term Action Plan (2012)

LDP 3.1.43 The Draft Action Plan seeks to address the measures to be taken, over and above the everyday activities, where there is a risk of Particulate Matter (PM10) limit values -

Environment being exceeded. In particular, the Draft Plan outlines the roles and responsibilities of the various organisations.

[3] Natural Heritage T opic UK Biodiversity Action Plan (UKBAP) (2004) Paper 3.1.44 The Convention on Biological Diversity of 1992, led to the UK Government’s (August publication of the UK Biodiversity Action Plan. It describes the biological resources of the UK and sets out how these resources will be protected. The objectives of the UKBAP

2013) provide the context for Local Biodiversity Action Plans (LBAPs).

Wildlife and Countryside Act (1981) (as amended)

3.1.45 Provides the main legislative framework for the protection of wildlife in the UK.

Natural Environment and Rural Communities Act (NERC) (2006)

3.1.46 Provides legislative changes to amend nature conservation legislation, and in relation to bylaws for motor vehicles (giving local authorities the power to make traffic regulation orders); SSSIs and extends the Countryside and rights of Way Act (CROW) biodiversity duty.

3.1.47 The NERC Act places a duty on every public authority, in exercising its functions, to "have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity".

3.2 Regional Policy Context

Western Wales River Basin Management Plan (2009)

3.2.1 The River Basin Management Plan addresses water quality and quantity and identifies the following expected outcomes:

Improving rural land management;

Reducing the impact of transport and built environments; 14 Securing sustainable amounts of water; Improving wildlife habitats; and

Addressing point source pollution. 3 . Policy Context: National, Regional & Local

3.2.2 The plan indicates priorities for addressing key pressures in the catchment, addressing the worst pollution problems first through local action. 2013)

Catchment Abstraction Management Strategies (August 3.2.3 The Neath Port Talbot area is covered by the 'Tawe, Loughor and Gower Catchment Abstraction Management Strategy' (Environment Agency Wales (EAW) 2007) and the Paper opic

'Neath, Afan and Ogmore Catchment Abstraction Management Strategy' (EAW Consultation T Document 2005). These indicate that there is a general shortage of water available for abstraction in the relevant catchments of the County Borough.

3.2.4 Both the Afan and Neath rivers are experiencing considerable pressures due to Environment - historic licences of key industries, while the Neath, Tennant and Swansea canals also provide water for industrial use. As a result of likely climate change, water availability LDP during summer months is likely to become more problematic and potential impacts on river and watercourse hydrology and ecology need to be considered, as well as possible Deposit shortages of supply for domestic or industrial use.

3.2.5 However, Dwr Cymru / Welsh Water's draft Water Resources Management Plan (2011) indicates that there are no anticipated problems in relation to the general domestic water supply in the 'Tywi Conjunctive Use System Water Resource Zone' and that there is adequate 'headroom' for anticipated future demand.

Shoreline Management Plan (SMP2) (2010)

3.2.6 The SMP is prepared by Natural Resources Wales (NRW) 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.

3.2.7 The SMP covers the shoreline between Lavernock Point (Vale of Glamorgan) in the east and St Ann’s Head (Pembrokeshire) in the west.

3.2.8 The area of coastline within Neath Port Talbot falls within Policy Scenario 8: Sker Point to Swansea Docks. The following policies are proposed:

For the majority of the shoreline hold the line through the maintenance and upgrading of existing defences.

Managed realignment for the sand dune systems which will allow them to continue to evolve naturally. 15 A long-term policy of hold the line is also recommended at the former BP tank farm site to the west of Crymlyn Burrows. 3 . Policy Context: National, Regional & Local

Deposit 3.3 Local Policy Context

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

Environment 3.3.1 The Community Plan identifies the following vision for Neath Port Talbot:

“We want Neath Port Talbot to be a place where local services help people look after T

opic themselves, each other and their communities; with greater opportunity for all, in a greener, healthier and safer environment". Paper

(August 3.3.2 The following environmental issues are identified:

2013) Local environmental issues are many and varied. Efforts continue to be made to meet targets for keeping streets and highways clean and for reusing or recycling municipal waste. During 2008/09, only 42% of municipal waste was sent to landfill – one of the best performances in Wales. A particular environmental concern is air pollution. During 2008, there were 34 exceedances of the short term limit for air pollution set by Government, but air quality is improving, with only 15 exceedances being recorded in 2009.

3.3.3 A number of aims, to be achieved by 2020, are identified in order to deliver the vision:

Neath Port Talbot’s carbon footprint will be significantly lower with energy being used more efficiently. Air, water and land pollution will be improved resulting in a cleaner and well maintained local environment with people and local communities taking ownership.

The biodiversity of habitats will continue to be protected and waste production will be reduced with levels of recycling increased and minimum use of landfill.

3.3.4 A number of priorities are identified in an Environment Theme to be achieved 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. 16 The public’s sense of responsibility to re-use, minimise, reduce and recycle waste is being demonstrated, with national targets being exceeded.

To help improve the health and well-being of all citizens; healthy and clean air, land and water are secured by robust environmental management systems. Also the diversity of local habitats and species is successfully managed, protected and enhanced; helping citizens enjoy wildlife and a healthy environment. 3 . Policy Context: National, Regional & Local

The quality of the built environment is improved, including its accessibility and energy

efficient street lighting is provided, which also helps people feel safer. 2013)

All citizens have safe, litter-free, accessible green spaces within walking distance (August from their homes. Paper opic

Neath Port Talbot Working in Partnership 2013 - 2023: Single Integrated Plan T

3.3.5 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 Environment - communities. The Council's vision is 'Creating a Neath Port Talbot where everyone has an equal opportunity to be healthier, happier, safer and prosperous'. LDP

3.3.6 An outcome that the SIP aims to achieve is that 'Neath Port Talbot's communities Deposit 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;

Develop sustainable transport;

Reduce waste and move towards maximising recycling; and

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

Neath Port Talbot County Borough Council Unitary Development Plan (2008)

3.3.7 Existing policies are set out in the adopted UDP. The Authority's existing strategy seeks to place sustainability at the heart of all planning decisions and to strike a balance between the need to allow and encourage economic and social developments to improve quality of life and any environmental impacts which may result from such developments.

3.3.8 The policies contained within the UDP include: 17 ENV1 - Development In The Countryside;

ENV2 - Green Wedges;

ENV3 - Impacts On The Landscape; 3 . Policy Context: National, Regional & Local

Deposit ENV4 - Proposals Affecting International And National Sites For Nature Conservation And Species Protected By European Or UK Legislation; LDP ENV5 - Nature Conservation; - Environment ENV6 - Agricultural Land;

ENV7 - New Dwellings For Agricultural And Forestry Purposes; T opic ENV8A - Replacement Dwellings In The Countryside; Paper ENV8B - Conversion Or Re-use Of Buildings In The Countryside; (August

ENV8C - Farm Diversification; 2013) ENV9 - Horse Related Proposals;

ENV10 - Coastal Protection;

ENV11 - Proposals In Areas Of Flood Risk;

ENV12 - Proposals Affecting Water Resources;

ENV13 - Brownfield, Derelict And Wasteland;

ENV14 - Unstable Land;

ENV15 - Air Quality;

ENV16 - Contaminated Land;

ENV17 - Design;

ENV18 - Listed Buildings;

ENV19 - Proposals Within Conservation Areas Or Which Would Affect The Setting Of A Listed Building;

ENV20 - Demolition Of Unlisted Buildings Within Conservation Areas;

ENV21 - The Designation Of New And Review Of Existing Conservation Areas; 18 ENV22 - Archaeological Remains; ENV23 - Archaeological Evaluation;

ENV24 - Archaeological Recording;

ENV25 - Advertisements; 3 . Policy Context: National, Regional & Local

ENV26 - External Lighting; 2013) ENV27 - Location Of Sensitive Uses;

ENV28 - Polluting Or Hazardous Installations; and (August Paper ENV29 - Environmental Quality And Amenity. opic T

Western Valleys Strategy (2006)

3.3.9 The Neath Port Talbot Western Valleys Strategy was launched in 2005 as a 10 Environment year strategy to improve the life in the Neath Port Talbot Valleys and improve the social - and economic prospects of people who live there. LDP

3.3.10 The Valleys promise for the area is: Deposit

To ensure that by 2015 the Valleys of Neath Port Talbot become stronger, more vibrant and sustainable places - with "Positive Futures".

3.3.11 Eight themes are identified including 'Enhancing the Environment.' The Strategy recognises that the environment is one of the strongest assets of Neath Port Talbot and protecting and enhancing it is an essential aspect of sustaining the Valleys as a better place to live and work. The aim is to enhance the Valley environment and to make them more widely known to visitors for recreation and enjoyment. This is to be achieved while protecting the landscape and habitats and concurrently improving the quality of the built environment and sustaining its essential character.

3.3.12 Key outcomes identified include:

Seek to enhance the built environment through the promotion of townscape schemes;

Encourage good architecture for new buildings;

Proposals for new buildings will be required to provide a design statement explaining the design proposal and how it will relate to its surrounding area of townscape and landscape;

Promote improved and accessible housing by controlling developments to avoid urban sprawl; 19 Seek external sources of funding to enhance the built environment (e.g. Commercial Improvement Grants);

Protect, as appropriate, the natural environment; 3 . Policy Context: National, Regional & Local

Deposit Maximise opportunities for recreation and enjoyment of the Valleys natural assets (e.g. Rivers / canal systems and the environment whilst protecting landscapes and

LDP habitats); -

Environment Support projects to improve and conserve habitats of importance and link green areas with the Biodiversity Plan. T

opic 3.3.13 The Strategy seeks to:

Paper Raise the architectural quality of new development by utilising planning design guidance; (August Soften existing landscapes (e.g. by tree planting, land reclamation so as to improve

2013) derelict and waste land, including contaminated brownfield land);

Encourage the re-use, redevelopment or renewal of redundant and derelict land and buildings and the removal of blights and eyesores by:

(a) Developing a Register of Derelict Properties and their Ownerships with a view to ensuring that derelict buildings receive attention; and

(b) Encouraging owners of privately owned buildings to restore or demolish derelict properties.

3.3.14 A number of further key outcomes are identified under this theme and also a specific action plan has been developed for each of the Valley areas which stipulates the outcome sought, key participants and specific actions.

Regeneration Initiatives

3.3.15 In order to help achieve the aims of the Valleys strategy and to make Neath Port Talbot a more attractive place to live, visit and invest, a number of regeneration initiatives and programmes are being implemented by the Council.

[1] Upper Neath Valley Regeneration Strategy

3.3.16 The strategy area includes the communities of Glynneath and Resolven as well as the smaller communities of Blaengwrach / Cwmgwrach, Pontwalby, Pontneddfechan, Clyne, Melincourt and Abergarwed. The strategy looks to create local employment opportunities and develop quality facilities to service the prosperity, health and wellbeing 20 of the communities. [2] Neath Town Centre Retail Led Mixed-Use Development Opportunity

3.3.17 An area in Neath Town Centre has been identified for redevelopment. The site comprises the old Civic Centre site, multi-storey car park, Magistrates Courts, Boots retail premises (with adjoining shops and car park) and additional vacant sites and car parks. 3 . Policy Context: National, Regional & Local

The uses proposed in the study include 20,522 sqm of retail floorspace; 1,329 sqm of café

/ restaurant premises; some 870 car parking spaces; a new library and museum building; 2013) a relocated shop-mobility facility and management offices and residential accommodation.

[3] Pontardawe Regeneration Strategy (August

3.3.18 The strategy reviews the townscape of central Pontardawe, identifying significant Paper opic buildings and character features and challenges. It identifies a number of objectives for T the town including developing vacant, underused or unattractive sites and sets out a masterplan which suggests some public realm improvements and identifies scope for development or redevelopment on small sites in the town centre. Environment - 3.3.19 Highway and traffic management improvements are identified to give a greater emphasis on cyclists and pedestrians and efficient traffic movement with improved LDP pedestrian links. Key projects include improvements to Herbert Street and Square, improvements to the by-pass and road bridge / underpass and redevelopments at Works Deposit Lane / Paradise Club and the old Brewery.

[4] Waterfront Strategy

3.3.20 The Waterfront Strategy covers the coastal corridor of Neath Port Talbot from Margam in the east to the borders of Swansea to the west and includes the town of Port Talbot as well as a number of smaller urban settlements.

3.3.21 The following major development sites are identified in the strategy area which will play a central role in shaping the future prosperity of the area:

Baglan Bay / Baglan Energy Park;

Coed Darcy;

Harbourside (Port Talbot);

Green Park, Gas Works, Port Talbot Industrial Estate;

Fabian Way;

Junction 38 (M4); and

Neath Estuary – Neath Abbey Wharf.

3.3.22 The strategy identifies the following tourism / leisure sites which have potential 21 to contribute to the growth and diversity of the local economy:

Margam Park;

Aberafan Seafront; and

Brunel Dock. 3 . Policy Context: National, Regional & Local

Deposit 3.3.23 The following strategic goals are identified:

LDP Strategic Goal 1 - to develop the town of Port Talbot as a hub for commercial, residential, social and employment activities through an integrated physical -

Environment regeneration of the town centre and the attraction of new investment.

Strategic Goal 2 - to bring forward the development of major strategic regeneration sites in the area of Port Talbot that will attract major new investment, create T

opic employment opportunities and spread prosperity to surrounding communities.

Paper Strategic Goal 3 - to develop existing and establish major new employment sites within the area of Port Talbot that meet the needs of modern business, strengthen (August the local economy and ensure the provision of employment opportunities.

2013) Strategic Goal 4 - to develop high quality sites for tourism and leisure that will attract visitors and new investment and improve the image and environment of Port Talbot Waterfront.

Strategic Goal 5 - to improve the physical fabric within the urban areas, improving quality of life and making the area of Port Talbot an attractive place in which to live, work and invest.

Strategic Goal 6 - to improve the transport and communications infrastructure, ensuring that the area of Port Talbot maximises its locational advantages and brings benefits to the economy and people of the area.

Topic Based Policy

[1] Natural Heritage

Local Biodiversity Action Plan (2008)

3.3.24 The Local Biodiversity Action Plan (LBAP) was produced on behalf of the Neath Port Talbot Biodiversity Forum and published in 2008. The LBAP lists action plans for a number of species and habitats of national and/or local priority in Neath Port Talbot and sets out the targets for conservation action over a five year period.

3.3.25 The overall aims of the LBAP are :

To increase awareness of the importance of our local wildlife;

22 To educate people about the importance of particular habitats in order to conserve the flora and fauna they support;

To encourage local people to get involved in protecting and enjoying their local biodiversity;

To increase and share the knowledge held about particular species and sites; 3 . Policy Context: National, Regional & Local

To influence man's activities to be more sensitive to local biodiversity needs; 2013) To enhance and protect existing habitats, to restore former habitat and actively create new ones; and (August

To halt the loss of biodiversity in Neath Port Talbot, in line with the national target to Paper halt biodiversity loss by 2010. opic T

[2] Pollution

Neath Port Talbot Contaminated Land Strategy (2005) Environment -

3.3.26 Sets out the Council’s approach to inspecting the area, locating and ensuring LDP the remediation of all statutory designated contaminated land under the requirements of the Environmental Protection Act 1990 (as amended). Deposit

Air Quality Management Area

3.3.27 An Air Quality Management Area (AQMA) was declared in the Margam / Taibach area in 2000 due to exceedances in PM10s breaching the national air quality objective.

3.3.28 A number of local hotspots relating to congestion have been identified and are being addressed through traffic and environmental health management.

Neath Port Talbot Local Air Quality Strategy “Air Wise – the Way Forward to Cleaner Air”(2006)

3.3.29 The main objectives of the strategy are:

To reduce air pollution below the seven National Objective Levels (for particles (PM10), nitrogen dioxide, sulphur dioxide, carbon monoxide, lead, benzene and 1,3 butadiene);

To improve air quality throughout the County Borough;

To reduce air pollution PM10 (dust particles) levels within the Margam / Taibach Air Quality Management Area (AQMA);

To reduce air pollution and monitor air quality levels across the County Borough and provide assurance that national agreed target levels of pollution are not breached.

23 3 . Policy Context: National, Regional & Local Deposit LDP - Environment T opic Paper (August 2013)

24 4 . Current Situation and Trends

4 Current Situation and Trends 2013) 4.0.1 This section of the paper considers the current situation and trends in relation to

the following: (August

Built Environment and Historic Heritage; Paper opic Countryside and the Coast; T

Biodiversity and Geodiversity; and Environment

Environmental Protection. - LDP 4.1 Built Environment and Historic Heritage Deposit 4.1.1 The built environment and urban form of Neath Port Talbot is distinctive. The County Borough contains the three main towns of Neath, Port Talbot and Pontardawe and five Valleys (the Afan, Amman, Dulais, Neath and Swansea Valley). The area has a rich heritage with many of the communities being built around the coal mines as people migrated to the area for employment. In recent years, mining and industrial decline has removed some of the original reasons for the historic pattern of towns and villages, especially in the valleys. Furthermore, the roles and functions of urban centres have changed through the development of out of town facilities and increased mobility as people travel further afield to access facilities and services or use the Internet; this has led to decline in some cases. A consequence is the loss of a range of iconic buildings that played important roles functionally, as well as visually. They range from public buildings to shops, chapels and churches.

4.1.2 Over recent years the County Borough has attracted a new range of industry and employment opportunities including tourism and service industries, leading to new patterns of development such as industrial estates and business parks, especially along the coastal corridor. The natural environment also remains an important source of employment with minerals and renewable energy developments such as wind farms introducing new types of built environment altering the landscape.

Historic Heritage

4.1.3 Neath Port Talbot has a significant built heritage resource in terms of conservation areas, listed buildings, scheduled ancient monuments and archaeologically sensitive areas that, together with their settings, require protection.

4.1.4 There are two designated Landscapes of Outstanding Historic Interest: 25 4 . Current Situation and Trends

Deposit Merthyr Mawr, Kenfig and Margam Burrows - areas of littoral, wind-blown sand dunes containing buried remains of great archaeological potential from the prehistoric, Roman

LDP and medieval periods; and -

Environment Margam Mountain - an area of upland displaying continuity, density and diversity of human occupation from the prehistoric period to the recent past(7). T

opic 4.1.5 There are six Historic Parks and Gardens:

Paper Jersey Park (Briton Ferry);

(August Margam Park (Margam);

2013) The Gnoll (Neath);

Victoria Gardens (Neath);

Talbot Memorial Park (Port Talbot); and

Rheola (Neath Valley).

4.1.6 There are six Conservation Areas:

Glynneath Woollen Mill;

Margam Park;

Neath Town Centre;

Tonna Canal Depot;

Llandarcy; and

Cilybebyll.

4.1.7 There are 92 Ancient Monuments the majority of which are prehistoric features including forts, cairns and standing stones, with significant numbers of Roman features and industrial remains. 26

7 The Glamorgan Gwent Archaeological Trust have produced information on the Historic Landscape Character areas. Further information on their unique characteristics and a map showing their location can be found on their website http://www.ggat.org.uk/cadw/historic_landscape/kenfig/english/merthyr_mawr_001.Html and http://www.ggat.org.uk/cadw/historic_landscape/margam/english/mynydd_margam_summary.html 4 . Current Situation and Trends

4.1.8 There are 391 Listed Buildings in the County Borough, seven of which are Grade

1, 36 Grade 2* with the remainder Grade 2. Listed buildings tend to be concentrated in 2013) the town centres and valley settlements, together with Margam Park. A register of listed buildings at risk is maintained, which indicates that more than 45 buildings are at serious (August risk, with a further 90 identified as needing close monitoring. Paper Map 4.1 Historic Designations in Neath Port Talbot opic T Environment - LDP Deposit

27 4 . Current Situation and Trends

Deposit 4.1.9 In addition to the designated areas of historic importance in Neath Port Talbot there are other areas of local importance; many communities in Neath Port Talbot have

LDP distinct identities and a rich cultural heritage. -

Environment 4.1.10 There are, however, a number of derelict buildings in the County Borough which are falling into disrepair. This is having a negative impact on the built environment and there is widespread support for these to be brought back into use as they form an important part of the area's heritage and history. T opic 4.1.11 The Canal network in particular is an important part of the County Borough's Paper historic heritage. There are three canals within Neath Port Talbot, the Neath, Tenant and Swansea Canals, and significant lengths of these have now been restored to a navigable (August standard. The canal system forms part of a network of green corridors which encourages walking and cycling and attracts visitors to the area. However, there are gaps in the network 2013) where the line of the canals have been lost, or navigation is prevented by obstructions such as low bridges.

4.1.12 Swansea Canal:

Canal filled in between Trebanos and Pontardawe;

Two low bridges in Pontardawe and Ynysmeudwy; and

Canal lost to new road between Godre'r Graig and Ystalyfera.

4.1.13 Tennant Canal:

The Aberdulais aqueduct has been de-watered and would require substantial remedial works before navigation could be restored.

4.1.14 Neath Canal:

Two low bridges in the Neath Town Centre area;

Missing section of canal above Ynysarwed;

Culvert at Resolven;

Culvert at Ysgwrfa Bridge below Glynneath; 28 Above the Lamb and Flag, Glynneath the canal effectively no longer exists although legal rights of navigation are understood to remain; and

Two low bridges at Giants Grave. 4 . Current Situation and Trends

4.1.15 The County Borough has traditionally attracted heavy industry, particularly along the M4 corridor. With the decline of mining and traditional industries large areas of land, 2013) along the coastal belt in particular, are now derelict and are currently being prepared for redevelopment. Of particular note is the building of Harbour Way which will provide a new (August access road into the Port Talbot Harbourside area, opening up areas of land for

redevelopment and providing a new 'gateway' into the town. Paper opic Design Issues T

4.1.16 Buildings are a major contributor to greenhouse gas emissions through both their construction and occupation. The Welsh Government (WG) has recognised this and has Environment

implemented stricter building standards with the aim of moving towards zero carbon - developments. There are a range of criteria which new developments have to meet and this is regulated by Building Control. LDP

4.1.17 Small-scale renewable energy schemes are likely to become increasingly common Deposit on both residential and commercial buildings and opportunities for utilisation of waste heat from commercial operations through the development of district heat networks are likely to be explored. In order to enable the use of these technologies the urban form will have to enable developments to be linked and appropriate infrastructure to be provided. These matters are considered further in the Renewable & Low Carbon Energy Topic Paper(8).

4.1.18 The urban form and design of developments also affects the ability of people to access facilities and services. With increased mobility, many are reliant on the private car and can travel further afield. This however contributes to greenhouse gas emissions and increased emphasis is being put on encouraging active, more sustainable modes of transport such as walking and cycling. For example, 'Manual for Streets' requires new developments to be designed to allow for permeability and easy access to facilities and services by non-car modes.

4.1.19 Most planning applications are required to be accompanied by a design and access statement explaining how the objectives of good design (including inclusive design principles) have been considered.

Design and Community Safety

4.1.20 The design and layout of new development can have a significant effect on public safety and the fear of crime. The following data relates to 'crime and the fear of crime' and is based on the year January 2009 to December 2009 - the base line is 2008 unless otherwise stated(9): Overall crime reduced by 17% across the County Borough; 29 Serious acquisitive crime reduced by 29%;

Assaults with less serious injury reduced by 9.5%;

8 Deposit Renewable & Low Carbon Energy Topic Paper (August 2013). 9 Safer Neath Port Talbot Partnership Community Safety Partnership Plan 2010-2013. 4 . Current Situation and Trends

Deposit Burglary of dwelling reduced by 50%;

LDP Criminal damage reduced by 26%; -

Environment Burglary from other premises reduced by 24%;

Theft from vehicles reduced by 26%; and T

opic Theft of motor vehicle reduced by 35%. Paper 4.1.21 But there are increases: (August Most serious violence increased by 42%; and 2013) Violence against the person (from minor assault to serious crime) is another high volume crime.

4.1.22 The information suggests that there is a link to the late night economy and this trend is increasing. However, overall public perception of feeling safe within their neighbourhood remains high at a level in excess of 81% and public perception of the levels of crime reduced by 17.5%.

4.1.23 The map below illustrates the risk of all recorded crime across the County Borough between March 2010 and April 2011 shown as a risk per 1000 population. Aberavon, Port Talbot, Neath North and Gwynfi wards are identified as those with the highest risk.

30 4 . Current Situation and Trends

Map 4.2 All Recorded Crime in Neath Port Talbot (March 2010 - April 2011) 2013) (August Paper opic T Environment - LDP Deposit

Source: South Wales Police

4.1.24 Local authorities (including National Park Authorities) are required to have due regard to crime and disorder prevention in the exercise of their functions under Section 17 of the Crime and Disorder Act 1998. There are a number of practical ways in which the design of development can reduce opportunities for crime, disorder and anti-social behaviour.

4.1.25 The following matters can be considered at the outset of the design process:

A layout which incorporates clear, direct routes which are desirable and hence likely to be well used;

Orientation of buildings, particularly housing, to allow natural surveillance. Careful design solutions will be needed to allow unobstructed views of neighbouring properties without compromising the need for privacy. Natural surveillance is particularly important in vulnerable areas such as communal space, play areas and parking spaces; 31 Design features which help to define clearly public and private areas. Design solutions are needed which avoid creating a 'fortress mentality'. For instance through the use of symbolic barriers such as a change of surface treatment or narrowing which help to define defensible space; 4 . Current Situation and Trends

Deposit Use of plant species to deter access, where appropriate, and careful selection and location of plant species in order to minimise opportunity for unobserved crime; and LDP Provision of adequate street lighting. - Environment

Gateways

T 4.1.26 Arterial Gateways are areas adjacent to the County Borough boundary which opic are prominent when entering or leaving Neath Port Talbot and help to define the character Paper and image of the area. There are concerns that developments have taken place in the past within these gateway areas that have detrimentally affected the appearance of the (August locality and consequently the first impressions given to visitors and the overall image of the County Borough. 2013) 4.1.27 The main routes into the County Borough are considered to be along the M4 and mainline railway at Margam in the southeast and Lonlas in the North west, along the A483 Fabian Way from Swansea and the A465 Heads of the Valleys trunk road in the Glynneath area. Other less major routes include the A474 and A4069 into the Amman Valley, the A4067 into the Swansea Valley, the A4107 into the Afan Valley and routes from Maesteg.

4.1.28 The most important route for traffic entering and leaving Neath Port Talbot is along the M4 corridor and rail route. However, the Lonlas area is partly built up with no clearly distinctive features or landscapes visible from either the motorway or main railway line. The Margam area is considered to be more significant as a 'gateway' , while Fabian Way serves as a main route into Swansea as well as from Swansea into Neath Port Talbot and has the potential for significant new developments in the industrial areas and in the vicinity of the University campus.

4.2 Countryside and the Coast

Landscape

4.2.1 The landscape in the County is varied and provides not only an important habitat for fauna and flora but is also important for leisure and activity for residents and visitors and has its own intrinsic beauty. Reflecting the County Borough's potential for large scale resource development in the countryside (i.e. mineral and wind farm), there is pressure for development that would impact upon these landscapes.

4.2.2 The Countryside Council for Wales' LANDMAP assessments confirm that Neath Port Talbot contains significant areas of landscape that are of local if not regional importance (LANDMAP information is available on the LDP website). The County Borough 32 also contains significant areas that are of national significance for their potential for mineral and wind resource. As a result much of the landscape faces pressure from large and intrusive development. Although significant efforts are made to restore workings and sites, it may not be possible to recreate distinctive features or character of the original landscape.

4.2.3 The current adopted Unitary Development Plan (UDP) designates the following five Green Wedges: 4 . Current Situation and Trends

Alltwen / Rhos / Bryncoch / Neath Abbey / Leiros Park; 2013) Skewen / Birchgrove;

Neath / Tonna / Cimla / Efail Fach; (August Paper Crymlyn Bog / Crymlyn Burrows / Llandarcy; and opic T Margam.

4.2.4 These areas are identified as being of particular importance firstly in providing a Environment backdrop to the main towns and secondly preventing the coalescence of settlements. -

Although they may not necessarily be particularly attractive scenically, they contribute LDP strongly to the quality of life in our communities. They face continual pressure from

development, and the range of community uses that need to be located in the countryside, Deposit all of which have the potential to harm the character of these areas.

The Coast

4.2.5 Large parts of the coastal belt of Neath and in particular Port Talbot are low lying former sand dunes, saltmarsh and moorland. The County Borough's coastline encompasses a broad range of different character types, from developed and entirely man-made stretches to natural areas of beach and sand dunes. The main coastal features and uses are categorised below.

[1] Natural Habitats

There are extensive natural areas along the County Borough's coastline, starting at the north western end with the Crymlyn Burrows SSSI, one of the last remaining sections of the Swansea Bay Coastline which has remained substantially unmodified by industrial development. The area comprises parallel sand dune ridges developed at right angles to the River Neath, which are continuing to accumulate and are interspersed by tongues of saltmarsh. Behind these are wet dune slacks and carr woodland.

The lower reaches of the River Neath and the Neath Estuary include significant areas of saltmarsh habitats.

Further areas of natural dunes exist at Whitford Point / Baglan Bay. Most of the land behind these dunes has previously been developed for industrial purposes, some of which has been redeveloped for business uses. 33 4 . Current Situation and Trends

Deposit To the south of the steelworks, there are further areas of dunes, backed by Margam Moors SSSI which is identified as the last remaining example of the once extensive

LDP coastal levels in West Glamorgan. -

Environment At the southern boundary of the County Borough, the dunes adjoin Kenfig Burrows, part of the extensive Kenfig SAC, NNR and SSSI. Nearly all of the designated area lies outside the boundaries of Neath Port Talbot. T opic [2] Recreation and Tourism Paper Aberafan Seafront - the seafront is a popular visitor attraction with an extensive sandy (August beach with promenade backed by gardens and visitor facilities. Significant improvements have been made over the last decade, with further developments

2013) planned including the replacement for the Afan Lido.

Leisure Boating - there is a small yacht marina at Earlswood on the western side of the River Neath, with some leisure / fishing boats based on the River Afan adjacent to Port Talbot docks.

Coastal Path - the new Wales coastal path encourages leisure access by bicycle, horse riding and walking.

[3] Port Facilities

The docks at Port Talbot provide for both general cargo and deep water facilities for bulk cargo.

There are wharfs on the River Neath at Neath Abbey, Giants Grave and Briton Ferry which handle sand and gravel and scrap materials.

[4] Industry and Employment

There are significant industrial and employment uses within the coastal zone, including employment uses at Fabian Way, Baglan Bay and around the wharfs and docks.

The Tata steelworks is one of the County Borough's major employers, located on the coast south of Port Talbot.

34 [5] Residential Extensive areas of existing housing and associated development are located within the coastal zone on relatively low lying land, including the Sandfields and Aberafan. 4 . Current Situation and Trends

4.2.6 It can be seen from the above that significant areas of the County Borough's industrial and residential development are located in the coastal zone, much of which is 2013) low lying, and parts of which may become increasingly vulnerable to flooding as a result of increasing sea levels and stormy weather associated with climate change. The important (August coastal biodiversity resources associated with the beaches and sand dunes are similarly

vulnerable to climate change impacts. Paper opic 4.3 Biodiversity and Geodiversity T

4.3.1 The County Borough has a range of distinctive habitats from the coastal salt marshes and sand dunes to ancient woodland and areas of purple moor grass in upland Environment

areas. Areas of importance are designated and protected under international conventions - (including European Directives), national legislation or are the subject of local designations, depending on their significance. LDP

European Sites Deposit

4.3.2 'European Sites' include all nature conservation sites designated as Special Protection Areas (SPAs), Special Areas of Conservation (SACs) and European Off-Shore Marine Sites (EOMS), as well as Ramsar sites. There are three SACs partly within Neath Port Talbot with others further afield that could be affected by proposals in the LDP.

35 4 . Current Situation and Trends

Deposit Map 4.3 Special Areas of Conservation (SACs) In and Around Neath Port Talbot LDP - Environment T opic Paper (August 2013)

36 4 . Current Situation and Trends

Table 4.1 : European Sites Within 5km of Neath Port Talbot 2013) Name of Site Location Reason for Designation

Crymlyn Bog SAC Straddles the boundary between Primary Habitats: (August and Ramsar Site Neath Port Talbot and Swansea

1. Transition mires and quaking bogs; Paper opic

2. Calcareous fens with Cladium mariscus and species T of the Caricion davallianae

Qualifying Habitats: Environment

1. Alluvial forests with Alnus glutinosa and Fraxinus - excelsior (Alno-Padion, Alnion incanae, Salicion albae) LDP

Coedydd Nedd a Straddles the boundary between Primary Habitats: Mellte SAC Neath Port Talbot and Brecon Deposit Beacons National Park 1. Old sessile oak woods with Ilex and Blechnum

Qualifying Habitats:

1. Tilio-Acerion forests of slopes, screes and ravines

Kenfig SAC Straddles the boundary between Primary Habitats: Neath Port Talbot and Bridgend County Borough Council 1. Fixed dunes with herbaceous vegetation (‘grey dunes’)

2. Dunes with Salix repens ssp. Argenta (Salicion arenariae)

3. Humid dune slacks

4. Hard oligo-mesotrophic waters with benthic vegetation of Chara spp

Qualifying Habitats:

1. Atlantic salt meadows (Glauco-Puccinellietalia maritimae)

Primary Species: 1. Petalwort Petalophyllum ralfsii 37 2. Fen orchid Liparis loeselii

Blaen Cynon, Rhonda Cynon Taf County Primary Species: Hirwaun, SAC Borough Council 3.7km from Neath Port Talbot boundary 1. Marsh Fritillary butterfly Euphydryas (Eurodryas, Hypodryas) aurinia 4 . Current Situation and Trends Deposit Name of Site Location Reason for Designation

Cefn Cribwr Bridgend County Borough Primary Habitats: LDP Grasslands SAC Council

- 0.32km from Neath Port Talbot 1. Molinia meadows on calcareous, peaty or Environment boundary clayey-silt-laden soils (Molinion caeruleae)

Qualifying Species: T opic 1. Marsh fritillary butterfly Eurodryas, Hypodryas)

Paper aurinia (August 4.3.3 As required by the Habitats Regulations, the LDP has been the subject of a Habitats (10)

2013) Regulations Appraisal (HRA) in relation to its likely effects on these sites. It is a requirement that these sites are afforded the highest level of protection.

National Sites

4.3.4 There are twenty designated Sites of Special Scientific Interest (SSSI) within the County Borough. Four of these have been designated partly or wholly for geological reasons, the remainder being for biodiversity interest. The geographical location of the SSSIs are illustrated below.

38

10 Habitats Regulations Appraisal (August 2013). 4 . Current Situation and Trends

Picture 4.1 SSSIs, NNRs and LNRs in Neath Port Talbot 2013) (August Paper opic T Environment - LDP Deposit

39 4 . Current Situation and Trends

Deposit 4.3.5 Legislation(11) requires all public bodies to take reasonable steps to further the conservation and enhancement of the features for which a site is of special interest.

LDP National policy requires authorities to ensure that adverse effects are avoided or minimised and positive steps are taken wherever possible to enhance the special interest features - Environment of a SSSI.

4.3.6 In addition, two of the sites are designated as National Nature Reserves (NNRs), namely Crymlyn Bog and Kenfig. T opic Regional and Local Sites Paper

4.3.7 Such sites can include Regionally Important Geological Sites (RIGS), Local Nature (August Reserves (LNRs) and Sites of Interest for Nature Conservation (SINCs)(12). These sites are identified at the local level following agreed criteria, and protection can be provided 2013) by policies in the LDP.

[1] Regionally Important Geodiversity Sites (RIGS)

4.3.8 RIGS are the most important places for Earth Science conservation outside statutorily protected sites such as SSSIs. They form a network of geological sites that are considered worthy of protection within the County Borough and wider region. A study was undertaken in 2000 by Cardiff University(13)which identified a number of sites of interest. Five of the more significant sites are now incorporated within geological SSSI designations, but no RIGS designations resulted from this study.

4.3.9 More recently, the South Wales RIGS Audit(14)has looked at geologically significant sites across the region. As a result of this exercise, two RIGS have been identified, at Aberdulais Falls and Melincourt Brook.

[2] Local Nature Reserves (LNRs)

4.3.10 Three LNRs have been designated, Eaglesbush Valley, Pant Y Sais Fen and Swansea Canal. These are shown on Picture 4.1 above, together with the LNR at Kenfig which is immediately adjacent to the County Borough boundary.

Protected and Priority Habitats & Species

4.3.11 Particular species of flora and fauna are protected under European and National legislation and the presence of a protected species is a material planning consideration. In addition, the Welsh Government has identified habitats and species of principal importance for the purposes of conserving biological diversity. Further information on these 40 habitats and species is available in TAN 5.

11 Section 28G(2) Wildlife and Countryside Act, inserted by the Countryside and Rights of Way Act 2000 12 There are currently no Sites of Interest for Nature Conservation (SINCs) designated in the County Borough. 13 Geological Site Survey Database of the Neath Port Talbot County Borough Council (V A Ratter et al Cardiff University 2000). 14 South Wales RIGS Audit; R. Kendall and A. Humpage; British Geological Survey 2012. 4 . Current Situation and Trends

4.3.12 The UK Biodiversity Action Plan lists priority habitats and species at a national level, while the Local Biodiversity Action Plan (LBAP) lists habitats and species that are 2013) a priority or are of local concern. The Neath Port Talbot LBAP identifies 62 priority species / species of local concern, and the following priority habitats / habitats of local concern: (August

Wetlands - ponds and lakes; canals; rivers and streams; fens and reedbeds; Paper opic

Grasslands - lowland hay meadow and old pasture; purple moor grass and rush T pasture; lowland dry acid grassland; roadside verges;

Heathland and Bog - heathland; lowland raised bog and blanket bog; Environment - Woodland - native woodlands and parkland; hedges and other boundary features; LDP Coastal Habitats - sand dunes; coastal floodplain grazing marsh and saltmarsh; and Deposit Previously developed land of biodiversity interest; coastal vegetated shingle.

4.3.13 Protected and priority habitats and species can be a material consideration to be taken into account in the preparation of the LDP.

Trends

[1] European Sites

4.3.14 Detailed information on the current status and trends for the internationally designated sites is given in the Habitats Regulations Appraisal (HRA). The following main issues are identified in relation to the three Special Areas of Conservation that are partly within Neath Port Talbot:

Crymlyn Bog - water quality, water levels / quantity, atmospheric pollution, alien plant species and urban pressure;

Coedydd Nedd a Mellte - access and visitor management; air quality;

Kenfig - hydrology and water levels; air quality; recreational and visitor pressure; introduced alien / exotic species; coastal processes.

4.3.15 The effects that the proposals of the LDP are likely to have on all relevant internationally designated sites are considered in detail in the HRA. 41 4 . Current Situation and Trends

Deposit [2] National Sites

LDP 4.3.16 In relation to the current condition of SSSIs, a first 'Rapid Review' exercise was carried out in 2003 by the Countryside Council for Wales (CCW)(15), and updated and -

Environment extended in 2006. This data is being used to make an interpretation of the condition of each SSSI, but the information has not been published to date.

4.3.17 In relation to NNRs, a Wales-wide assessment of the status of NNR ecological T

opic features was undertaken in 2007, but again information has not been published to date.

Paper [3] Local Sites

(August 4.3.18 Monitoring the effects of development on wildlife indicates a variable but continuing loss of priority habitats in recent years (See pictures 4.2 and 4.3). 2013) Picture 4.2 LBAP Habitat Area lost (2003-2011)

Figure 1. LBAP HABITAT AREA LOST 2003-2011

20 18 16 14 12 HABITAT 10 LOST (HA) 8 6 4 2 0 2003 2004 2005- 2006- 2007- 2008- 2009- 2010- 2006 2007 2008 2009 2010 2011 YEAR

42

15 CCW is now part of Natural Resources Wales (NRW). 4 . Current Situation and Trends

Picture 4.3 Linear Habitat Lost (2003-2011) 2013) (August

Figure 2. LINEAR HABITAT LOST 2003-2011 Paper opic

500 T 450 400 Environment

350 - 300 LINEAR LDP HABITAT250

LOSS (M)200 Deposit 150 100 50 0 2003 2004 2005- 2006- 2007- 2008- 2009- 2010- 2006 2007 2008 2009 2010 2011 YEAR

4.4 Environmental Protection

Soils

4.4.1 Soils are essential for plant growth, the support of habitats and the provision of environmental services, in particular clean water and the storage of carbon. They are also a source of minerals and are integral to the landscape.

4.4.2 Good quality soils for agricultural purposes are largely concentrated in the south and east of the County Borough area and in particular the Margam area where there are well-drained loamy soils. Soils in the upland areas are agriculturally poor, however poorer quality soils can often be important in supporting valuable habitats.

Land Contamination 43

4.4.3 There are significant areas of ‘brownfield’ land within Neath Port Talbot due to the industrial history of the area. Many of these areas are sites of former coal, oil, petrochemical and metal manufacturing which are very often contaminated and can require extensive remediation before redevelopment. Over recent years a number of these sites have been 4 . Current Situation and Trends

Deposit prepared for redevelopment for example the old BP works at Coed Darcy and Baglan Bay. On most sites, remediation is often only achieved as part of the redevelopment of the site,

LDP but adds significantly to development costs and hence affects the viability of the site. - Environment Air Quality

4.4.4 National air quality objectives are set for a range of pollutants(16) and Neath Port Talbot’s air quality is measured against these objectives at a number of sites across the

T (17) opic County Borough. The following results have been recorded for 2011 :

Paper Table 4.2 Neath Port Talbot Air Quality Results (2011) (August Pollutant Monitoring Site

2013) PM10 Port Talbot Fire Station (official site for assessing compliance)

The National Air Quality Objective level was Monitoring is also conducted at : Little Warren, Port breached on 29 days during 2011, but there has Talbot Docks, Talbot Road, Theodore Road, Twll been no breach of the Air Quality Objective since yn y Wal Park and Dyffryn School. The 2007. The trend shows that exceedances are Environment Agency also monitors at Prince Street decreasing. on a temporary basis.

Nitrogen Dioxide Port Talbot Fire Station and other sites

Levels of nitrogen dioxide did not breach the Monitoring was conducted for a full year at 32 Objective level at most locations, but there were locations around the County Borough. possible exceptions at Victoria Gardens in Neath and near to Pontardawe Post Office. Continuous analysers are to be deployed at these locations in order that detailed assessments of air quality may be conducted.

Sulphur Dioxide Port Talbot Fire Station

None of the National Air Quality Objective levels were exceeded during 2011.

Carbon Monoxide Port Talbot Fire Station

No exceedances

Ozone Port Talbot Fire Station

There were exceedances of the air quality standard on 18 days during 2011. 44 4.4.5 The exceedances in PM10s in the Margam / Taibach area led to the declaration of an Air Quality Management Area (AQMA) in 2000.

16 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland (DEFRA 2007) 17 NPT Local Air Quality Strategy ('Airwise') (2006) 4 . Current Situation and Trends

Picture 4.4 Margam / Taibach Air Quality Management Area 2013) (August Paper opic T Environment - LDP Deposit

(18) 4.4.6 Monitored levels of PM10s are illustrated below .

45

18 NPT Local Air Quality Strategy ('Airwise') (2006): 4 . Current Situation and Trends

Deposit Picture 4.5 Monitored Levels of PM10s LDP - Environment 70

60 T opic

Paper 50

(August 40 35 30 2013) No Exceedances No 20

10

0 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

4.4.7 The relationship between communities and air quality issues is illustrated in Picture 4.6 'Welsh Index Multiple Deprivation - Air Emissions Index (2011)'. This latest information shows a marked improvement from the position in 2008 as there are no red (most deprived) or orange areas across the County Borough.

46 4 . Current Situation and Trends

Picture 4.6 Welsh Index Multiple Deprivation - Air Emissions Index (2011) 2013) (August Paper opic T Environment - LDP Deposit

Nickel

4.4.8 Historically, levels of nickel in air have been high. The European Union has set a target air quality standard of 20 ng/m3 for nickel concentrations in the air which has to be met by the end of 2012. Nickel levels in parts of Pontardawe do not currently comply with this target, but work by Natural Resources Wales (NRW) has reduced contributions from one local source to below the target limit, while additional work is required at another source to ensure improvements are made at this site also.

4.4.9 Two new nickel air monitoring sites have been proposed in Pontardawe which will form part of the UK metals monitoring sites. Initial results show that the levels of nickel are above the target value and a local company is investing in improved filtration and dust controls to reduce the releases of nickel from their site. Public Health Wales and the Health Protection Agency have advised that the nickel levels measured in the Tawe Valley are unlikely to have any long term adverse public health implications. 47 Habitats

4.4.10 Air pollution can also have impacts on sensitive habitats, for example nitrogen enrichment and acid deposition is a significant issue on a number of sites within and outside Neath Port Talbot, including Crymlyn Bog SAC. This issue is addressed in detail in the Habitats Regulations Appraisal. 4 . Current Situation and Trends

Deposit Water

LDP [1] Water Quality -

Environment 4.4.11 The Western Wales River Basin Management Plan (RBMP) is a statutory plan prepared by the Environment Agency which delivers the requirements of the Water Framework Directive. The RBMP adopts the principles of sustainable water management and identifies the current status of waters and proposes a programme of actions to protect T

opic and improve the aquatic environment over the current plan period (2009 – 2015). Public authorities are legally required to have regard to RBMPs when exercising their functions. Paper

4.4.12 Chemical and biological water quality in Neath Port Talbot’s rivers has fluctuated (August in recent years with no clear overall improvement or deterioration trends. The ecological quality of rivers in the Ogmore to Tawe catchment (which covers nearly all of Neath Port 2013) Talbot) is shown below. The plan shows the current ecological status, together with ecological potential for heavily modified water bodies (HMWB) and artificial water bodies (AWB).

Map 4.4 Current Ecological Status / Potential of Surface Waters in the Ogmore to Tawe Catchment

48

4.4.13 Ecological classification comprises:

The condition of biological elements (e.g. fish);

Concentrations of supporting physico-chemical elements (e.g. the oxygen or ammonia levels); 4 . Current Situation and Trends

Concentrations of specific pollutants (e.g. copper); 2013) High status, largely undisturbed hydromporphology. (August 4.4.14 The RBMP indicates that key pressures in the catchment will be addressed through local actions and that those waters in the worst state will be prioritised. The plan Paper opic

identifies the following objectives: T

Table 4.3 : Water Quality of Surface Waters in the Ogmore Tawe Catchment

River and Lake Water Bodies Now 2015 Environment -

% at good ecological status or potential 37 49 LDP

% assessed at good or high biological status (52 water bodies 40 57 assessed) Deposit

% assessed at good chemical status (12 water bodies 75 75 assessed)

% at good status overall (chemical and ecological) 34 46

% improving for one or more elements in rivers 21

[2] Water Availability

Although Neath Port Talbot is located in an area with copious rainfall, NRW has identified a concern over the abstraction of water from rivers and watercourses. There is limited potential to abstract further amounts and this is likely to be exacerbated as Climate Change brings stormier winters but also increased dry periods in the summer.

In relation to the public water supply, the majority of the County Borough is supplied from the Tywi Conjunctive Use System (abstracted from the River Tywi north east of Carmarthen). Dwr Cymru / Welsh Water's draft 'Water Resources Management Plan' indicates that there are no anticipated problems in this water resource zone and there is adequate 'headroom' to allow for water supply to anticipated future development.

Noise

4.4.15 The Welsh Government is the ‘competent authority’ implementing the European Noise Directive in accordance with the Environmental Noise (Wales) Regulations. Four Environmental Noise Action Plans have been published - a Roads Action Plan, a Railways Action Plan, a Cardiff & Vale of Glamorgan Agglomeration Action Plan and a Swansea & 49 Neath Port Talbot Agglomeration Action Plan.

[1] Quiet Areas

4.4.16 Quiet areas are defined as public open spaces within each agglomeration which: 4 . Current Situation and Trends

Deposit Are considered by the relevant local authorities to have local amenity value that warrants protection from noise intrusion; LDP Are considered by the Welsh Ministers to be relatively quiet by urban standards, both -

Environment in actual and perceived terms, according to strategic noise maps and the qualitative descriptions provided by local authorities; and

(recommended but not mandatory for designation purposes) Do not suffer from poor T

opic performance in terms of certain other criteria such as perceived safety and disabled access, which, while not directly related to quiet, nonetheless compromise the health Paper and wellbeing benefits that would otherwise be conferred by quiet. (August

4.4.17 Five ‘pillars’ of urban tranquillity, or criteria, have been identified. Soundscape,

2013) presence of nature and visual / aesthetic qualities are criteria directly related to perceived quiet, while a sense of personal safety and the culture and freedom of the place are criteria which are not directly related to perceived quiet but which may nonetheless detract from the health and wellbeing benefits otherwise conferred by quiet.

4.4.18 Ten Quiet Areas have been designated by the Welsh Government in consultation with the Council. PPW requires development plan policies to have regard to the need to protect Quiet Areas from increases in noise and requires special consideration where noise-generating development is proposed nearby.

[2] Noise Action Planning Priority Areas (NAPPAs)

4.4.19 Under the Environmental Noise Regulations, areas where people are exposed to the highest levels of road and railway noise have been identified for designation as Noise Action Planning Priority Areas (NAPPAs). These have been identified through computer modelling initially, with further investigation and verification before formal designation.

4.4.20 Consideration will need to be given to possible noise mitigation actions that can be taken, and the designation will become a planning consideration as outlined in PPW.

Light

4.4.21 Whilst there is limited information available about light pollution, satellite images over recent years show a general increase in light emissions across the country. Over 90% of the UK population live under a severely light polluted sky (British Astronomical Association Survey) and matters are deteriorating further.

50 4.4.22 Increasing levels of light pollution are known to have detrimental effects on wildlife, disrupting natural patterns of activity, and may affect human health in a similar way in addition to preventing viewing and study of the night sky. It also represents a significant waste of energy. 5 . Summary of Consultation Responses

5 Summary of Consultation Responses 2013) 5.0.1 This section of the paper summarises the main issues and comments raised

following: (August

The formal Pre-Deposit Consultation (September/October 2011); and Paper opic The informal Emerging Deposit Plan Proposals Consultation (September/October T 2012). Environment

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. A previous version of this Topic Paper was published alongside the Pre-Deposit LDP Plan. Deposit 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.

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 It should be emphasised however that this section does not present a comprehensive and exhaustive list of all comments received, moreover the following seeks only to summarise the main issues raised. Full details of comments received and the Council's responses to those comments are set out in the Initial Consultation Report(19).

Built Environment and Historic Heritage

[1] Canals

Concerns raised that Swansea Canal above Ynysmeudwy and the Neath Canal in Glynneath are not safeguarded. The Canals should be preserved and restored.

Canals should not be included as a key issue. These are largely negative and relate to problems, the canals are a positive characteristic. 51

[2] Design

There should be more emphasis in the Plan of architecture, heritage and design.

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

Deposit Existing properties should be renovated and converted rather than developing new housing estates. LDP The LDP should press for higher design standards (e.g. energy efficiency / space -

Environment standards).

[3] Gateways T opic Clarification on gateways is required. Concern that not all development presents a Paper negative image – not appropriate to simply maintain open views. (August Countryside and the Coast 2013) [1] Countryside

Development should be allowed on small brownfield sites in the open countryside.

[2] Landscape

Clarification is required about the purpose of Special Landscape Areas. Concerns expressed if they restrict agriculture / employment / rural communities.

Landscape protection should be extended to cover a more diverse range of the County Borough's landscapes.

Green Wedge designations are contradicted by proposed developments at Tonna and Leiros Park.

[3] Coast

Concerns expressed about effects of the Plan's strategy and proposals on the coastal environment and the possible erosion and continuing loss of habitats.

Biodiversity and Geodiversity

[1] Biodiversity

Policies are needed to secure habitat enhancement and creation as well as avoiding 52 harm and providing adequate mitigation. New ways are needed to find and secure these opportunities. 5 . Summary of Consultation Responses

A 'step-wise' approach should be followed in relation to biodiversity following the

approach outlined in TAN 5: (1) avoid harm; (2) mitigate unavoidable harm; (3) 2013) compensate for residual harm; and (4) look for opportunities to enhance biodiversity; (5) where there may be significant harmful effects, consider all reasonable alternative (August sites. Paper Perceived conflict between aspiration for development along coastal strip and opic biodiversity interests (including Brunel Dock, Port Talbot Docks, Baglan Bay). T

Environmental capacity and Ecosystems Services approaches should be applied ('A Living Wales'). Environment - Implications of developments / sites on biodiversity designations and biodiversity interest within sites needs to be taken into account. LDP Deposit Environmental Protection

[1] Air Quality

Air pollution issues are not yet fully understood or overcome. Air Quality remains a significant issue, especially in the designated Air Quality Management Area (AQMA) and central parts of Neath and Port Talbot. There is no clear evidence that air quality will improve in the future. Improvements as a result of tightening legislation may be outweighed by additional development next to the AQMA.

The type and location of development needs careful consideration in air quality sensitive areas. New development within air quality areas should be subject to strict environmental controls.

[2] Water Quality

Water quality is a key issue that the LDP needs to address. A specific policy is needed.

Water resources and water quality management do not have a sufficiently high profile in the Plan. This should be an integral part of the strategy.

53 5 . Summary of Consultation Responses Deposit LDP - Environment T opic Paper (August 2013)

54 6 . Issues to be Addressed

6 Issues to be Addressed 2013) 6.0.1 Having considered (1) the requirements of National policy and guidance, (2) the

matters that have emerged from the evidence base and (3) the responses received to the (August 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 Paper the key requirements and issues that the LDP has to address. opic T 6.0.2 Each of the following is considered in turn:

Built Environment and Historic Heritage; Environment - Countryside and the Coast; LDP

Biodiversity and Geodiversity; and Deposit Environmental Protection.

6.1 Built Environment and Historic Heritage

6.1.1 National policy and guidance indicates that the following matters in relation to the built environment should be addressed in the development of the LDP:

Historic Environment - development plans should include locally specific policies for the conservation of the built environment.

Listed Buildings - development plans should include locally specific policies for works of demolition, alteration, extension or re-use of listed buildings and their curtilages.

Promoting Traditional & Local Distinctiveness - in areas recognised for their landscape, townscape or historic value (e.g. conservation areas) and more widely in areas with an established and distinctive design character, it can be appropriate to seek to promote or reinforce traditional and local distinctiveness.

Design Considerations - (1) LPAs are under a legal obligation to consider the need to prevent and reduce crime and disorder in all decisions that they take. Crime prevention and fear of crime are social considerations to which regard must be given by local planning authorities in the preparation of development plans; (2) development plans should also provide clear policies, supported where appropriate by supplementary planning guidance, setting out the design expectations of local planning authorities for various places and development proposals; and (3) LDPs may incorporate targeted design policies for major areas of change or protection, strategic 55 sites or for certain types of development.

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. 6 . Issues to be Addressed

Deposit 6.1.2 In accordance with national guidance, the LDP will include policies which seek to:

LDP Protect the historic environment and built heritage. -

Environment Protect buildings of local importance.

Ensure the achievement of high quality design, with development proposals in particular taking account of (1) the natural, historic and built environment context; (2) T

opic 'Secured by Design' principles; and (3) 'inclusive' design principles.

Paper Encourage higher building standards where possible(20). (August Derelict Buildings 2013) 6.1.3 There are significant numbers of derelict buildings and listed buildings at risk. More than 45 listed buildings have been identified as being at serious risk, with a further 90 identified as needing close monitoring. Furthermore, there is also a perception that significant numbers of buildings are derelict or are becoming derelict and areas within various communities are falling into disrepair. Some of the County Borough's settlements and urban centres have lost significant elements of their original role and are consequently declining and losing significant 'iconic' buildings that give them their distinctive character.

6.1.4 The LDP will need to include a policy which seeks to protect buildings that are of local historic, architectural or cultural importance (i.e. those that play an important part in defining the character of an area). Furthermore, the policy will also need to encourage the incorporation or adaption of existing derelict buildings into development schemes where possible.

Canal Network

6.1.5 The Canal network is an important part of the County Borough’s historic heritage. It forms part of a network of green corridors which encourages walking and cycling, attracts visitors to the area and is important for local ecology and biodiversity. Whilst the canal network is not central to the future development of the County Borough, it will nevertheless be important to protect and enhance the canal network and encourage its restoration.

6.1.6 Whilst significant lengths of the canals have been restored to navigable standard, there remain significant gaps in the network where the lines of the canals have been lost, or navigation is prevented by obstructions such as low bridges.

6.1.7 The LDP will need to include a policy which seeks to protect the canals where 56 appropriate and in particular, in areas where development could compromise their use and future restoration. A distinction will however need to be made between safeguarding the lengths of the canal network where there is a realistic prospect of restoration and those stretches of canal where restoration would be less likely.

20 Opportunities for Higher Sustainable Building Standards is considered in the 'Deposit Renewable & Low Carbon Energy Topic Paper' (August 2013). 6 . Issues to be Addressed

Arterial Gateways 2013) 6.1.8 'Arterial Gateways' are those areas adjacent to the County Borough boundary which are prominent when entering or leaving Neath Port Talbot. Such areas help to define the character and image of the area. (August

6.1.9 There is concern that Neath Port Talbot's image and character is not clearly Paper opic apparent and that areas around the main entrances or 'gateways' into the County Borough T have suffered inappropriate development in the past that have resulted in a poorer image for the area as a whole. Developments in such areas should therefore be carefully planned to create a strong impression on arrival in a distinctive and attractive place. Environment - 6.1.10 An analysis has been undertaken of the main routes by which people enter and leave the County Borough and the following four principal gateways have been identified: LDP

M4 / mainline railway at Margam (boundary with Bridgend); Deposit

M4 / mainline railway at Lonlas (boundary with Swansea);

A483 Fabian Way (boundary with Swansea); and

A465 (T) Heads of the Valleys (boundary with Rhondda Cynon Taff).

6.1.11 Other less major routes include the A474 and A4069 in the Amman Valley (boundary with Carmarthenshire), the A4067 in the Swansea Valley (boundaries with Swansea to the south west and Powys to the north east) and the A4107 in the Afan Valley (boundary with Rhondda Cynon Taff).

6.1.12 The LDP will include an all-encompassing design policy which will need to make specific reference to the important arterial gateways. Within these gateway areas, it will be important that new developments take full account of their visual impact when seen from the main transport arteries, with careful attention being paid to siting, design, appearance, massing and scale in order to minimise any visual intrusion and where appropriate enhance the visual aspects of the area.

Key Issues

6.1.13 The Pre-Deposit Plan identified the following key issues which were linked to the built environment:

Neath Port Talbot has a significant built heritage resource in terms of conservation areas, listed buildings, scheduled ancient monuments and archaeologically sensitive 57 sites that together with their settings require protection and enhancement. 6 . Issues to be Addressed

Deposit The arterial gateways into the County Borough play an important role in defining an area’s image. In the past, developments have taken place within these gateways that

LDP have detrimentally affected the aesthetics of the area. -

Environment The Canal network is an important part of the County Borough’s historic heritage. It forms part of a network of green corridors which encourages walking and cycling and attracts visitors to the area. T opic 6.1.14 In order to improve clarity for the Deposit Plan and as a result of an improved Paper understanding of an up-to-date evidence base, the following key issue relating to the built environment has been developed for the Deposit Plan(21): (August

There is a need to address dereliction and loss of character in settlements and

2013) urban centres.

6.2 Countryside and the Coast

6.2.1 National policy and guidance indicates that the following matters in relation to the natural environment should be addressed in the development of the LDP:

Conservation and Enhancement of Locally Designated Landscape Areas - non-statutory designations, such as Special Landscape Areas (SLAs), should be soundly based on a formal scientific assessment of the landscape or geological value of the site. Although non-statutory designations carry less weight than statutory designations, they should be given adequate protection in development plans.

Coastal Areas - Local Planning Authorities should clearly establish what the coast means for them and develop, or apply, specific policies which reflect the characteristics of their coastlines.

6.2.2 In accordance with national guidance, the LDP will include policies which seek to protect and where feasible enhance the countryside and coast, including landscapes, seascapes and agricultural land.

Assessing the Landscape

6.2.3 In regard to the assessment of landscapes in Neath Port Talbot, TACP Environmental Consultants were commissioned by the Authority in January 2010 to provide landscape advice to assist with the preparation of the LDP. In respect of local designations, 58 the Study(22) principally reported on:

21 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. 22 Consultancy Services for the Provision of Landscape Advice - Final Report. TACP (June 2011). 6 . Issues to be Addressed

An assessment of the need of, and justification for, the identification of areas of

countryside as Special Landscape Areas (SLAs), and the identification of those areas 2013) concerned(23); and (August An assessment of the existing Green Wedges designated in the current adopted

Unitary Development Plan (UDP) and whether (1) there was a need to redefine those Paper boundaries; and (2) whether there was a need to identify further areas where

(24) opic appropriate . T

Special Landscape Areas (SLAs) Environment - 6.2.4 The use of non-statutory designations such as SLAs to protect areas of landscape value has long been a policy tool within the planning system. They are seen by LPAs as LDP a means of protecting sensitive landscapes and in developing an understanding and

awareness of those features and characteristics that give a locality its sense of place. Deposit

6.2.5 The methodology for the study applied the Special Landscape Area Designation Criteria originally developed for the South East Wales Local Authority Consortium, and now included within the Countryside Council for Wales Guidance Note 1 (June 2008)(25). This methodology utilises the comprehensive data set associated within the LANDMAP Information System landscape assessment methodology. The methodology essentially derives SLAs from groupings of 'Outstanding' and 'High' evaluations from the underlying LANDMAP data.

6.2.6 The study recommended the designation of six SLAs.

6.2.7 Mynydd y Garth SLA is a high value landscape in terms of its underlying geology, cultural and historical heritage, ecology, visual amenity, tranquillity and sense of place. It has a distinctive character and relates in landform and cover to the Brecon Beacons National Park to the north and is part of a coherent upland plateau which continues into Swansea to the west and is defined to the south east by the Vale of Neath.

6.2.8 The Dulais Valley SLA is visually one of the most significant upland valleys in the County Borough. This enclosed heavily wooded pastoral mosaic valley has high scenic qualities, presents attractive views both within the valley at an intimate scale and also long views out from the higher ground. Although there is forestry on the higher slopes, the dominant landform on both sides of the valley reinforces its significance within the landscape.

6.2.9 The Vale of Neath SLA is a prominent broad valley of considerable importance within the area and it has a different character to other narrower valleys of the County Borough. This is a high value landscape in terms of its underlying geology, cultural and 59 historical heritage, ecology, visual amenity and sense of place. It also has important visual links with the Brecon Beacons National Park.

23 Chapter 5 Final Report TACP (June 2011). 24 Chapter 6 Final Report TACP (June 2011). 25 CCW is now part of Natural Resources Wales (NRW). 6 . Issues to be Addressed

Deposit 6.2.10 Margam SLA provides protection for the high quality landscape with its culturally and historically important associations to Margam Abbey. It is a unique landscape which

LDP includes Margam Park and Margam Castle with Margam Mountain as the backdrop and a visually prominent landmark from the M4 and associated transport routes. - Environment 6.2.11 Mynydd y Gelli SLA is an open upland bounded by Caerau Forest to the south, the forested Mynydd Blaenafan to the north and the river Afan to the north and west. It forms a contiguous landmass with Llangeinwyr across the County Borough boundary in T

opic Bridgend.

Paper 6.2.12 Foel Trawsnant SLA is an open upland surrounded by forested valley sides. It forms a contiguous landmass with Foel y Dyffryn across the County Borough boundary (August in Bridgend.

2013) 6.2.13 To reflect the recommendations of the study and protect the areas of high landscape value, the approach to be taken in the LDP will be as follows:

A policy will be included to control development within such areas, ensuring that there will be no significant adverse impacts on the features and characteristics for which the SLA has been designated.

The SLAs will be identified on the Proposals Map.

Green Wedges

6.2.14 The designation of a Green Wedge differs from that of SLAs as it is primarily a planning tool to prevent urban coalescence and to protect the setting of built-up areas, rather than specifically protecting high quality landscapes. The existing Green Wedges designated in the current adopted UDP were therefore reviewed initially considering issues of potential coalescence and secondly issues of urban setting.

6.2.15 The study concluded that the existing Green Wedges appeared to function well and recommended that the following five areas be retained as Green Wedges and carried forward as a policy commitment in the LDP. The Study also acknowledged the fact that if the Authority decides to release land for development on the edge of the existing settlements, the Green Wedge boundaries should be adjusted accordingly.

6.2.16 Alltwen / Rhos / Bryncoch / Neath Abbey / Leiros Park - the area includes a belt of countryside between Rhos and Bryncoch and smaller areas on the fringes of Bryncoch, Rhos, Alltwen, Gelli Nedd and Pontardawe.

60 6.2.17 The countryside between Rhos and Bryncoch only extends for approximately 1.5 kilometres and contains a grouping of houses in the identified dormitory settlement of Fforest Goch(26). As a result, development in the area could have a significant impact in terms of eroding the character of the area and extending the urban form of Neath northwards towards Rhos.

26 Deposit Settlement Topic Paper (August 2013). 6 . Issues to be Addressed

6.2.18 The land between and around the settlements of Alltwen, Rhos and Gelli Nedd contains smaller areas of countryside which while very limited in extent play an important 2013) role in separating and defining the communities. Such areas are under increasing pressure for development. The area to the east and west of Bryncoch and extending down to Neath (August Abbey performs an important role in defining the urban area of Neath. Paper 6.2.19 Strategically the area is of great importance in landscape terms in separating opic and defining the urban forms of Pontardawe and Neath. T

6.2.20 Skewen / Birchgrove - this small area prevents the coalescence of urban Neath with urban Swansea and will also manage the urban form of the settlement of Skewen. Environment - 6.2.21 Neath / Tonna / Cimla / Efail Fach - the majority of the area is visually prominent and under increasing pressure for development, particularly in the Cimla area. The area LDP is also important as it incorporates the historical setting of the Gnoll Country Park which provides an important setting to urban Neath. Deposit

6.2.22 Crymlyn Bog / Crymlyn Burrows / Llandarcy - strategically the area is of great importance in landscape terms in that it separates and defines the urbanised area of Swansea, Neath, Skewen and Coed Darcy.

6.2.23 Margam - this extensive area of countryside forms an important break in the landscape between the urban and predominantly industrialised area of Port Talbot and Pyle across the administrative boundary in Bridgend. The landscape is unusually open in character with extensive pasture land extending from the M4 to the foot of Margam Mountain.

6.2.24 To reflect the recommendations of the study and (1) prevent the coalescence of settlements; and (2) protect the setting of urban areas, the approach to be taken in the LDP will be as follows:

A policy will be included to control development within such areas, ensuring that there will be no inappropriate development.

The Green Wedges will be identified on the Proposals Map.

The Coast

6.2.25 An analysis of the County Borough's coastline has shown that it can be divided into distinctively contrasting character areas, based on their current and historic uses, namely: 61 6 . Issues to be Addressed

Deposit The Developed Coast - which includes the industrialised areas and associated uses (i.e. Tata Steelworks, Port Talbot Docks and Harbourside); Aberafan seafront which

LDP incorporates leisure, recreation and tourism uses; and the new University Campus at Crymlyn Burrows which involves the redevelopment of a brownfield area close to the - Environment County Borough boundary.

The Undeveloped Coast - which includes the dune systems at Baglan Bay and the estuary of the River Neath and Crymlyn Burrows, comprising extensive areas of T opic natural dunes, natural saltmarsh, dune slacks and carr woodland. Paper

6.2.26 The Shoreline Management Plan (SMP2) indicates that the areas of developed (August coastline and the area of the River Neath will be defended with the maintenance of existing defences. Furthermore, the developed areas of coastline either lie within existing industrial 2013) areas or identified settlement limits. Within settlement limits development proposals will generally be acceptable.

6.2.27 The areas of undeveloped coast fall under the 'managed realignment' policy of the SMP2 which involves allowing the shoreline to move back with management to control and limit movement. A relatively limited area of Neath Port Talbot's coastline can be classed as undeveloped and includes:

The areas around the estuary of the River Neath; and

The sand dunes and salt marsh areas at Baglan Bay and Crymlyn Burrows.

6.2.28 Within the identified areas of the undeveloped coast, only a limited range of development is likely to be acceptable. As such, the approach to be taken in the LDP will be as follows:

A policy will be included to control development within such areas, ensuring that there will be no inappropriate development.

The areas of undeveloped coast will be identified on the Proposals Map.

Key Issues

6.2.29 The Pre-Deposit Plan identified the following key issues which were linked to the countryside: 62 Extraction industries will continue to have a major impact on our landscapes. The County Borough's landscapes are important for leisure and activity for residents and visitors. Reflecting the County Borough's potential for the large scale development of resources that are located in the countryside including coal, stone and wind farms, there is pressure for development that would impact upon these landscapes. 6 . Issues to be Addressed

6.2.30 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 following key issue relating to the 2013) countryside and the coast has been developed for the Deposit Plan(27):

There is a need to balance the impact of development on the countryside, (August landscape and coast, in particular the exploitation of mineral and renewable Paper energy resources. opic T

6.3 Biodiversity and Geodiversity

6.3.1 National policy and guidance indicates that the following matters in relation to Environment biodiversity must be addressed in the development of the LDP: - LDP Biodiversity and Climate Change (safeguarded areas and buffer zones) - LPAs should consider how they might accommodate a response to climate change as part of their Deposit 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.

Conservation and Enhancement of Locally Designated Nature Areas - non-statutory designations, such as Sites of Interest for Nature Conservation (SINCs), should be soundly based on a formal scientific assessment of the nature conservation value of the site. Although non-statutory designations carry less weight than statutory designations, they should be given adequate protection in development plans.

Protection of Trees and Woodlands - LPAs should seek to protect trees, groups of trees and areas of woodland where they have natural heritage value or contribute to the character or amenity of a particular locality.

Landscape Features of Major Importance for Wild Flora and Fauna - development plans should encourage the appropriate management of features of the landscape which are of major importance for wild flora and fauna in order to complement and improve the ecological coherence of the Natura 2000 network.

6.3.2 In accordance with national guidance, the LDP will include policies which seek to:

Protect and enhance important habitats, species and sites of geological interest - including Regionally Important Geodiversity Sites (RIGS), Sites of Interest for Nature Conservation (SINCs), sites meeting SINC criteria and national or local Biodiversity Action Plan (BAP) habitats or species. 63

Protect green infrastructure - including trees, woodlands, hedgerows, watercourses and ponds.

27 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

Deposit Approach to Protecting Important Biodiversity and Geodiversity Sites

LDP 6.3.3 The approach to be taken in the LDP will expand upon the compensation and enhancement steps as outlined in the 'step-wise' approach set out in national guidance, -

Environment through the:

Identification of any existing, or potentially, important habitat / species and ecological connectivity; T opic Avoiding loss of any existing, or potentially important, habitats / species or the Paper fragmentation of ecological connectivity;

(August Mitigation for any unavoidable harm or loss of important habitats / species or the fragmentation of ecological connectivity; 2013) Compensation for any un-mitigatable habitat / species losses that can be justified; and

Enhancement of the biodiversity on-site, or off-site if the site is unable to accommodate such requirements.

6.3.4 Where loss or harm to biodiversity is unavoidable, effective mitigation measures will be required to ensure that there is no overall reduction in the value of the area or feature. Where mitigation is not possible, compensation measures will normally be required to offset harm as far as practicable.

6.3.5 It should be emphasised that compensation will only be considered as a last resort option for development that can demonstrate that all avoidance and mitigation measures have been fully investigated in the first instance. It can be argued that artificially created habitat may be of inferior quality to existing habitat as natural species diversity can only be achieved over a considerable period of time. Compensation therefore is unlikely to be able to replicate the quality of the biodiversity interest lost and as such will only be considered as a last resort.

6.3.6 Whilst it is expected that in the majority of cases the biodiversity requirements of a development will be able to be adequately addressed on site, there will be cases where off-site compensation will need to be delivered.

6.3.7 In light of the above, the approach to be taken in the LDP will be as follows:

A policy will be developed to protect important biodiversity and geodiversity sites 64 which incorporates the 'step-wise' approach as set out in national guidance. SINCs are currently being identified and the policy will need to refer to both identified SINCs and to sites that 'meet SINC criteria';

6.3.8 Supplementary Planning Guidance (SPG) will be subsequently prepared which will set out: 6 . Issues to be Addressed

The procedure for, and identification of, SINCs across the County Borough; 2013) The strategic approach to provide general biodiversity enhancement in a way that would deliver the greatest value; (August

The approach that can transparently and robustly deliver off-site compensation, should Paper it be required; and opic T The procedure for, and identification of, 'Strategic Compensation Sites' across the County Borough to facilitate any off-site compensation. Environment 6.3.9 SINCs are essentially local sites identified as being of substantive nature - conservation value. They represent the most important places for wildlife outside the LDP statutorily designated sites. National guidance dictates that their designation should be

based on a formal scientific assessment of the nature conservation value of the site. Deposit

6.3.10 There are a high number of potential SINCs within Neath Port Talbot, for example river corridors, canal corridors and extensive areas of ancient woodland. The identification of SINCs will need to be based upon the criteria contained in 'Wildlife Sites Guidance Wales' (Wales Biodiversity Partnership) with input and involvement from the Neath Port Talbot Biodiversity Forum.

Key Issues

6.3.11 The Pre-Deposit Plan identified the following key issues which were linked to biodiversity:

Development ranging from housing to opencast and wind farms have continuing impacts on wildlife and their habitats. There is a need to ensure that areas of important habitats are protected and remain connected and that development is guided away from areas of particular importance.

6.3.12 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 following key issue relating to biodiversity has been developed for the Deposit Plan(28):

The continuing loss of habitats and species needs to be addressed.

6.4 Environmental Protection

6.4.1 National policy and guidance indicates that the following matters in relation to 65 environmental protection must be addressed in the development of the LDP:

28 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

Deposit Soil / Contamination - where appropriate, development plans should indicate the general location of known areas of contamination and may also include specific

LDP proposals for sites known to be contaminated or where the site history suggests a risk of contamination or the land is designated as contaminated land. LDPs may - Environment indicate that the LPA will need to be satisfied that any actual or potential contamination can reasonably be overcome. Policies for the rehabilitation and development of existing polluted land and derelict sites should also be included. LPAs should take into account the nature, scale and extent of contamination which may pose risks to health. T opic

Paper Land Stability - where appropriate, development plans should indicate the general location of known areas of unstable ground. Proposals for areas of land instability

(August should take due account of physical constraints and may recommend action on land reclamation or other remedial action to enable beneficial use of unstable land. LDPs may indicate that the LPA will need to be satisfied that a site is stable or that any 2013) actual or potential instability can reasonably be overcome. LPAs should take into account in plan preparation the nature, scale and extent of ground instability which may pose direct risks to life and health, buildings and structures, or present indirect hazards associated with ground movement such as the possible migration of landfill or mine gas.

Pollution - development plans are important vehicles for the promotion of environmental protection and should enable consideration of the effects which proposed developments, and transport demand associated with them, may have on air or water quality and the effects which air or water quality may have on proposed developments.

Strategic Policies for Potentially Polluting Developments - development plans are important vehicles for the promotion of environmental protection and should enable consideration of the effects which proposed developments, and transport demand associated with them, may have on air or water quality and the effects which air or water quality may have on proposed developments. LDPs should include strategic policies on the location of potentially polluting developments and should set out criteria by which applications for such developments will be determined, but they should not exclude provision for such projects or prohibit all applications to set them up. Plans may set out policies and proposals to ensure that incompatible uses of land are separated, in order to avoid potential conflict between different types of development.

Avoiding Potential Conflict between Incompatible Land Uses - they should make realistic provision for the types of industry or facility that may be detrimental to amenity or conservation interests, or a potential source of pollution, ensuring resilience to climate change.

66 Noise Sensitive Development and Potentially Noisy Development - development plan policies should be designed to ensure, as far as is practicable, that noise-sensitive developments, such as hospitals, schools and housing, that need to be located close to the existing transportation infrastructure to facilitate access, are designed in such a way as to limit noise levels within and around those developments. Policies should also be designed to ensure, as far as possible, that potentially noisy developments are located in areas where noise will not be such an important consideration or where 6 . Issues to be Addressed

its impact can be minimised. LPAs should adopt policies to prevent potentially noisy

developments in areas which have remained relatively undisturbed by noise. 2013) Development plan policies should have regard to any relevant Noise Action Plan, including the need to protect urban ‘quiet areas’ against an increase in noise. (August

Lighting and Light Pollution - LPAs should adopt policies for lighting, including the Paper control of light pollution, in their development plans. opic T

6.4.2 The issue of air quality in particular within the County Borough and more specifically Port Talbot, is an ongoing issue. Air quality has been a top priority for the Council since Environment

the declaration of the Port Talbot Air Quality Management Area (AQMA) in 2000. - Accordingly, the Plan will need to acknowledge that air quality can affect and be affected by development proposals and as such, the Plan will need to protect and improve the LDP environment as far as possible. Deposit 6.4.3 In order to achieve this and in particular deliver the Council's commitment to address the air quality issues within the central Port Talbot area in particular, in line with national guidance the LDP will include policies which seek to:

Protect and where feasible improve air, water and ground quality;

Prevent development that would have an unacceptable adverse effect on health, biodiversity and/or local amenity or would expose people to unacceptable risk;

Establish strict controls on development in the central Port Talbot area; and

Protect areas of 'tranquillity / quiet' within urban areas.

Key Issues

6.4.4 The Pre-Deposit Plan identified the following key issues which were linked to environmental protection:

The air quality in Neath Port Talbot has improved over recent years with the main issue relating to the levels of particulates.

Noise from everyday activities is increasing. It is important to reduce this and protect certain areas from noise pollution in an attempt to enhance the general health and well-being of the community.

Due to its industrial past there are large areas of previously developed land. 67 6 . Issues to be Addressed

Deposit 6.4.5 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 following key issues relating to (29)

LDP environmental protection has been developed for the Deposit Plan : -

Environment Some areas of the County Borough experience issues with air quality.

There are significant areas of brownfield (previously developed) land requiring remediation and regeneration. T opic Paper (August 2013)

68

29 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. 7 . Objectives

7 Objectives 2013) 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. (August

Pre-Deposit Objectives Paper opic 7.0.2 The Pre-Deposit identified a number of objectives, the following referred to the T environment (the numbering follows the numbering in the Pre-Deposit Plan).

Built Environment and Historic Heritage Environment - [18] Preserve and enhance the area's historical heritage and identity. LDP [20] Preserve and where possible enhance the built environment and heritage of the

County Borough and promote local character, distinctiveness and the role of towns Deposit and other centres as a focus for the communities.

[21] Preserve and enhance the main arterial gateways into the County Borough and its towns.

Countryside and the Coast

[10] Conserve and enhance Neath Port Talbot's seascapes, townscapes, landscape, wildlife and habitats.

Biodiversity and Geodiversity

[10] Conserve and enhance Neath Port Talbot's seascapes, townscapes, landscape, wildlife and habitats.

Environmental Protection

[7] Minimise the adverse impacts from noise generating and polluting activities.

[11] Promote the efficient use of land, water and energy and safeguard the quality of land and water.

Deposit Objectives 69 7.0.3 In order to better reflect the revised key issues, take account of the comments received at the Pre-Deposit stage and improve clarity for the Deposit Plan, the following specific objectives are proposed. 7 . Objectives

Deposit Built Environment and Historic Heritage

LDP Protect and enhance the County Borough's historical heritage, built environment and identity. - Environment Conserve and enhance the County Borough's main arterial gateways.

T Countryside and the Coast opic

Paper Conserve Neath Port Talbot's important landscapes, undeveloped coast, important wildlife, habitats and geodiversity sites, ensuring that developments (August throughout the County Borough respect all landscapes and minimises adverse impacts. 2013)

Biodiversity and Geodiversity

Conserve Neath Port Talbot's important landscapes, undeveloped coast, important wildlife, habitats and geodiversity sites, ensuring that developments throughout the County Borough respect all landscapes and minimises adverse impacts.

Environmental Protection

Address air quality issues and minimise the adverse impacts from noise generating and polluting activities.

Promote the efficient use of land and safeguard the quality and quantity of environmental assets.

70 8 . Strategic Policy Development

8 Strategic Policy Development 2013) At the Pre-Deposit stage, the overall Preferred Strategy was for 'Moderate growth with a

focus on the coastal / M4 corridor whilst reinvigorating the Valley communities'. This overall (August strategy was underpinned by a number of topic based and area based strategies. Paper Having considered the consultation responses, issues and objectives outlined in previous opic chapters, this section of the paper sets out how the strategy has evolved since the T Pre-Deposit stage. Where appropriate, amendments and additions to the strategies are highlighted and explained. Environment

Each of the following is considered in turn: -

Built Environment and Historic Heritage; LDP

Countryside and the Undeveloped Coast; Deposit

Biodiversity and Geodiversity; and

Environmental Protection.

8.1 Built Environment and Historic Heritage

Pre-Deposit Strategy

8.1.1 Whilst the Pre-Deposit Plan did not include a specific topic based strategy for the built environment and historic heritage, the following provisions were included in the Area Based Spatial Strategies:

Neath

An indication that the town's heritage and cultural history including the canal network will be promoted as part of enhancing its distinctive character.

Port Talbot

Margam is identified as a key gateway from the east, with a indication that the LDP will seek high quality design from new developments in the area. Older parts of the town contribute to Port Talbot's character and it is indicated that the townscape will be protected and enhanced and that the Harbourside development will create a new waterfront identity for the town. 71 The Valleys

It is indicated that the LDP will seek to protect and enhance the culture, buildings, landscapes and facilities that contribute to this distinctiveness. 8 . Strategic Policy Development

Deposit 8.1.2 The Pre-Deposit Plan also contained the following Strategic Policies (the numbering follows the numbering in the Pre-Deposit Plan): LDP -

Environment Policy 31 - The Canal Network

The Line of the Neath, Swansea and Tennant Canals will be protected except for the section of the Neath Canal above Ysgwrfa Bridge, Glynneath and the Swansea Canal T

opic above Ynysmeudwy. Paper (August Policy 33 - Protection of the Built Environment and Heritage Features

2013) The built environment and heritage of the County Borough will be protected and wherever possible enhanced.

Policy 34 - Design

All new development will be required to demonstrate good design which is sympathetic to its surroundings.

Policy 35 - Gateways

The main gateways into the County Borough, and its main towns, will be enhanced and any new proposals for development in these areas will be required to enhance the surroundings by virtue of good design, use of materials and landscaping.

Deposit Plan Strategy

8.1.3 In order to improve clarity for the Deposit Plan, the single strategic policy set out below has been developed which incorporates all relevant elements of the Preferred Strategy outlined above.

8.1.4 Strategic Policy: Built Environment and Historic Heritage

72 Built Environment and Historic Heritage

The built environment and historic heritage will, where appropriate, be conserved and enhanced through the following measures:

1. Encouraging high quality design standards in all development proposals; 8 . Strategic Policy Development

2. Protecting arterial gateways from intrusive and inappropriate development; 2013) 3. Safeguarding features of historic and cultural importance; (August 4. The identification of the following designated sites to enable their protection: Paper (a) Landscapes of Historic Interest; opic T (b) Historic Parks and Gardens;

(c) Conservation Areas; Environment (d) Scheduled Ancient Monuments. - LDP Deposit 8.1.5 The built environment and urban form of Neath Port Talbot is varied and distinctive, with important remaining features from all periods from prehistory onwards, including Iron Age hill forts and burial mounds, Roman military infrastructure and medieval ecclesiastical buildings and farmsteads.

8.1.6 The town of Neath retains the character of a traditional market town, while the key character of most of the County Borough's other towns and villages derives from the area's industrial heritage, from the mining and metal working of the early industrial revolution through to the large scale steel and petro-chemical industries of the 20th century. The historic heritage of the area is recognised through a range of designations, mostly protected by national policies. Within the County Borough, there are two designated Landscapes of Historic Interest, six Historic Parks and Gardens, six Conservation Areas, 92 Ancient Monuments and 391 Listed Buildings.

8.1.7 Over time however, the role and function of settlements has been changing with the loss of many of these industries, and there has been a consequent loss of character and distinctive buildings including shops, chapels and churches that played important roles functionally, as well as visually.

8.1.8 In recent years, the County Borough has attracted a new range of industry and employment opportunities including tourism and service industries, leading to new patterns of development such as industrial estates and business parks, especially along the coastal corridor. The natural environment also remains an important source of employment with minerals and renewable energy developments such as wind farms introducing new types of built environment altering the landscape.

8.1.9 There are also concerns that areas around the main entrances or 'gateways' into 73 the County Borough have suffered inappropriate development that have resulted in a poorer image for the area as a whole. The strategic policy therefore seeks to conserve and enhance the built environment and heritage of the whole County Borough including the identified 'gateways'. 8 . Strategic Policy Development

Deposit 8.2 Countryside and the Undeveloped Coast

LDP Pre-Deposit Strategy -

Environment 8.2.1 The Pre-Deposit Plan included the following topic based strategy for the countryside:

The strategy aims to protect and, where feasible, enhance the landscape, wildlife T

opic and habitats, soil and agricultural land and this will include the use of Green Wedges and Special Landscape Areas. Paper

(August Farming and rural communities will be supported through encouraging the diversification of farming businesses, allowing the younger generation to take

2013) over when farmers wish to retire and the creation and growth of rural enterprises.

Tourism and leisure led opportunities offered by the County Borough will be supported and enhanced.

Coal and aggregate resources that are of national significance will be protected. Policies will set out how they may be exploited and how settlements and the environment will be protected. Adverse effects on the local environment and communities will be minimised and benefits, sometimes drawn from developer contributions, will be maximised.

Common and designated open access land will be protected from unnecessary development for biodiversity, agricultural and amenity reasons.

8.2.2 In addition, the Pre-Deposit Area Based Spatial Strategies included the following provisions:

Neath

The hills surrounding Neath and their role in the landscape will be protected and unnecessary development resisted through the designation of green wedges and special landscape areas. Outline given of green wedges and special landscape areas. It is indicated that important wildlife and habitats included designated areas will be protected and where feasible enhanced.

74 Port Talbot

As with Neath, an indication is given of green wedges and special landscape areas is given protecting the setting and coalescence of urban areas and it is indicated that wildlife, habitats and designated areas will be protected.

The Valleys 8 . Strategic Policy Development

As with the other areas, an indication is given of proposed special landscape areas and that wildlife, habitats and designated areas will be protected. 2013) (August 8.2.3 The Pre-Deposit Plan also contained the following Strategic Policies (the numbering follows the numbering in the Pre-Deposit Plan): Paper opic T Policy 17 - Development in the Countryside

Neath Port Talbot's countryside and habitats will be protected from unnecessary Environment

development. Where adverse impacts from development will result, the LDP will set - out a strategic approach to mitigation. LDP Deposit Policy 18 - Green Wedges

Green Wedges will be used to identify areas and sites that are of local importance at the following locations:

i. Alltwen/Rhos/Bryncoch/Neath Abbey/Leiros Park;

ii. Skewen/Birchgrove;

iii. Neath/Tonna/Cimla/Efail Fach;

iv. Crymlyn Bog/Crymlyn Burrows/Llandarcy;

v. Margam

Policy 19 - Special Landscape Areas

Special Landscape Areas to identify areas and sites that are of local importance will be designated and protected at the following locations:

i. Mynydd y Garth (Pontardawe); ii. Vale of Neath; 75 iii. Dulais Valley;

iv. Margam to include Margam Park, Margam Mountain and Mynydd Emroch; 8 . Strategic Policy Development

Deposit v. Mynydd y Gelli (Cymmer);

LDP vi. Foel Trawsnant (Cynonville/Dyffryn) - Environment

Deposit Plan Strategy T

opic 8.2.4 In order to improve clarity for the Deposit Plan, the single strategic policy set out below has been developed which incorporates all relevant elements of the Preferred Paper Strategy outlined above. In addition, the policy has been expanded to include reference to the undeveloped coast. (August

8.2.5 Strategic Policy: The Countryside and the Undeveloped Coast 2013)

The Countryside and the Undeveloped Coast

The countryside and undeveloped coast, including landscapes, seascapes and agricultural land, will be protected and where feasible enhanced through the following measures:

1. The protection of the open countryside through the control of inappropriate development outside settlement limits;

2. The protection of the undeveloped coast through the control of inappropriate development;

3. The designation and protection of Special Landscape Areas;

4. The designation and protection of Green Wedges.

8.2.6 Neath Port Talbot has a variety of distinctive and contrasting landscapes and seascapes. The Neath Port Talbot LANDMAP landscape assessment(30)evaluates approximately half of the County Borough area as 'high' or 'outstanding' for its geological landscapes, much of the visual and sensory aspect layer is evaluated as 'moderate' or of local importance with 'high' values applied to plateau and coastal areas, there are 'high' and 'outstanding' values for landscape habitats and the majority of the County Borough is 'high' or 'outstanding' in terms of its cultural aspect layer.

76 8.2.7 While a detailed study has been undertaken of the County Borough's landscapes(31)which recommends areas which should be specifically protected for their landscape value or to prevent the coalescence of settlements (i.e. Special Landscape Areas and Green Wedges), the LDP strategy aims to protect all areas of countryside where appropriate.

30 Neath Port Talbot LANDMAP Landscape Assessment - White Consultants (2004). 31 Consultancy Services for the Provision of Landscape Advice - TACP (2011). 8 . Strategic Policy Development

8.2.8 The strategic policy aims to conserve the County Borough's countryside, landscapes and undeveloped coast, support rural enterprise including tourism and leisure activities 2013) and concentrate development in sustainable locations. The approach is implemented through a range of detailed policies, including those relating to minerals, waste, renewable (August energy and the Settlement Limits policy. Paper 8.3 Biodiversity and Geodiversity opic T Pre-Deposit Strategy

8.3.1 The Pre-Deposit Plan included the following topic based strategy for biodiversity: Environment -

Protect and enhance priority habitats and species and sites of national, LDP international and local importance. This will be achieved by shaping the growth

of urban areas, protecting habitats in the countryside and along the undeveloped Deposit coast and avoiding their fragmentation or isolation.

Identify, via the greenspace strategy, a network of green corridors to provide habitats and connectivity for wildlife.

Require new developments to take full account of the implications of the development on wildlife and habitats and mitigate any negative effects.

8.3.2 In addition, the Pre-Deposit Area Based Spatial Strategies included the following provisions:

Neath

Important wildlife and habitats including Crymlyn Burrows, Crymlyn Bog, Pant Y Sais Fen and the Neath Estuary will be protected and where feasible enhanced. Areas of land meeting SINC criteria will be protected wherever possible.

Port Talbot

Important wildlife, habitats and areas of land meeting SINC criteria will be protected wherever possible.

The Valleys 77 Important wildlife, habitats and areas of land meeting SINC criteria will be protected wherever possible.

8.3.3 The Pre-Deposit Plan also contained the following Strategic Policy (the numbering follows the numbering in the Pre-Deposit Plan): 8 . Strategic Policy Development Deposit Policy 20 - Protection of Habitats and Species LDP Priority habitats, species and areas of land meeting SINC criteria will, wherever -

Environment possible, be protected and enhanced.

Deposit Plan Strategy T opic 8.3.4 In order to improve clarity for the Deposit Plan, the single strategic policy set out Paper below has been developed which incorporates all relevant elements of the Preferred Strategy. In addition, the policy has been expanded to include reference to geodiversity. (August

8.3.5 Strategic Policy: Biodiversity and Geodiversity 2013)

Biodiversity and Geodiversity

Important habitats, species and sites of geological interest will be protected, conserved, enhanced and managed through the following measures:

1. The identification of the following Internationally and Nationally designated sites within the County Borough to enable their protection:

(a) Special Areas of Conservation (SACs) and Ramsar Sites;

(b) Sites of Special Scientific Interest (SSSIs);

(c) National Nature Reserves (NNRs).

2. The identification and protection of sites of regional and local importance;

3. The protection of important natural heritage features.

8.3.6 In parallel with the variety of different landscapes across the County Borough, there is a wide variety of different habitats and species, from coastal beaches and sand dunes to upland heaths and moors, including river estuaries, farmland and extensive woodland and forest.

8.3.7 Three sites partly within Neath Port Talbot have European designations for nature 78 conservation (Natura 2000 and Ramsar sites) with others further afield that could also be affected by developments within the County Borough. These sites are protected by European and UK legislation and any proposals that could have an adverse effect will not be permitted except under certain very limited and specific circumstances. Proposals that 8 . Strategic Policy Development

are likely to significantly affect any of these sites will be subject to Habitats Regulations

Appraisal (HRA) to ensure that no harm will be caused. The LDP has been subject to 2013) HRA(32).

8.3.8 There are twenty Sites of Special Scientific Interest (SSSIs) within the County (August Borough including four which are designated partly or wholly for geological reasons. These Paper sites are of national importance and are protected by national policy with a presumption opic against development likely to cause any damage. Policy relating to Internationally and T Nationally designated sites is set out in Planning Policy Wales and associated documents.

8.3.9 In addition to the formally designated areas, much of the County Borough area Environment

contains habitats and species which should be conserved and enhanced. The LDP - biodiversity strategy and policies aim to ensure that biodiversity is fully taken into account in all planning decisions. LDP

8.4 Environmental Protection Deposit

Pre-Deposit Strategy

8.4.1 The Preferred Strategy included an aspiration of balancing the regeneration and remediation of brownfield sites against releasing greenfield land that would be attractive to developers and home buyers. Whilst the Pre-Deposit Plan did not include a specific strategy relating to environmental protection and pollution, the following strategies were relevant:

Settlement Strategy

The Settlement Strategy seeks to create more sustainable, healthier, safer and cohesive communities which should have a positive effect on traffic levels and air pollution generally through encouraging walking and cycling to local facilities.

Transport Strategy

This strategy intends to focus on reducing dependence on the car and use walking, cycling, bus, rail and community transport and car sharing for at least part of journeys. It is also indicated that improvements to the highway network will focus on addressing key congestion points.

Climate Change Strategy

It is indicated that development will be guided away from land that is at risk from flooding or environmental pollution (noise, air quality or instability). It is also proposed 79 to co-locate facilities and encourage the joint use of facilities and to promote a more sustainable patterns of settlements to reduce the need to travel and to support active travel.

32 Habitats Regulations Appraisal (August 2013). 8 . Strategic Policy Development

Deposit 8.4.2 The Pre-Deposit Plan also contained the following Strategic Policy (the numbering follows the numbering in the Pre-Deposit Plan): LDP -

Environment Policy 13 - Noise, Contamination and Air Quality

Development proposals should wherever possible help address existing environmental problems and otherwise minimise their impacts. T opic

Paper Deposit Plan Strategy

(August 8.4.3 In order to improve clarity for the Deposit Plan, the single strategic policy set out below has been developed which incorporates all relevant elements of the Preferred

2013) Strategy.

8.4.4 Strategic Policy: Environmental Protection

Environmental Protection

Air, water and ground quality and the environment generally will be protected and where feasible improved through the following measures:

1. Ensuring that proposals have no significant adverse effects on water, ground or air quality and do not significantly increase pollution levels;

2. Giving preference to the development of brownfield sites over greenfield sites where appropriate and deliverable;

3. Ensuring that developments do not increase the number of people exposed to significant levels of pollution.

8.4.5 The quality of the environment and the basic natural needs that it provides for are of great importance for human health and wellbeing, with the potential to affect quality of life in fundamental ways. The legacy of past activities in the area, mainly relating to heavy industry, coupled with present day industry, transport and development pressures all have impacts on the environment which need to be taken into account and addressed where possible. Air quality, ground contamination and stability and the quality of water resources can all affect and be affected by development proposals in the Plan, together with levels 80 of light pollution and noise levels. The Plan strategy is to protect and improve the environment as far as possible, and policy SP16 sets out the approach that will be taken.

8.4.6 In relation to environmental pollution, there is a wide range of control and permitting systems and regimes which developments and operations have to comply with that are separate from the Town and Country Planning system. These requirements cannot be 8 . Strategic Policy Development

duplicated in the Plan or in planning control, but have been taken into account in the development of Plan's proposals and policies and will need to be reflected in planning 2013) decisions. (August Paper opic T Environment - LDP Deposit

81 8 . Strategic Policy Development Deposit LDP - Environment T opic Paper (August 2013)

82 9 . Detailed Policy Development

9 Detailed Policy Development 2013) 9.0.1 In order to implement the strategy at the local level (through the determination of

planning applications), a number of detailed topic-based policies have been developed (August for the Deposit Plan. Paper 9.0.2 Each of the following is considered in turn: opic T Built Environment and Historic Heritage;

Countryside and the Undeveloped Coast; Environment - Biodiversity and Geodiversity; and LDP Environmental Protection. Deposit

9.1 Built Environment and Historic Heritage

9.1.1 Policy BE1: Design

Design

All development proposals will be expected to demonstrate high quality design which fully takes into account the natural, historic and built environmental context and contributes to the creation of attractive, sustainable places.

Proposals will only be permitted where all of the following criteria, where relevant, are satisfied:

1. It complements and enhances the character and appearance of the site, building or area in terms of siting, appearance, scale, height, massing and elevation treatment;

2. It respects the context of the site and its place within the local landscape, including its impact on the important arterial gateways into the County Borough, its effects on townscape and the local historic and cultural heritage and it takes account of the site topography and prominent skylines or ridges;

3. It utilises materials appropriate to its surroundings and incorporates hard and soft landscaping and screening where appropriate; 83 4. It would not have a significant adverse impact on highway safety, the amenity of occupiers of adjacent land or the community;

5. Important local features (including buildings, amenity areas, green spaces and green infrastructure, biodiversity and ecological connectivity) are retained and enhanced as far as possible; 9 . Detailed Policy Development

Deposit 6. It achieves and creates attractive, safe places and public spaces, taking account of 'Secured by Design' principles (including where appropriate natural surveillance,

LDP visibility, well lit environments and areas of public movement); - Environment 7. It plays a full role in achieving and enhancing an integrated transport and communications network promoting the interests of pedestrians, cyclists and public transport and ensures linkages with the existing surrounding community; T opic 8. It uses resources, including land and energy, as efficiently as possible through: Paper (a) Making the best and most efficient use of the land available through being of

(August appropriate density taking into account the character and appearance of the area;

(b) The layout and form of the development does not preclude the reasonable 2013) use of other adjacent land;

(c) Developing brownfield land in preference to greenfield land where possible;

(d) Minimising building exposure while maximising solar gain.

9. Its drainage systems are designed to limit surface water run-off and flood risk and prevent pollution;

10. The layout and design of the development achieves inclusive design by ensuring barrier free environments, allowing access by all and making full provision for people with disabilities.

9.1.2 The design of new development has a major influence on the conservation and enhancement of the character of an area and on people's quality of life. The policy addresses concerns raised about dereliction and loss of character and Plan objectives concerning the built and natural heritage of the County Borough. It aims to ensure that development proposals will complement and enhance the area generally, including its arterial gateways, townscapes, landscape and seascape, and retain existing character where this is desirable.

9.1.3 'Arterial Gateways' are those areas adjacent to the County Borough boundary which are prominent when entering or leaving Neath Port Talbot and help to define the character and image of the area. There are concerns that previous developments within these areas have detrimentally affected the appearance of the locality and consequently 84 the first impressions given to visitors and the overall image of the County Borough. 9.1.4 An analysis has been undertaken of the main routes by which people enter and leave Neath Port Talbot. Such routes include the M4 and mainline railway at Margam in the south east and Lonlas in the north west, along the A483 Fabian Way from Swansea and the A465 Heads of the Valleys trunk road at Glynneath. Other less major routes include the A474 and A4069 into the Amman Valley, the A4067 into the Swansea Valley, the A4107 into the Afan Valley and routes from Maesteg. 9 . Detailed Policy Development

9.1.5 Within these gateway areas, new developments will be required to take full account of their visual impact when seen from the main transport arteries, with careful attention 2013) being paid to siting, design, appearance, massing and scale to minimise any visual intrusion and where appropriate enhance the visual aspects of the area. (August

9.1.6 Drainage systems should be designed to ensure that developments have no Paper detrimental effects on the water environment or on flood risk. Normally this will involve the opic use of Sustainable Drainage Systems (SuDS) techniques. T

9.1.7 In order to make the best use of available land, developments should be designed where possible to maximise the accommodation provided while remaining in keeping with Environment

the surrounding area. In central locations which have good access to services, facilities - and public transport links, higher density developments will be appropriate. Policy H1 indicates those allocated residential sites where higher densities are considered to be LDP appropriate and will be encouraged. Deposit 9.1.8 Where appropriate, new developments will be required to demonstrate how they connect to existing, nearby communities. In the interest of achieving sustainable communities and to promote accessibility, connectivity between communities and facilities will need to be considered and routes to support these principles may need to be included within development proposals.

9.1.9 Good design includes paying regard to general amenity as well as appearance, accessibility and resource use. Where a site is to be developed with a mix of uses, careful consideration will need to be given to the interaction and relationship between the uses to ensure that they are compatible and integrate with one another and existing adjacent uses.

9.1.10 Detailed building design, from overall massing to finishing materials, plays an important role and should take account of and enhance the site's surroundings including other buildings, open spaces and topography. Landscaping has an important effect and is a significant part of the overall design process. The design and layout of new development can also have a significant effect on public safety and the fear of crime. The Local Planning Authority is required to have regard to crime and disorder prevention and the design of development should help to reduce opportunities for crime, disorder and anti-social behaviour.

9.1.11 Further information on design considerations will be given in Supplementary Planning Guidance.

9.1.12 Policy BE2: Buildings of Local Importance 85 Buildings of Local Importance

Development proposals that would affect buildings that are of local historic, architectural or cultural importance will only be permitted where: 9 . Detailed Policy Development

Deposit 1. They conserve and where appropriate enhance the building and its setting; or

LDP 2. It is demonstrated that the development could not reasonably be accommodated without affecting or replacing the building and the reasons for the development - Environment outweigh the heritage importance of the site. T

opic 9.1.13 Across the County Borough, there are many examples of buildings that play an important part in defining the character of places, but that do not merit inclusion in the Paper statutory list of buildings of architectural or historic importance. (August 9.1.14 Buildings may be significant for architectural reasons, giving character and sense of place to local centres and settlements, or may be of particular local historic or cultural 2013) importance. Where possible, developments should aim to complement such buildings and incorporate and adapt them within schemes where appropriate.

9.1.15 An inventory of 'Buildings of Local Importance' will be compiled as part of preparing Supplementary Planning Guidance and will include details of the interest of each building.

9.1.16 Policy BE3: The Canal Network

The Canal Network

1. In order to protect and conserve the canal network, the following lengths of canal will be safeguarded:

(a) The Swansea Canal at Trebanos from the County Borough boundary to the southern edge of the playing fields;

(b) The Swansea Canal from Pontardawe Town Centre to Godre'r Graig;

(c) The Tennant Canal;

(d) The Neath Canal from Briton Ferry to Ysgwrfa Bridge, Aberpergwm.

Proposals which would prejudice the conservation, restoration and operation of these safeguarded lengths of canal will be resisted. Proposals will need to demonstrate that they would not adversely affect the setting of the canals or prevent or discourage the use of the canals for recreation and water supply; 86 2. Developments affecting locations where lengths of canal have been drained, infilled or cut off from the remainder of the network, but where there is the possibility of future reinstatement, will be expected to take into account the historic line of the canal and to avoid where possible the introduction of buildings or structures that would prevent reinstatement. 9 . Detailed Policy Development

9.1.17 The canal network is an important part of the County Borough's historic heritage and is also significant for recreation, biodiversity and landscape reasons. There are three 2013) principal canals within Neath Port Talbot, comprising the Neath, Tennant and Swansea canals. Significant lengths of these canals have now been restored to navigable standards (August and they form part of a wider network of green corridors which encourage walking and

cycling attracting visitors to the area. There are however gaps in the network where the Paper line of the canals have been lost, or navigation is prevented by obstructions such as low opic bridges. T

9.1.18 The policy seeks to protect the canals where appropriate, in particular in areas where development could compromise their use and future restoration. Remaining extant Environment lengths of canal and lengths where there is a realistic prospect of restoration are - safeguarded by the policy thereby ensuring that they are not adversely affected by future LDP development. Such lengths of canal are identified on the Proposals Map.

9.1.19 The stretches of canal where restoration currently appears to be less likely, but Deposit may be feasible in the future, are also protected by the policy to ensure that new development does not cause any physical impediment.

9.2 Countryside and the Undeveloped Coast

9.2.1 Policy EN1: The Undeveloped Coast

The Undeveloped Coast

Development proposals within the undeveloped coast will only be permitted where it is demonstrated that a coastal location is necessary and the proposal relates to:

1. The management and/or maintenance of coastal or flood defences or coastal processes; or

2. The management and/or maintenance of shipping channels/ port access and other associated infrastructure; or

3. The provision of appropriate recreational, leisure, access or other necessary infrastructure.

9.2.2 A relatively limited area of Neath Port Talbot's coastline can be defined as undeveloped and much of this is protected by nature conservation designations, such as Crymlyn Burrows Site of Special Scientific Interest (SSSI). The area of coastline to which 87 the policy relates is defined on the Proposals Map and comprises the area around the estuary of the River Neath, sand dunes and salt marsh areas at Baglan Bay and Crymlyn Burrows. 9 . Detailed Policy Development

Deposit 9.2.3 Within the identified area only a limited range of development is likely to be acceptable, relating to necessary works for the maintenance of defences and shipping

LDP channels and provision for recreation, which should be limited generally to small scale provision for access where appropriate. The undeveloped coast designation will allow - Environment flexibility in responses to the future effects of climate change, in particular enabling the provisions of the Shoreline Management Plan in relation to managed realignment to be implemented. It will also help to protect areas of visual and biodiversity importance. T

opic 9.2.4 Policy EN2: Special Landscape Areas Paper

(August Special Landscape Areas

In order to protect areas of high landscape quality, the following Special Landscape 2013) Areas are designated:

Reference Special Landscape Area

EN2/1 Mynydd y Garth

EN2/2 Dulais Valley

EN2/3 Vale of Neath

EN2/4 Margam

EN2/5 Mynydd y Gelli

EN2/6 Foel Trawsnant

Development within the designated Special Landscape Areas will only be permitted where it is demonstrated that there will be no significant adverse impacts on the features and characteristics for which the Special Landscape Area has been designated.

9.2.5 As indicated above, a study has been undertaken of the County Borough's landscapes(33). Special Landscape Areas (SLAs) have been identified using the SLA Designation Criteria in the Countryside Council for Wales Guidance Note 1 (2008), utilising LANDMAP data. LANDMAP separates the landscape into five topic areas: geological landscape, landscape habitats, visual and sensory, historic landscape and cultural landscape and enables the identification of high quality landscapes.

9.2.6 This has resulted in the identification of six SLAs, designated to protect areas of 88 high landscape quality which are shown on the Proposals Map. The study identifies reasons for designation, primary landscape qualities and features and key policy and management issues relevant to each SLA.

33 Consultancy Services for the Provision of Landscape Advice - TACP (2011). 9 . Detailed Policy Development

9.2.7 While development is not precluded within the SLAs, these areas will be protected as far as possible from any development that would harm their distinctive features or 2013) characteristics. Applications for developments within these areas will thus have to conform to high design standards. (August

9.2.8 It is anticipated that minerals and renewable energy developments are likely to Paper be the predominant types of proposal that could have significant impacts. In the case of opic renewable energy developments, it will need to be demonstrated that component elements T have been designed and sited to minimise visual intrusion and adverse effects on the landscape, while mineral developments will be expected to provide screening or bunding during the operational phase and a site restoration scheme which returns the landscape Environment as far as practicable to its original form and appearance on completion of the works. -

9.2.9 In the case of single buildings, generally these should be located within an existing LDP building curtilage, farm complex or other group of buildings or immediately adjacent to a settlement limit wherever possible. In the case of groups of new buildings, these should Deposit be located adjacent to the settlement limit where appropriate, and the scale, form and design of the proposed development should conserve and where possible enhance the distinctive or characteristic features of the SLA.

9.2.10 Where approved, all developments will be expected to meet the highest design standards including use of appropriate materials and landscaping, careful attention to siting and retention as far as possible of important landscape features such as field boundaries, walls, hedges and trees to conserve and/or enhance the special qualities for which the SLA has been designated.

9.2.11 Policy EN3: Green Wedges

Green Wedges

In order to prevent the coalescence of settlements and to protect the setting of urban areas, Green Wedges have been designated in the following locations:

Reference Green Wedge

EN3/1 Alltwen / Rhos / Bryncoch / Neath Abbey / Leiros Park

EN3/2 Skewen / Birchgrove

EN3/3 Neath / Tonna / Cimla / Efail Fach

EN3/4 Crymlyn Bog / Crymlyn Burrows / Llandarcy 89 EN3/5 Margam

Within these areas there is a presumption against inappropriate development. 9 . Detailed Policy Development

Deposit 9.2.12 The landscape study referred to above in relation to SLAs also included consideration of Green Wedges. Green Wedges differ from that of SLAs in that they are

LDP primarily a planning tool to prevent urban coalescence and protect the setting of built-up areas, rather than specifically protecting high quality landscapes. - Environment 9.2.13 The study recommended that the five existing Green Wedges be retained largely unchanged, with the exception of minor changes to boundaries to take account of proposed developments and allocations where appropriate. T opic 9.2.14 Within the designated Green Wedges, inappropriate development will not be Paper permitted except in very exceptional circumstances. 'Inappropriate development' is defined in Planning Policy Wales and relates to all types of development other than those for (August certain justified or essential activities that need to be located in the area and small scale extensions or farm diversification. 2013) 9.2.15 Apart from those forms of development which are specifically defined as appropriate, any other development which would prejudice the openness of the Green Wedge are considered to be inappropriate. Green Wedge designations can provide opportunities for recreation and countryside access, support biodiversity, agriculture and rural interests, improve derelict land, provide carbon sinks and mitigate the effects of urban heat islands.

9.2.16 Policy EN4: Replacement Dwellings in the Countryside

Replacement Dwellings in the Countryside

The replacement of a dwelling outside settlement limits will only be permitted where all of the following criteria are satisfied:

1. It is demonstrated that the building has a current lawful use as a permanent dwelling;

2. The replacement dwelling, its means of enclosure, garden, parking space and other associated features, are sited within the curtilage of the building to be replaced;

3. The proposed scale, form, siting, design, materials and landscaping are suitable within its context and/or the context of the building to be replaced and would not have an unacceptable adverse effect on the character of the area;

4. The conservation of existing buildings which are of architectural or historic interest 90 would not be prejudiced;

5. The original dwelling is removed and the land suitably reinstated prior to the occupation of the new dwelling. 9 . Detailed Policy Development

9.2.17 The replacement or rebuilding of an existing lawful dwelling located in the countryside outside settlement limits is likely to be acceptable where the proposal will 2013) conserve and where possible enhance local biodiversity interest, the countryside and landscape. Opportunities to provide a high quality design which respects the local style (August and scale of dwellings, but which may be innovative, will be encouraged where appropriate.

The size, bulk and siting of the proposed building is likely to have a significant influence Paper on the visual and landscape characteristics of the area, and proposals should not normally opic exceed the overall dimensions or cubic content of the original building by more than 20% T or deviate significantly from the siting of the original building.

9.2.18 Policy EN5: Conversion and Extension of Existing Buildings in the Environment

Countryside - LDP

Conversion and Extension of Existing Buildings in the Countryside Deposit The alteration, extension or conversion of existing suitable buildings outside the defined settlement limits for residential, employment, or tourism uses will only be permitted where:

1. The existing building is structurally sound and is capable of conversion without substantial major external alteration or reconstruction.

2. In the case of changes of use to residential purposes alone:

(a) It can be demonstrated that there are no viable alternative uses to secure the retention of the building; and

(b) That the building is of architectural and/or historic merit.

3. In the case of residential extensions, the extension does not result in a disproportionate increase in the size, scale and massing of the building.

9.2.19 Buildings in the countryside that are to be converted to alternative uses will need to be suitable for the proposed purpose and in terms of their appearance in relation to their surroundings, the wider landscape and countryside and should be sound and capable of conversion to the proposed use without major reconstruction. Proposals that involve major significant changes to the original building will be dealt with in accordance with policy relating to new development outside settlement limits.

9.2.20 Residential uses of industrial, commercial or agricultural buildings can have an 91 adverse impact on the local economy and will therefore only be acceptable where the conversion facilitates the retention of an important building. These are likely to be substantial established buildings that are of significant merit in architectural or historic terms and developers will need to demonstrate that reasonable efforts have been made to market the premises for sale or lease for employment generating uses. 9 . Detailed Policy Development

Deposit 9.2.21 Extensions to buildings that are either existing dwellings in the countryside or are buildings being converted into dwellings should be limited in size to ensure that the

LDP form and character of the original building is not adversely affected. The size of extension likely to be acceptable will depend on the circumstances of each individual case, but - Environment extensions should not normally exceed the overall dimensions or cubic content of the original building by more than 20%.

9.3 Biodiversity and Geodiversity T opic 9.3.1 Policy EN6: Important Biodiversity and Geodiversity Sites Paper (August Important Biodiversity and Geodiversity Sites

2013) Development proposals that would affect Regionally Important Geodiversity Sites (RIGS), Local Nature Reserves (LNRs), Sites of Interest for Nature Conservation (SINCs), sites meeting SINC criteria or sites supporting Local Biodiversity Action Plan (LBAP) or S42 habitats or species will only be permitted where:

1. They conserve and where possible enhance the natural heritage importance of the site; or

2. The development could not reasonably be located elsewhere, and the benefits of the development outweigh the natural heritage importance of the site.

Mitigation and/or compensation measures will need to be agreed where adverse effects are unavoidable.

9.3.2 Regionally Important Geodiversity Sites (RIGS), Local Nature Reserves (LNRs) and Sites of Interest for Nature Conservation (SINCs) are locally identified sites that meet agreed criteria relating to their biodiversity or geodiversity importance, while the Local Biodiversity Action Plan (LBAP) identifies habitats and species that are priorities. S42 habitats and species are those listed by the Welsh Government as being of principal importance for the purposes of conserving biological diversity under the provisions of S42 of the Natural Environment and Rural Communities Act 2006(34).

9.3.3 Two RIGS have been identified within the County Borough(35) and these will be detailed in Supplementary Planning Guidance. The identification of SINCs is an on-going process, and identified sites will also be shown in SPG together with the criteria used for designation. The policy therefore relates to both identified SINCs and sites that meet SINC 92 criteria.

34 http://www.biodiversitywales.org.uk/biodiversity in wales-2.aspx 35 Geodiversity Sites: South Wales RIGS Audit (R Kendall and A Humpage - British Geological Survey 2012). 9 . Detailed Policy Development

9.3.4 Where harm to biodiversity sites is unavoidable, effective mitigation measures will be required to ensure that there is no reduction in the overall value of the area or 2013) feature. Where mitigation is not possible, compensation measures will normally be required to offset harm as far as practicable. However, compensation measures are considered to (August be a last resort option. Paper 9.3.5 The Biodiversity SPG will indicate how biodiversity should be taken into account opic in the planning process and will also give details of the procedure for providing off-site T compensation if necessary.

9.3.6 Policy EN7: Important Natural Features Environment -

Important Natural Features LDP

Development proposals that would adversely affect ecologically or visually important Deposit natural features such as trees, woodlands, hedgerows / field boundaries, watercourses or ponds will only be permitted where:

1. Full account has been taken of the relevant features in the design of the development, with measures put in place to ensure that they are retained and protected wherever possible; or

2. The biodiversity value and role of the relevant feature has been taken into account and where removal is unavoidable, mitigation measures are agreed.

9.3.7 In addition to designated SINCs and sites that meet SINC criteria, there are numerous local landscape features that are of importance for biodiversity, such as trees, woodland, hedgerows and other field boundaries, watercourses, wetlands and ponds and green lanes. These features can serve as 'corridors' or 'stepping stones' that connect areas of biodiversity importance and allow movement of species. Many such features may be multi-functional, having important roles as footpaths or cycle routes connecting settlements, as recreational open space and as visual/landscape features as well as their biodiversity role. Such features and areas should be retained and enhanced wherever possible.

9.4 Environmental Protection

9.4.1 Policy EN8: Pollution and Land Stability 93 Pollution and Land Stability

Proposals which would be likely to have an unacceptable adverse effect on health, biodiversity and/or local amenity or would expose people to unacceptable risk due to the following will not be permitted: 9 . Detailed Policy Development

Deposit Air Pollution;

LDP Noise Pollution; - Environment Light Pollution;

Contamination; T opic Land Instability; Paper Water (including groundwater) Pollution. (August

2013) Proposals which would create new problems or exacerbate existing problems detailed above will not be acceptable unless mitigation measures are included to reduce the risk of harm to public health, biodiversity and/or local amenity to an acceptable level.

9.4.2 Pollution of all types can cause significant damage to human health, biodiversity, quality of life and residential amenity and Policy EN8 is intended to ensure that developments will not exacerbate existing problems, cause new problems or result in more people being routinely exposed to unacceptable pollution levels of any type. The policy refers to unacceptable effects or risk, and the interpretation of this will depend on the type of pollution being considered and likely effects.

9.4.3 In relation to air quality, objectives are set for a range of pollutants(36)and Neath Port Talbot's air quality is measured against these objectives at a range of sites across the County Borough. This monitoring has identified areas of concern in some central urban areas, with exceedances in the Margam / Taibach area leading to the declaration of an Air Quality Management Area (AQMA) in 2001.

9.4.4 Development proposals that could potentially result in or contribute to breaches of any air quality objective will be required to show (through modelling exercises or other appropriate technical information, including taking into account cumulative impacts) that this will not occur. While the provisions would apply throughout the County Borough, developments in the vicinity of the AQMA that would result in additional direct emissions to the atmosphere or could have indirect effects such as through generating significant additional traffic are an example of such a proposal. If this requirement cannot be met, either with or without mitigation measures, the proposal will not be acceptable under the terms of the policy.

94 9.4.5 In the central Port Talbot area in particular, operations during the construction phase of developments have the potential to result in exceedences of air quality objectives relating to particulates. This may depend on local weather or atmospheric conditions and

36 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland (DEFRA 2007). 9 . Detailed Policy Development

the type of operations being undertaken. Policy EN9 sets out specific requirements for development in the central Port Talbot area and further information on this topic will be 2013) provided in Supplementary Planning Guidance.

9.4.6 In relation to noise, potentially noisy proposals should not be located close to (August sensitive uses (such as hospitals, schools and housing) and new noise-sensitive Paper developments should not be located near to existing noisy uses (including industry and opic existing or proposed transport infrastructure) unless it can be shown that adverse effects T can be dealt with through mitigation measures incorporated into the design. Where noise levels are likely to be a significant issue, developers may be required to provide information to show that no nuisance is likely to be caused through increased noise levels at sensitive Environment locations if the development proceeds. Policy EN9 sets out policy relating to designated - Quiet Areas. LDP

9.4.7 Light pollution can be an issue where it has potential adverse effects on the natural or historic environment, on people's health and amenity or on wildlife and habitats. These Deposit concerns will need to be balanced against the need to enhance safety and security and to enable sport, recreation and other activities to take place. Where lighting proposals have the potential to cause adverse effects, mitigation measures will be required to ensure that their impact is minimised.

9.4.8 Some of the Plan's brownfield allocations and proposals incorporate land that is contaminated due to past industrial uses. In many cases remediation measures have been or are being undertaken as part of the development process. In other cases, where contamination is likely or is found to be present, information will be required to show the level and type of contamination present, and proposals for remediation and mitigation to show that no adverse effects will be caused at any stage of development within or outside the site. In addition, developments and operations involving scrub clearance and soil removal off-site can have implications for the spread of invasive species, some of which (such as Japanese knotweed and Himalayan balsam) are subject to the Natural Resources Wales' licence control measures as part of the Environmental Protection Act (1990).

9.4.9 In cases where there is evidence that a site may be unstable, or that development may cause stability issues, developers may be required to undertake specialist investigation or assessment to show that the development can proceed safely and without having adverse effects. However, in such cases the responsibility and subsequent liability for the safe development and secure occupancy of the site rests with the developer and/or landowner.

9.4.10 Developments will be expected to minimise any adverse effects on water quality, and additional information may be required in cases where there may be issues relating to existing poor water quality or a development has the potential to cause pollution. 95 Developments will be required to ensure that no pollution is caused through drainage.

9.4.11 Policy EN9: Developments in the Central Port Talbot Area 9 . Detailed Policy Development Deposit Developments in the Central Port Talbot Area LDP Developments in the central Port Talbot area that could result in breaches of air quality -

Environment objectives during their construction phase, will be required to be undertaken in accordance with a Construction Management Plan submitted as part of the planning application and agreed by the Council. T opic 9.4.12 The construction of major developments in the central Port Talbot Area, including Paper (but not limited to) those within the Harbourside SRA, may potentially result in breaches

(August of air quality objectives in the surrounding area (including within the Margam/Taibach AQMA). The main risk relates to an increase in atmospheric particulates resulting from construction activities. Any such developments will consequently be required to submit a 2013) Construction Management Plan detailing measures to be taken to avoid this possibility. The Construction Management Plan should identify the construction operations that could cause air quality impacts and measures to prevent such impacts arising. These may include measures to minimise as far as possible the generation of dust, the modification or phasing of the more polluting activities and the suspension of any polluting activities at times of particular air pollution risk. Further details concerning these requirements will be set out in Supplementary Planning Guidance.

9.4.13 Policy EN10: Quiet Areas

Quiet Areas

In order to protect areas of tranquillity within urban areas, the following 'Quiet Areas' have been identified:

Reference Quiet Area

EN10/1 Neath Abbey Ruins, Neath

EN10/2 Mount Pleasant Park, Neath

EN10/3 Skewen Park, Neath

EN10/4 Shelone Woods, Neath

EN10/5 Victoria Gardens, Neath

EN10/6 Church Place, Neath 96 EN10/7 Talbot Memorial Park, Port Talbot EN10/8 Vivian Park, Port Talbot

EN10/9 Baglan Park, Port Talbot

EN10/10 King George V Park, Pontardawe 9 . Detailed Policy Development

Development proposals that would have unacceptable impacts on the characteristics that led to the designation will be resisted. 2013) (August 9.4.14 The Quiet Areas listed have been designated by the Welsh Government under the Environmental Noise (Wales) Regulations. They are public open spaces located within Paper the urban area that have local amenity value that warrants protection from noise intrusion opic and are relatively quiet by urban standards in actual and perceived terms. T

9.4.15 The following five ‘pillars’ of urban tranquillity, or criteria, have been identified: Environment

Soundscape; -

Presence of nature; LDP

Visual / aesthetic qualities; Deposit

A sense of personal safety;

The culture and freedom of the place.

9.4.16 The first three are criteria directly related to perceived quiet, while the remaining two are criteria which are not directly related to perceived quiet but which may nonetheless detract from the health and wellbeing benefits otherwise conferred by quiet.

9.4.17 The policy protects Quiet Areas from significant increases in noise or other impacts from development that would adversely affect these criteria. Where development is proposed near to a Quiet Area, it will be assessed in relation to its effects on the 'pillars' of urban tranquillity, and will be required to ensure that there are no significant adverse effects.

97 9 . Detailed Policy Development Deposit LDP - Environment T opic Paper (August 2013)

98 Local Development Plan Cynllun Datblygu Lleol

August 2013 ENVT1545 www.npt.gov.uk/ldp