Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Roger Pawling In general Concerned about apparent lack of Noted – the A55 Caerwys junction is not in Paragraph 37. p29 - mention of light pollution despite the the AONB but it is accepted that the light sentence starting current Dark Sky Wales to assess the in this area is visible from the higher ‘Excessive lighting…’ to feasibility of gaining Dark Sky status. ground of the AONB. The issue of light read ‘Excessive lighting Concerned about floodlighting of buildings pollution in and around the AONB is will produce glare and and their surroundings, whether important, particularly in the context of light trespass outside residential or commercial. The A55 the Dark Skies initiative. Development the site which can Caerwys roundabout has become an area proposals that are likely to affect the impact on tranquillity, of light pollution, with petrol station, cafe amenity of local residents or the wildlife and local and the nearby plant hire business all characteristics of the locality by virtue of quality of life. It is brightly lit at night. The level of lighting is light pollution are specifically assessed in possible to provide typical of an urban area, but is in the line with policies in the Denbighshire LDP, shields and baffles and AONB. Should be both restrictions on the Flintshire UDP and Wrexham UDP. Draft angle lighting brightness and quantity of light fittings, AONB SPG, paragraph 37, provides further downwards to prevent and on the percentage of light that design considerations for the installation the upward spillage of escapes upward from them? of lighting facilities – either within or in light, minimise lighting the vicinity of the AONB. However, it is output, introduce agreed that para 37 could be timers and specify strengthened. In addition, a Design Note colour temperature to may be prepared on this topic (see para moderate the impact 17). (See also response to representations of lighting over a wider from Bro Partnership). area.’ Michael Skuse In general Overall I think it is a splendid document Support welcomed. No change proposed. and will give balanced and thorough guidance to developers within the AONB. Paragraph 1, Grammatical error; use of Plural form, not Grammatical error to be rectified. Paragraph 1, first word first word possessive noun to read: AONBs
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
The AONB In my view the house on the right is poorly Subjective view of representor is Replace photo in the Landscape designed and not suitable as an example acknowledged; Consideration will be given top right hand on page Michael Skuse Types – Built of good design. It appears to be a cottage to an alternative photo which better 10 at document design environment, and a barn, joined together to make one illustrates the key ‘built environment’ stage. p. 10 big house. The white finish is incompatible characteristics in this section. with the stone finish, the blue colour is inappropriate, and the long strip window in the ‘joining’ section is out of keeping with the other windows. The AONB I think the picture of the quarry is outside The picture on the left is a former sand pit No change proposed. Landscape the AONB? which lies on the north side of the A541; Types – adjacent to the boundary of the AONB. Quarries, p. Nevertheless, the draft SPG is not only 11 pertinent to development proposals within the AONB boundary but applies to development outside the AONB that could have an impact on its setting or characteristics. Paragraph Grammatical/ typo error; duplication of Typo error to be rectified. ‘There are Paragraph 14, p.18, 14, p.18, last words similar smaller scale examples elsewhere, last sentence to read: sentence where villages follow the line of the line of ‘There are similar the lower hillslopes - for example the smaller scale examples villages to the west of the Clwydian Ridge.’ elsewhere, where villages follow the line of the lower hillslopes - for example the villages to the west of the Clwydian Ridge.’;
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Re-paragraphing the Michael Skuse document for ease of reference Paragraph Line 3: the use of the word ‘However’ is Avoiding conflicting sentiments in Paragraph 14, p.19, 14, p.19, inappropriate. It should be ‘Moreover’ interpretation of sentence, delete the Renewable energy and Renewable because it adds another similar sentiment word ‘however’ i.e. ‘However, Llarger climate change section, energy and to what has gone before. (The word renewable energy proposals outside the second sentence to climate ‘however’ introduces a conflicting idea, AONB can be highly visible and impact on read: ‘Larger change e.g. 2 and 2 are 4; however 2 and 3 are its setting.’ renewable energy section not. The word ‘moreover’ reinforces what proposals outside the has gone before, e.g. 2 and 2 are 4; AONB can be highly moreover 1 and 3 are 4 as well.) visible and impact on its setting.’; Re- paragraphing the document for ease of reference Paragraph “The influence of climate change will not A fundamental principle embodied in No change proposed to 14, p.19, be immediately obvious, but increases in Planning Policy Wales is ‘Planning for content; Re- Renewable temperature will lead to habitat loss and Climate Change’. Para 4.4.4 of PPW states paragraphing the energy and change.” Perhaps you should not be so ‘Climate change will have potentially document for ease of climate dogmatic here.....it might be wiser to profound environmental, economic and reference change hedge your bets! You do not absolutely social justice implications…’ and goes on section, sixth know without any doubts whatsoever that to list some of the ‘events’ that Wales ‘can sentence climate change will lead to increases in expect’. In this context the wording of this temperature, nor that habitat loss will section of the guidance note, and the result. The use of the word ‘may’ rather examples of climate change given, are than ‘will’ would be more appropriate. considered to be reasonable.
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Tony King Paragraph 3 The consultation document is primarily There are specific Supplementary Planning Paragraph 14, p18 targeted at individuals proposing new Guidance notes for ‘Listed Buildings’ and Development section - development. However I am concerned ‘Conservation Areas’ which complement add additional bullet that nowhere in the document is there a development plan policies. The AONB SPG point after ‘the major reference to developments affecting must be read in conjunction with them. town of Llangollen…’ Listed Buildings. Some years ago Llanferres Paragraphs 14 and 21 refer to Listed ‘The built environment Mill was de-Listed because planning Buildings and conservation areas but it is of the AONB, notably consent had been given for a development agreed that further reference could be the World Heritage that detracted from its original made in paragraph 14 relating to ‘Factors Site, Listed Buildings, appearance. Currently a planning for Landscape Change’. Conservation Areas application is under consideration at the and Historic Parks and Nant Engine House, Llanarmon yn Ial, Gardens all contribute which is also a Listed Building. If consent is to the special character given in this case some characteristic of the area, and features of this building will be lost and insensitive therefore may lead to de-Listing. development and change can impact on the quality of these heritage assets.’ Paragraph 9, In para 9, table 6, AONB Special Qualities: There is a distinction between an AONB No change proposed. table 6 the relevant AONB policy is to conserve Management Plan, which focus on the and enhance features and sites of special characteristics, and a archaeological, cultural or historic Supplementary Planning Guidance note, importance. It is perfectly possible to carry which can be material in determining out sympathetic development of most planning applications by a local planning Listed Buildings. I would argue that the authority. The draft AONB SPG will apply development of a Listed Building within in conjunction with the procedures for the AONB should not result in de-Listing securing listed building consent, and,
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
except in exceptional circumstances. Some therefore, should ensure that the guidance on this issue should be given in qualifying features of the building are the Guidance note. preserved. De-listing is not within the remit of this SPG. The AONB Paragraph 9 The bold type sentence starting Change agreed. Delete ‘…during the Paragraph 9, 4th Partnership ‘Consideration ….’ should be amended by process’ as the AONB Special Qualities sentence, to read: deleting ‘during the process’ at the end. should not only be considered in the ‘Consideration should The rationale behind the comment was to planning process. be given to how new give it added strength in, for example, an ‘Consideration should be given to how development proposals
appeal where an applicant might argue new development proposals impact on impact on these special
that they did consider such matters these special qualities and whether they qualities and whether ‘during the process’ of developing their are conserved and enhanced during the they are conserved and scheme but dismissed them! process.’ enhanced.’ Paragraph Factors for Landscape Change - Agriculture There is no reference in the document to Paragraph 14, 14, and Forestry section. The Brexit word the United Kingdom of Great Britain and Agriculture and Agriculture came up in relation to the sentences about Northern Ireland’s decision to leave the Forestry section, new and Forestry agri-conservation schemes and the European Union. It is acknowledged that third sentence to read: section, potential impact this could have. I don’t changes in land management may have an ‘Future changes to second think it would be appropriate to impact on the landscape. That will be agri-environmental sentence specifically mention Brexit, but would reflected in the document by inserting the support schemes may have no problem with adding a more following sentence: ‘Future changes to also impact on the general sentence after ‘... the agri-environmental support schemes may landscape.’ management of common land.’ along the also impact on the landscape.’ lines of ‘Possible future changes to agri- environment support schemes may also impact on the landscape.’ BRO Paragraph 37 My initial thoughts are that the reference See response to representations made by See changes to Partnership to lighting in para 37 is fine, though of Roger Pawling. In addition, paragraph 14 - paragraph 37. p29 in
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
(Dark Skies course if Dark Skies Community status is Development section - could make response to comments project) secured at a later point this could be additional reference to the benefits of by Roger Pawling. strengthened. Also, it might be useful to dark skies. include some references earlier in the Paragraph 14, p18 document to set out the added value of Development section – add new bullet point dark skies to the special qualities of a ‘Excessive lighting of landscape, especially in terms of a sense of development impacts on place and protecting wildlife. the sense of tranquillity, wildlife and quality of life.’ Friends of the In general On behalf of the “Friends of the Clwydian Support welcomed. No change proposed. Clwydian Range and Dee Valley AONB” I write to Range and Dee express the Charity’s support for the draft Valley Supplementary Planning Guidance Note which has been the subject of the recent consultation exercise. The draft document made available as part of the consultation process is both comprehensive and properly understanding of the sensitivities needed to protect and enhance this most important landscape. The document has the “Friends” full and unequivocal support.
Ramblers In general On behalf of the Ramblers’ Association’s Support welcomed. No change proposed. Association Flintshire Footpaths Committee I write to Flintshire express full support for the draft SPG.
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Ramblers In addition The draft document is both Agreed – new development should No change proposed. Association comprehensive and properly sensitively incorporate and wherever Flintshire understanding of the sensitivities needed possible enhance opportunities for active to protect and enhance this most travel and recreation. Welsh Government important landscape. Our only additional published guidance on rights of way for comment concerns cases where sensitive local authorities and individuals on their development is permitted, and that website. Obstructions to rights of way are development affects or possibly the responsibility of the Highways incorporates a public right of way. In these authority, not the local planning authority. circumstances, developers should be Concerned ramblers should report any encouraged to make use of the footpath obstructions to them. Nevertheless, or bridleway in a way which supports development proposals likely to affect a active travel and stimulates residents to right of way will be consulted on with access adjacent countryside and, where Highways. To that extend, it is expected available, local shopping and recreational that they also comply with the provisions facilities. This should mean sensitively of the Active Travel (Wales) Act. retaining and, where necessary, improving the existing path and not merely making it part of the development’s adopted highway. The Coal In general The Coal Authority has no specific Comment noted. No change proposed. Authority comments to make. The Campaign In general Although generally supportive of the Noted - Supplementary Planning Guidance No change proposed. for the contents of the SPG, it is felt that AONBs notes are neither national nor local policy. Protection of are likely to become hubs for the Planning policies are laid out in Planning Rural Wales development of intensive tourism (chalet / Policy Wales (PPW) and the adopted Local (CPRW), Clwyd lodge / static caravan park / touring Development Plans. PPW Edition 9, Branch caravan park), leisure activities, renewable paragraph 2.3.1, ‘Selective use of
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
The Campaign energy with associate infrastructure and supplementary planning guidance (SPG) is for the economic development at the expense of a means of setting out more detailed Protection of landscapes. SPG is not in itself policy and thematic or site specific guidance on the Rural Wales therefore fails to carry the same weight, way in which the policies of an LDP are to (CPRW), Clwyd although it is a material planning be interpreted and applied in particular Branch consideration when making development circumstances or areas.’ management decisions. In addition It is recommended that there is a stated The Sandford Principle was introduced as No change proposed. commitment within the document that a means of reconciling conflicts in National the Sandford Principle will be applied as Parks between conservation and and when necessary. This is a long recreation. In effect it advises that standing mechanism for ensuring that conservation interest should take priority. priority is given to conservation where However, the SPG is not in itself the there are irreconcilable conflicts with means for decision making on other purposes and duties. development proposals as this rests on conformity with policies in the development plan, national policy and other material planning considerations. In many instances it is necessary to balance competing policy objectives or effects and benefits of developments, and this is a matter of planning judgement in each case. PPW Edition 9 advises in in 5.3.5 ‘The primary objective for designating AONBs is the conservation and enhancement of their natural beauty. Development plan policies and development management decisions affecting AONBs should favour
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
The Campaign conservation of natural beauty, although it for the will also be appropriate to have regard to Protection of the economic and social well-being of the Rural Wales areas. Local authorities, other public (CPRW), Clwyd bodies and other relevant authorities have Branch a statutory duty to have regard to AONB purposes.’ Hence it is not considered necessary or appropriate for the Sandford Principle to be embodied within this SPG. In general Uniformity of the three local authority Noted - all three local planning authorities, No change proposed. planning policies and SPG Notes require to i.e. Denbighshire, Flintshire, Wrexham, are be taken into account with regard to aiming to adopt the SPG subject to any development management decisions for approved changes following public the AONB. Failure to address omitted or consultation. National planning policy for conflicting planning policy or guidance AONB’s applies across all the planning occurring will result in difficulties when authorities. Local development plans are defending planning appeals. at different stages of preparation and it is acknowledged that there is a need for consistency across the AONB. In general It is advised that prior to formal adoption, Comment noted. Typo errors to be proofreading is undertaken to eliminate corrected. errors. P. Gill In general There is one particular aspect of the SPG The comments raise policy issues which No change proposed. which relates to the approach to be are outside the remit of supplementary adopted in relation to disused quarries guidance. The role of the SPG is not to set within the AONB of which there are out a strategy for the restoration of number, mainly limestone quarries. By its quarries (active or disused) within the area very nature, a disused quarry leaves a but to identify the matters which should
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
substantial scar on the countryside in the be taken into account when considering P. Gill form of a large void which is not easy to planning applications for development ameliorate due to its size. Planning policies within the AONB and its setting. Quarries in the past have attempted to address this are identified as an important feature of problem by insisting, rightly, that the AONB as they reflect its industrial restoration and aftercare measures are heritage. Many of the disused quarries taken on the cessation of quarrying within the AONB have been assimilated activities. However, even the most careful into the landscape, offering valuable scheme of restoration usually still leaves a habitat for protected and important substantial hole in the ground which is a species and some also offer significant blot on the AONB and as a disused quarry opportunity for tourism. (National policy is a dangerous place, it becomes an area seeks to move mineral extraction away of the AONB to which access generally is from the AONB, however, there are prohibited and which cannot be enjoyed existing quarries which are yet to be fully by others. Whilst restoration and aftercare restored within the AONB and quarries provide a short to medium term (i.e. a 5 to within the setting of the AONB which 25 year) solution to the visual impact of a could have an adverse impact on the disused quarry, the long term outcome is a AONB if not given adequate consideration problem which neither the Consultation at the planning application stage.) The Draft nor the SPGN address directly. draft SPG sets out the importance of A disused quarry void will, to all intents quarrying and its history as a key and purposes, be there forever and whilst characteristic of the AONB and advises the surface itself may well become that any after uses should not have an overgrown in time, the void containing it adverse impact on the tranquillity of the will remain out of bounds for pretty well AONB. The SPG therefore doesn’t forever because of the inherent dangers in preclude any specific after uses within it. I submit, therefore, that the SPGN disused quarries but does highlight the needs to address this problem in a manner fact that reuse for waste management and which takes a long term view of the industrial uses can reintroduce
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
disused quarries and allows for sensible disturbance to what are now tranquil P. Gill and sensitive development of them which places. The infill of voids within hard rock has the objective of returning them in quarries created by quarrying brings with some way to a more positive presence it potentially significant impacts (noise, within and in the context of the AONB. For dust, disturbance and so on) which could example, sensitively carried out be contrary to the special qualities of the development which would reduce the AONB. The policies of the Denbighshire extent of the void and return it to a LDP seek to direct waste management contour more in keeping with the activities away from the AONB and surrounding countryside should be significantly, Policy VOE 8 directs disposal encouraged not least from the point of of waste away from the AONB so any re- view of improving the long-term visual contouring of quarries would need to be impact of the quarry on the AONB. Quarry carried out without reliance on waste faces which are interesting from a material. Any benefits of in filling a void geological or other point of view could be would therefore need to be carefully easily preserved within development of balanced with any disbenefits, with this kind for future generations. In significant weight to be given to the need addition, properly managed development to protect the special characteristics and of this kind could and would be very likely qualities of the AONB. to improve the natural habitat of local flora and fauna and the general In respect of the commentary on p11 a The first bullet point biodiversity of the disused quarry site and minor factual amendment is necessary to under Specific its environs. The restrictive nature of the reflect the presence of active quarries development SPGN when applied to disused quarries, both within and adjacent to the AONB’ management which should be considered differently considerations’ in the from working quarries, positively ‘Quarries’ section on discourages attempts to ameliorate and p11 should read: improve their impact on the AONB and ‘There are a number of return the countryside of which they form active quarries within
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
part to “natural beauty” as defined by the and adjacent to the P. Gill Countryside Council for Wales as follows:- area. Long term…’. “Natural Beauty applies to unspoiled, rural landscapes that are largely free from the effects of disfiguring development or urbanisation...” Whilst quarrying activities, by their very nature, undoubtedly disfigure the countryside, existing planning policies need to take a far longer term view than at present regarding the means to enable and encourage these sites to be improved and returned where possible to a state of natural beauty within the AONB for the enjoyment and benefit of future generations not only for the next 25 years or so but also for those in the remainder of this century and the next. If this is not done, disused quarry sites will become largely inaccessible to visitors to the AONB and sterilised for future enjoyment by future generations. That does seem to defeat an essential purpose of the AONB. Bourne Leisure In general Of relevance to this consultation, Bourne Support welcomed. No change proposed. (c/o Lichfields) Leisure operates Presthaven Sands Holiday Park, which is located almost immediately to the north of the Clwydian Range and Dee Valley Area AONB. The Park straddles the boundary of Flintshire and
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Denbighshire Councils’ administrative Bourne Leisure areas. Bourne Leisure also operates (c/o Lichfields) Bodelwyddan Castle Hotel which is located approximately 5 miles away from the AONB. As a matter of principle, Bourne Leisure supports the recognition of the value of the AONB and the tourism sector. Importantly, it is noted that the draft SPG does not seek to preclude new development, but rather ensures that new development conserves and enhances the special qualities of the AONB. This approach accords with the primary objective for designating AONBs that is set out within Planning Policy Wales (PPW) (edition 9, November 2016), at paragraph 5.3.5. It also aligns with paragraph 5.5.5 of PPW which states that “statutory designation does not necessarily prohibit development…”. Paragraph From reading Para 14 of the draft SPG it is Comment noted. No change proposed to 14, Tourism clear that tourism is a significant content; Re- section contributor to the AONB, and the paragraphing the Company considers that it is vitally document for ease of important that local planning authorities reference support the future growth of tourism- related development. This accords with national planning policy, which states that
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
development plan policies and Bourne Leisure development management decisions (c/o Lichfields) affecting AONBs should ‘favour conservation of natural beauty’, although also ‘have regard to the economic and social well-being of the areas’ (PPW, (edition 9, November 2016), paragraph 5.3.5). Paragraph 14 will also contribute positively towards meeting the Welsh Government’s aim which is for “tourism to grow in a sustainable way and to make an increasing contribution to the economic, social and environmental well-being of Wales” (PPW, paragraph 11.1.2). The AONB Page 10 of the draft SPG sets out the The list is not all embracing as it is pre- The AONB Landscape Landscape special qualities and key characteristics of fixed by ‘and includes…’. It would not be Types – Built Types – Built the built environment of the AONB. It helpful to list all forms or types of environment, p. 10; environment, states “The built environment has varying development and if ‘tourism’ were added amend sentence to p. 10 influences on the character of the AONB then other individual types of read: ‘The built and its setting, and includes towns, development could also make a case for environment has villages, rural farming and residential inclusion. Nevertheless, it would be varying influences on settlement and transport, energy and reasonable to add a catch all category of the character of the communications infrastructure” (page 10). ‘rural enterprise development’ which AONB and its setting, Bourne Leisure raises no objection in could include a wide variety of rural and includes towns, principle to the key characteristics listed employment generating activities, which villages, farming and within the draft SPG but considers that would include tourism. rural enterprise tourism-related development, such as development, holiday parks and hotels, should also be residential settlement
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
specifically identified as a key and transport, energy Bourne Leisure characteristic of the built environment. and communications (c/o Lichfields) This will align with paragraph 14 of the infrastructure.’; Re- draft SPG, which recognises tourism as paragraphing the being a factor that influences landscape document for ease of change of the AONB and its setting. It also reference recognises the value of tourism to the local economy. Bourne Leisure therefore requests that the sentence is reworded “The built environment has varying influences on the character of the AONB and its setting, and includes towns, villages, rural farming and residential settlement and transport, energy and communications infrastructure, and tourism-related development”. Paragraph 31 Paragraph 31 of the draft SPG relates to Support welcomed. No change proposed. new development that impacts on the setting of the AONB and Bourne Leisure supports this approach; the recognition that the visual impact of new development on the setting of the AONB can be minimised is important. The Company recognises that this can be achieved through sensitive design, such as for example the use of natural vegetation for screening, and by siting development with the contours / flow of the landform
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Bourne Leisure and the prevailing patterns of the land. (c/o Lichfields) The Company also supports the recognition that elements of the landscape may be locally changed to accommodate development, provided that the prevailing character of the landscape remains intact. Bourne Leisure understands the importance of conserving and enhancing the special qualities of the AONB. As many of Bourne Leisure’s sites are located in rural and/or coastal areas, incorporating or adjacent to conservation sites and protected areas, the Company has significant experience of operating within and adjacent to such locations and takes the need for conservation and enhancement fully into account – both in day to day operations and when preparing development proposals for sites. This approach is considered to be consistent with national planning policy which recognises the importance of balancing conservation objectives with the wider economic needs of local businesses and communities (PPW, paragraph 5.5.1). National planning policy also encourages local planning authorities to consider whether environmental issues can be adequately addressed by modifying the
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Bourne Leisure development proposal, where possible (c/o Lichfields) (PPW, paragraph 5.5.3), and recognises that unavoidable harm to nature conservation can be minimised by mitigation measures (Technical Advice Note 5, paragraph 2.4). This proposed approach in the draft SPG will ensure that suitable and sustainable development proposals that would bring positive benefits to the local area would not be prevented from coming forward. It will also contribute positively towards meeting the Welsh Government’s aim which is for “tourism to grow in a sustainable way and to make an increasing contribution to the economic, social and environmental wellbeing of Wales” (PPW, paragraph 11.1.2). Paragraphs Landscaping Support welcomed. No change proposed. 35 to 39 Paragraphs 35 - 39 of the draft SPG refer to landscaping and Bourne Leisure supports the recognition that buildings can be screened by good planting schemes, earth mounding and other forms of boundary treatment, and that this can result in new development assimilating into the countryside. The Company has significant experience of preparing and
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Bourne Leisure implementing high quality landscaping (c/o Lichfields) schemes as part of recent development proposals. These successfully assimilate new development into the countryside, while also providing environmental benefits and biodiversity enhancement. The draft SPG’s approach to landscaping is considered to be consistent with national planning policy, which recognises the importance of balancing conservation objectives with the wider economic needs of local businesses and communities (PPW, paragraph 5.5.1), and which recognises that unavoidable harm to nature conservation can be minimised through mitigation (Technical Advice Note 5, paragraph 2.4) as referred to above. This will ensure that development proposals that contribute positively towards meeting the Welsh Government’s aim for tourism are not prevented from coming forward, where any unavoidable harm to the AONB is suitably mitigated through a landscaping scheme.
Natural In general It is noted that the document once Support welcomed. No change proposed. Resources adopted will be treated as material
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Wales (c/o consideration during the application North determination process. Planning) NRW welcome the Supplementary Planning Guidance (SPG) for the Clwydian Range and Dee Valley AONB. The SPG marks an important collaboration between the three local planning authorities (Denbighshire, Flintshire and Wrexham) in developing a common approach to managing development change within and adjacent to the AONB. The SPG helpfully describes the characteristic landscape attributes of the area that contribute to local and regional distinctiveness and experience of the area’s natural beauty. It then provides an analytical process and uses a series of questions to help structure planning and design thinking. This should lead to developing appropriate forms of development that are responsive to their local context and avoiding forms and locations resulting in landscape impact. In general We consider that additional photographs / More representative photos will be Add more pictures illustrations would be helpful within the included in the final document. final documents in order to help explain some of the points made.
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Natural Resources Wales (c/o North Planning) Canal & River In general The Trust supports the thrust of the SPG, Support welcomed. No change proposed. Trust but has no specific comments to make on the document as currently drafted. Welsh Section 3 Our only comment is that would wish to Denbighshire CC and Wrexham CBC have a No change proposed. Government see a specific mention of the Welsh local policy on the Pontcysyllte Aqueduct (Cadw) Government History Environment Service and Canal World Heritage Site in their (Cadw) guidance “Managing Change to local plans, which is supplemented by a World Heritage Sites in Wales” in section joint topic-specific SPG. Draft AONB SPG, 3: paragraph 4, highlights that the AONB http://cadw.gov.wales/ guidance note should be read in historicenvironment/publications/ conjunction with other SPG’s. There are worldheritagesites/?lang=en numerous guidance documents that could be cross referenced within the document, but given the objective and content of the guidance note in seeking to improve the quality of development generally, it is not considered that this is necessary or appropriate.
Design In general General formatting and legibility of the Improving legibility and formatting of Changes to design and Commission document could be improved to be more document will take place once the text has document format prior for Wales user-friendly, though we understand that been approved by the local planning to publication. authorities.
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Design this may come at a desktop publishing Commission stage of the final document. for Wales In general The document would benefit from more Detailed analyses of local conditions No change proposed. analysis and presentation of existing local within and in the vicinity of the AONB is conditions to helpfully inform proposals. provided in the AONB Management Plan, There is reference to various aspects Natural Resources of Wales’ Landmap throughout the text in the design section system, and design guidance for selective but it may be more useful to consolidate towns such as, Llangollen. The draft AONB this into one place. SPG draws information from these Plans, and summarises the essential design information in paragraphs 11, 13. Paragraphs 15 to 39 provide guidance for prospective applicants by posing questions under the heading ‘It’s a question of…’ Paragraph 15 New development should be encouraged Thrust of comment agreed – paragraph 15 No change proposed. to firstly seek to contribute positively to explicitly makes this point. In addition, the AONB, rather than simply avoiding Planning Policy Wales (PPW) Edition 9, adverse impacts. This approach to design paragraph 5.3.5., and draft AONB SPG, would avoid the need for any mitigation of paragraph 2, ‘Development Plan policies detrimental impacts. Reference should be and development management decisions made to sustainable building practice in should favour the conservation of natural relation to orientation, mass, materials beauty and have regard to economic and glazing. See Welsh Government guide issues and social well-being.’ http://gov.wales/docs/desh/publications/ 150311practice-guidance-planning-for- sustainable-buildings-en.pdf
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
Paragraph 18 The introduction to Key Design Paragraph 15, second sentence, highlights Paragraph 15, add the Considerations should stress that the importance of having regard to the following sentence at Design thorough site and context analysis be setting and site surroundings for good the end to read: ‘It is Commission undertaken with demonstration of how quality design in new developments. crucial that new for Wales this has informed the proposal, with However, this can further be strengthen development proposals specific attention to the sensitive by adding another sentence at the end of are informed by a landscape context. See Welsh Government paragraph 15. thorough assessment guide of the site http://gov.wales/docs/desh/publications/ surroundings and its 160513-site-and-context-analysis-guide- setting.’ en.pdf Paragraph 23 Contemporary designs should be Regardless of modern, traditional, or No change proposed. encouraged where proper site analysis is experimental design, all new development demonstrated and a contextual design should be informed by a thorough response has been developed. assessment of the site surroundings and its setting. This is reflected in paragraph 15, as amended (see previous comment). Paragraph 26 Broken internet link Internet links are easily out-of-date, i.e. Update the link to the broken. Consideration is given to include a ‘Malvern Hills AONB’ more generic link to the document. Paragraph 31 Thorough site analysis with distance views Photomontages are a useful tool for Paragraph 15, add the and photomontages can be used to assessing the impact of a development following sentence at demonstrate how the proposal has been proposal on the wider landscape. the end to read: sensitively integrated into the Reference to the tool to be included in ‘Making use of environment. Paragraph 31. photomontages can be helpful in demonstrating how a development proposal
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Appendix 1 – Summary of representations received on draft document
Name, Paragraph / Summary of representation Council’s response Changes proposed to Organisation Section draft document
sits within the landscape.’ Design Paragraph 35 Sensitively designing for the landscape This point is considered to be made within No change proposed. Commission context of the development should be the last sentence ‘However, landscaping for Wales considered from the outset so as to avoid will not by itself, make a poor the need for landscape screening as development acceptable’. mitigation for bad design. In general Use of the term ‘contemporary’ rather This point is a matter of semantics. There No change proposed. than ‘modern’, is more appropriate could be a lengthy discussion about the language to use in this context and will difference between ‘contemporary’ and give the reader more clarity on the ‘modern’. However, the language of the aspiration of the Local Authorities. document should be kept plain and easily Additionally, when schemes are described accessible for all readers. as ‘innovative’, this innovation should be detailed and evidenced to set a high precedent for innovative design in the AONB.
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