For Office Use LDP Representor No: Date received: Action: / scanned / copied / acknowledgement / entered:

Powys Local Development Plan (LDP) 2011-2026

Matters Arising Changes Representation Form, September 2017 It is recommended that representations are made on this standard form. More copies are available at Powys Council offices and at local libraries where the Schedule of Matters Arising Changes is available for public inspection or online at www.powys.gov.uk/ldp Please complete Sections 1 and 2 of this standard form; it only needs to be done once. For Section 3 you will need to use a separate form for each representation on each Matters Arising Change that you wish to make and attach it to sections 1 and 2. Send your completed form to: Powys LDP Team Planning Policy Powys County Council The Gwalia, Llandrindod Wells, LD1 6AA or via email to ldp@powys.gov.uk Representations must be received by 5.00 pm, Monday 30th October 2017. Representations at this stage must only relate to the Matters Arising Changes (MAC). It is not an opportunity to add to or make new comments on the Deposit LDP 2015, the Focussed Changes January 2016 or the Further Focussed Changes October 2016. Any such representations will be disregarded as they should have been made during the earlier stages of the Plan preparation. Duly made representations will be forwarded to the Inspector appointed to examine the soundness of the Plan for her consideration. Group Representations Where there are groups who share a common view on how they wish to see the LDP changed, it would be very helpful for the group to send a single representation which represents that view. (Repeating the same points numerous times will not add weight to the case being made). Groups should indicate how many people they represent and how the representation has been authorised. The group’s representative should be clearly identified.

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Please note that information provided in Sections 2, 3 and 4 will be made publicly available. Personal information, as provided in Section 1, will be treated confidentially and will not be made publicly available) SECTION 1: Personal Information – this section MUST be completed. Your Details Agents Details (if applicable) Name:

1. Jonathan Colchester, Chair Brecon & Radnor Branch

2. Christine Hugh-Jones

3. Margaret Tregear

Tel: Email: Signature: Date:

30/10/2017

Representor Number *:

6235

*You will have a Representor Number if you have made representations at previous stages of the LDP process or if you have requested to be included on the Council’s LDP database. The Representor number will be clearly indicated on previous correspondence from the Council/Programme Officer. PLEASE QUOTE THIS NUMBER TO ASSIST THE COUNCIL IN IDENTIFYING YOU IF YOU ALREADY HAVE A NUMBER. Privacy Statement Personal Data will be processed in accordance with the Data Protection Act 1988. We will only use the information for the purpose of the LDP process. By submitting a representation, the following personal information may be placed in the public domain including publication on the Powys County Council website: Your name, organisation / company, address, and your representation. All personal telephone numbers and email addresses will be treated as confidential. Powys County Council accepts the following responsibilities for personal information recorded:

1. The information will only be used for the agreed reason and will be looked after securely. 2. The information will only be kept for as long as needed or to comply with statutory requirements and

will then be securely destroyed. 3. If the information has to be shared with other agencies initial consent will be gathered at this point

and explicit (signed) consent will obtained by the service / department concerned as soon as possible. Unless we are obliged by law to disclose the information.

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Detailed guidance can be found on our webpages – search Freedom of Information - or from the Information Management Team. SECTION 2: Contact Details Your Details Your Agent’s Details (if applicable) Name:

1. Jonathan Colchester, Chair Brecon & Radnor Branch

2. Christine Hugh-Jones

3. Margaret Tregear

Organisation/Company: Address: Postcode:

The Brecon & Radnor Branch of the Campaign for the Protection of Rural Wales

c/o Cooks House, Norton, Presteigne, Powys

LD8 2HA

From this point onwards please use a separate representation form for each Matters Arising Change you wish to make a comment on. All representations made will be available for the public to view. SECTION 3: Commenting on the Matters Arising Changes: 3a: Which document are you commenting on: Please tick one: Schedule of Matters Arising Changes (September 2017) ____

Sustainability Appraisal Report (September 2017) ____

Environmental Report Addendum (Strategic Environmental Assessment) (September 2017) ____

Habitat Regulations Assessment Screening of Matters Arising Changes (September 2017) ____

3b: Which Matters Arising Change are you commenting on? When making a comment or representation, it is important you tell us which Matters Arising Change you are commenting on.

Please remember to use one form per change/representation:

Which Matters Arising Change are you commenting on? (Please refer to MAC Schedule)

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Matters Arising Change reference

number (e.g. MAC1) Support Object

If you are objecting to a MAC, please state which Test of Soundness you think that it

fails. Test 1 Test 2 Test 3

37

The Tests of Soundness

Test 1 Does the plan fit? (i.e. is it clear that the LDP is consistent with other plans?)

Test 2 Is the plan appropriate? (i.e. is the plan appropriate for the area in the light of the evidence?)

Test 3 Will the plan deliver? (i.e. is it likely to be effective?)

Paragraph Number (Particularly if commenting on the Sustainability Appraisal, Strategic Environmental

Assessment Addendum, or Habitat Regulations Assessment)

Para 3.3.41

3c: Your Comments Please set out your comments below using additional sheets as necessary. Explain why you object to or support the identified Matters Arising Change. Include any information, evidence and supporting information necessary to support your representation. This will help the Inspector to understand the issue you raise. Please use the space below to set out your representation: MAC 35 Policy SP7

MAC 37 Para 3.3.41

IMPORTANCE OF OFFA’S DYKE: NATIONAL TRAIL AND ARCHAEOLOGICAL MONUMENT

CPRW have submitted statements requesting adequate protection of Offa’s Dyke, recognising the dual

nature of Offa’s Dyke..preferably in policy SP7 which has been substantially re-written at the MAC

stage.

ED032-11

CPRW (ID1519) 11-1519 Statement

We request that this earlier submission be taken into account.

Offa’s Dyke is internationally famous. The Powys parts of the archaeological monument is Powys’ best

known historical monument and tourist asset. The full length of Offa’s Dyke is probably Wales’ best

known tourist asset. The National Trail, part of it along the archaeological dyke is Powys’ most popular

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long distance walking route.

Strategic Policy SP7 - Safeguarding of Strategic Resources and Assets “To safeguard strategic resources and assets in the County, development proposals must not have an unacceptable adverse impact on the resource or asset and its operation. The following have been identified as strategic resources and assets in Powys: 3. Recreational Assets, including: i) National Trails” ….…

iii) Scheduled Ancient Monuments and other archaeological remains

RJ 3.3.41 “The potential cumulative impacts of existing and proposed development(s) should be carefully considered. Resources and assets may offer multiple benefits, the Offa's Dyke Path for example, contributes to heritage historic, recreational, tourism and visual / landscape assets. Offa’s Dyke is a nationally important archaeological monument, part of which is designated as a Scheduled Ancient Monument, and other parts are unscheduled sections. The route of the Offa’s Dyke Path National Trail also follows along or near sections of the monument as it passes through the Plan area. The safeguarding to be applied under Policy SP7, in combination with the protection afforded at the national level to Scheduled Ancient Monuments, and in respect of archaeology generally, will serve to protect this asset and its setting. The policy seeks to safeguard archaeological remains, whether scheduled or not, and their settings, in line with national legislation, policy and guidance. Further information on historic environment designations identified within Policy SP7 can be found within Appendix 6 of the Plan.”

MAC 35: CPRW welcomes the substitution of “National Trails” for “Offa’s Dyke Path and Glyndwr’s

Way” in SP7 3 and appreciates that the archaeological Dyke is covered by 2 iii).

MAC 37: However we do not consider that RJ 3.3.41 is satisfactory.

MACs 35 & 37: The original paragraph starts with a statement about cumulative impacts of

developments on strategic assets. Then Offa’s Dyke is introduced as an example of assets offering

multiple benefits. These two ideas are separate and unrelated.

The new (green) section is useful in ensuring that Offa’s Dyke as both trail and monument (whether

scheduled section or not) is protected but, by stating that different sections are protected in different

ways, it fails to emphasise the integrity of Offa’s Dyke as a longitudinal archaeological feature or

acknowledge its huge historical importance for Wales. Offa’s Dyke monument deserves strategic asset

status in its own right.

These problems would be resolved by

mentioning the archaeological monument in SP7 2 iii) so that it reads: iii) Scheduled Ancient Monuments and other archaeological remains, including the whole of Offa’s Dyke linear archaeological feature in Powys

having a separate RJ paragraph on cumulative impacts of proposed and existing development on strategic assets

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having a separate RJ paragraph on multiple benefits of strategic assets, with Offa’s Dyke as one example and perhaps others such as town conservation areas or cycle trails.

retaining the new green text in RJ 3.3.41 as a coherent RJ about Offa’s Dyke and its dual identity.

SOUNDNESS

Test 1

PPW 9

6.1.3 “The historic environment is relevant to and is a vibrant part of the culture and economy of

Wales. To enable the historic environment to deliver rich benefits to the people of Wales, what is of

significance needs to be identified and change that has an impact on historic assets must be

managed in a sensitive and sustainable way.”

6.2 Objectives

6.2.1 “It is important that the historic environment is protected, managed and conserved. The Welsh

Government’s objectives in this field are to:

base decisions on an understanding of the significance of Wales’ historic assets”

It is not sufficient to introduce Offa’s Dyke monument in RJ as an example of a general situation. It

should be included as a strategic asset

Test 2

The LDP treatment of Offa’s Dyke does not reflect its importance to Powys history, the local tourist

industry and, in particular, the town of Knighton.

Test 3

The importance to Development Control of protecting the structure and setting of Offa’s Dyke

monument is unlikely to be recognised unless it is mentioned by name in policy.

Outline what changes are needed to the Matters Arising Change to make the LDP sound:

Problems would be resolved by

having a separate RJ paragraph on cumulative impacts of proposed and existing development on strategic assets

having a separate RJ paragraph on multiple benefits of strategic assets, with Offa’s Dyke as one example and perhaps others such as town conservation areas or cycle trails.

retaining the new green text in RJ 3.3.41 as a coherent RJ about Offa’s Dyke and its dual identity.

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I am enclosing further supporting information and material. Yes ____ No ____ . SECTION 4: What Happens Next? At this stage of the LDP process, you can only make comments in writing (these are called 'written representations'). It is for the Inspector to determine whether further Hearing Sessions are necessary as a result of the Matters Arising Changes consultation to more fully consider any issues raised. In the event that additional Hearing Sessions are arranged you should indicate on the form whether you would like to participate and speak at any future Hearing Session(s) if they are held. You should bear in mind that your written comments on this form will be given the same weight by the Inspector as those made verbally at any future Hearing Session(s).

All duly made representations received by the closing date will be forwarded directly to the Inspector for consideration. Please note that the Council will acknowledge all representations.

a) Do you want your comments to be considered by “written representations” or do you want to speak at any additional hearing sessions? (If requested by the Inspector) (Please tick one of the following):

i) I do not want to speak at a hearing session and am happy for my written comments

to be considered by the Inspector. ____

ii) I want to speak at a hearing session.

b) If you wish to speak, please confirm which part of your representation you wish to speak to the Inspector about and why you consider it to be necessary to speak at the Hearing Session.

As above

If you wish to speak (If requested by the Inspector), please indicate which language you would like to be heard in:

English ____ Welsh ____

THANK YOU FOR YOUR COMMENTS ON THE SCHEDULE OF MATTERS ARISING CHANGES

Please remember to enclose any additional relevant documentation with this form.

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Completed representation forms should be returned to: BY POST – To The LDP Team, Planning Policy, Powys County Council, The Gwalia, Llandrindod Wells, Powys. LD1 6AA or, BY EMAIL - to ldp@powys.gov.uk . The closing date for representations is 5.00pm Monday 30th October 2017. Representations received after this date will not be considered duly made. Representations on the Matters Arising Changes submitted during this consultation period (Tuesday 19th September – Monday 30th October 2017) will be forwarded to the appointed Inspector.