Comment . Consultee Mrs Jane Hennell (376324) Email Address Company / Organization Canal and River Trust Address The Dock Office Commercial Road Gloucester GL1 2EB Event Name Register of Alternative Sites Comment by Canal and River Trust (Mrs Jane Hennell) Comment ID AS340 Response Date 3/10/14 4:54 PM Consultation Point AS(A) 9: Swansea Canal: Trebanos Playing Fields to Pontardawe Town Centre ( View ) Status Processed Submission Type Web Version 0.10 Do you require information and guidance on the No process of making a comment? Participation at oral part of examination At this stage you can only make comments in writing (these are called 'written representations'). However, everyone who wants to change the Plan can appear before and speak to the Inspector at a 'hearing session' during the Public Examination. If you are objecting to the inclusion of an 'alternative site' you will be considered to be a supporter of the Plan and you will not be entitled to speak at a hearing. But you should bear in mind that your written comments will be given the same weight by the Inspector as those made verbally at a hearing session. Participation at a Hearing Session - the Inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at a Hearing Session of the Public Examination. Do you want your comments to be considered by YES, I want to speak at a Hearing Session 'Written Representations' or do you wish to speak at a Hearing Session of the Public Examination? As you have stated you wish to speak at the Hearing, please confirm which part of your representation you wish to speak to the Inspector about, and why you consider it to be necessary to speak at the Hearing Powered by Objective Online 4.2 - page 1 This matter is of great importance to the future success of the restoration of the entire canal. We wish to discuss the canal policy as a whole. Are you objecting to or supporting the inclusion I am supporting the inclusion of the Alternative of the Alternative Site? Site Your Representation Please leave your comment The Canal & River Trust (the Trust) is the new charity set up to care for England and Wales' legacy of 200-year-old waterways, holding them in trust for the nation forever. The Trust has responsibility for 2,000 miles of canals, rivers, docks and reservoirs, along with museums, archives and the country's third largest collection of protected historic buildings. The Trust has a range of charitable objectives including: To hold in trust or own and to operate and manage inland waterways for public benefit, use and enjoyment; To protect and conserve objects and buildings of heritage interest; To further the conservation, protection and improvement of the natural environment of inland waterways; To promote sustainable development in the vicinity of any inland waterways for the benefit of the public; and Proactively champion restoration of redundant waterways and the construction of new links, as a public good. Within Neath Port Talbot County Borough, the Trust owns and manages part of the Swansea Canal (from Clydach to Ynysmeudwy) but is also supportive of the Neath and Tennant Canals which are still owned in the main by the Company of Proprietors of the Neath Canal. We firmly believe that all the waterways within the borough present a truly unique multi-functional resource and an opportunity to deliver unparalleled high quality public benefits to their surrounding areas. The Trust objected to the Deposit Version of the Local Development Plan (LDP) as we were concerned that sections of the Canal may not be adequately safeguarded and thus prevent the full restoration of the Swansea Canal or the proposed 35-mile integrated waterway scheme involving all three canals via the SA1 development in Swansea. Following our objection, a meeting took place with Neath Port Talbot County Borough (NPT) Planning Officers, the Canal & River Trust, Inland Waterways Association and Swansea Canal Society. The Council has suggested that the section of canal which concerns us should be considered as an ‘alternative site'. It has been put forward as AS(A)9. The Trust therefore supports the inclusion of this alternative site AS (A) 9 though the Local Develpoment Plan process. The Trust has already set out our concerns in writing regarding the need to protect the historic line of the Swansea Canal.The Trust also notes that the Council considers that this objective can be achieved by draft Policy BE3. We also appreciate that the Council is concerned that it may not be practical to restore the section of canal which is not in water and that the Council is concerned that the policies and proposals in the LDP have to be ‘deliverable, realistic and sound'. At our recent meeting, NPT Officers stressed that every section of the canal must be ‘deliverable and viable' with ‘funding in place' if it to be included. Therefore in order to ensure the safeguard is applied over the whole canal line, deliverability and therefore, in their opinion, funding needs to be in place over the entire line. However, the Welsh Assembly Local Development Plan Manual June 2006 makes no reference to a requirement to demonstrate that a site has funding in order for it to be safeguarded. Its suggested types of ‘safeguarded sites' include open space and ‘greenways' which may not have specific funding in place. The Swansea Canal Society make a valid point that it appears that the council may be confusing two issues, the aspiration to restore the canal (which obviously requires funding) and the aspiration to safeguard the route which does not. On this basis, this would allow the entire line to be safeguarded, including the length including in AS (A)9 even if no funding is in place to restore that particular stretch at present. Powered by Objective Online 4.2 - page 2 The Council has asked the Inland Waterways Association (IWA) and Swansea Canal Society to prepare a Feasibility Study to support the safeguarding of the canal between Trebanos and Pontardawe as an amendment under the alternative sites process. This has now been provided and it makes it clear that the only structural barrier to the re-opening of the canal in this location is the A474 road. The report concludes that with the addition of a lock there is sufficient clearance to allow the canal to pass underneath the A474 without affecting road alignment. A tunnel has recently been built under the A419 to accommodate the newly restored Droitwich canal. Several other canal restoration projects proposed passing under roads. For example the proposed Cotswold Canal restoration includes the canal passing under the M5 motorway in a culvert and the proposed new Bedford - Milton Keynes Waterway will pass under a Trunk Road. This should therefore not be viewed as a barrier to restoration. The feasibility report concludes that the full restoration of the canal is possible and relatively straightforward. Restoration could bring many benefits to the area, as detailed in our original response but it is critical to the success for the project that both local authorities, the Swansea Canal Society, Inland Waterways Association and Canal & River Trust all work together to support and facilitate the full restoration of the canal. It is critical that the canal is not blighted by further development, thus the retention of the protection within the emerging local plan is essential if the overall benefits are to be achieved. The Welsh Assembly Local Development Plan Manual 2006 states that in proposing any new or alternative site, a proponent will need to show that the site accords with the LDP strategy, that the LDP would be sound if the site is included. The Trust has already provided detailed information supporting the necessary changes to the canal policy in its original objection (copy attached). We do not wish to see this section considered as a separate site but instead consider that the whole canal network should be treated as one.We therefore do not believe that this section should be treated as an alternative site but must support it as an alternative site as the Council have made the decision to treat it in this manner. The LDP manual also suggests that the proponents of an alternative site should carry out a sustainability appraisal using the Councils' baseline data and methodology and that the Council should advise proponents what is needed in order to promote the site. In this case the Canal Society and Inland Waterways Association have been asked to provide a Feasibility Study. The Council's own Sustainability Appraisal on Policy BE3 can be applied here as the proponents are not wishing to put forward this site as a ‘standalone‘ but simply as an amendment to ensure that it is fully safeguarded along with the other sections of canal. The Council has assessed Policy BE3 ‘as being positive in relation to the SA biodiversity objectives as the canals are generally important features for biodiversity, and in relation to the landscape/townscape and historic character objectives. Safeguarding the canals should also have health and wellbeing benefits due to general public access for recreation purposes. No significant adverse impacts have been identified'. This section of canal does have a ‘realistic prospect of restoration' (Policy BE3 5.5.24). It was in-filled in the eighties when the Leisure Centre and Shopping Centre were built but the access road was designed not to impede the route of the canal. There is no vehicular access along the route of the canal and there are no buildings on it, therefore re-opening it is possible.