APPENDIX 6 – CONSULTATION QUESTIONNAIRE

For Office Use

Representation Number: ______

SNOWDONIA NATIONAL PARK AUTHORITY

ERYRI NATIONAL PARK MANAGEMENT PLAN

AND

ERYRI LOCAL DEVELOPMENT PLAN

Strategic Options and Preferred Strategy Comments Form

Completed forms should be returned to:

The Policy Team,

Snowdonia National Park Authority,

Penrhyndeudraeth,

Gwynedd,

LL48 6LF

Or by e-mail to: dyfodoleryri@eryri-npa.gov.uk

CONTACT DETAILS

	Personal Details	Agents Details (If applicable)

Title	Dr

First Name	David

Last Name	Lewis

Job Title (If applicable)	Chair of Policy Sub-Committee

Organisation (If applicable)	Cymdeithas Eryri Snowdonia Society

Address	Ty Hyll Capel Curig Betws-y-Coed

Post Code	LL24 0DS

E-mail Address	director@snowdonia-society.org.uk

Telephone No.	01690 720287

CONSULTATION QUESTIONNAIRE

Test of Soundness

Question 1 (Page 3)

Do you agree with the Authority’s assessment of its progress in meeting the tests of soundness (in appendix 2)?

Not entirely

If not, please give reasons?

The Authority’s self-assessment in appendix 3 shows that it has made good progress towards meeting many of the tests of soundness summarised in appendix 2. It is not possible to be confident as yet, however, that the Authority will succeed in meeting all the tests of soundness, for at least the following reasons:

a key element in the tests of soundness is a ‘a robust and credible evidence base’, but development of the evidence base can be described only as ‘ongoing’ (appendix 3 under P1 and CE2) - this also has implications for the identification of indicators for monitoring (appendix 3, under CE3)

the proposed objectives fail to reflect the central importance of climate change in current national policies (see the Society’s response to question 4)

the draft Preferred Strategy fails to reflect the concept of ‘sustainable communities’, and the associated concept of ‘dependency catchment areas’, which are central features of the recently adopted Gwynedd Unitary Development Plan (see the Society’s response to question 12)

there are some discrepancies between the proposed Settlement Strategy and settlement strategies emerging within the framework of the Wales Spatial Plan – it is claimed in appendix 3 (under C3) that ‘there are robust reasons why the Preferred Settlement Strategy was chosen’, but those reasons have not been spelled out.

Special Qualities

Question 2 (Page 13)

Have we identified all those qualities that make Snowdonia special?

If not what other qualities would you wish to include?

Identifying the special qualities of Eryri is the essential basis for formulating policies for conservation and enhancement as well as for promoting understanding and enjoyment. We are concerned that the consultation document (2.1.1) glosses over this point by not quoting the statutory purposes of National Parks in full and omitting the reference in those purposes to their ‘special qualities’. The list of qualities offered in chapter 4 is not adequate for the purpose. It is often vague and repetitious. Crucially, it fails to focus on the qualities which are special to National Parks or unique to Eryri. We propose the following as a replacement for 4.1.2:

The main views expressed on Snowdonia’s special qualities are summarised

below:

1. great diversity and beauty of landscape in a relatively small area, ranging from coast and estuary to high rugged mountains (with more peaks over 900m than any other English or Welsh National Park)

2. areas offering tranquility and solitude, especially in the remoter parts

3. a sense of man’s activities and impact on the landscape through the centuries from Neolithic to modern times, evidenced by the rich archaeological and historical heritage and the present-day agricultural scene

4. complex and varied geology including superb and classic examples of glaciation and volcanic activity

5. rich biodiversity reflecting the landscape, geology and climate, and man’s influence, and including species and habitats of national and international importance

6. the vibrant Welsh language and culture, with communities demonstrating strong communal spirit

7. opportunities for a wide range of quiet recreation and leisure activities.

Drivers of Change

Question 3 (Page 17)

Have we identified the main drivers of change?

A heavily qualified ‘yes’

If not what else would you wish us to include?

The Society endorses the singling out of climate change as the most important driver of changes. The list of 33 further factors under 9 separate headings is wide-ranging. But, to be helpful as the basis for planning, it needs to be rationalised and shortened, by eliminating duplication, and omitting or rephrasing references to factors which, as described here, are effects of change or deliberately adopted policies, rather than drivers of change. It will then be more practicable to assess how important particular drivers are likely to be, and in what contexts. Specific suggestions to that end are:

5.1.6 The final bullet of the preceding paragraph on climate change should be merged with this paragraph, with which it overlaps considerably. The wording should reflect the status of the factors mentioned as drivers (for example, ‘The need to achieve sustainable power production’). The reference to development of renewable energy as a driver of change should be general, and not confined to householder and community schemes, albeit not all renewable energy schemes would be acceptable in the National Park

5.1.7 In place of a separate section on the European Union, reducing assistance should be covered under ‘Public sector funding’, with a specific mention also of the Common Agricultural Policy; and ‘Increasing economic mobility’ should appear under ‘Demographic changes’ (with the words ‘within the European Union’ perhaps added). ‘Environmental directives’ are probably not sufficiently important to be listed as a driver of change for the future; or, to the extent they might be, could be covered in the paragraph on climate change

5.1.8 The 2^nd and 3^rd factors should be combined as ‘Increased pressures for public sector efficiency and partnership working’; and the 5th bullet in 5.1.5 should be merged with the 4^th bullet here and similarly reworded as a driver

5.1.9 Migration may have various causes and is appropriately covered here under ‘Demographic changes’. The references to ‘increasing in-migration’ in 5.1.5 should be transferred to here, and preferably made more precise, still mentioning climate change as the ultimate cause. There are three possible forms of inward migration that might be caused by climate change: from Africa and surrounding areas fleeing excessive heat and drought (presumably not meant here), from other parts of Britain for permanent residence (unlikely on a large scale), or in the form of tourism and second homes. The loss of young people moving away from the area should be mentioned as a driver.

5.1.10 Housing is a crucial policy issue, but the two bullets in this paragraph seem to range well beyond drivers of change, and their meaning is in any case obscure. We suggest they should be replaced by an additional factor under ‘Demographic changes’ or under ‘Economy’: ‘Repercussions on a low wage economy from the housing market elsewhere in Britain’

5.1.11 This paragraph, headed ‘Increasing Requirements for Sustainability and Environmental Protection’, should be omitted, as those matters are covered in broad terms in the paragraph on climate change. The sentence of text is incontrovertible, but describes a driver against change, rather than a driver of change

5.1.12 Under ‘Economy’ the 3^rd factor should be omitted, as covered already, and the 6^th is an effect rather than a driver. The 1^st factor should be converted into two separate drivers: ‘Demand for higher standards in tourism, including quality information and interpretation’ and ‘Need for agriculture to gear up to serve increasingly demanding markets’. The last but one factor should be omitted, unless it can be expressed much more precisely, and is not already covered by the expanded paragraph on climate change. The last factor should be merged into the 3^rd factor in 5.1.13, as ‘Reduced availability of local services, associated with increased use of the internet’

5.1.13 The 1^st factor is already covered by the earlier mention of pressure for increased public sector efficiency and partnership working - or could be covered more explicitly by a small amendment there. The 2^nd and last factors should be amalgamated as ‘Need to extend the benefits of the National Park to all social groups and to deprived communities adjoining the National Park’. The 4^th factor should be worded more appropriately in this context as ‘Young people’s career aspirations which cannot be fulfilled at present within North West Wales’. The 6^th bullet, ‘Design quality’, is very cryptic: insofar as there are pressures for change in the design of buildings, they are largely associated with increasing the efficiency of energy use, and have already been covered under the heading of climate change

5.1.14 The 1^st factor should be amended to ‘Increased demand for active outdoor recreation, linked to healthier lifestyles’; the 2^nd factor should be reworded as ‘High expectations about community participation in initiatives and decisions’ and transferred to 5.1.13; and the 3^rd should be reworded as ‘Demand for increased access to coast and inland waters’.

Two other drivers of change ought also to be mentioned in this chapter. The first, increased longevity as leading to increased use of the National Park by older people seeking less energetic recreation, should appear either under ‘Health and Wellbeing’ or as a further factor in the section on ‘Economy’. The other, pressure to increase food production in Britain, is a further driver of change which may well result from climate change.

The Society welcomes the commitment that ‘Identified responses [to drivers of change] will be consistent with National park Purposes and duty’ (5.1.2) and the reference made to the general inappropriateness of major developments in National Parks. We urge that reference should also be made at this point to the undesirability of activities that would damage the special qualities of the National Park, including its tranquillity.

The Vision

Question 4 (Page 22)

Do you agree that the vision, as supported by the aims and objectives, has the right emphasis?

Yes, with certain additions, in the case of the vision and aims

No in the case of the objectives

If not please identify elements that you consider to be important.

The Society welcomes the setting out of a long-term vision for Eryri, and is broadly supportive of the VISION the National Park Authority has proposed. However, there are a few additional points that need to be covered.

Despite the emphasis that has been placed on the role of National Parks in sustainable development, and the major changes in ways of living that are likely to be required in future, the wording of the vision does not make any reference to sustainability. The word ‘sustainable’ is used twice in the proposed AIMS (7.2.2), but we do not consider this is sufficient by itself. There are also a number of differences between the version of the vision which appears on page 21 of the consultation document and the version which appears in the summary for consultation; and we believe the latter’s references to diversity and social inclusion are important. To cover these points we propose that the second sentence of the vision as it appears in the consultation document should be amended to read as follows:

The purposes of the Snowdonia National Park will be delivered in a diverse and prospering economy, with thriving bilingual and inclusive communities which will be models of sustainability, and continue to be founded on strong relationships with high quality landscapes and rich cultural traditions.

A further difference between the two versions is that the version of the vision in the summary for consultation contains an additional sentence which we think definitely merits inclusion:

Partnership between many different players will have shown that by working together we can achieve so much more.

The first paragraph of the AIMS (7.2.1) should include a reference to ‘superb opportunities for recreation and enjoyment’.

On the proposed OBJECTIVES in table 1 on pages 23-26 of the consultation document the Society has four general comments and some more detailed comments.

First we note that, in formulating objectives for the National Park Management Plan and the Local Development Plan, the Authority has taken as the starting-point the set of objectives agreed for the purpose of carrying out the Sustainability Appraisal/Strategic Environmental Assessment of the Plans, as set out in the 1^st column in table 1. Although those objectives have been arranged here under the headings of the National Parks purposes and duty, they do not mirror exactly the activities the Authority undertakes. That is understandable because the purpose for which they were formulated was checking on the sustainability of the National Park Authority’s Plans. In the section on economic and social wellbeing a number of the objectives in the 1st column of table 1 (for example, the objective on housing) justifiably extend beyond the National Park Authority’s own responsibilities; it is the Appraisal/Assessment which will seek to establish whether the Authority’s Plans will contribute to or work against the wider social objective. The damaging effect of adopting this approach is totally inadequate coverage of the National Park Authority’s activities in pursuit of the second statutory purpose. Presumably promotion of understanding and enjoyment was not thought to be a critical factor in the Sustainability Appraisal/Strategic Environmental Assessment. Nevertheless it is a central statutory requirement for National Park Authorities. The only objective which appears under this heading in the 1st column of table 1, ‘Improve the quality and quality of publicly accessible open space’, is clearly an off-the-shelf objective applicable to all local authorities, and if anything particularly to urban authorities.

The section of objectives on ‘Promoting Understanding and Enjoyment’ must logically appear before the section on ‘Foster Economic and Social Well Being’. The Society supports the one objective for the National Park Management Plan, on access for people of all physical abilities, which currently appears in the understanding and enjoyment section of table 1. But it needs to be accompanied by other objectives to cover other key aspects of promoting understanding and enjoyment, and to reflect such key messages of the vision for Eryri 2035 as providing inspiration and promoting social inclusion. Specific matters which were covered in the Society’s response to the discussion paper on recreation and access, and which ought to be covered by the objectives listed in table 1, include improving the quality of rights of way, creating and promoting low-level routes, improving the management of open access land, opening up access to the coast, and improving provision for other forms of healthy outdoor recreation. We emphasise that, as in the case of economic and social wellbeing, these topics should be covered in the Authority’s Plans irrespective of whether action on them is directly or exclusively the Authority’s responsibility or whether, on the other hand, objectives will be pursued through partnership between the Authority and other organisations.

Our second general point is that there are no objectives in table 1 which relate directly either to reducing emissions of greenhouse gases or to adapting to climate change. Selecting objectives for the Sustainability Appraisal/Strategic Environmental Assessment was an element in the Scoping Report for those exercises, and we record that there was no public consultation during preparation of that Report, despite requests from the Society. Some of the proposed objectives have some relevance in relation to climate change (for example, the 5^th objective on page 24, which mentions energy, and the 1^st objective on page 25 on flood risk to developments), but it is not their primary focus. Because of the overriding importance of climate change as an issue, mitigating it and adapting to it must be addressed directly in the Plans. The Society would want to have the opportunity to enlarge on this point, if that is necessary.

Guidance on preparation of National Park Management Plans in Wales says that ‘wherever possible’ the objectives they contain should meet the SMART criterion, by being specific, measurable, achievable, relevant to the National Park and time-bound. None of the objectives in the 2^nd column of table 1 is time-bound, and many are not specific or not measurable.

Our final general comment is that there are a number of unjustified gaps in the 3^rd column of table 1, even allowing for the difference in scope between the Local Development Plan and the National Park Management Plan. We suggest the following additional entries to set objectives for the Local Development Plan:

page 23

2^nd row: an objective for the LDP in relation to air quality seems misplaced in the 2^nd row on page 25, and ought to appear here if anywhere

5^th row: there could be an objective for the LDP in relation to RIGS corresponding to that in the 4^th row in relation to biodiversity

page 24

4^th row: the 2nd objective in the 2^nd column could be moved to the 3^rd column (amending ‘promote’ to ‘encourage’, if that is thought necessary)

6^th row: the planning system has a clear and acknowledged role in promoting sustainable transport

page 25

1^st row: likewise for flood prevention

3^rd row: the objective in the 3^rd column must be an error, and instead reference should be made to the potential for the planning system to encourage reuse and recycling of construction materials (including material resulting from demolition and excavation) and the need to ensure that the detailed design of all new housing and commercial developments allows for temporary storage of items to be recycled

7th row: the planning system should also promote community involvement - there is indeed a Community Involvement Scheme for Eryri under planning legislation

page 26

1^st row: here again the role of the planning system in relation to transport should be acknowledged, including specifically in reducing distances between homes and jobs

Our other comments on the 2^nd and 3^rd columns of table 1 are as follows:

page 24

1^st row: as the present condition of many ancient monuments is unsatisfactory, it would be appropriate for the 2^nd column to use the word ‘enhance’ in relation to them too; and the 2^nd column should also refer to listed historic landscapes, not just registered parks and gardens

3^rd row: the entry in the 3^rd column does not seem to reflect fully the Authority’s objectives in relation to the Welsh language

page 25

2^nd row: the Society very much welcomes the reference here to soil conservation, but it should appear in the 1^st and 2^nd column as well as the 3^rd column (we have commented above on the inappropriateness of referring to air quality at this point)

3^rd row: as the Authority is not responsible for waste management, the words ‘Promote mechanisms to’ should be inserted at the beginning of the proposed objective in the 2^nd column

5^th row: in the 3^rd column amend ‘Encourage new developments to locations’ to ‘Ensure new developments are located’

page 26

3^rd row: remove the limitation ‘rural’ in the 3^rd column, as much of the employment and economic activity in the National Park is in the towns and larger villages and/or not related to agriculture or forestry.

These detailed comments are subject to the proviso that an attempt to come closer to meeting the SMART criterion for objectives in the National Park Management Plan would involve more far-reaching changes.

Spatial Objectives

Question 5 (Page 28)

Do you agree with this spatial approach and the spatial categories proposed?

Yes

If not please indicate those spatial elements that you consider to be important.

The Society welcomes the recognition in the consultation document that different policies may be appropriate in different parts of the National Park, because of their different circumstances. We believe the spatial categories proposed (7.4.2) and shown in plan 2 provide a useful basis for applying this spatial approach. However , the Preferred Strategy does not as yet contain an adequate set of differentiated policies for these different areas.

Moreover, the spatial approach needs to be taken further by fully integrating the Settlement Strategy, which is dealt with in a different part of the consultation document. Although the Settlement Strategy has direct implications for the Preferred Strategy for housing, it is important in other contexts as well. For this immediate purpose, however, we have respected the structure of the consultation document, and made our comments on the Settlement Strategy in response to question 12; we have also covered there 7.4.3 and the Key Diagram (plan 1).

The consultation document does not explain how the work on landscape character assessment mentioned in 7.4.4 and illustrated in plan 3 fits into this spatial approach. Nor does it make clear the function the Authority’s planned Landscape Strategy is intended to fulfil. As we understand it, the Landscape Strategy will not be produced in time to be incorporated into the National Park Management Plan. It would not therefore be a satisfactory substitute for including basic policies about landscape within the Plan itself. We deal with the need for such policies in our comments on section 8.2 of the consultation document. However, in applying the spatial approach to management of the National Park, it will be essential that all decisions and policies also take full account of the particular characters of its landscapes. To register that point, we suggest that 7.4.4 should be replaced by a paragraph on the following lines:

Measures adopted in relation to any area of the National Park must have full regard to the particular character of the landscape. Work on landscape character assessment in the National Park, drawing on LANDMAP data, is ongoing, and will lead to the production of a Landscape Strategy. This will take into account the ecological capacity of different areas of the National Park and the implications of climate change for landscape. It will provide detailed guidance on appropriate interventions within identified categories of landscape and serve as supplementary guidance to support development control decisions.

The last two lines of 7.4.4, on the other hand, need to be expressed more robustly, and appear in section 8.2.

In advance of production of the Landscape Strategy the map of landscape character areas (plan 3) may cause some confusion; we suggest it might be better not to include it in the text of the National Park Management Plan unless a detailed explanation of its significance can be provided.

GENERAL COMMENTS ON THE MATTERS COVERED BY QQ 6, 7 & 8

The three sections of the consultation document covered by Questions 6, 7 and 8 raise closely related issues: agriculture and forestry are the main land uses in the National Park (8.2.3), and the land management practices adopted in those industries are the major influences on both the landscape and the biodiversity of the National Park, and their influence on its landscape is largely mediated through its biodiversity. While the whole of the National Park is regarded as having high landscape quality a substantial part of its area has also been formally designated for its high nature conservation value (8.3.3-8.3.6). This interrelationship between land management, landscape and biodiversity exists in all British National Parks, but is possibly closest in the varied landscapes of Eryri (8.2.1, 8.3.6). Many of the Society’s comments on this part of the consultation document are therefore relevant to all three of these sections.

The consultation document acknowledges there will be physical impacts from climate change (8.4.4). The range and seriousness of the likely impacts (the Society’s previous summary of these is reproduced here as an Annex) show that land management in the National Park is going to face great challenges, and will need to undergo significant changes.

The issues raised are crucial for the future of the National Park, but the analysis of them in the consultation document is confused and fragmented.[1] The future of agriculture in the National Park is central to the analysis, yet (bizarrely) that is not an aspect on which the consultation document invites views. The Authority needs to engage with the future of agriculture and forestry in the National Park, and to do so within the framework of , on the one hand, the national and international response to the threat of climate change and on the other hand the statutory purposes of National Parks, especially in relation to natural beauty and biodiversity. The Society believes the Authority ought to be leading a debate on what, in the light of the changes that will take place over the next few years, would be the most desirable outcomes in terms of land management. Indeed, we believe the Authority should, not only aim to meet the challenges in Eryri, but also aspire to provide a 'Greenprint’ for other areas of the countryside, as an exemplar of how we can plan and manage our landscapes to mitigate and adapt to the impacts of global warming and climate change.

The Society is in general supportive of the Authority in adopting the options for which it has expressed a preference in these three sections of the consultation document and in rejecting the other options which it has specifically identified. But some relevant options have not been considered, and the preferred options do not at the moment add up to a coherent strategy for the National Park. Nor are they adequate to achieve all the objectives for the National Park Management Plan and the Local Development Plan set out in table 1 in chapter 7. The Authority must make clear what kinds of change it regards as inevitable, what kinds of change it regards as unacceptable, what kinds of change it will seek to manage, and what criteria it will apply in managing the latter changes.

There is no one solution for the whole National Park. In fact there may be several, including for example:

In some areas, an increase in woodland may be desirable - though it needs to be clear what the purpose of this is, whether to protect particular habitats or landscape, or to provide an income from timber for the local community (not easy, given current market conditions)

In other areas the current level of agricultural activity may be the optimum – and should be supported by efforts to diversify and add value to local produce

In other areas modified agricultural practices, such as less intensive grazing, may be called for, taking into account in particular the need to support water conservation and quality

There may be areas where a more substantial reversion to more natural vegetation would best serve a number of purposes, and

In many areas, there will also be the potential for increased use for quiet recreational activity, which could support the local economy and aid diversification.

Changes of the sort described above could lead to a real enrichment of the National Park, by maintaining and enhancing its distinctive landscapes, improving its value as habitat and supporting the local economy. The Authority, in conjunction with its partners, needs to bring forward a plan for what might be most appropriate where. The task will then be to drive this forward, by supporting or introducing appropriate policies and programmes at national and local level. That may not be easy, and will not be a matter of a single policy (and/or, where necessary, source of funding) providing for everything.

The soil of Eryri contains very large amounts of carbon. The release of that carbon into the atmosphere as a result of inappropriate methods of land management could add considerably to the releases of greenhouse gases from Wales. There might also be the potential to adopt methods of land management that would remove carbon frorn the atmosphere and retain it securely. Actions to maximise the amounts of carbon retained might also have the benefit of restoring typical local habitats which have been damaged or destroyed as a result of past methods of land management. The Authority needs to respond to these issues. In view of the overriding importance of climate change as an issue it should be a strategic priority for the Authority in the National Park Management Plan to:

Investigate the scope for improved methods of land management which would reduce net emissions of greenhouse gases, and promote appropriate methods of land management in conjunction with partners.