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TOPIC PAPER

POLLUTION AND ENVIRONMENTAL

CONSTRAINTS

August 2013

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About This Document This document is one of series of Topic Papers which provide the supporting evidence to underpin the preparation of the City and County of Swansea Council’s Local Development Plan (LDP): www.swansea.gov.uk/ldpps . Each Topic Paper provides in-depth analysis of a particular issue that the LDP needs to respond to, including the national policy context, a review of local policy, current circumstances and trends, and also suggests appropriate polices for inclusion within the Plan. As further evidence and information becomes available each Paper will be revised and updated as appropriate.

Who to Contact for Further Information? Further information on the LDP process is available to view on the Council’s website: http://www.swansea.gov.uk/ldp. The Council’s Planning Policy Team are available during normal office hours to discuss any aspect of the LDP. They can be contacted by letter/in person: Planning Policy Team, Room 2.6.2, City and County of Swansea Council, Civic Centre, Oystermouth Road, Swansea, SA1 3SN. or via: Tel: 01792 635744 Email: ldp@swansea.gov.uk

If you require this document in a different format, e.g. large print, Braille, audio version, etc. please contact the Planning Policy on 01792 635744, email ldp@swansea.gov.uk or write to Room 2.6.2, Civic Centre, Oystermouth Road, Swansea, SA1 3SN.

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Contents Page No. About This Document 2 Who to Contact for Further Information 2 Contents 3 1.0 Introduction 4 2.0 Planning Context 5 3.0 Evidence Base and Issues 11 Contaminated Land 11 Unstable Land 13 Water Pollution 14 Noise Pollution 20 Air Pollution 22 Light Pollution 26 Climate Change 28 Flood Risk 30 4.0 Proposed Policy for Safeguarding the Environment 37

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1.0 Introduction 1.1 The planning system is fundamental for delivering sustainable development

and has a key role to play in addressing environmental issues. Through the regulation of the use of land in the interest of the public, the planning system should ‘reconcile the needs of development and conservation, securing economy, efficiency and amenity in the use of land, and protecting natural resources and the historic environment.’ (Planning Policy Wales (PPW), 5th edition, 2012, para. 1.2.1). Avoiding, minimising or remedying adverse impacts on the environment through the implementation of mitigation measures is central in achieving this.

1.2 Within the City and County of Swansea (the County) there are a number of

environmental challenges to be addressed, including the impacts of climate change and the consequences for the environment, not least on water quality, in accommodating increased population levels.

1.3 This Topic Paper will look at these environmental challenges in relation to:

contaminated land; unstable land; water quality; noise pollution; air pollution; light pollution; climate change (greenhouse gas emissions); and flood risk.

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2.0 Planning Context

INTERNATIONAL GUIDANCE 2.1 European Parliament Directive 2000/60/EC established a framework for

Community action in the field of water policy “The EU Water Framework Directive (WFD)”1 that:

• Commits European Union member states to achieve good qualitative and quantitative status of all European water bodies, which includes marine waters up to one nautical mile from shore by 2015.2

2.2 European Parliament Directive 2006/7/EC concerning the management of

bathing water quality and repealing Directive 76/160/EEC “The Bathing Waters Directive 2006”3 seeks:

• Protection of public health whilst bathing. • Detailed management practices at bathing waters. • Standardisation of information provided to European bathers.4

2.3 European Parliament Directive 2002/49/EC relating to the assessment and

management of environmental noise “The Environmental Noise Directive (END)” 5 defines:

• A common approach intended to avoid, prevent or reduce on a prioritised basis the harmful effects, which includes annoyance, due to the exposure to environmental noise.6

2.4 European Parliament Directive 2004/35/EC on environmental liability with

regard to the prevention and remedying of environmental damage “The Environmental Liability Directive”7 establishes:

1 Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a

framework for Community action in the field of water policy Official Journal L 327 , 22/12/2000 P. 0001 –

0073 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32000L0060:EN:HTML 2 The Water Framework Directive Tap into it! European Commission Directorate-General Environment 2002

http://ec.europa.eu/environment/water/water-framework/pdf/tapintoit_en.pdf 3 Directive 2006/7/EC of the European Parliament and of the Council of 15 February 2006 concerning the

management of bathing water quality and repealing Directive 76/160/EEC Official Journal L 064 , 04/03/2006

P. 0037 – 0051 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:064:0037:01:EN:HTML 4 Revised Bathing Water Directive Environment Agency http://www.environment-

agency.gov.uk/business/regulation/107017.aspx 5 Directive 2002/49/EC of the European Parliament and of the Council of 25 June 2002 relating to the

assessment and management of environmental noise - Declaration by the Commission in the Conciliation

Committee on the Directive relating to the assessment and management of environmental noise Official

Journal L 189 , 18/07/2002 P. 0012 – 0026 http://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32002L0049:EN:HTML 6 Noise – European Commission Environment http://ec.europa.eu/environment/noise/directive.htm

7 Directive 2004/35/CE of the European Parliament and of the Council of 21 April 2004 on environmental

liability with regard to the prevention and remedying of environmental damage Official Journal L 143 ,

30/04/2004 P. 0056 – 0075 http://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32004L0035:EN:HTML

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• A framework for environmental liability based on the "polluter pays"

principle, with a view to preventing and remedying environmental damage.8

2.5 Council Directive 92/43/EEC on the conservation of natural habitats and of

wild fauna and flora “The Habitats Directive”9 introduced measures that: • Promote the maintenance of biodiversity by requiring Member States to

take measures to maintain or restore natural habitats and wild species listed on the Annexes to the Directive at a favourable conservation status.

• Provide robust protection for those habitats and species of European importance.

• Require Member States to take account of economic, social and cultural requirements, as well as regional and local characteristics.10

2.6 European Parliament Directive 2008/1/EC concerning “Pollution Prevention

and Control”11: • Defines the obligations with which industrial and agricultural activities

with a high pollution potential must comply. • Establishes a procedure for authorising these activities and sets

minimum requirements to be included in all permits, particularly in terms of pollutants released.

• Aims to prevent or reduce pollution of the atmosphere, water and soil, as well as the quantities of waste arising from industrial and agricultural installations, to ensure a high level of environmental protection.12

NATIONAL CONTEXT

2.7 Climate Change Act (2008) 13

• Sets legally binding targets for the reduction of all six of the Kyoto greenhouses gases.

2.8 The Flood and Water Management Act (2010) 14

• Details management of flood risk.

8 Environmental Liability Europa

http://europa.eu/legislation_summaries/enterprise/interaction_with_other_policies/l28120_en.htm 9 Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and

flora Official Journal L 206 , 22/07/1992 P. 0007 – 0050 http://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31992L0043:EN:HTML 10

Joint Nature Conservation Committee EC Habitats Directive http://jncc.defra.gov.uk/page-1374 11 Directive 2008/1/EC of the European Parliament and of the Council of 15 January 2008 concerning

integrated pollution prevention and control (Codified version) Text with EEA relevance Official Journal L 024 ,

29/01/2008 P. 0008 – 0029 http://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:024:0008:01:EN:HTML 12 Europa Integrated pollution prevention and control (until 2013)

http://europa.eu/legislation_summaries/environment/waste_management/l28045_en.htm 13 Climate Change Act 2008 http://www.legislation.gov.uk/ukpga/2008/27/contents 14

Flood and Water Management Act 2010 http://www.legislation.gov.uk/ukpga/2010/29/contents

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2.9 The Air Quality Strategy for England, Scotland, Wal es and Northern

Ireland Volume 1 (2007) 15 and Volume 2 (2007) 16 • Sets out the air quality standards and objectives to be achieved. • Introduces a new policy framework and policy measures for air quality.

2.10 Environmental Protection Act 1990, Part IIA “Contam inated Land

Regime” (Wales, 2001) 17 • The Act which came into force in Wales in 2001 places new

responsibilities on local authorities to identify, and where required, deal with contaminated land.

2.11 Pollution Prevention and Control Act (1999) 18

• Details regulation of pollution. 2.12 Environment Act (1995) 19

• Sets standards for environmental management.

WELSH GUIDANCE 2.13 People, Places, Futures - The Wales Spatial Plan – 2008 update Wales

Spatial Plan 2008 - People, Places, Futures • Sets out the Spatial Vision for Swansea Bay which includes Valuing the

Environment as a core principle and promoting a sustainable economy. • Highlights the importance of safeguarding and enhancing the natural

environment. 2.14 Environment Strategy for Wales (2006) and annual progress reports

Environment Strategy for Wales • Is the 20 year Welsh Government (WG) Strategy for the environment

which includes details on environmental hazards, covering pollution; chemicals; and radioactivity.

2.15 Planning Policy Wales (PPW) Edition 5 (November 201 2) Planning Policy

Wales (Edition 5, November 2012) • One of the main principles of the WG’s approach to planning concerns

pollution prevention … “while preventing pollution as far as possible, ensuring that the polluter pays for damage resulting from pollution. In

15 Air Quality Strategy for England, Scotland, Wales and Northern

Ireland Volume 1

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69336/pb12654-air-quality-

strategy-vol1-070712.pdf 16 Air Quality Strategy for England, Scotland, Wales and Northern

Ireland Volume 2

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69337/pb12670-air-quality-

strategy-vol2-070712.pdf 17

Part IIA Contaminated Land http://www.legislation.gov.uk/ukpga/1990/43/part/IIA 18

http://www.legislation.gov.uk/ukpga/1999/24/contents 19

http://www.legislation.gov.uk/ukpga/1995/25/contents

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general the Welsh Government will seek to ensure that costs are met by those whose actions incur them.”

2.16 Climate Change Strategy for Wales (2010) Climate Change Strategy for

Wales • Refers to air pollution and light pollution. • The Strategy outlines the WG’s role in tackling climate change.

2.17 One Wales: One Plane t – The Sustainable Development Scheme of the WG

(2009) • Provides a vision of a sustainable Wales and the priority attached to

sustainable development. • Advocates the reduction and control of pollution to achieve a sustainable

Wales. 2.18 Technical Advice Note (TAN) 11 – Noise (1997) Technical Advice Note

(TAN) 11: Noise (1997) • Provides guidance in relation to noise and development. Outlines

considerations for the preparation of development plans and the determination of planning applications.

2.19 Environmental Noise (Wales) Regulations (2006) The Environmental Noise

(Wales) Regulations 2006 • The Environmental Noise Directive became law in Wales under the

Environmental Noise (Wales) Regulations 2006. • Calls for action plans to be created to prevent and reduce environmental

noise where necessary and particularly where exposure levels can induce harmful effects on human health as well as to preserve environmental noise quality where it is good.

2.20 Contaminated Land (Wales) Regulations (2001) and (2 006) The

Contaminated Land (Wales) Regulations 2006 • Defines ‘contaminated land’ and places new responsibilities on local

authorities to deal with contaminated land, including the designation of Special Sites.

• The 2006 update expanded the regulations to include radioactivity. 2.21 The Air Quality Standards (Wales) Regulations (2010 ) International,

European and national standards for air quality Incorporate the CAFÉ Directive (2008/50/EC) and the Fourth Daughter Directive into Welsh law, and replace the 2007 Regulations. The CAFÉ Directive on ambient air quality and cleaner air for Europe consolidates and repeals previous ambient air quality legislation with the exception of the Fourth Daughter Directive. The Fourth Daughter Directive relates to arsenic, cadmium, mercury, nickel and polycyclic hydrocarbons in ambient air.

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2.22 Environment Strategy for Wales (2006) Environment Strategy for Wales

• Targets reduced air pollution leading to increased life expectancy and ecological protection’. The Strategy seeks that ‘by 2020 reduction in life expectancy due to air pollution is cut.’

LOCAL GUIDANCE CONTEXT

2.23 Swansea Contaminated Land Inspection Strategy (2005 )20

• Provides the baseline data on contaminated land in Swansea. • Identifies the Council’s duties.

2.24 Swansea Neath Port Talbot Environmental Noise Actio n Plan (2006) 21

• Addresses noise from roads, railways and industry within the agglomeration (urban area) of Swansea/Neath Port Talbot. It is one of four Action Plans required by EC Directive 2002/49/EC relating to the Assessment and Management of Environmental Noise and the Environmental Noise (Wales) Regulations 2006 which transpose the Directive into domestic law.

2.25 Air Quality Management Area (AQMA) Action Plans in Swansea (2004) 22

• Forms the basis of the Council’s obligation under section 84 of the Environment Act 1995 to produce a written plan in pursuit of the achievement of air quality standards and objectives within the designated Hafod Air Quality Management Area.

2.26 Western Wales River Basin Management Plan (2009) 23

• Delivers the requirements of the WFD and focuses on the protection, improvement and sustainable use of the water environment. It describes the river basin district, as well as the pressures that the water environment faces. The Plan highlights the programme of investigations to be undertaken.

2.27 Tawe, Loughor and Gower Catchment Abstraction Manag ement Strategy

and Update (2009) 24 • The Strategy sets out how water resources in the Tawe, Loughor and

Gower catchment will be managed and provides information about how the Environment Agency will manage existing abstraction licences and the availability of water for further abstraction.

• The Update details progress on the Strategy actions and water availability.

20 City & County of Swansea Contaminated Land http://www.swansea.gov.uk/index.cfm?articleid=1084 21

Final Environmental Noise Action Plans for major roads, railways and agglomerations in Wales http://wales.gov.uk/topics/environmentcountryside/epq/noiseandnuisance/environmentalnoise/noisemonitoringmapping

/actionplans/finalplans/?lang=en 22

City & County of Swansea Action Plan http://www.swansea.gov.uk/index.cfm?articleid=9930 23 Environment Agency Western Wales River Basin Management Plan http://www.environment-

agency.gov.uk/research/planning/125095.aspx 24

EA Wales CAMS http://www.environment-agency.gov.uk/business/topics/water/119933.aspx

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2.28 Ogmore to Tawe Catchment Flood Management Plan 2009 25

• Details the scale and extent of flooding now and in the future, and set policies for managing flood risk within the catchment.

2.29 Loughor to Taf catchment Flood Management Plan 2009 26

• Details the scale and extent of flooding now and in the future, and set policies for managing flood risk within the catchment.

2.30 Shoreline Management Plan 2001 27

• Sets out an assessment of the shoreline and outlines how tidal systems in and around Swansea should be managed over the next 100 years.

• A second Shoreline Management Plan (SMP2) for the South Wales coast has been produced and will be published in the near future South Wales SMP

2.31 City & County of Swansea Preliminary Flood Risk Ass essment 2011 28

• Sets out an assessment of most at risk areas from local sources of flood risk, primarily from surface water, groundwater and ordinary water courses

2.32 Local Flood Risk Management Strategy (Draft) 2013 29

• Provides a framework for effective local flood risk management

25 EA Catchment Flood Management Plans – Wales http://www.environment-

agency.gov.uk/research/planning/64223.aspx 26 EA Catchment Flood Management Plans – Wales http://www.environment-

agency.gov.uk/research/planning/64223.aspx 27

Shoreline Management Plan http://www.swansea.gov.uk/index.cfm?articleid=10877 28 Preliminary Flood Risk Assessment 2011

29 local Flood Risk Management Strategy - Swansea

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3.0 Evidence Base and Issues 3.1 The LDP SA/SEA Scoping Report sets out the baseline data for the Plan and

contains detailed baseline data on various topics, the relevant baseline data has been updated where necessary and duplicated here in order to inform the development of conclusions and broad policy outcomes on the topic of Pollution and Environmental Constraints. Key Issues are highlighted in italics and underlined. Any baseline data relating to the Habitats Directive and other associated biodiversity guidance can be found with the LDP Natural Heritage Topic Paper: www.swansea.gov.uk/ldpps

CONTAMINATED LAND

Evidence Base

3.2 The Council’s Contaminated Land Inspection Strategy, 2005 identified 289 potentially contaminated sites. The sites are selected on the basis of the use to which the land has been put in the past one hundred years, as far as is known. The list contains sites that were used by former heavy industries such as mining, non-ferrous metal smelting, iron foundries, steel manufacture and tinplate. Sites were often used for a succession of activities, each of which could have left chemical contaminants or other physical problems. The latest estimate of the area of contaminated land remaining in Swansea, taken from the 2010 progress review of Swansea’s Environment Strategy, is 2148.5 hectares, a reduction of 23.5 hectares or about 1% of the area estimated in 2007 (see Table 1). The figures are approximations based on the redevelopment of contaminated sites as not all have been subject to formal validation as yet.

Table 1: Area of Contaminated Land in Swansea

Year Ha of land 2007 2,172 2010 2,149

(Source: Time to Change: three years on. 2010 Progress Review of the Swansea Environment Strategy)

Key Issues

3.3 The remediation of contaminated land through the planning process The presence of contamination can represent risks to human health, property

and the environment, including long-term limitations on the use of soils. It has been identified as an important issue in the Environment Strategy for Wales. Key objectives of this Strategy are to understand the extent of land contamination better and to ensure that actions are being taken to remediate contaminated land for beneficial use where appropriate.

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3.4 In response to this national objective the LDP must ensure that:

• New development is not undertaken without an understanding of the risks, including those associated with the previous land use, mine and landfill gas emissions, and rising groundwater from abandoned mines.

• Development does not take place without appropriate remediation. • Consideration is given to the potential impacts which remediation of land

contamination might have upon the natural and historic environments.30 3.5 Land contamination is dealt with under Part IIA of the Environmental

Protection Act 1990, which requires the Council to identify and, where necessary, deal with contaminated land. For the County this is being addressed through the Contaminated Land Inspection Strategy 200531 and this forms part of the LDP evidence base.

3.6 Contaminated land for the purposes of the Act, and adopted for use by the

Council, is defined as: “any land which appears to the local authority in whose area it is situated to be in such a condition, by reason of substances in, on or under the land, that either: significant harm is being caused or there is a significant possibility of such harm being caused; or pollution of controlled waters is being, or is likely to be, caused.”(Contaminated Land Inspection Strategy, CCS, 2005:12)

3.7 Not all contaminated Land has been identified

For the purposes of the LDP the Contaminated Land Inspection Strategy ensures that potential impacts of land contamination, both current and future, and subsequent remediation are taken into consideration. However a potential issue for the LDP is whether all contaminated land is identified within the Contaminated Land Strategy, if not, further investigations may be required.

3.8 Most of the remediation costs will be passed on to the developer

The contaminated land regime in Part IIA is aimed at addressing the historical legacy of land contamination. The Council remains committed to implementing Part IIA however, the remediation of contaminated land is a massive and costly undertaking which is difficult to achieve on a restricted budget. The planning process offers an alternative way of dealing with remediation. Through the planning system Local Planning Authorities (LPA’s) can secure the appropriate investigation and remediation of contaminated land through funding by redevelopment schemes. Much progress has been made over the past thirty years on restoration of contaminated land associated with developments in the Lower Swansea Valley, the Swansea docks area, and sites in Pontarddulais and Gorseinon. The Contaminated Land Inspection Strategy states that the Council’s priority will be to deal with those sites where the greatest potential for human health effects is considered to exist.

30 Planning Policy Wales 2012 section 13.6 PPW edition 5 2012 31 Swansea Contaminated Land Inspection Strategy 2005 Swansea Contaminated Land Inspection Strategy

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3.9 Much of the brownfield land in the County is contaminated

The full cost of undertaking formal monitoring and remediation works, which are usually passed on to the developer, needs to be recognised. This is particularly relevant for the LDP because much of the Brownfield land in the County is contaminated. Therefore a sustainable growth strategy which seeks to maximise the use of Brownfield land for development is likely to involve significant remediation works. Whilst it is recognised that this is a good way to remove contamination, the concern is that this approach may make the development of Brownfield sites less economically viable and therefore less appealing to the developer. This will need to be taken into consideration when looking at how the Community Infrastructure Levy may/will be implemented or other S106 contributions (including affordable housing) are to be sought.

3.10 Contaminated sites can be important for other reasons

A further issue for the LDP is that some contaminated sites are of cultural and archaeological value and/or have been naturally re-colonised to become valuable natural heritage sites. Such aspects of contaminated sites will need to be preserved or conserved as part of any remediation work.

UNSTABLE LAND

Evidence Base

3.11 There is an extensive legacy of underground workings and surface spoil heaps in parts of Swansea due to the area’s long history of mining and quarrying. Information on coal mining features is available from the Coal Authority The Coal Authority Information. However, there is only evidence of one defined slip area which is located at Graig Trewyddfa, near Morriston (see figure 1 below) Limited information on ground stability can be obtained from the Council’s Environmental Health Section.

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Figure 1: Graig Trewyddfa Slip Area

Key Issue 3.12 In some parts of the County there are significant risks from land instability

The possible effects on land stability of past workings, as well as natural processes in limestone areas need to be assessed when allocating land for development. The nature, scale and extent of ground instability which may pose direct risks to life and health, buildings and structures or which present indirect hazards associated with ground movement will need to be taken into account. Development at Graig Trewyddfa must be avoided. Elsewhere, in areas where development could create, affect or be affected by unstable land, site proposers may have to carry out their own site investigation assessments to demonstrate that the site is developable.

WATER POLLUTION

Evidence Base

3.13 The following figures show the 2009 baseline classification of Water

Framework Directive (WFD) water bodies. The WFD requires no deterioration from this baseline.

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Figure 2: Surfacewater Body Quality Classification for the City &

County of Swansea: Ecological Status and Chemical S tatus

Figure 3: Groundwater Body Classification for the C ity & County of Swansea: Chemical Status and Quantitative Status

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Figure 4: Ecological Status of Lakes in City & Coun ty of Swansea

Table 2: Summary of Water Body Classification in t he City & County of Swansea

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Figure 5: Extent of Surfacewater and Groundwater Pr otected Areas in

the City & County of Swansea

Figure 6: Risk of Future Non Compliance with Guidel ine Standards of Current Bathing Water Directive and Predicted Classification under the Revised Bathing Water Dire ctive

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Key Issues

3.14 The protection and management of water quality is covered by European law The WFD requires the protection of the water quality of surface waters e.g. rivers, lakes, estuaries and coastal waters and groundwaters e.g. underground streams, rivers and aquifers. The water quality classifications for the County are shown in Figures 2 to 4 and summarised in Table 2. Water pollution is a major cause of failing water quality and can occur for numerous reasons.

3.15 Surface water runoff from roads and urban spaces and sewer discharge are

prime causes of failing water quality The WFD indicates that for the County nearly a quarter of the water quality failure is caused by diffuse pollution from a non agriculture source. This includes surface water runoff that contains contaminates from roads and urban spaces. Another significant source of water pollution is sewer discharge primarily continuous but also intermittent including overflows of untreated sewage during storm events. These factors are issues for the LDP and need to be taken into consideration when allocating land for development. There must be sufficient capacity in waste water treatment infrastructure to accommodate proposed new development. All new development must consider the use of SuDS in the first instance in line with the SuDS Management Train32 and forthcoming national guidance. A connection to public sewerage network to dispose of surface water should only be considered once all other options have been exhausted. This approach will contribute to a reduction in storm water flow to sewage works.

3.16 The Burry Inlet and Loughor Estuary is a particularly sensitive water body

A major issue for the LDP is the water quality of the Burry Inlet and Loughor Estuary, which forms part of the Carmarthen Bay and Estuaries European Marine Site (CBEEMS). Maintaining the water quality of the CBEEMS will also safeguard the biodiversity of this internationally protected site. Protection of the water quality should be achieved by the proper treatment of waste water and surface water run off. Currently there are issues with the number of sewer discharges taking place into the CBEEMS (more details are provided in the Physical Infrastructure Topic Paper). Therefore it is essential that there is sufficient capacity within the waste water treatment infrastructure that drains into the CBEEMS to accommodate all new development and that surface water run-off from development within the water catchment area of the CBEEMS is appropriately managed. Various SuDS features can be used to manage and treat surfacewater on site before disposal these include swales, reed beds, rain gardens, filter strips and ponds. The inclusion of such features in development schemes will reduce loading to the sewers and would be expected as part of national standards.

32 http://www.susdrain.org/delivering-suds/using-suds/suds-principles/management-train.html

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3.17 Ground water quality must be safeguarded

Groundwater needs to be protected from pollution. NRW has identified different types of aquifers within the County and these will need to be taken into consideration in allocating sites. Because of the nature of the geology of the County, which allows for rapid movement of water, the groundwater of the entire County has been classified as at risk from pollution (Figure 5 refers).

3.18 Managing the bathing water quality of Swansea Bay

Swansea Bay has complex pollution issues because of the complicated catchment geology around the Bay. The problem is compounded during periods of heavy rain when untreated storm water discharge enters the sea. Pollution Control (City & County of Swansea) has worked with Natural Resources Wales (formerly the Environment Agency) and Aberystwyth University to develop a working bathing water quality prediction model. This means that Swansea Bay is now officially classified as ‘Good’ under the European Bathing Water Directive 2006. DCWW is working to reduce the number of spills into the Bay from the sewerage network to improve the current situation. The sewage infrastructure that drains into Swansea Bay must be able to accommodate all new development and surface water runoff from development must be appropriately managed. Failing bathing water quality is a potential deterrent for tourism.

3.19 Lack of capacity for the treatment of waste water is a potential constraint on

future development In order to address this major issue there are two main factors to be taken into consideration. One is the capacity of the waste water treatment infrastructure that discharges into the CBEEMS and Swansea Bay to physically accommodate additional quantities of foul water. This is the responsibility of DCWW as the statutory sewage undertakers for the County and will need to be addressed in DCWW’s long term improvement plans. The second is the significant environmental constraints of the area and the capacity in particular for the CBEEMS to accommodate additional treated discharge. This is regulated through a discharge consent from Natural Resources Wales (NRW). Development from parts of Carmarthenshire County Council (CCC) also drains into the CBEEMS and this will need to be taken into consideration in determining overall capacity. To date capacity issues associated with planning applications that fall under the catchment of the treatment works that run into the CBEEMS have been addressed through a Memorandum of Understanding (MOU) agreed between the Council, CCC, DCWW, the Environment Agency and the Countryside Council for Wales (the latter two have now combined to form NRW). The agreed approach centres on removing surface water from the waste water treatment infrastructure and thereby increasing the capacity for the treatment of foul water. In order to ensure there is sufficient capacity to accommodate proposed LDP allocations it is intended to review the MOU and agree a way forward between all relevant bodies. This could involve a continuation of the removal of surface water from the waste water treatment infrastructure, an enhancement of the level of treatment to meet discharge consent requirements and the upgrading of waste water treatment infrastructure where appropriate and feasible.

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NOISE POLLUTION

Evidence Base

3.20 Noise is unwanted or harmful sound resulting from human activity and is a

pollutant. It can have a detrimental impact on people's health and quality of life, local amenity and wildlife. Major transport routes (road, rail and air) and some industrial and commercial activities can generate particularly high noise levels. Housing, schools and hospitals are particularly sensitive to noise, as can be areas of landscape, wildlife or historic importance. National planning guidance requires development plan policy to consider noise when planning new development.

3.21 Transportation noise has historically been an issue for the County, with

problems around the airport and night-time problems around railway activities. There are currently few noise issues with the airport due to very low levels of activity, but late-night train servicing is still an issue receiving attention from the Council’s Pollution Control Team. It is anticipated that the electrification of the rail network in South Wales will bring the additional benefit of reduced noise to some locations. This is of particular interest around the Swansea terminus for the high-speed trains where late-night servicing and cleaning takes place very close to residential areas.

3.22 Under the Environmental Noise Directive a Noise Action Plan for the

combined urban area of Swansea and Neath Port Talbot has been produced.33 This Action Plan seeks to combat the harmful effects of over-exposure to environmental noise in the County through the identification of Priority Areas where mitigation measures are needed (see Figure 7 below) and the designation of Quiet Areas (see Table 3 below) for safeguarding. It will inform the allocation of sites in the LDP.

33 Swansea Neath Port Talbot Noise Action Plan

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Figure 7: Noise Action Planning Priority Areas

Table 3: Quiet Areas and Candidate Quiet Areas in S wansea

Confirmed Quiet Areas Candidate (proposed) Quiet Areas

Cwmdonkin Park Brynmill Park Dunvant Park Clyne Country Park Fendrod Lake Clyne Cycle Track Llewellyn Park Clyne Gardens Morriston Park Coed Gwilym Park Oystermouth Castle Singleton Park Oystermouth Cemetery Swansea Beach Ravenhill Park Swansea Urban Woodland Tawe Riverside Park Underhill Park

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Key Issues

3.23 Existing areas with environmental noise problems

In some areas of the County a significant number of people are exposed to high levels of environmental noise. These problem areas have been identified as Priority Areas within the Action Plan and referred to as Noise Action Planning Priority Areas (NAPPA’s). For these existing noise ‘hotspots’ mitigation measures will need to be put in place to diminish the problems. This could include traffic management measures and mitigation measures for new developments proposed in the LDP.

3.24 Currently the programme for highway improvements is being examined to see

which schemes would bring a noise reduction benefit to the greatest number of residents. All resurfacing work reduces road noise but this could be optimised by comparing the range of materials currently used and looking for mutual benefits against other parameters such as cost and resilience.

3.25 New development will have to take account of any noise implications

New developments proposed in the LDP that would give rise to high noise levels, including proposed transport schemes, should be located and designed so as to minimise their noise impact on existing and proposed communities and areas of landscape, wildlife and historic importance. Where possible, particularly noise-sensitive new developments should be located away from significant existing or proposed noise sources. Where such developments need to be located close to transport infrastructure for access reasons, they should be designed so as to reduce noise impact.

3.26 Places of refuge from the noise of urban living will need to be protected

The Noise Action Plan recognises the need to safeguard places of refuge from the noise, hustle and bustle of city life. Quiet Areas have been identified and further ones are proposed (Table 3 refers) throughout the County with the aim of protecting them against any increase in environmental noise. Special consideration should be given where noise generating development is likely to affect a designated quiet area. In allocating future development the tranquillity of these areas must be safeguarded.

AIR POLLUTION

Evidence Base

3.27 The Air Quality Standards (Wales) Regulations require that Wales is divided

into air quality zones. Swansea is situated within the South Wales Air Quality Zone A and forms part of the Swansea and Neath Port Talbot agglomeration. An agglomeration is an area that has a population of over 250,000 inhabitants and there are two in the South Wales Zone.

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3.28 Since 1997 local authorities have undertaken a review and assessment of air

quality in their areas in order to ensure that national air quality objectives are met. The Environment Act 1995 required local authorities to designate areas where it is likely that the standards for any of the identified pollutants would be exceeded as Air Quality Management Areas (AQMAs).

3.29 An AQMA is an area where the objectives are not met for Particulate Matter

PM10 and Nitrogen Dioxide (NO2). NO2 is usually derived from Nitrogen Oxide (NO) produced from the combustion of fossil fuels. In sunlight a photochemical reaction rapidly oxidises NO to NO2, which is considered harmful to human health, and a contributing factor to acid rain. NO2 does not move very far from its point of source but will also react in sunlight with volatile organic compounds (VOCs) to create low lying ozone and smog. Epidemiological evidence links concentrations of both particles and NO2 in the atmosphere with human health effects. Particles can vary widely in size and composition. The PM10 (particles measuring 10µm or less) standard was designed to identify those particles likely to be inhaled by humans and PM10 has become the generally accepted measure of particulate material in the atmosphere in the UK and in Europe. The main sources of primary PM10 are road transport (all road transport emits PM10, but diesel vehicles emit a greater mass of particulate per vehicle kilometre), stationary combustion (domestic coal combustion has traditionally been the major source of particulate emissions in the UK) and industrial processes (including bulk handling, construction, mining and quarrying).

3.30 Since 2001 an AQMA has been identified in the Hafod area of the County as

a result of exceedence of the annual mean objective for NO2. In 2010, exceedences of NO2 were also recorded in the Sketty and Fforestfach areas, and as a result the AQMA was expanded to include these additional areas, as shown in Figure 8

Figure 8 : Swansea Air Quality Management Area 2010

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3.31 The most recent monitoring undertaken also indicates newly identified areas

of exceedences of the nitrogen dioxide annual mean objective outside of the Swansea AQMA 2010 within the Uplands, Morriston, Llansamlet, Ynystawe and City Centre areas of the County. Several other areas also exhibit the potential to exceed the annual mean objective. However it is not proposed to amend the existing Swansea AQMA 2010 at present to include these newly identified failing areas. This decision has been taken due to the atypical meteorological conditions of recent years coupled with the future year projections of the annual mean objective within these areas. This decision is further supplemented by the requirement for additional monitoring to establish the exact extent of failure. Updates on the situation will be provided within future reporting and, if necessary, in due course a recommendation may be made that these areas are added to the Swansea AQMA 2010.

3.32 The 2008 Welsh Index of Multiple Deprivation (WIMD) includes a physical

environment theme assessing the four factors of air quality, air emissions, flood risk and proximity to waste disposal and industrial sites. Figure 9 below shows the position of LSOAs, which are small geographical areas or communities based on the census output areas, against the Air Quality Concentration Index. The areas in red are ranked highest and clear links with the AQMA can be identified.

Figure 9: Shows Communities with the Most Significa nt Air Quality

Issues (shown in red)

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3.33 The effects of acid deposition vary according to habitat or species. Figure 10

illustrates the effect of acid and nitrate deposition on European designated sites within Swansea, modelled for 2010. In general, where acid deposition is high there is a decrease in overall biodiversity.

Figure 10: Natura 2000 Sites which have exceeded cr itical load for

Acid and Nitrate Deposition (shown in red)

Key Issues 3.34 New development must have regard to air quality

Prolonged exposure to poor air quality can have serious human health implications. Therefore, allocating future development housing allocations within the AQMA should be avoided as far as possible. Care should also be taken when allocating sites that could have the potential to result in increased traffic in the AQMA and other areas where air quality is becoming a concern, including Mumbles, Uplands, Morriston, Llansamlet, Ynystawe and the City Centre.

3.35 The Air Quality Action Plan identifies ways to reduce NO2 within the AQMA to

acceptable levels and the situation is continually being monitored. Detailed LDP policy will need to be suitably flexible to allow for changing air quality conditions.

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3.36 Swansea is experiencing increasing levels of poor air quality

Evidence suggests that increasing levels of poor air quality are linked to increases in traffic flows. It is important that the LDP allocates development so as to minimise the need to travel by private car. Locations for development that would lead to an increase in traffic through an AQMA should be avoided as far as possible.

3.37 Air Pollution is a threat to biodiversity

Acidification as a result of air pollution can have an effect on biodiversity. In the County there is evidence to suggest that European Designated Sites with high acid deposition are experiencing a damaging effect on biodiversity. A sustainable growth strategy would help to alleviate this issue. Detailed policy should allow for this impact on biodiversity to be taken into consideration when forming a judgement on how a proposed development may have an effect on its surroundings.

3.38 The potential have a combined approach to deal with air and noise pollution

There are synergies between the actions required to reduce air pollution concentrations and those required to reduce road traffic noise. Usually the worst affected areas are matching, and the overall need to keep traffic moving at a sensible pace, minimising sharp braking and acceleration, will benefit both Air Quality and Noise Action Plans. Joint working on local air quality and environmental noise is currently being pursued by the Council

LIGHT POLLUTION

Evidence Base

3.39 There is limited information available about local light pollution, but satellite

images over recent years have shown a general increase in light emissions across Wales.

3.40 CCW (Now NRW) produced a Tranquil Areas map for Wales in 1997 (updated

in 2009). This assessment includes the consideration of light pollution and shows satellite derived information on sky glow across Wales in 2000. The results are shown in Figure 11 below. For the County, Gower is an area relatively free from light pollution whilst the urban area not surprisingly experiences the worst light pollution.

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Figure 11: Wales Tranquil Areas Map 2009

Key Issues 3.41 Inconsiderate or incorrect lighting

Light pollution can be described as an artificial light causing an intrusion by illuminating an area that is not intended to be illuminated. One of the main intrusion problems that occurs is from poorly directed and over bright lights on neighbouring properties that shine light through windows

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3.42 Another concern for the County is sky glow, this is the orange glow seen from

towns and roads from upward light. In some areas this can be a particular problem for astronomers viewing the night sky.

3.43 Increasing levels of light pollution can result in a number of detrimental

impacts. These include: the production of glare when over bright light against a dark background affects a person’s ability to view objects; detraction from the architectural appearance of attractive and/or historic buildings; damage to wildlife and the ecology of an area by disrupting natural patterns of activity; and problems for human health from similar problems of disruption. Light pollution also represents a significant waste of energy and resources.

3.44 Some of these problems can be resolved through the submission of a lighting

plan at the planning application stage and LDP policy should encourage this approach. This would allow for the proper consideration of impacts on neighbours, ecology and surrounding buildings, and ensure that lighting for new development takes place in a sensitive and sustainable manner.

3.45 Dark skies should be recognised for their qualities and protected

The dark skies of Gower are shown to be one of the few places in South Wales where there is minimum light pollution. There are however instances of this quality being eroded through, for example, the inappropriate lighting of caravan and camping sites, farm yards and security lighting on residential properties. This has resulted in the production of a lighting guide34 with the intended aim of protecting dark skies on Gower. The effectiveness of this guidance is to be reviewed and policies need to be put in place to afford appropriate protection.

CLIMATE CHANGE - GREENHOUSE GAS EMISSIONS

Evidence Base

3.46 Greenhouse gases (GHGs) are Methane; Nitrous Oxide; Hydroflourocarbons

(HFCs); Perfluorocarbons (PFCs) and Sulphur Hexafluoride (SF6). They can be emitted through, for example, transport and the production and consumption of food, fuels, manufactured goods, materials, wood, roads, buildings, and services. For simplicity GHG emission is often expressed in terms of the amount of Carbon Dioxide CO2 and will include a level of CO2 that has the equivalent global warming potential of any other GHGs emitted. The considerable increases in CO2 in the Earth’s atmosphere since the industrial revolution are believed to have resulted in global warming,

34 Lighting Scheme Guidance for Gower AONB

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3.47 The Department of Energy and Climate Change (DECC) has released

statistics on carbon dioxide emissions for each local authority area for the period 2005-2009 for each sector (see Table 4 below). The dataset is a spatial disaggregation of the National Atmospheric Emissions Inventory (NAEI) CO2 inventory on an end user basis. This means that emissions from the production and processing of fuels (including electricity) are reallocated to users of these fuels to reflect total emissions for each type of fuel consumed. This is in contrast to ‘at source’ emissions, in which all emissions are attributed to the sector that emits them directly. The end user basis for reporting emissions has been chosen for this dataset because it fully accounts for the emissions from energy use at the local level and does not penalise local areas for emissions from the production of energy which is then ‘exported’ to other areas. The trend for carbon emissions is in decline in the industry/commercial, domestic and transport sectors and slightly increasing in the forestry sector.

Table 4: Carbon Emissions for City and County of S wansea:

2005- 2009 in kt (Kilo tonnes) of CO2

Year Industry and Commercial

Domestic Road Transport

LULUCF (land use, land use change and forestry)

Total Population ‘000’s

Per capita emissions (t)

2005 667 591 409 6 1673 227 7.4 2006 686 596 407 6 1695 228 7.4 2007 599 599 415 5 1579 229 6.9 2008 624 574 394 6 1597 230 6.9 2009 522 520 375 7 1423 231 6.2 Source DECC

3.48 The latest progress report (2013) into the reduction of carbon emissions in

Wales suggests that, apart from a slight rise in 2010 probably due to a severe winter, this trend in reducing CO2 emissions is continuing.35

3.49 Alternative methods of calculating carbon emissions reveal a higher level for

the County. For example, the approach adopted by the Stockholm Environmental Institute (SEI) shows the County’s Carbon Footprint to be 11.59 tonnes CO2/capita (SEI, 2008) which is higher than other calculating methods but still lower than the UK figure of 12.08 tonnes CO2/capita. However these figures date back to 2004 and are considered experimental.

35 Climate Change Strategy Wales: Progress Report 2013

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Key Issues

3.50 A requirement to reduce GHG emissions

The Climate Change Strategy for Wales (2010)36 highlights the need for urgent and sustained action to cut GHG emissions worldwide to avoid the worst impacts of climate change in the future. The WG has set targets of reducing GHG emissions by 3% each year from 2011. This is against a baseline of average emissions between 2006 and 2010. In addition to this, a target has been set of achieving at least a 40% reduction in all GHG emissions in Wales by 2020 against a 1990 baseline.

3.51 The Council signed up to the “Welsh Climate Change Declaration” in March

2006, Swansea and Welsh Climate Change Declaration committing it to delivering a significant reduction in GHG. Since 2006 there has been a slight but steady decline in CO2 emissions.

3.52 Energy supply and road transport are probably the biggest sources of GHG

emissions in the County. The LDP has a role to play in helping to reduce these levels by seeking to limit traffic movement through the sustainable selection of strategic sites. Carefully designed urban form for ease of access to services and employment by non-car modes will be required and will also have a positive impact.

3.53 Alternative sources of energy will need to be promoted through the LDP,

including district heating networks that utilise waste heat from commercial operations and appropriate renewable energy schemes. It is likely that small scale renewable energy schemes for residential and commercial buildings will become increasingly more common.

3.54 Developers need to be encouraged to site and design new development to

minimise energy demands. This combined with the WG’s strict building standards that are aimed at reducing carbon emissions in the construction and operation of buildings, should result in increasing numbers of low carbon buildings in the County over the lifetime of the LDP.

FLOOD RISK

Evidence Base

3.55 Detailed information on the County’s flood risk is provided in the Strategic Flood Consequences Assessment (SFCA)37 and the Shoreline Management Plan (SMP)38. These assessments identify and assess sources of flooding in the County on a strategic scale. The SFCA considers fluvial, groundwater, drainage, overland flow, sewers and artificial sources. The SMP outlines how the South Wales coastline should be managed and covers coastal flooding.

36 Climate Change Wales document 2010 37 Swansea LDP Strategic Flood Consequence Assessment 38 South Wales Shoreline Management Plan

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3.56 The SFCA considers all relevant flooding information from a variety of

different sources. This data includes TAN 15 Development Advice Maps, Environment Agency (EA) Flood Maps (Shown in Figure 12 below), EA Tidal Flood Maps, EA Historical flooding records, CCS Maps of Areas Susceptible to Surface Water Flooding (ASTSWF), EA information on existing flood defences, Catchment Flood Management Plans (CFMP) Loughor to Taf and Ogmore to Tawe, CCS historical records and local knowledge of problem surface water areas.

Figure 12: Environment Agency Flood Risk Map and We lsh

Government Advice Maps 3.57 The SFCA also takes into consideration flood defences (identified in Figure 13

below) to provide an accurate assessment of flood risk in the County.

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Figure 13: Overview of Flood Defence in the City an d County of

Swansea 3.58 The key findings of the SFCA show that the main causes of flooding in the

County are fluvial and tidal. To a lesser extent a flood risk from overland flow exists, whilst flood risk from ground water is considered minimal. There is some localised sewer flooding due to a limited sewer capacity.

3.59 Areas of the County at most risk from fluvial flooding are Morriston,

Llansamlet, Loughor and Pontarddulais, however there is extensive fluvial flood defence in place in the Morriston/ Llansamlet area. Areas at risk from tidal flooding are the City Dock area, St Thomas and Loughor. Areas susceptible to surface water flooding include Morriston, Llansamlet, Pontarddulais, Gowerton, Gorseinon, Blackpill, Sketty and Swansea Docks. These key findings are presented in Table 5 below which are taken from the SFCA.

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Table 5: A Summary of Flood Risk Areas in the City and County of

Swansea (source: Swansea SFCA)

Type of Flooding

Worst Affected Areas

Fluvial River Tawe corridor (Morriston, Llansamlet) and River Loughor corridor (Loughor, Pontarddulais)

Tidal River Loughor estuary

(Loughor), Coastal Gower peninsula, River Tawe estuary (St Thomas/ Dock area of Swansea)

Surface Water (ASTSWF - areas susceptible to surface water flooding)

Lower topographical areas, particularly River Tawe (Morriston, Llansamlet), Rivers Loughor and Lliw (Pontarddulais, Gowerton, Gorseinon), Southern Swansea (Blackpill, Sketty, Docks)

Surface Water (sewer flooding) Oxwich, Manselton,

Swansea, Gorseinon, Sketty, Crofty and Penllergaer.

Surface water (local incidence) Blackpill, Parkmill area

Cockett, Llansamlet, Gorseinon, Port Tennant, Loughor Bypass, Llangyfelach, Killay, Hendrefoilan

Groundwater Not considered to be a

significant flood source.

Artificial Sources Down stream of Nant-y-Fendrod reservoir

3.60 The WIMD (2011) shows that the City Dock area and Pontarddulais are at

most significant flood risk in relation to population (Figure 14 below shows). This correlates with the findings of the SFCA.

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Figure 14: Communities At Most Risk of Flooding (sh own in red)

3.61 Detailed information on coastal flooding is provided in the Shoreline

Management Plan (SMP)39. An updated version of the SMP (known as SMP2) has been prepared and is due o be published later in 2013. SMP2 covers the length of coastline from St Anne’s Head, Milford to Lavernock Point, Barry and therefore includes the County’s coastline. This Management Plan provides a high level assessment of the risks associated with coastal processes including flooding and sea level rise. It proposes policies over three different time scales up to 100 years. Of most relevance to the LDP is the present day period of up to 20 years. The coast is divided into separate policy units to which one of the four policy options, described in Table 6 below, is applied and illustrated in Figure 15

39 South Wales Shoreline Management Plan

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Table 6: The four management policy options applied by SMP2

Policy

Action

Hold the Line (HTL) Maintain or upgrade level of protection provided by existing defences

Advance the Line (ATL) Build new defences seaward of existing defences

Managed Realignment (MR) Allow shoreline to move backwards or forwards with management to control or limit movement

No Active Intervention (NAI) No investment in providing or maintaining defences

Figure 15: SMP2 Policy Units for the City and Count y of Swansea 3.62 For most of the developed coast around the County the policy for flood

management is to ‘hold the line’ which, as sea levels rise, could involve the upgrading of existing defences.

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Key Issues

3.63 Flooding events are likely to become more frequent and further limit sites for

development It is likely that flooding events will become more frequent and severe in the future due to the effects of climate change, in particular rising sea levels and more intense rainfall. Areas at risk of flooding will constrain and limit the availability of sites for development.

3.64 Expansion of existing settlements in low lying locations will require careful

consideration Much of the County’s existing urban settlement is located along the coast, rivers and low lying areas, and any expansion of these areas will need to take into account the probability of increasing flood risk from all potential sources. It is important to ensure that development proposals are not at risk from flooding and also do not increase the risk of flooding elsewhere, either by occupying valuable flood water storage areas, or through additional run-off from development in any location.

3.65 A change in the approach to flood management

National guidance places an emphasis on flood management, as opposed flood defence. This involves the use of soft engineering options that maximise use of the natural environment to minimise the consequences of flooding. Examples include leaving low lying areas next to rivers undeveloped to act as water storage areas and reconnecting rivers to their natural flood plains. The LDP should seek to protect those natural flood water storage areas that contribute to the Green Infrastructure (further details in the Green Infrastructure Topic Paper) and avoid allocating land for development on flood plains.

3.66 The CFMPs provide the whole river catchment flood defence strategy that is

required for soft engineering to function as intended, while the SMP provides a whole coast defence strategy. It is clear from the national guidance that new hard defences to enable the development of high flood hazard areas will not be acceptable.

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4.0 Proposed Policy for Safeguarding the Environmen t 4.1 The Council’s Vision for the LDP, as currently drafted, is that: 4.2 The City and County of Swansea will be a desirable place to live, work and

visit that • Capitalises on the distinctive relationship between its vibrant urban areas

and outstanding rural and coastal environments • Have sustainable, distinct communities, in both urban and rural locations

that benefit from sufficient good quality accommodation, supporting infrastructure, community facilities and opportunities for recreation.

• Supports a competitive and prosperous economy that acts as a focal point for the wider Swansea Bay City Region

• Is a thriving city centre destination that offers excellent shopping facilities and supporting leisure and business opportunities which capitalises on its proximity to the waterfront

• Celebrates and conserves its unique natural heritage and cultural and historic environments.

4.3 To help achieve this, the following LDP objectives seek to reduce

environmental impacts: • Promote a sustainable development strategy that pri oritises the re-

use of appropriate previously developed land, avoid s significant adverse environmental impacts and respects environm ental assets.

• Support measures to minimise the causes and consequ ences of climate change

• Encourage appropriate development of low carbon and renewable energy resources and energy infrastructure

• Support the safeguarding and sustainable use of nat ural resources where appropriate

• Preserve and enhance the County’s high quality cult ural and historic environments

• Conserve and enhance the County’s natural heritage • Maintain and enhance green infrastructure networks

4.4 This means that the LDP must provide for sustainable development by

protecting, and where possible enhancing, the environment whilst facilitating sustainable economic growth and ensuring that all new development is supported by appropriate physical and social infrastructure. It is therefore important to locate new development so as to minimise the hazards from pollution, flooding, land contamination and land instability, and aim to enhance the environment where possible.

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4.5 In order to achieve this balance between safeguarding the environment and

allowing for appropriate growth, a Strategic Policy on Safeguarding the Environment is proposed for inclusion in the Draft LDP Preferred Strategy. The supporting text explains that the acceptability of adverse effects will depend on the nature and location of the development and that in some cases adverse effects can be mitigated to make the development acceptable.

Policy 14 : Safeguarding the Environment The County’s environment will be protected from mat erially harmful development and where possible enhanced. Development that would result in unacceptable adver se environmental effects will not be permitted, particularly in resp ect of :

(i) air, noise or light pollution (ii) flood risk (iii) the quality or quantity of water resources (iv) land contamination, and (v) land instability or subsidence

Detailed Policy 4.6 A detailed or set of detailed policies relating to safeguarding the environment

should be included in the Deposit LDP. This policy will work alongside the LDP Constraints Map that identifies all known environmental constraints, as far as possible. The Map will include details of flood risk, unstable land, contamination, landfill sites, hazardous installations, AQMAs, NAPPAs and Quiet Areas. The associated detailed policy will explain that not all potential environmental hazards have been identified and that developers may be required to provide further site investigations and assessments as appropriate.

4.7 The Deposit LDP should also include a ‘natural resources protection policy’

relating to air, noise, light, water, contaminated land pollution and any other identified hazards. This policy must aim to prevent development that would result in unacceptably high levels of pollution for sensitive uses and also ensure that new development is not located in close proximity to existing sources of pollution.

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4.8 Detailed policy on flood risk will ensure that unacceptable development is not

permitted in flood hazard areas and that development does not increase the risk of flooding elsewhere, for example, by occupying a valuable flood water storage area or through additional surface water run-off from development. This policy will work alongside policy that promotes the use of SuDs and a Green Infrastructure policy that protects natural flood water storage areas.

4.9 Detailed policy on unstable land will seek to avoid potential problems through

a requirement for stability reports for proposals that affect land with instability/landslip issues.

4.10 An overall policy on climate change will combine and reinforce the polices

outlined above, and also address the issue of greenhouse gas emissions. Such a policy should require development proposals to consider the impact on the climate and to demonstrate how it will adapt to the effects of climate change by promoting:

• energy efficiency • sustainable building methods • sustainable drainage systems • the use of local materials and supplies • the use of renewable energy generation • the location of development so as to reduce the need to travel • efficient use of resources • minimum waste, water use and pollution • Avoidance or mitigation of the risk of flooding and /or adapt to the

increased risk of flooding