VOLUME 2 APPENDIX 3.2. Scoping Opinion from Brecon Beacons National Park Authority

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1 C A N T R E F A D V E N T U R E F A R M L U G E E N V I R O N M E N T A L S T A T E M E N T VOLUME 2 APPENDIX 3.2 Scoping Opinion from Brecon Beacons National Park Authority

2 Mr Wynne Davies Cantref Adventure Farm Annedd Wen Llanddew Brecon Powys LD3 9SY Date: 2 June 2016 Contact: Mr Ryan Greaney Our Ref: 15/12959/FUL Your Ref: Dear Sirs, Town & Country Planning Act 1990 (as amended) Proposal: Change of use of agricultural land to accommodate the installation of a luge run with ancillary buildings and the erection of a toilet block and refreshment kiosk. Scoping Opinion Address: Upper Cantref Farm, Cantref, Brecon Powys LD3 8LR I refer to your Environmental Impact Assessment (EIA) Scoping Request and supplementary information received on 26 th April 2016 in relation to the above proposal. This is, of course, further to the EIA Screening decision issued by this Authority on 24 th March Background For ease of reference, it was determined by the Authority during the Screening process that the proposed development, due to its nature, size, cumulation with other development and location on a previously undeveloped greenfield site within a National Park is likely to have an environmental impact in the following ways: A likely visual impact on the National Park landscape being on an elevated and exposed parcel of land. The LVIA submitted in support of the application goes some way to demonstrate that there will be no long term significant landscape impacts from the proposed development. However, I am concerned with regard to the visual sensitivity of users of surrounding farmland, public rights of way and open access areas, particularly in the short term. The likely long term highway impacts arising from a resurgence of visitor numbers and, accordingly, increased traffic generation and movements as a direct result of the development. A likely long term noise impact arising from the use and operation of the proposed luge and the associated increase in visitor numbers in a National Park offering peace and tranquillity with opportunities for quiet enjoyment, inspiration, relaxation and spiritual renewal as a special quality (Brecon Beacons National Park Management Plan). The Noise Impact Assessment goes some way to demonstrate that there will be no significant noise impact arising from the proposed generator. However, I am particularly concerned with the lack of information provided with regard to the noise generated as a result of

3 the general operation of the proposed luge and the sensitivity of nearby residents, users of surrounding farmland, public rights of way and open access areas, particularly in light of the special qualities of the National Park. Accordingly, you agreed to undertake an EIA and have requested a Scoping Opinion. In this regard, the information specifically viewed includes: Location and ownership plans Landscape and Visual Impact Assessment, Haire Landscape Consultants, November 2015 Planning and Design and Access Statement (undated but received by BBNPA 4 March 2016) Landscape Impact This Scoping Opinion seeks to review the scope and content of the existing LVIA and sets out preferred requirements for a revised LVIA including further work. The specific issues dealt with include: Guidance and contextual information to be taken into account General method issues Landscape effects- method and issues Visual effects- method and issues Viewpoints Standard for visualisations eg photos and photomontages Cumulative effects assessment Suggested additional mitigation measures Policy, guidance and landscape reports to be taken into account The development should be assessed to ensure that it is consistent with the adopted BBNP Local Development Plan , its policies and related supplementary planning guidance. It is requested that the following current landscape guidelines and reports are taken fully into account: Guidelines for Landscape and Visual Impact Assessment, third edition, LI and IEMA, 2013 (GLVIA 3). Landscape Institute Advice Note 01/2011. Photography and photomontage in landscape and visual impact assessment. Landscape Visual Representation of Windfarms Good Practice Guidance, December 2014, SNH. LANDMAP information Guidance Note 3, NRW/CCW, June 2010 BBNP Landscape and Development Supplementary Planning Guidance including the Landscape Character Assessment (LCA) BBNP Management Plan It is expected that the LVIA will be carried out to current good practice.

4 Site and Proposal Site and Environs The site lies 1.15km west of Llanfrynach in the rolling transitional landscape between the Brecon Beacons Massif with associated open upland ridges to the south and the Usk valley to the north. The land cover of the area is primarily pastoral farmland with low cut hedges, some oak field trees and strong deciduous tree belts, some associated with watercourses. The developed part of the site is a pasture lying between 223m AOD and 181m AOD on south eastern facing valley slopes falling to the Afon Cynrig which is a tributary of the River Usk. The northern boundary is defined by a small watercourse with outgrown hedges with trees on its lower eastern part. Low cut hedges with very occasional trees bound the site to the east, west and south. The latter is gappy due to grazing from animals in the farm park to the south. The Upper Cantref Farm complex to the south of the site is run primarily as a privately run horse riding centre and rural leisure attraction centred on a series of agricultural sheds of varying ages. In 2000 the farm complex was fairly compact and completely agricultural and rural in character. Since then the leisure uses have been added. By 2012 the uses included a manege, car parking, static caravans, play areas and display pens with limited planting and trees. These were added to from 2013 onwards with a campsite, associated facilities to the south of the farm complex and additional planting throughout. The proposed development The components of the proposed development are as follows: Luge- constructed in a series of curves running down the valley side and a straight run back up with associated cut and fill Entrance building at the top of the slope to the south west Toilet block building in field to the south Access to the site Footpaths around the site with bridges over the luge Maize maze Drainage works including attenuation ponds to the south east Additional planting including tree belts and hedges Creation of a hedged paddock to the north east. The development would necessitate the removal and/or relocation of hedgerows. Additional information on the development The following information would be helpful in assessing effects: Building drawings Luge details- visualisations, cross sections and materials and sections through the luge cut and fill Access track and path details and materials Contours clearly annotated Consistency between the masterplan and landscape mitigation plan e.g. areas of fill

5 Information on the trees removed and length of hedgerow removed and relocated An accurate description of the proposed planting mitigation with typical dimensions eg width of tree belts and plant spacing. Current LVIA and scoping opinion Issues The site is sensitive as it is on a sloping valley side within open countryside and located within a National Park. It is open to views from at least the southern and eastern quadrants. There are a variety of visual receptors including users of PROWs, open access land and local roads, and there is both scattered rural settlement and Llanfrynach which may have views of the development. The proposed development diverges from the pattern of the pastoral enclosed landscape and so mitigation is very important. This should be designed both to screen the development effectively and to reflect the enclosure pattern. For instance, tree belts should link and anchor into the existing field boundaries rather than appear as separate blocks. Current LVIA The current LVIA put forward to support the planning application is a useful start to considering the landscape and visual impact of the proposals. However, its level of detail of assessment is equivalent to a landscape and visual appraisal broadly following GLVIA principles. It is not a full LVIA carried out in line with GLVIA 3. However, information from it can be usefully integrated into a revised LVIA. LVIA scoping- general It is understood that the exact method should be determined by the landscape assessor and the assessment should be proportionate to the size of the development. However, the effects need to be demonstrated and the following points will be taken into consideration by the Authority in evaluating the LVIA and assist in decision-making. The assessment should be carried out in accordance with GLVIA3 by one or more suitably experienced chartered landscape architects. A full method should be set out as an appendix which should allow judgements to be consistent, transparent and understandable. There should be full definitions of all categories of landscape and visual sensitivity, magnitude and significance of effect used in the assessment, and how these are arrived at. A 5 point calibration for sensitivity, magnitude and significance is preferred as it is considered to better reflect the subtleties of landscape and visual impact. If intermediate terms are used such as high/medium or medium/low these should be defined in the method. The level at which effects are significant in terms of Environmental Impact Assessment Directive and UK Regulations should be defined. A helpful diagram showing how significance of effect can be derived is included in Appendix A. The assessment and conclusions should be consistent with the method. For each landscape and visual receptor, there should be an assessment of the sensitivity and magnitude of change leading to the significance of effect and nature of change (beneficial, neutral or adverse) with a justification. The LVIA should take into account winter and summer effects to come to overall assessments.

6 The effects of the development should be assessed for Year 0, directly after completion, and at Year 10 or 15- whenever the planting mitigation is considered to be established. The expectation of growth of the planting should be explained (including heights) and should be based in part on what has been achieved by plants on the adjacent site so far. Judgements on the nature of the effects i.e. beneficial, neutral or adverse at year 0 and year 15 should be separated from the magnitude of change. Landscape character impact assessment The sensitivity of a landscape receptor should be assessed by describing and combining its susceptibility and value. The effect on landscape should be divided into the effects on the landscape character area (LCA), on the site, and on landscape elements within the site. The LANDMAP assessment of the area should also be noted and taken into account. The LCA in which the proposed development is located is no.6 Middle Usk Valleys LCA (see Appendix B). The assessment sets out the distinctive characteristics, special qualities, overall strategy and specific management guidelines amongst other information. The LVIA should address how the proposed development affects these and how it minimises impacts. There should be an assessment of the sensitivity and magnitude of change leading to the significance of effect. There should also be a tabulated assessment of the effects on the special qualities of the LCA. With regard to the site, there should be an assessment of the sensitivity and magnitude of change leading to the significance of effect with a justification. The susceptibility of the site is likely to include its sloping nature. Its value will include location in the National Park. From the above, the effect on BBNPA policies should be assessed. Visual impact assessment The zone of visual influence (ZVI) in the current LVIA is a partial assessment of the areas which would have views of the development. Even taking in consideration the screening effect of intervening landform and vegetation the site would be visible from a wider area than defined. This should be reflected graphically and in the analysis. However, taking into consideration the value of the development and a proportionate approach it is accepted that a GIS generated Zone of Theoretical Visibility (ZTV) may be too expensive to be justified, although it would be helpful. A very thorough site appraisal is needed to ensure that all key and representative viewpoints are explored. The precise viewpoints from which a formal visual impact assessment will be made will need to be agreed between the developer s landscape architect and the Authority. Photos from each of the viewpoints proposed to be assessed should be sent through to the Authority for agreement. These should include specific and representative viewpoints for a range of receptors from a range of distances.

7 The range of receptors which will need to be considered will include PROWs including promoted trails- Three Rivers Ride, Usk Valley Walk, Taff Trail; open access land- Cefn Cyff and Rhiw, dwellings/settlement and roads. Viewpoints in the LVIA which should be included are: R1, R2, R5, F5/R6 to illustrate the effects on the Three Rivers Ride. F1 and F2 to illustrate the effects on local PROWs. F3 and F4 to illustrate the effects on open access land/prows. Viewpoints near H3 and H5 to illustrate the effects on settlement. The play area at Llanfrynach may be a suitable proxy for the settlement but this will need to be agreed. This list is not exhaustive and there may need to be other viewpoints which may illustrate the worst case more effectively. Other receptors which would not have a view of the development such as nearby dwellings or listed buildings should be described as in the current LVIA for completeness. Each agreed viewpoint should be assessed in terms of its sensitivity and magnitude of change with the justification. This should preferably be in tabulated form with a written summary and a summary table. For each viewpoint it would be acceptable to have an A3 panorama photo providing an A3 sized single photo focused on site is also provided for key views to be agreed. The photos should be annotated clearly showing the extent of the site. It would be desirable to have year 0 and year 15 photomontages of the development from a couple of viewpoints. If this is not possible, a number of A3 photos should be provided with applied colour tones indicating where the proposed buildings, luge development, maize maze and pastoral field are located. The location of these visualisations would need to be agreed with the Authority. Cumulative effects Whilst the LVIA will address the effects on landscape and visual receptors of the proposed development against the existing baseline, it is also considered important that the cumulative effects of this development are considered in conjunction with the existing leisure uses at Cantref Farm. Cumulative landscape and visual impact assessments of the combined effect of all the development is needed. Also, the additional effect of the proposal over and above the existing development is needed. This will define its relative contribution to landscape and visual impact compared to the rest of the complex. A discussion on how the cumulative development affects the special qualities of the LCA would be helpful. Given the size of the development it would not be expected that this would be carried out in the same level of detail as the LVIA but it is an important factor to be considered by decision-makers. Highway Impact In seeking to set out the required scope of any EIA relating to this site from a highways perspective, the Authority has sought the advice of the Highways Authority at Powys County Council.

8 In their response, the Highways Authority state that they welcome the need for the submission of an EIA for this development and would request that the following assessment is included within the document: A full Transport Assessment should be submitted. This will need to include the provision of traffic count data over a minimum 8 day period at locations to be agreed with the Highway Authority. The TA should include an assessment of each of the routes identified together with all constraints and junctions along the routes which need to be assessed in accordance with current standards. In addition, they should identify all the lawful uses that are located on the site and the traffic generation from each plus the anticipated volume of traffic from the new use. In addition to their views on the scope of any EIA, it was also commented that: having read the Design and Access Statement I would advise that we have significant reservations with regard to the proposed development and the likely impacts on the surrounding highway network. The fact that they are indicating that the site can be accessed from either Bailihelig Road in Brecon or from the Class II B4558 is considered reason enough to formally oppose the application due to the likely increase in traffic along severely substandard highways. We also are unable to accept the rationale that the decrease in visitor numbers to the existing use from previous years is a reason to allow the increase for this new development. Whilst this doesn t necessarily form part of the scoping process, I am of the view that it is prudent to inform you of this consultation comment at this stage so that is can be fully addressed through the EIA and reflected in the submitted Environmental Statement. Noise Impact In seeking to set out the required scope of any EIA relating to this site from a noise perspective, the Authority has sought the advice of the Environmental Health Department at Powys County Council. In their response, they commented that the noise impact assessment provided in support of the application concludes in 7.1 of the report that that the impact of a super silent generator with an acoustic enclosure will be low when assessed as per the general guidelines of BS4142 and this is accepted. However 7.5 states that the addition of the luge is not anticipated to result in any adverse impact on nearby residents. To this end further information is requested in the proposed EIA in respect of the noise impact on the nearest noise sensitive property during the operation of the luge as well as that from customers during the use of the luge. In addition, further information is also required in relation to the impact upon users of surrounding farmland, public rights of way and open access areas. Whilst it is not necessarily a matter to be addressed as part of this Scoping Opinion, Powys County Council s Environmental Health Department also commented as follows: In addition it is noted that a new toilet block is proposed which is to utilise an existing septic tank. It is requested that further information is provided in the EIA in the form of a report, together with

9 percolation test results, in order to demonstrate that the existing septic tank, its soakaway and the ground conditions are suitable and sufficient for the additional foul drainage. The percolation test should be carried out in accordance with document H2 of the Building Regulations. I trust this is of assistance to you at this time. However, please do not hesitate to contact me should you require any further information. Yours faithfully, Mr Ryan Greaney Principal Planning Officer

10 Appendix A IEMA significance diagram Derived from Figure 6.3,page 61- IEMA Special Report The state of environmental impact assessment practice in the UK, Appendix B Link to Brecon Beacons landscape character assessment - LCA 6