Contents

1 Background 1 1 201

2 Introduction 3 3 National Policy Context 5 September

4 Regional Policy Context 15 , Paper 5 Local Policy Context 17 opic T 6 Key Issues in 25 7 Current and future trends 41

8 Conclusions and Strategy Formulation 45 Environment

and 9 Preferred Strategy 47 Change Appendices Climate A Strategic Flood Consequences Assessment 57 A.1 Introduction 57 A.2 National Policy, Guidance, Plans and Strategies 57 A.3 The Strategic Flood Consequences Assessment 62 A.3.1 Fluvial/River Flood Risk 62 A.3.2 Tidal Flood Risk 62 A.4 LDP Strategy on Flood Risk 63 A.5 How to comment 63 A.6 Maps 65 A.6.1 Development Advice Map for 65 A.6.2 Shoreline Management Plan 66 A.6.3 Flood Risk Areas in Neath Port Talbot 68 Contents Climate

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1 Background 1 201

1.0.1 This is one of a range of emerging papers prepared to offer more detailed information and explain the approach of the plan in relation to different topics and issues September affecting the County Borough. This paper will look specifically at the Climate Change and , the Environment and encompasses a range of issues including the built environment, Paper natural heritage, flooding and pollution. It will explain the background which will help to

identify objectives, issues, options and the preferred strategy for the LDP. The paper will opic T be developed as the preparation of the Deposit Plan proceeds and a final version will be published at the Deposit stage.

1.0.2 A Strategic Flood Consequences note is contained as an independent document Environment in Appendix A. and

1.0.3 The Pre-Deposit Plan is the first statutory stage of the LDP. The LDP shapes

the future growth of communities in Neath Port Talbot and will set out the policies and Change land allocations against which planning applications will be assessed.

1.0.4 The Pre-Deposit Plan is also an important opportunity to comment on the strategies Climate that will shape the final Deposit Plan. The Deposit Plan is the second statutory stage of the plan and will allow a further period of formal public consultation. The Deposit Plan will be submitted to the Welsh Government, which will appoint an Independent Inspector to assess the soundness of the Plan in the Examination in Public. If the Inspector considers the Plan to be sound it will be recommended for adoption. Once adopted the LDP will supersede the Neath Port Talbot Unitary Development Plan, and be the document which allocates sites for development and identifies policies which will be used to determine all planning applications in Neath Port Talbot.

1.0.5 The topic paper can be read in isolation or in conjunction with the other Topic papers and Background papers that have been prepared to give a full picture of Neath Port Talbot.

1.0.6 If you have any comments on this Topic Paper they can be submitted on line on the Council's website www.npt.gov.uk/ldp. Follow the LDP logo to the portal page and post your comments direct. Alternatively you may submit them in writing to the address below or via email to [email protected]. Comments will have to be received before midnight on 17th October 2011 and the name of the Topic Paper and specific paragraph to which the comment relates will need to be identified in your response.

1 1 . Background Climate LDP Team

Change Neath Port Talbot County Borough Council The Quays

Brunel Way and Baglan Energy Park

Environment Neath SA11 2GG

01639 686821 T opic

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2 2 . Introduction

2 Introduction 1 201

2.0.1 Delivering sustainable development is a central principle of the Planning Process. This paper covers a range of issues and topics under the umbrella 'Climate Change and September

Environment.' ,

2.0.2 The Planning system has a key role in addressing environmental issues, ensuring Paper new developments and the urban form enable residents to reduce their ecological footprint opic T and where adverse impacts on the environment do occur taking this into account through mitigation measures. There are a number of challenges which the County Borough will face over coming years, including addressing the impacts of Climate Change, and integrating policies and strategies to promote and deliver sustainable development. Environment

and 2.0.3 This paper will cover the following topic areas:

Climate Change Change

Built environment - including design, sustainable building standards and heritage Climate Natural heritage - including biodiversity, habitats, greenspace, seascapes and landscape

Pollution - noise, air, land, light and water pollution

Flooding - including Appendix A 'Strategic Flood Consequences Assessment'

2.0.4 In addition to this topic paper the LDP Pre-Deposit has been subject to a Sustainability Appraisal/Strategic Environmental Assessment 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 SEA/SA Interim Report.

3 2 . Introduction Climate

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4 3 . National Policy Context

3 National Policy Context 1 201

Wales Spatial Plan (WSP) 2008

3.0.1 One of the key priorities for the Waterfront and Western Valleys September

Area, in which Neath Port Talbot lies, is to ensure that environmental protection and ,

enhancement are fully integrated. This includes protecting and enhancing the biodiversity Paper of the area and managing the risks of the disconnection and isolation of habitats from opic T changes in land use and climate.

3.0.2 The WSP recognises that the natural environment underpins the success of the Area and is central to the quality of life of residents, visitors and employees and is vital in Environment ensuring that we retain jobs, attract inward investment and diversify our local economy. and

3.0.3 In terms of the built environment, the Spatial Plan states that the quality of design of buildings and public spaces in the area’s city, town centres and smaller Change 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 Climate to the attractiveness of the city-region as a whole

3.0.4 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.

3.0.5 A more detailed extract from the Wales Spatial Plan is provided in Appendix K of the Pre-Deposit Plan.

Planning Policy Wales (PPW) (2011)

3.0.6 PPW identifies a number of broad objectives which reflect the sustainable development agenda and the Welsh Government's 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 . National Policy Context

Climate 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

Change enhanced standards, and ensure that public buildings (including major renovations) fulfill an exemplary role.

and Support the need to tackle the causes of climate change by moving towards a low

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

T opic Minimise the risks posed by, or to, development on, or adjacent to, unstable or

Paper 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 ,

September and built environment.

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

201

1 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 Green Wedges and local designations such as 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 . National Policy Context

Encourage opportunities to reduce waste and all forms of pollution and promote good 1 201 environmental management and best environmental practice. Waste arising from demolition and construction should be minimised, and opportunities to recycle and re-use this waste promoted. September

, 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 needs where appropriate, in safe neighbourhoods. opic T

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

and Foster improvements to transport facilities and services which maintain or improve accessibility to services and facilities, secure employment, economic and environmental

objectives, and improve safety and amenity. In general, developments likely to support Change

the achievement of an integrated transport system should be encouraged.

Foster social inclusion by ensuring that full advantage is taken of the opportunities to Climate secure a more accessible environment for everyone that the development of land and buildings provides. This includes helping to ensure that development is accessible by means other than the private car.

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

Support initiative and innovation and avoid placing unnecessary burdens on enterprises (especially small and medium sized firms) so as to enhance the economic success of both urban and rural areas, helping businesses to maximise their competitiveness.

Respect and encourage diversity in the local economy.

Promote a greener economy and social enterprises.

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 7 local diversity and protecting the character and cultural identity of communities.

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

Chapter 4: Planning for Sustainability. 3 . National Policy Context

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

Change Chapter 6: Development Plans and the historic environment which includes conservation areas, areas of archaeological interest and listed buildings.

and

Environment 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

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Paper 3.0.8 More specific guidance is provided in supporting Technical Advice Notes: ,

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

3.0.9 TAN 5:

201 Identifies the legislative requirements, including the National Environment and Rural 1 Communities Act 2006, Countryside Act 1968, the Wildlife and Countryside Act 1981, and the specific requirements of the Conservation (Natural Habitats & c.) Regulations 1994 concerning European Wildlife Sites;

sets out the key principles of planning for nature conservation;

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 species.

3.0.10 The TAN provides advice on how the land use planning system should contribute to protecting and enhancing biodiversity and conserving geodiversity. The importance of geodiversity is identified as the basis for landscapes, rocks, minerals, soils and other superficial deposits. Geodiversity is important because it underpins biodiversity with soils being the link between them. The geology of Wales, including its landforms, minerals and fossils, is diverse, visually impressive and of great scientific importance. 8 Draft Technical Advice Note (TAN)5 Annex ‘The Assessment of Development Plans in Wales under the Provisions of the Habitats Regulations’ (2006)

Provides advice on the implementation of the Regulations for Local Development Plans. 3 . National Policy Context

Technical Advice Note (TAN) 8: Planning for Renewable Energy (2005) 1 201

3.0.11 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 September development and BREEAM scheme for non-residential development form a useful ,

framework for energy efficiency consideration. Furthermore, developers need to consider Paper the use of low and zero carbon energy sources as part of their approach to reducing carbon opic T emissions associated with developments.

Technical Advice Note (TAN)11: Noise (1997) Environment 3.0.12 TAN 11 indicates that noise policies may apply to the plan area as a whole but and that area specific noise policies may be useful in some circumstances with relevant boundaries illustrated on the proposals map. It is pointed out that it will generally be inappropriate for a proposals map to show detailed noise contours as noise emissions Change may change significantly over time.

3.0.13 It is suggested that plans should contain an indication of any general policies Climate which the local planning authority proposes to apply in situations where it is particularly 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 planning applications for residential development near transport related noise sources.

Technical Advice Note (TAN)12: Design (2009)

3.0.14 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. 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 occupiers.

3.0.15 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. 9 3.0.16 Detailed advice is given on the following design issues:

• Inclusive design

• Transport and movement 3 . National Policy Context

Climate • Landscape

Change • Biodiversity

• The historic environment

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Environment • Urban regeneration

• Rural areas

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Paper • The public realm ,

September • Public art

• Signs and advertisements

201 • Housing design and layout 1 • Employment and commercial areas

• Environmental sustainability

3.0.17 • Design and public safety

Technical Advice Note (TAN) 15: Development and Flood Risk (2004)

3.0.18 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.

3.0.19 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.

10 Technical Advice Note (TAN)18: Transport (2007) 3.0.20 The TAN 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 . National Policy Context

3.0.21 Careful consideration should be given to location, access arrangements and 1 201 design to encourage walking as a prime means for local journeys.

Technical Advice Note (TAN) 22: Sustainable buildings (2010) September

3.0.22 TAN 22 states that design guidance on delivering sustainability and in meeting ,

sustainable building standards can usefully be addressed through supplementary planning Paper guidance. Furthermore, the scale and mix of a development can provide opportunities to opic T 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 technologies. It is the aspiration of the Welsh Government for all buildings built from 2011 onwards to be zero carbon hence the Local Authority needs to maximise opportunities to Environment meet higher sustainable building standards. and

Environment Strategy for Wales (2006) Change 3.0.23 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 Climate Government's Vision for the environment and how change will be enabled under 5 key environmental themes

Addressing climate change

Sustainable resource use

Distinctive biodiversity, landscapes and seascapes

Our local environment

Environmental hazards

3.0.24 The Environment Strategy for Wales indicates that in order to deliver high quality 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 where flood risk is understood and managed.

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

3.0.26 The Environment Strategy specifically considers Biodiversity and provides outcomes for 2026. 11 3 . National Policy Context

Climate In addition to the TANs and The Environment Strategy more specific policies and information is provided in documents relating to specific topics within the Climate Change

Change and Environment theme:

Design

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Environment Manual for Streets (2007)

3.0.27 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,

T

opic mixed communities consistent with the policy objectives of Planning Policy Wales.

Paper 3.0.28 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

September is encouraged.

3.0.29 The way streets are laid out and how they relate to the surrounding buildings

201 and spaces has a great impact on the aesthetic and functional success of a neighbourhood. 1 3.0.30 The importance of inclusivity is stressed, and the need for good design and high-quality construction, followed by good management and maintenance.

Pollution

Environment Act (1995)

3.0.31 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.

Pollution Prevention and Control Act (1999)

3.0.32 The Act implements European Directive 96/61/EC concerning integrated pollution prevention and control. It sets out powers for local authorities and the Environment Agency to regulate pollution (emissions and waste production) from installations through regulation, permitting and monitoring.

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

3.0.33 Sets out air quality standards and objectives to be achieved: introduces a new policy framework for tackling fine particles; identifies potential new national policy measures to give further health benefits.

12 Environmental Noise (Wales) Regulations (2006)

3.0.34 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 3 . National Policy Context

and Quiet Areas within the agglomeration are being defined. These will need to be taken 1 201 into account in the development of LDP policies and allocations. The LDP will also include policies on the location of noisy uses and the protection of areas undisturbed by noise

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

,

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

EU Thematic Strategy for Soil Protection (COM(2006)231) Environment 3.0.36 Emphasises the protection and sustainable use of soil, with restoration of degraded

soils where possible. and

Environmental Protection Act 1990 (amended by the Environment Act 1995) Change

3.0.37 Places a duty on local authorities to inspect their area for contaminated land.

Contaminated land is defined as: Climate

“Any land which appears to the local authority in whose area it is situated to be in such a condition, by reason of substances in, on or under the land that:

(a) significant harm is being caused or there is a significant possibility of such harm being caused; or

(b) pollution of controlled waters is being, or is likely to be caused.”

Natural Heritage

UK Biodiversity Action Plan (UKBAP) (2004)

3.0.38 The Convention on Biological Diversity of 1992, led to the UK Government’s 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 provide the context for Local Biodiversity Action Plans (LBAPs).

Wildlife and Countryside Act 1981 (as amended)

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

Natural Environment and Rural Communities Act 2006

3.0.40 Provides legislative changes to amend nature conservation legislation, and in 13 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 . National Policy Context Climate

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14 4 . Regional Policy Context

4 Regional Policy Context 1 201

4.0.1 There are two regional Plans of relevance to flooding which are described in greater detail in Appendix A 'Strategic Flood Consequences Assessment.' September

Ogmore to Tawe Catchment Flood Management Plan (CFMP) (2010) , Paper 4.0.2 This is prepared by the Environment Agency and identifies policy areas affecting opic T Neath Port Talbot. The CFMP considers all types of inland flooding, from rivers, groundwater, surface water and tidal flooding, but not flooding directly from the sea (coastal flooding) – this is covered by the Shoreline Management Plan (SMP). Environment 4.0.3 The role of the CFMP is to establish flood risk management policies which will and deliver sustainable flood risk management for the long term.

4.0.4 The Plan identifies a number of sub-areas which have similar characteristics, Change sources of flooding and levels of risk. In each of these sub-areas the most appropriate approach to managing flood risk is identified and a generic risk management policy allocated. Five of the sub-areas fall within Neath Port Talbot: Climate

Upland Rivers (including the upland reaches of the Rivers Tawe, Neath and Afan) – areas of low to moderate flood risk where the Environment Agency and partners are generally managing the flood risk effectively;

Tawe Valley (from Trebanos to and beyond) – areas of moderate to high flood risk where the Environment Agency and partners can generally take further action to reduce flood risk;

Upper Neath (including the area covered by the Neath Valley spatial area) – areas of low, moderate or high flood risk where the Environment Agency and partners are already managing the flood risk effectively but where there may be a need to take further actions to keep pace with climate change;

Lower Neath (including the dense urban area of Neath) – areas of low, moderate or high flood risk where the Environment Agency and partners are already managing the flood risk effectively but where there may be a need to take further actions to keep pace with climate change; and

Port Talbot (including the dense urban area of Port Talbot and ) – areas of moderate to high flood risk where the Environment Agency and partners can generally take further action to reduce flood risk. 15 4 . Regional Policy Context

Climate Shoreline Management Plan (SMP) (2010)

Change 4.0.5 The SMP is prepared by the Environment Agency 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

and manage these risks to people and to the developed, historic and natural environment in

Environment a sustainable manner.

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

T opic 4.0.7 The area of coastline within Neath Port Talbot falls within Policy Scenario 8: Sker

Paper Point to Swansea Docks. The following policies are proposed: ,

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

201 Managed realignment for the sand dune systems which will allow them to continue

1 to evolve naturally.

A long-term policy of hold the line is also recommended at the former BP tank farm site to the west of Crymlyn Burrows.

4.0.8 More detail is provided in Appendix A 'Strategic Flood Consequences Assessment.'

16 5 . Local Policy Context

5 Local Policy Context 1 201

Neath Port Talbot Unitary Development Plan (2008)

5.0.1 A primary aim of the UDP is to move towards Sustainable Development and the September effective protection of the environment is identified as one of the plan's most fundamental ,

and important duties. Paper

opic T 5.0.2 A key task is to protect and enhance the County Borough's landscape, seascape, natural resources, habitats and species and hold them in trust for future generations. The UDP also recognises that the protection and enhancement of the area's built environment, open areas and cultural heritage are of central importance to the quality of life. Environment

and

5.0.3 The key objectives for the Environment in the UDP are:

protecting and enhancing Neath Port Talbot’s landscape, seascape, species and Change habitats, not only the most special but whenever the site contributes to the landscape character and, or the biodiversity of the area; Climate protecting and encouraging the enhancement of the area’s buildings, townscape, and historic remains;

minimising the creation of pollution, and contamination and within the Port Talbot Air Quality Management Area the creation of new sources of particulates (which are the main cause of pollution within the area) and protecting sensitive uses from pollution;

resisting development which would bring hazardous or bad neighbour processes into close contact with housing or other sensitive uses;

resisting development which could create or be affected by flooding, tidal inundation or unstable ground;

resisting development which would sterilise significant reserves of natural resources;

resisting development which would have an adverse effect on the amenity or security of residential areas, whether on an individual case or if a number of similar proposals took place;

ensuring that new development makes its fair contribution to mitigating its impacts on the environment, and community, including design, energy and water efficient layout and design, density of development measures to encourage recycling of waste and tree planting to address global warming; 17 ensuring that the most sustainable use is made of previously developed (brownfield) land, and that opportunities are taken to address pollution,contamination and unstable land. 5 . Local Policy Context

Climate Community Plan (2010)

Change 5.0.4 The Community Plan identifies the following vision for Neath Port Talbot:

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

Environment themselves, each other and their communities; with greater opportunity for all – in a greener, healthier and safer environment.”

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opic 5.0.5 A key environmental issue is identified:

Paper 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

September 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

201 government, but air quality is improving, with only 15 exceedances being recorded 1 in 2009;

5.0.6 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.

5.0.7 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.

The public’s sense of responsibility to re-use, minimise, reduce and recycle waste is 18 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. 5 . Local Policy Context

The quality of the built environment is improved, including its accessibility and energy 1 201 efficient street lighting is provided, which also helps people feel safer.

All citizens have safe, litter-free, accessible green spaces within walking distance September

from their homes , Paper Western Valleys Strategy (2006) opic T

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

5.0.9 The Valleys promise for the area is: and

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

5.0.10 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 environments 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.

5.0.11 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;

Seek external sources of funding to enhance the built environment e.g. Commercial Improvement Grants; 19 Protect, as appropriate, the natural environment; 5 . Local Policy Context

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

Change habitats;

Support projects to improve and conserve habitats of importance and link green areas

and with the Biodiversity Plan.

Environment

5.0.12 The Strategy Seeks to:

T

opic (i) Raise the architectural quality of new development by utilising planning design guidance;

Paper (ii) Soften existing landscapes e.g. by tree planting, land reclamation so as to improve ,

September derelict and waste land, including contaminated brownfield land;

(iii) Encourage the re-use, redevelopment or renewal of redundant and derelict land

201 and buildings and the removal of blights and eyesores by: 1 (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.

5.0.13 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

5.0.14 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 do business a number of Regeneration initiatives and programmes are being implemented by the Council.

These include:

Upper Neath Valley Regeneration Strategy

5.0.15 The strategy area includes the communities of and as well as the smaller communities of /Cwmgwrach, Pontwalby, Pontneddfechan, Clyne, Melincourt and . The strategy looks to create local employment 20 opportunities and develop quality facilities to service the prosperity, health and wellbeing of the communities.

Milland Road/ Canal Green Regeneration Study

5.0.16 The study envisages the redevelopment of an area adjacent to the east bank of the adjoining Neath town centre (Canal Green). The area is currently occupied by a number of established industrial uses with areas of dereliction adjacent to the canal. 5 . Local Policy Context

The proposal is to redevelop the area into a new ‘East Bank Quarter’ with a mixture of 1 201 retail, office, community and residential uses. The study highlights the importance of the area in historical terms and recommends reconnecting it to the town centre and routes along the river and canals to other parts of the town and nearby countryside. September

Neath Town Centre Retail Led Mixed Use Development Opportunity , Paper 5.0.17 An area in Neath town centre has been identified for redevelopment. The site opic T 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. The uses proposed in the study include 20522 sq.m of retail; 1329 sq.m of café/restaurant premises; some 870 car parking spaces; a new library and museum building; a relocated Environment shop-mobility facility and management offices and residential accommodation. and

5.0.18 The illustrative scheme envisages a central feature building for the proposed library and museum and the creation of new public squares and open areas including a Change café quarter and the re-alignment/closure of parts of some existing streets.

Pontardawe Regeneration Strategy Climate

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

Waterfront Strategy

5.0.20 The Waterfront Strategy that 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.

5.0.21 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 21 Coed D’Arcy

Port Talbot Harbour Way - a major mixed use redevelopment scheme. Supplementary Planning Guidance is available on the UDP web site

Green Park, Gas Works, Port Talbot Industrial Estate 5 . Local Policy Context

Climate Fabian Way

Change Junction 38

Neath Estuary – Wharf

and

Environment 5.0.22 The strategy identifies the following tourism / leisure sites which have potential to contribute to the growth and diversity of the local economy:

T Margam Park opic

Paper Aberafan Seafront ,

September Brunel Dock

5.0.23 The following strategic goals are identified: 201

1 Strategic Goal 1

To develop the town of Port Talbot as a hub for commercial, residential, social and employment activities through an integrated physical 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 employment opportunities and spread prosperity to surrounding communities.

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 the local economy and ensure the provision of employment opportunities.

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 22 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 5 . Local Policy Context

To improve the transport and communications infrastructure, ensuring that the area of 1 201 Port Talbot maximises its locational advantages and brings benefits to the economy and people of the area.

5.0.24 In addition to the documents detailed above providing the overarching Policy September

Framework guidance is provided for specific topics within the Climate Change/Environment ,

theme. Paper

opic T Natural heritage

Local Biodiversity Action Plan (2008) Environment 5.0.25 A Local Biodiversity Action Plan was produced on behalf of the Neath Port Talbot

Biodiversity Forum and published in 2008. and

5.0.26 The LBAP lists action plans for a number of species and habitats of national Change and/or local priority in Neath Port Talbot and sets out the targets for conservation action over the next 5 years (2008-2012). Climate 5.0.27 The overall aims of the LBAP are :

To increase awareness of the importance of our local wildlife

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

To influence man's activities to be more sensitive to local biodiversity needs

To enhance and protect existing habitats, to restore former habitat and actively create new ones

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

Pollution Western Wales River Basin Management Plan (RBMP) (2009) 23 5.0.28 The RBMP addresses water quality and quantity, with the following objectives:

Improving rural land management;

Reducing the impact of transport and built environments; 5 . Local Policy Context

Climate Securing sustainable amounts of water;

Change Improving wildlife habitats;

Addressing point source pollution

and

Environment Neath Port Talbot Contaminated Land Strategy (2005)

5.0.29 Sets out the Council’s approach to inspecting its area, locating and ensuring the

T remediation of all statutory designated contaminated land under the requirements of the opic Environmental Protection Act 2001.

Paper Air Quality Management Area ,

September 5.0.30 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.

201 5.0.31 A number of local hotspots relating to congestion have been identified and are 1 being addressed through traffic and environmental health management.

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

5.0.32 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.

24 6 . Key Issues in Neath Port Talbot

6 Key Issues in Neath Port Talbot 1 201

6.0.1 An overarching aim of the LDP is to deliver sustainable development which requires the balancing of economic, environmental and social issues and concerns. The Pre-Deposit September

Plan has been subject to a Sustainability Appraisal and the key findings are presented in , the SEA/SA Interim Report. Paper

Climate Change opic T

6.0.2 A key issue which Neath Port Talbot has to tackle is climate change. Research into the likely impacts of climate change is leading to an increasing consensus about the implications for the UK. The UK Climate Change Impacts Programme (UKCIP) published Environment information in summer 2009 detailing a range of results taking into account variations and between different global climate models and uncertainties in global climate modelling.

The medium emissions scenario for 2050 indicates: Change

Across Wales by 2050 average annual temperatures are projected to increase by

2.3ºC Climate

In summer, daily maximum temperatures are projected to increase by 3.4ºC

In winter, daily maximum temperatures are projected to increase by 2.5ºC

Rainfall is projected to increase in winter on average by 14% and decrease in summer by 16%. Overall, the total annual rainfall is predicted to remain the same.

Sea levels around Wales are predicted to rise by approximately 20cm by 2050.

6.0.3 The LDP has a central role in responding to the challenges presented by Climate Change in order to create a more resilient environment and in reducing emissions and mitigating against climate change.

Built Environment

6.0.4 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 25 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; 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. 6 . Key Issues in Neath Port Talbot

Climate 6.0.5 Over recent years the County Borough has attracted a new range of industry and employment opportunities including tourism and service industries. The natural environment

Change also remains an important source of employment with coal mining and renewable energy developments such as wind farms altering the landscape.

and 6.0.6 The LDP will need to assess and take into account these pressures, evaluate

Environment which are most likely to influence the area over the plan period and set out the aims and objectives for the built environment and how these are to be achieved.

Historic Conservation:

T opic 6.0.7 Neath Port Talbot has a significant built heritage resource in terms of conservation

Paper areas, listed buildings, scheduled ancient monuments and archaeologically sensitive areas ,

that, together with their settings, require protection: September

There are two Designated landscapes of outstanding historic interest; Merthyr Mawr, Kenfig and Margam Burrows; and Margam Mountain.(1)

201

1 There are 6 Historic Parks and Gardens: Jersey Park in , Margam Park in Margam, The Gnoll in Neath, Victoria Gardens in Neath, Talbot Memorial Park in Port Talbot and Rheola in the Neath Valley.

There are 6 Conservation Areas in the County Borough:

Glynneath Woollen Mill

Margam Park

Neath Town Centre

Tonna Canal Depot

Llandarcy

Cilybebyll

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.

There are 391 Listed Buildings in the County Borough, seven of which are grade 1, 26 36 grade 2* and the remainder are grade 2.

1 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 6 . Key Issues in Neath Port Talbot

6.0.8 In addition to the designated areas of historic importance in Neath Port Talbot 1 201 there are other areas of local importance; many communities in Neath Port Talbot have distinct identities and a rich cultural heritage.

6.0.9 There are, however, a number of derelict buildings in the County Borough which September are falling into disrepair. This is having a negative impact on the built environment and, ,

as discussed in the stakeholder meetings, there is widespread support for these to be Paper brought back into use as they form an important part of the area's heritage and history. opic T

6.0.10 The Canal network in particular is an important part of the County Borough's 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 Environment standard. The canal system forms part of a network of green corridors which encourages and walking and cycling and attracts visitors to the area.

6.0.11 The County Borough has traditionally attracted heavy industry, particularly along Change the M4 corridor. With the decline of mining and traditional industries large areas of land, 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 Climate access road into Port Talbot Docks, open up areas of land for redevelopment and provide a new gateway into the town.

6.0.12 The arterial gateway into Port Talbot in this location, and others routes into the County Borough, play an important role in defining the area's image. In the past, developments have taken place within these gateways that have detrimentally affected the aesthetics of the area. It is important that important gateways are protected and enhanced in a positive and aesthetically pleasing way.

Renewable Energy and Low Carbon Generation

6.0.13 Buildings are a major contributor to greenhouse gas emissions through both their construction and occupation. WG has recognised this and have implemented stricter building standards with the aim of moving towards zero carbon developments while the LDP is expected to identify strategic sites to make enhanced contributions. There are a range of criteria which new developments have to meet and this is regulated by Building Control. Small-scale renewable energy schemes are likely to become increasingly common 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. 6.0.14 The Coed Darcy Urban Village is to be an exemplar development of low carbon 27 living.

6.0.15 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 the Planning framework is placing increased emphasis on encouraging active, more 6 . Key Issues in Neath Port Talbot

Climate sustainable modes of transport for example walking and cycling. This therefore requires new developments to be designed to allow for permeability and easy access to facilities

Change and services by non-car modes.

Natural Heritage

and

Environment 6.0.16 The County Borough has a varied landscape and a number of distinctive habitats ranging from the coastal salt marsh and sand dunes to ancient woodland and areas of purple moor grass in upland areas. There are a number of areas of international, national, regional and local importance in Neath Port Talbot:

T opic European Sites

Paper

, 6.0.17 “European Sites” include all nature conservation sites designated as Special

September Protection Areas (SPAs), Special Areas of Conservation (SACs) and European off-shore marine sites (EOMS), as well as Ramsar sites. There are three SACs in Neath Port Talbot and a further 2 within 5km:

201

1 Table 6.1 : European Sites within 5km of Neath Port Talbot

Name of site Location Reason for designation

Crymlyn Bog Straddles the boundary Primary habitats: SAC and Ramsar between Neath Port Talbot and Site Swansea 1. Transition mires and quaking bogs;

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

Qualifying habitats:

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

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

Qualifying habitats:

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

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

2. Dunes with Salix repens ssp. Argenta (Salicion arenariae) 6 . Key Issues in Neath Port Talbot 1 Name of site Location Reason for designation 201

3. Humid dune slacks

4. Hard oligo-mesotrophic waters with benthic September

vegetation of Chara spp , Paper

Qualifying habitats: opic T

1. Atlantic salt meadows (Glauco-Puccinellietalia maritimae) Environment

Primary species: and

1. Petalwort Petalophyllum ralfsii Change 2. Fen orchid Liparis loeselii Climate

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

Cefn Cribwr Bridgend County Borough Primary habitats: Grasslands SAC Council 0.32km from Neath Port Talbot 1. Molinia meadows on calcareous, peaty or boundary clayey-silt-laden soils (Molinion caeruleae)

Qualifying species:

1. Marsh fritillary butterfly Eurodryas, Hypodryas) aurinia

There are 20 Sites of Special Scientific Interest and their condition is of concern.

There is a National Nature Reserve (Crymlyn Bog and Pant-y-Sais Fen) and 3 Local Nature Reserves (Eaglesbush Valley, Pant-y-Sais Fen and Swansea Canal). The Local Biodiversity Action Plan identifies 62 priority species/species of local 29 concern.

6.0.18 Monitoring the effects of development on wildlife indicates a continuing loss of priority habitats. The LDP needs to address this in a co ordinated approach including avoiding harm and providing adequate mitigation. 6 . Key Issues in Neath Port Talbot

Climate Landscape

Change 6.0.19 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. Reflecting the County Borough's potential for the large scale development of resources

and that are located in the countryside including coal, stone and wind farms, there is pressure

Environment for development that would impact upon these landscapes.

6.0.20 There are a number of Green Wedges identified in the UDP in order to protect the setting of communities and prevent coalescence between settlements. These are

T

opic located in the following areas:

Paper /Rhos/Bryncoch/Neath Abbey/Leiros Park ,

September /Birchgrove

Neath/Tonna/Cimla/Efail Fach

201

1 Crymlyn Bog/Crymlyn Burrows/Llandarcy

Margam

6.0.21 These areas are identified of particular importance in providing a backdrop to our main towns, or in separating and defining settlements. Although they may not necessarily be particularly attractive scenically, they contribute strongly to the quality of life in our communities. They face continual pressure from erosion for development, and the range of community uses that need to be located in the countryside, all of which have the potential to harm the character of these areas.

6.0.22 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 also contain significant areas that are of national significance for their coal, stone aggregate and wind power resources. As a result much of the landscape faces pressure for large and intrusive development. Some of the development such as coal mining would be of limited time scale (although open cast coal mining in some areas has continued for over 60 years), while others such as wind farms or quarries would be longer term or permanent. Although strenuous efforts are made to restore workings and sites, it may not be possible to recreate distinctive features or character of the original landscape. 30 Pollution Land contamination

6.0.23 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 6 . Key Issues in Neath Port Talbot

extensive remediation before redevelopment. Over recent years a number of these sites 1 201 have been prepared for redevelopment for example the old BP works at Coed Darcy and .

Air quality September

,

6.0.24 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland sets Paper national air quality objectives for a range of pollutants and Neath Port Talbot’s air quality opic T is measured against these objectives at a number of sites across the County Borough. The following results have been recorded for 2009:

Table 6.2 : Air Quality, Neath Port Talbot, 2009 Environment

Pollutant Monitoring Site and

PM10 Port Talbot Fire Station Change

The National Air Quality Objective level was breached on 15 days during 2009. This is the lowest number ever recorded. It is not yet clear whether this is due to Climate improvements in emissions or reduced production at the Tata site.

Port Talbot Fire Station and other Nitrogen Dioxide sites

Levels of nitrogen dioxide did not breach the Objective level Monitoring was conducted for a full at most locations. The exception was Water Street, Port year at 16 locations including Neath, Talbot, where steps are currently being taken to combat the Briton Ferry, Port Talbot and problem Pontardawe

Sulpuhr Dioxide Port Talbot Fire Station

The National Air Quality Objective level was not exceeded at any point during the year. There were five exceedances during 1998.

Carbon Monoxide Port Talbot Fire Station

No exceedances

Ozone Port Talbot Fire Station

There were 15 exceedances during 2009 (Highest areas nationally tend to occur in rural areas in Summer) 31 6.0.25 The exceedances in PM10s in the Margam/Taibach area led to the declaration of an Air Quality Management Area (AQMA) in 2000. Monitored levels of PM10s are shown below: 6 . Key Issues in Neath Port Talbot

Climate Figure 6.1 PM10 Exceedances, 1999-2009

Change

and

Environment

T opic

Paper ,

September

201 1

6.0.26 Map 6.1 'Location of AQMA and concentrations of PM10s' shows the location of

the AQMA, together with concentrations of PM10s, indicating in general terms that there are higher concentrations of particulates along the M4 corridor and other major roads.

6.0.27 A detailed assessment of nitrogen dioxide levels in the county borough was undertaken in 2007 which concluded that the Air Quality Objective for nitrogen dioxide would not be exceeded. However, two sites (in central Port Talbot and central Neath) were identified for monitoring since they are at risk of exceedence. High levels of nitrogen dioxide are related to traffic pollution.

6.0.28 Communities with the most significant air quality issues are shown in Map 6.2 'Welsh Index Multiple Deprivation, Air Emissions Index, 2008', which again indicates that central Port Talbot and Taibach areas have the most significant problems, together with central Neath, Pontardawe and parts of Skewen.

32 6 . Key Issues in Neath Port Talbot

Map 6.1 Location of AQMA and concentrations of PM10s 1 201

September

, Paper

opic T

Environment

and

Change

Climate

Map 6.2 Welsh Index Multiple Deprivation, Air Emissions Index, 2008

33 6 . Key Issues in Neath Port Talbot

Climate 6.0.29 Metals monitoring at Pontardawe has shown that the nickel concentration is over three times the EC target value. It is considered likely that the Target Value of 20 ng/m3

Change will be exceeded by the Target Date of 31 December 2012.

Water quality

and

Environment 6.0.30 The Western Wales River Basin Management Plan 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 and improve

T

opic 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 ,

6.0.31 Chemical and biological water quality in Neath Port Talbot’s rivers has fluctuated September 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 Talbot) is shown in fig.4. The plan shows current ecological status, together with ecological

201 potential for heavily modified water bodies (HMWB) and artificial water bodies (AWB). 1 Map 6.3 Current ecological status/potential of surface waters in the Ogmore to Tawe Catchment

34

6.0.32 Ecological classification comprises:

The condition of biological elements (e.g. fish); 6 . Key Issues in Neath Port Talbot

Concentrations of supporting physico-chemical elements (e.g. the oxygen or ammonia 1 201 levels);

Concentrations of specific pollutants (e.g. copper); September

High status, largely undisturbed hydromporphology. , Paper

opic T

6.0.33 The RBMP indicates that the Environment Agency will address the key pressures in the catchment through local actions and that those waters in the worst state will be prioritised. The plan identifies the following objectives: Environment

Table 6.3 : Water Quality of surface waters in Ogmore Tawe Catchment and River and lake water bodies Now 2015

% at good ecological status or potential 37 49 Change

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

% 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

Key issues that will need to be considered when assessing the likely effects of the LDP on water quality include nutrient enrichment, run-off, soil erosion, industrial pollution, acidification, water abstraction and climate change.

Current Position

The General Quality Assessment Scheme (GQA) is used to classify the quality of rivers and canals. Water quality is assessed in four ways: chemistry, biology, nitrates and phosphates.

GQA Biology compares the number and variety of macro-invertebrates with what would be expected, and classifies the water body as one of six grades ranging from A (very good) to F (bad). GQA Chemistry describes the quality of rivers in terms of chemical measurements which detect the most common types of pollution (Biochemical Oxygen Demand; Dissolved Oxygen; and Ammonia. Again, stretches of river are graded from A (best quality) to F (worst). 35 The GQA Assessment for Biology and Chemistry is shown below 6 . Key Issues in Neath Port Talbot

Climate Map 6.4 Biological and Chemical Water Quality, Neath Port Talbot

Change

and

Environment

T opic

Paper ,

September

201 1

Figure 6.2 Biology and Chemical Trends in Neath Port Talbot

36 6 . Key Issues in Neath Port Talbot

GQA Nutrients 1 201

6.0.34 Two nutrients, nitrates and phosphates, are assessed under the GQA scheme, graded from 1 to 6 (very low to excessively high). These nutrient concentrations vary for

rivers in different parts of the country and are not necessarily good or bad in themselves. September

,

Map 6.5 GQA of nutrients Paper

opic T

Environment

and

Change

Climate

37 6 . Key Issues in Neath Port Talbot

Climate Figure 6.3 GQA Nutrient and Phosphate Trends in Neath Port Talbot

Change

and

Environment

T opic

Paper ,

September

201 1

Water Quality

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

Bathing water quality

6.0.36 Aberafan Beach is considered likely to meeting good bathing water quality standards in 8 out of 10 bathing seasons on average and achieves Blue Flag status. The EU Bathing Waters Directive sets a number of microbiological and physio-chemical standards that bathing waters must either comply with (“mandatory” standards) or endeavour to meet (“guideline” standards).

Noise pollution

6.0.37 The Welsh Government is the ‘competent authority’ implementing the European 38 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 and Vale of Glamorgan agglomeration action plan and a Swansea and Neath Port Talbot agglomeration action plan). The boundaries of the agglomerations were established by the action plans and WG is in the process of finalising Quiet Areas and Noise Action Planning Priority Areas in consultation with local authorities. 6 . Key Issues in Neath Port Talbot

Candidate Quiet Areas 1 201

6.0.38 Quiet areas are defined as public open spaces within each agglomeration which: i. are considered by the relevant local authorities to have local amenity value that September

warrants protection from noise intrusion; , Paper ii. are considered by the Welsh Ministers to be relatively quiet by urban standards, both opic T

in actual and perceived terms, according to strategic noise maps and the qualitative descriptions provided by local authorities; and iii. (recommended but not mandatory for designation purposes) do not suffer from poor Environment performance in terms of certain other criteria such as perceived safety and disabled and

access, which, while not directly related to quiet, nonetheless compromise the health and wellbeing benefits that would otherwise be conferred by quiet. Change

6.0.39 Five ‘pillars’ of urban tranquillity, or criteria, have been identified. Soundscape, presence of nature and visual/aesthetic qualities are criteria directly related to perceived Climate 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.

6.0.40 The council has put forward candidate quiet areas for designation by WG, although these are subject to change and the process is still ongoing. The LDP will also need to consider how to protect quiet areas on the fringe of the urban area.

Candidate Noise Action Planning Priority Areas (CNAPPAs)

6.0.41 Under the Environmental Noise Regulations, areas where people are exposed to the highest levels of road and railway noise are being identified for designation as Noise Action Planning Priority Areas (NAPPAs). These are being identified through computer modelling initially, with further investigation and verification before formal designation. At present there are no candidate NAPPAs relating to railway noise proposed in Neath Port Talbot.

6.0.42 Once the NAPPAs are confirmed, consideration will be given to possible noise mitigation actions that can be taken, and the designation will become a planning consideration as outlined in PPW.

Light pollution

6.0.43 There is limited information available about light pollution, but satellite images 39 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. 6 . Key Issues in Neath Port Talbot

Climate 6.0.44 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

Change addition to preventing viewing and study of the night sky. It also represents a significant waste of energy.

and Flooding

Environment 6.0.45 Due to the topography of Neath Port Talbot, tidal and river flooding pose particular threats. Significant areas of the County Borough near to the coast fall within Flood Zone C2, together with large areas of the Valley floors. This constrains and limits the availability

T

opic of sites for development.

Paper 6.0.46 Further information on areas of flood risk, due to tidal and river flooding, in Neath ,

Port Talbot is provided in Appendix A 'Strategic Flood Consequences Assessment.' September

201 1

40 7 . Current and future trends

7 Current and future trends 1 201

Built Environment

7.0.1 The cultural heritage and identity of the County Borough are recognised as September important assets and are attracting visitors to the area. The tourism strategy aims to further ,

develop this potential and provide new sources of employment. This is however limited to Paper specific areas and features of the County Borough where funding has been made available opic T to maintain, enhance and promote the areas of importance.

7.0.2 Whilst the County Borough has a number of listed buildings, conservation areas and areas of archaeological importance which are protected and subject to stricter planning Environment rules, for proposed developments (either affecting them or their setting) there remain a and number of features of local importance. These local features, for example iconic buildings, are not offered additional protection and some are falling into disrepair. This is likely to

continue over the course of the LDP as there are insufficient funds to maintain these areas Change of importance and this is likely to be exacerbated by the current economic climate.

7.0.3 As identified in the previous chapter there is increasing recognition of the need to Climate tackle Climate Change and the role of the built environment in mitigating against the effects of Climate Change and reducing green house gas emissions. Stricter building standards are being enforced as the WG is promoting zero carbon homes. This is likely to result in new, innovative designs in order to accommodate the new building materials and methods in order to reduce the environmental footprint of buildings.

7.0.4 Car ownership rates have been rising as people travel greater distances to access facilities and services. This has led to a decline in the provision of services in local communities which is leading to social exclusion and undermining community cohesion. There is therefore a move towards strengthening local communities and ensuring easy access to facilities and services by non-car modes; the built environment is a key instrument in delivering this vision as developments will need to be designed with permeability in mind and to ensure they link with the wider urban form.

Natural Heritage

7.0.5 There is increasing pressure on the countryside in Neath Port Talbot as a result of new developments and this could lead to a continuing loss and fragmentation of wildlife habitats. The Green Wedges, which were identified in the UDP, remain important tools to protect the settings of communities and to prevent their coalescence, but they themselves face pressure both from erosion as urban areas expand, and from developments that need to be located in the countryside. As more land is developed, to accommodate the needs of existing and new residents, pressure will also increase on the habitats and species. 41 The LBAP identifies 62 species of local importance which should be protected. Applications for development will thus have to take into account the impact on biodiversity, if feasible protect biodiversity and if this is not achievable then implement mitigation measures.

7.0.6 In seeking to protect biodiversity, habitats and species there is growing recognition of the importance of wildlife corridors which provide ecological connectivity and these are likely to become increasingly important as a result of climate change as the behaviour and 7 . Current and future trends

Climate migration patterns of species are predicted to change. These wildlife corridors can also provide important recreational routes and the role of the natural environment in encouraging

Change healthier, more active lifestyles and providing opportunities for recreation and leisure is recognised.

and 7.0.7 The natural environment is also enabling Neath Port Talbot to market itself as a

Environment tourist destination. The Afan Valley has emerged as a major forest and countryside recreation area and has an international reputation for activity based tourism. It is anticipated that over coming years the Neath Valley will be able to capitalise on its unique position as water based tourism is encouraged and tourists are attracted by the network

T opic of canals, rivers and waterfalls.

Paper 7.0.8 There is, however, potential for conflict as the County Borough has also been ,

September identified as having potential for wind farms and the exploitation of natural resources. The development of large scale wind farms, open cast mining and quarry operations are thus transforming the landscape.

201 Pollution 1 Land contamination

7.0.9 As identified in the previous chapter there are large areas of brownfield land within the County Borough, along the coastal belt in particular, which are contaminated. In line with National Policy many of these areas are currently being remediated and are to be redeveloped as mixed use schemes over the LDP period for example Coed Darcy, Port Talbot Docks and Baglan Energy Park.

Air Quality

7.0.10 While air quality remains a concern in some areas of the County Borough, the air quality in Neath Port Talbot has improved over recent years with the main issue relating to the levels of particulates. Air quality will continue to be monitored in the AQMA in the Margam/Taibach area in Port Talbot and in other locations throughout the County Borough if particular problems are identified.

7.0.11 New developments in Neath Port Talbot, which lead to emissions, are subject to strict environmental controls in order to minimise their impact on air quality and to monitor their emissions. Industry is a significant cause of the air pollution and Tata are implementing a major scheme that should reduce the emissions significantly. As technologies develop the situation may improve further. In addition, the opening of Harbour Way which will reduce the amount of traffic on the M4, should also reduce the level of particulates within this area. Local action is addressing local areas of concern (largely relating to traffic growth), 42 but as congestion increases, this will continue to be a problem. 7 . Current and future trends

Water Quality 1 201

7.0.12 As identified in the previous chapter, water quality has fluctuated over recent years in Neath Port Talbot and also varies between different rivers in the County Borough. September

7.0.13 The RBMP has identified targets to be met by 2015 and the situation will continue ,

to be monitored and controlled by the Environment Agency. The Environment Agency will Paper continue to assess the potential impact of new development proposals on the water quality opic T in the County Borough and advise accordingly. However, the Agency has indicated that identifying and addressing the causes of adverse quality is likely to be a slow and long term process. Environment Noise Pollution and

7.0.14 Noise pollution is increasingly recognised as an environmental determinant of poor health and has to be considered when allocating land for development and assessing Change planning applications.

7.0.15 The Environmental Noise Regulations aim to address issues with noise by Climate stipulating the need for Noise Plans and the identification and allocation of Quiet Areas. Securing improved noise levels generally will be a concern for the LDP as part of the delivery of sustainable communities with a better quality of life.

Flood risk

7.0.16 It is likely that flooding events will become more frequent and severe in the future due to the effects of climate change, in particular rising sea levels and more extreme winter rainfall.

7.0.17 While summer average rainfall in Wales is expected to decrease, the UK Climate Projections (UKCP09) indicate that (for the medium emissions scenario), winter average rainfall is projected to increase by 7% by the 2020s, by 11% by the 2040s and 19% by the 2080s.

7.0.18 For the medium emissions scenario, the relative sea level rise around Wales is predicted to be 36cm by the 2080s (this figure takes into account land level changes).

7.0.19 These projected changes give an indication of the likely increases in flooding that can be expected between now and the end of the century, but the effects of these changes may be exacerbated by increases in population, economic activity and traffic/communications and by changing technology. Currently, many of the county borough's major transport links, centres of population and economic activity are located along the coast and in lower lying areas and any expansion or development in these areas will need 43 to take into account the probability of increasing flood risk.

7.0.20 Furthermore, the ways in which flood risk is managed are changing, with the emphasis moving away from the use of hard defences. Currently, the implications of this for Neath Port Talbot are limited, with most coastal defences being identified for retention by the Shoreline Management Plan and other fluvial defences being maintained. However, 7 . Current and future trends

Climate guidance makes it clear that generally, new hard defences will not be considered and that consequently new development will not normally be acceptable in flood risk areas.

Change Increasingly the location of development will need to avoid or mitigate flood risk, while the use of Sustainable Urban Drainage Systems will need to play an important role in reducing

the speed and amount of run off from new developments. and

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44 8 . Conclusions and Strategy Formulation

8 Conclusions and Strategy Formulation 1 201

8.0.1 As identified in the previous sections there are a number of environmental issues that have to be addressed during the LDP period. September

8.0.2 Whilst the area has a number of important habitats, biodiversity and landscapes ,

these are under increasing pressure from development and an integrated strategy for their Paper management and protection is required. They are becoming increasingly valued as they opic T offer leisure and recreational opportunities for residents and attract visitors to the area. Their protection also has to be balanced with the exploitation of the area's natural resources (coal, sand, stone and wind) which are of national importance. The LDP will thus seek to balance these often conflicting objectives. Environment

and Landscape

8.0.3 The strategy proposes the retention of the UDP Green Wedges, subject to Change refinement to follow more defensible boundaries and take account of any new development allocations. Their main purpose is to safeguard the backdrop and gaps between urban areas. Climate

8.0.4 The designation of Special Landscape Areas (SLA's) is proposed to identify land that is of special landscape quality. The approach used is based on Countryside Council for Wales (CCW) guidance. It uses CCW's Landmap landscape classification and the method of assessment used by a number of Local Authorities across South East Wales, which is informing their LDP's. The land identified is indicated diagrammatically on the Key Diagram in the Pre Deposit Plan (Chapter 10). The areas of land designated would overlap with other land identified under other policies as containing reserves that are of national significance (coal, aggregates, stone and wind power). The SLA's would not take precedence over these resources, but will play an important role when planning and other applications are considered.

Wildlife

8.0.5 The strategy recognises the need to reduce or reverse the loss of habitats and wildlife resulting from planning decisions. It proposes to protect; priority habitats (as identified in the Neath Port Talbot LBAP); land that meets Sites of Nature Conservation Interest (SINC) criteria; and avoid the fragmentation of and erosion of habitats generally, irrespective of whether the habitat lies within the countryside or urban areas. The Open Space and Greenspace strategy will identify and protect the most significant areas of habitat within urban areas. 8.0.6 The intention is to prepare an integrated approach to secure meaningful and 45 adequate mitigation where habitat loss or erosion is considered justified.

8.0.7 The detailed policies in the Deposit Plan will be accompanied by Supplementary Planning Guidance identifying the various categories of habitat and the approaches the Authority will use when considering applications. 8 . Conclusions and Strategy Formulation

Climate Built Environment

Change 8.0.8 The area contains a wealth of historic features, including listed buildings, conservation areas, registered parks and gardens and ancient monuments, which in line with national policy will have to be protected. The historic environment is wider than this

and and there remain a number of features of local importance, for example iconic buildings,

Environment which also form an important part of the areas heritage.

8.0.9 The built environment and urban form needs to be considered holistically and opportunities to encourage healthier and more sustainable lifestyles promoted when new

T

opic developments are designed. In order to deliver more sustainable buildings the design of

new buildings may alter as new methods and technologies are used. Paper ,

8.0.10 Due to the history of the area there remain areas of the County Borough which September are contaminated and these will be transformed through redevelopment schemes. Furthermore, air quality and noise pollution will have to be addressed at all stages of the planning process; from ensuring that sites proposed for development will have no negative

201 impact to ensuring adequate mitigation measures are implemented, if required, when 1 planning permission is granted.

8.0.11 A core theme of the LDP is to deliver sustainable development and sustainable communities to enable the County Borough to become more resilient to environmental and economic change and this theme drives the plan and its strategies. The Preferred Strategy is discussed in the following chapter and further detail will be provided in the Deposit Plan.

8.0.12 The formulation of this Strategy was heavily influenced by the findings of the Sustainability Appraisal Scoping exercise and work with stakeholders. The strategy is compatible with the SA objectives and this is discussed in the SA Interim Report.

46 9 . Preferred Strategy

9 Preferred Strategy 1 201

9.0.1 The LDP has a central role in delivering sustainable development and reducing environmental impacts. There are a number of LDP objectives to deliver this aim, the September majority of which are contained within the theme 'valuing our environment' which 'aims to , enhance resilience to Climate Change and ensure development recognises the importance Paper of natural and historic assets' and 'building healthy, sustainable communities' which 'aims

to build communities that: meet the needs of all residents, recognises the diverse and opic T complementary roles of settlements and ensures new development integrates with the existing communities, improves health and ensures adequate access to facilities.' The following objectives are identified: Environment Minimise the adverse impact from noise generating and polluting activities; and

Manage the effects of Climate Change including the needs to avoid vulnerable Change

developments in areas that are at risk from flooding or that may increase the risks of flooding elsewhere;

Conserve and enhance Neath Port Talbot's seascapes, townscapes, landscape, Climate wildlife and habitats;

Promote the efficient use of land, water and energy and safeguard the quality of land and water;

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

9.0.2 A number of strategic policies are identified which will deliver these objectives:

47 9 . Preferred Strategy Climate Policy 3

Change Sustainable Development

and Proposals for new development will reflect sustainable development principles by(2):

Environment Guiding development to sustainable locations in accordance with the settlement framework;

T

opic Reducing the use of natural resources including water, energy, waste, good

quality agricultural land and priority wildlife habitats; Paper ,

Offering sustainable transport options that reduce the need for the private car; September

Creating safe, attractive and accessible neighbourhoods/ communities;

201

1 Promoting, where appropriate, the efficient use of land including previously developed sites;

Avoiding siting vulnerable developments within areas of noise and air pollution or flood risk; (3)

Promoting high quality design;

Addressing the impacts of climate change through the sustainable design and location of development (i.e. low carbon and mitigation);

Promoting the greening of urban areas including tree planting and ‘green roofs’;

Reducing carbon emissions and promoting the use of renewable energy resources including on-site generation.

9.0.3 Developments will need to plan for Climate Change through addressing its causes and potential impacts.

48

2 Developments must also accord with the criteria set out in TAN22: Sustainable Buildings (2010) 3 TAN 15 Development and Flood risk (2004) provides further guidance on assessing flood risk and includes a definition of vulnerable development in relation to the specific flood zones 9 . Preferred Strategy

9.0.4 Addressing flood risk is a duty that will be shared by the LDP and the Authority’s 1 201 Flood Risk Management Plan. The LDP will identify how new development will be located to minimise the risk from flooding, how land will be safeguarded to provide flood capacity and how developments will be assessed against the need to provide Sustainable Urban (4) September

Drainage Systems (SUDS). ,

9.0.5 The Settlement Framework is a key instrument in delivering sustainable Paper development as it aims to guide development to the most appropriate and sustainable opic T locations by recognising the role and function of each settlement in the County Borough. The identification of a Settlement Framework will help to tackle health, safety, deliver a better quality of life and improve access to facilities, services and jobs. Environment

and Policy 2 Change

Settlement Framework

The location of development should be compatible with the settlement framework strategy: Climate

- At the local level residents should be within walking distance of open space, green space, local shops and community facilities;

- At a community level residents should be within easy access of a wider range of facilities and shops;

- The town centres will provide the widest range of facilities and services and act as hubs for surrounding communities.

9.0.6 A key element of the settlement strategy is to ensure a minimum level of provision within each local area and to promote a wider mix of uses, facilities and services within the local level, community level and the town centres including retail, meeting places, community facilities, open space and green space. Furthermore, to maximise the benefits of development, where new community facilities are planned they should offer opportunities for the building to be used/shared by a number of groups. This co-location and joint use of facilities will reduce the need to travel, thus reducing greenhouse gas emissions, and also promote social inclusion, community cohesion and help to deliver safe and confident communities.

9.0.7 In order to reduce reliance on the private car and to deliver more sustainable communities the LDP seeks to improve accessibility and promote active travel: 49

4 A drainage system which aims to mimic natural water movement from a development as though it was a greenfield site. 9 . Preferred Strategy Climate Policy 27

Change Accessibility

and Accessibility will be improved by providing and enhancing cycling and walking routes

Environment for everyday and leisure use.

T opic Policy 28

Paper Active Travel ,

September All new development proposals will need to provide safe and active forms of transport.

201 9.0.8 Walking and cycling routes will be used to link local communities to their services 1 and facilities on a day to day basis at the local level and encourage greater activity levels amongst the population to improve health and well-being. Furthermore,new developments will be expected to provide appropriate linkages to existing routes. In order to deliver this policy new developments will have to consider permeability and provision for walking and cycling routes at the design stage in order to ensure they link to, and are integrated with, existing developments and communities.

9.0.9 Active transport includes walking and cycling. Green Transport Plans submitted as part of planning applications will need to address active transport and ensure that adequate facilities (e.g. cycle racks, lighting, showers etc) are provided to encourage active travel options.

9.0.10 Further information is provided within the Settlement Strategy and Transport Topic Papers.

Built Environment/Heritage

9.0.11 As discussed in chapter 6,the County Borough contains a wealth of townscapes, buildings and historic features that have an important role in creating a sense of place and provide character and uniqueness to its communities. Policy 33 relates specifically to the Built Environment and Heritage features:

50 Policy 33 Protection of the Built Environment and Heritage Features

The Built environment and heritage of the County Borough will be protected and wherever possible enhanced. 9 . Preferred Strategy

9.0.12 Additional guidance relating to designated features of the built environment, 1 201 including listed buildings, conservation areas, archaeological sites and ancient monuments, is provided in PPW.

9.0.13 In recognition of the importance of the wider built environment, the Deposit Plan September will contain policies which will identify how proposals for development will be considered, ,

and seek to retain important or iconic buildings as part of redevelopment proposals. Paper

opic T 9.0.14 The network of canals in Neath Port Talbot are also an important part of the built environment and heritage and form part of the proposed Swansea Bay network of waterways. They will be protected in line with Policy 31: Environment

and Policy 31

The Canal Network Change

The line of the Neath, Swansea and Tenant Canals will be protected except for the section of the Neath Canal above Ysgwrfa Bridge Glynneath and the Swansea Canal Climate above Ynysmeudwy.

9.0.15 It is proposed that the two short lengths of former canals above Ynysmeudwy and in Glynneath are not protected as their restoration would be particularly expensive, difficult and compromise existing roads and residential properties.

9.0.16 Policy 34 relates specifically to design:

Policy 34

Design

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

9.0.17 The design of new development can have a massive impact on its local surroundings. Proposals for all new development will need to fully consider:

The character of the local area;

How the development relates to adjoining spaces and buildings; 51

The provision of a safe, secure and accessible environment;

Massing, density and height;

Landscaping. 9 . Preferred Strategy

Climate 9.0.18 In order to meet the requirements of Code for Sustainable Homes for residential dwellings and BREEAM for commercial properties the design of buildings may alter in

Change order to meet these higher standards and become zero carbon. Buildings will have to become more energy efficient and accommodate renewable energy in order to mitigate

against climate change. The LDP will also identify locations where higher building standards and may be sought so they can become 'exemplar' developments.

Environment 9.0.19 The LDP will also identify potential sources of renewable energy which will include industrial operations that generate a significant amount of waste heat. The infrastructure and design of the built environment will have to allow and support this.

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9.0.20 In order to ensure the County Borough is portrayed in a positive and aesthetically September pleasing way the gateways into the area will be enhanced. This will be achieved through the delivery of Policy 35:

201

1 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.

9.0.21 The Deposit Plan will identify locations to which this policy will apply.

Countryside and Landscape

Policy 17

Development in the Countryside

Neath Port Talbot’s countryside and habitats will be protected from unnecessary development. Where adverse impacts from development will result the LDP will set out a strategic approach to mitigation.

9.0.22 The “countryside”, including the undeveloped coast, is defined as the whole of 52 Neath Port Talbot outside Settlement Limits and other development allocations. The Deposit Plan will define development that may be justified in a countryside location(5) with the overall aim of supporting farming and rural communities by encouraging the

5 For further information on the National Planning Policy Framework relating to development in the countryside, including farm diversification, refer to TAN 6: Planning for Sustainable Rural Communities (2010) 9 . Preferred Strategy

diversification of farming businesses, allowing the younger generation to take over when 1 201 farmers wish to retire and the creation and growth of rural enterprises. Countryside policies are required in order to protect landscape, the undeveloped coast and habitats from incremental erosion and to shape and restrict the growth of settlements in order to relate September growth to the settlement framework which seeks to promote sustainable development. ,

9.0.23 Furthermore, Common and designated open access land will be protected from Paper unnecessary development for biodiversity, agricultural and amenity reasons. opic T

9.0.24 In order to prevent settlement coalescence and protect the setting of communities and their backdrop Green Wedges will be allocated in the Deposit Plan. The Council appointed consultants to identify appropriate locations for Green Wedges within the County Environment Borough and the following are proposed: and

Policy 18 Change

Green Wedges Climate 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.

9.0.25 The Green Wedges identified in Policy 18 are similar to those allocated in the UDP although the boundaries may be amended to reflect current guidance, the advice of consultants and depending on the new sites selected in the housing strategy. The principle of Green Wedges will remain the same and their boundaries and locations will be identified in the Deposit Plan.

9.0.26 In addition, reflecting the importance of the landscape within Neath Port Talbot a number of Special Landscape Areas are proposed: 53 9 . Preferred Strategy Climate Policy 19

Change Special Landscape Areas

and Special Landscape Areas to identify areas and sites that are of local importance will

Environment be designated and protected at the following locations:

i) Mynydd y Garth (Pontardawe);

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opic ii) ;

Paper iii) Dulais Valley; ,

September iv) Margam to include Margam Park, Margam Mountain and Mynydd Emroch;

v) Mynydd y Gelli (Cymmer);

201

1 vi) Foel Trawsnant (Cynnonville/ Dyffryn).

9.0.27 These areas have been identified as Special Landscape Areas, following an appraisal by consultants, for their local landscape significance. This designation differs from that of Green Wedge as SLAs aim to specifically protect high quality landscapes. They have been identified in accordance with guidance provided by Countryside Council for Wales and using the same methods used by the consortium of planning authorities in South East Wales

9.0.28 Neath Port Talbot also includes resources (such as coal, aggregates and sources of wind energy) that are of national significance but their workings and exploitation can have a detrimental impact on the landscape. In order to balance these potential conflicts, the Deposit Plan policies will identify where their exploitation should be balanced against landscape interests.

Habitats and Species

9.0.29 In recognition of the important habitats and species in the County Borough the LDP will protect and enhance priority habitats and species and sites of national, international and local importance:

54 9 . Preferred Strategy 1 201 Policy 20

Protection of Habitats and Species September

, Priority habitats, species and areas of land meeting SINC(6) criteria will, wherever Paper

possible, be protected and enhanced. opic T

9.0.30 This will be achieved by shaping the growth of urban areas (through settlement limits and the settlement framework), protecting habitats in the countryside and along the undeveloped coasts and avoiding their fragmentation and isolation. Furthermore, new Environment developments will be required to take full account of the implications of the development and on wildlife and habitats and mitigate any adverse impacts. Information will be provided through Supplementary Planning Guidance (SPG) and links to other sources to help identify Change the habitats and species concerned.

9.0.31 Within urban areas a green space strategy will help identify and protect a network of ‘green areas and corridors'. Green corridors may include; disused railway lines, canal Climate towpaths and cycle routes. They have a dual purpose. They act as an important amenity resource for the community providing access routes and recreational opportunities and also providing quality habitats and connectivity for wildlife.

Pollution

As identified in Chapter 6 'Key Issues in Neath Port Talbot' and Chapter 7 'Current and Future Trends' there are areas of Neath Port Talbot which suffer from problems with noise, contamination and air quality. Policy 13 aims to address this:

Policy 13

Noise, Contamination and Air Quality

Development proposals should wherever possible help address existing environmental problems and otherwise minimise their adverse effects.

9.0.32 More detailed policies will be included in the Deposit Plan which will aim to minimise adverse impacts of developments on communities and the environment. 9.0.33 In recognition of the potential for the impact of noise (created by road, rail, industry 55 and power generation) on health and quality of life to increase over coming years, the EU Environmental Noise Directive 2002/49/EC (END) sets out to reduce the impact of noise on citizens by managing the sources, reducing the causes in areas that suffer from high

6 A SINC is a Site of Interest for Nature Conservation which are identified as being the most important sites for biodiversity in the County Borough outside of nationally designated sites. The Deposit Plan will outline the criteria which will be used to identify land meeting SINC criteria 9 . Preferred Strategy

Climate levels of noise and protecting areas that are currently quiet from the intrusion of disturbing and harmful noise. The Deposit Plan will designate Quiet areas which will be protected

Change from the intrusion of noise. Furthermore, traffic management measures and new development will need to address the Noise Action Areas identified under WG's noise

regulations. and

Environment 9.0.34 There are a number of brownfield sites which are to be redeveloped over the course of the LDP including mixed use development at Port Talbot Docks, Coed Darcy and Baglan Bay Energy Park.

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56 A . Strategic Flood Consequences Assessment

A Strategic Flood Consequences Assessment 1 201

A.1 Introduction

A.1.1 This is a background paper supporting the Pre-Deposit LDP, comments and September suggestions would be welcomed (details are set out below). , Paper A.1.2 Addressing flood risk is a major duty for the planning system. This includes guiding opic T sensitive development away from flood-risk areas, minimising new development’s contribution to flood risk and protecting areas that are important in channelling and holding flood water. Environment A.1.3 The risk of flooding in Neath Port Talbot derives from rivers and tidal floods. and

Climate change is increasing the risk as the area faces wetter and stormier weather, particularly in winter and as sea levels rise. Change A.1.4 This report relates to the LDP Pre-Deposit Plan. This Plan sets out the proposed strategy that will guide the preparation of the detailed policies, allocations and land-use boundaries in the full Deposit Plan. For more information on the preparation of the LDP Climate and its Sustainability Appraisal see the contact details at the end of this report.

A.2 National Policy, Guidance, Plans and Strategies

A.2.1 The Welsh Government’s Technical Advice Note (TAN) 15: Development and Flood Risk(2004)sets out national policy on flood risk. The general approach of national policy is to advise caution in respect of new development in areas at high risk of flooding by setting out a precautionary framework to guide planning decisions. The overarching aim of the precautionary principle is to:

Direct new development away from those areas which are at high risk of flooding; and Where development has to be considered in high risk areas, only those developments which can be justified on the basis of certain tests are located within such areas.

A.2.2 The operation of the precautionary framework is governed by:

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

A.2.3 The table below describes the composition and use of these zones to control and manage development. 57 A . Strategic Flood Consequences Assessment

Climate Table A.1 : Flood risk Zones

Change Description of Zone Zone Use within the Precautionary Framework

Considered to be at little or no risk A Used to indicate that justification test is not

and of fluvial or tidal/coastal flooding applicable and no need to consider flood risk

Environment further.

Areas known to have been B Used as part of a precautionary approach to flooded in the past evidenced by indicate where site levels should be checked

sedimentary deposits against the extreme (0.1%) flood level. If site T opic levels are greater than the flood levels used to

Paper define adjacent extreme flood outline there is no need to consider flood risk further. ,

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

201 coastal) assessment of consequences 1 Areas of the floodplain which are C1 Used to indicate that development can take place developed and served by subject to application of justification test, including significant infrastructure, including acceptability of consequences flood defences

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

A.2.4 National policy states new development should be directed away from zone C and towards suitable land in zone A, otherwise to zone B, where river or coastal flooding will be less of an issue. In zone C certain tests will be applied, recognising, however, that highly vulnerable development and Emergency Services in zone C2 should not be permitted.

A.2.5 All other new development should only be permitted within zones C1 and C2 if determined by the planning authority to be justified in that location. Development, including transport infrastructure, will only be justified if it can be demonstrated that:

Its location in zone C is necessary to assist, or be part of, a local authority regeneration 58 initiative or a local authority strategy required to sustain an existing settlement; or

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

It concurs with the aims of Planning Policy Wales and meets the definition of previously 1 201 developed land; and

The potential consequences of a flooding event for the particular type of development September

have been considered, and found to be acceptable. , Paper A.2.6 Appendix A.6.1 presents the DAM for Neath Port Talbot. Whilst the DAM identifies opic T land that is at risk from flooding, the Environment Agency also produces flood risk maps for main rivers (an Environment Agency responsibility) and smaller watercourses (a local flood authority: NPT responsibility). The maps take account of the increased flow rates, sea level rises and flood risk resulting from anticipated Climate Change. Environment

and

A.2.7 The Ogmore to Tawe Catchment Flood Management Plan (CFMP) prepared by the Environment Agency identifies policy areas affecting Neath Port Talbot. The CFMP considers all types of inland flooding, from rivers, groundwater, surface water and tidal Change flooding, but not flooding directly from the sea (coastal flooding) – this is covered by the Shoreline Management Plan (SMP). Climate A.2.8 The role of the CFMP is to establish flood risk management policies which will deliver sustainable flood risk management for the long term.

A.2.9 The Ogmore to Tawe CFMP is divided into a total of 12 distinct sub-areas which have similar physical characteristics, sources of flooding and level of risk (see Map A.1). In each of these sub-areas the most appropriate approach to managing flood risk is identified and a generic flood risk management policy allocated. Five of the sub-areas fall within Neath Port Talbot and the generic flood risk policies include:

Upland Rivers (including the upland reaches of the Rivers Tawe, Neath and Afan) – areas of low to moderate flood risk where the Environment Agency and partners are generally managing the flood risk effectively; Tawe Valley (from Trebanos to Ystalyfera and beyond) – areas of moderate to high flood risk where the Environment Agency and partners can generally take further action to reduce flood risk; Upper Neath (including the area covered by the Neath Valley spatial area) – areas of low, moderate or high flood risk where the Environment Agency and partners are already managing the flood risk effectively but where there may be a need to take further actions to keep pace with climate change; Lower Neath (including the dense urban area of Neath) – areas of low, moderate or high flood risk where the Environment Agency and partners are already managing the flood risk effectively but where there may be a need to take further actions to keep pace with climate change; and 59 Port Talbot (including the dense urban area of Port Talbot and Margam) – areas of moderate to high flood risk where the Environment Agency and partners can generally take further action to reduce flood risk. A . Strategic Flood Consequences Assessment

Climate Map A.1 Sub-Areas in the Ogmore to Tawe CFMP. Source: Ogmore to Tawe Catchment Flood Management Plan Summary Report (January 2010)

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A.2.10 The Shoreline Management Plan (SMP) also prepared by the Environment Agency again 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.

A.2.11 The SMP covers the shoreline between Lavernock Point (Vale of Glamorgan) in the east and St Ann’s Head (Pembrokeshire) in the west. The table below describes the policies contained within the SMP for managing the shoreline.

60 A . Strategic Flood Consequences Assessment

Table A.2 : Policy Options, Shoreline Management Plan Lavernock Point to St Ann's Head (July 2010) 1 201

Policy Description Non-Technical Option Description September

Hold the This policy means that existing defences are Keeping the shoreline , line(HTL) maintained, or replaced, along their current alignment. in the same place. Paper Typically this will result in an increased risk of coastal opic

flooding due to future sea level rise. If a significant T number of assets are at risk it may be justifiable to upgrade existing defences (raise and strengthen) to reduce this risk. Environment Advance the New defences are built seaward of the original Creating more land by and line (ATL) defences, in order to create new land. This policy is moving coastal restricted to places where significant land reclamation defences into the sea.

is considered. Change

Managed This policy allows the shoreline to move backwards Letting the shoreline

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

Managed realignment has been assigned to all dune areas since it is not sustainable to artificially fix a line of dunes. Although dune areas will generally be allowed to evolve naturally, a policy of managed realignment means that management techniques could be used, if necessary.

No Active This policy means that there is no investment in Letting nature take its Intervention coastal defences or operations. Where there are course on the currently no defences, this policy means that the shoreline once shoreline will continue to evolve naturally. defences (if present) fail. However, where the shoreline is currently defended, any existing defences will not be maintained and will be allowed to fail. This means that areas inshore would be at increased risk of flooding and coastal erosion in the future.

A.2.12 The coastline of Neath Port Talbot is divided into seven policy units, each having an individual preferred policy and approach to managing the coastline. The proposed SMP 61 Policies are shown on Maps A2 and A3 which follow. The proposed management is :

Port Talbot Steelworks – hold the line; (including ) – hold the line; Port Talbot Docks to Baglan Burrows ( Beach) – hold the line; Baglan Burrows – managed realignment; A . Strategic Flood Consequences Assessment

Climate Neath Estuary – hold the line; Crymlyn Burrows (River Neath to the former BP tank farm) – managed realignment;

Change and Former BP tank farm – hold the line.

and A.2.13 As part of the Flood Water Management Plan process, the known problem

Environment locations in Neath Port Talbot have been identified. The map in Section A.6.3 outlines the indicative flood risk areas across the County Borough.

A.2.14 These indicative areas have been identified by mapping information prepared

T opic by the Defra and the Environment Agency coupled with local flooding data records and

Paper known areas of concern. ,

A.3 The Strategic Flood Consequences Assessment September

A.3.1 Based on the national planning guidance, areas of risk identified by the Environment Agency and through the Flood Water Management Act process, a strategic, Pre-Deposit

201 plan-making level assessment has been undertaken. A fuller exercise will be undertaken 1 in relation to the Deposit Plan.

A.3.1 Fluvial/River Flood Risk

A.3.1.1 The areas subject to fluvial flood risk affect a considerable proportion of the County Borough’s valley floors. The smaller streams running off uplands are usually steep, with a rapid flow and a tendency to flash-flood during and after heavy rain and snow. Although it is necessary to plan for peak flow periods, they tend to be short-lived.

A.3.1.2 Larger streams and rivers tend to be slower flowing. The escape of water from watercourses may be constrained by tidal conditions or where they join larger watercourses that may themselves be in flood. As a result, for example, low lying, flat parts of Glynneath (Morfa Glas/ ) are subject to flood risk as a result of streams discharging from the hillsides above.

A.3.1.3 Much work has been done to reduce or remove flood risk through providing protection and removing and replacing bridges, culverts and natural features that may impede flow.

A.3.2 Tidal Flood Risk

A.3.2.1 Neath Port Talbot has a shoreline that extends along Swansea Bay from Fabian Way to the mouth of the . In addition, the River Neath is tidal as far upstream as . As a result the floor of the lower Neath Valley and adjacent land is subject 62 to tidal inundation. This includes parts of existing urban areas in Melincryddan, Briton Ferry and Aberdulais. The proposed waste landfill contingency site at Giant’s Grave lies within the floodplain. A . Strategic Flood Consequences Assessment

A.3.2.2 The River Afan is tidal for a much shorter distance (to Velindre) but in this densely 1 201 urbanised area this means that areas of existing housing and other development are subject to flood risk (as shown on the EA’s map above). This area extends from the Port Talbot Docks across Aberavon and via a finger of land alongside the M4 towards Briton September

Ferry. ,

A.3.2.3 Tidal and fluvial flooding can combine and interact to create complicated patterns Paper of flood risk. Should peak river flow coincide with high tides then the highest flooding could opic T result, but is short-lived as the tide recedes.

A.4 LDP Strategy on Flood Risk Environment A.4.1 The LDP’s strategy is to guide sensitive development (e.g. housing) away from and areas subject to flood risk in accordance with national guidance. In some locations the potential to redevelop previously developed land is important to the prospects for regenerating the economy and communities. Such areas include Port Talbot’s Harbourside Change and Green Park area and Neath’s Milland Road and areas. Within these areas, Flood Consequences Assessments are likely to be needed to justify development proposals and set out any mitigation work that is necessary to address flood risk. Climate

A.4.2 Elsewhere some employment sites that were prepared for development some years ago (e.g. Glanrhyd in Pontardawe and the Glynneath Business Park) are now subject to flood risk as a result of increased river flows caused by Climate Change assumptions. Proposals to develop them may also need to be subject to Flood Risk Assessments.

A.4.3 Through guiding development away from areas subject to flood risk, the LDP will also protect these areas in relation to their role in providing water holding capacity in times of flood.

A.4.4 The application of the Sustainable Urban Drainage Systems (SUDS) approach will help ensure that the sites of new development only release water at previous “greenfield” rates.

A.5 How to comment

A.5.1 The Pre-Deposit LDP, Interim Sustainability Appraisal, Note on the need for a Habitats Regulations Assessment and supporting documents are available on the LDP website: http://www.npt.gov.uk , and copies are available for inspection at libraries and Civic Centres within NPT and the First Stop Shop in Pontardawe (where help is also available to access the website).

A.5.2 Comments and suggestions on this note’s findings would be welcomed. They may be made: 63

On line via the LDP website: www.npt.gov.uk/ldp

By E-mail to: [email protected]

Or in writing to: A . Strategic Flood Consequences Assessment

Climate LDP SFCA Note Neath Port Talbot County Borough Council,

Change The Quays, Brunel Way,

Baglan Energy Park, and Neath,

Environment SA11 2GG.

Comments must be received by midnight on 17th October 2011.

T

opic For further information please contact:

Paper David Morris ,

September Tel: 01639 686004

Fax: 01639 686101

201

1 E-mail: [email protected]

64 A . Strategic Flood Consequences Assessment

A.6 Maps 1 201

A.6.1 Development Advice Map for Neath Port Talbot September

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Climate A.6.2 Shoreline Management Plan

Map A.2 Sker point to Port Talbot Docks Change

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Map A.3 Port Talbot Docks to Swansea Docks 1 201

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Climate A.6.3 Flood Risk Areas in Neath Port Talbot

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