Exmoor National Park Draft Landscape Character Assessment Supplementary Planning Document –
Consultation Response Schedule APRIL 2018
There have been three key phases of consultation during the production of the Exmoor Landscape Character Assessment (2018), as follows:
Representatives from a wide range of organisations were invited to attend a Stakeholder Workshop at Exmoor House on the 10th November 2016. In addition to Exmoor National Park Authority staff and Members, many local organisations, landowners and community bodies were represented. Those who were unable to attend were invited to respond through completion of questionnaires. The stakeholder workshops had three primary purposes:to ensure local knowledge and expertise is fed into the Landscape Character Assessment update; to make sure that the information on the landscape characteristics and forces for change is as comprehensive as possible; and to enable a positive discussion to take place between stakeholders regarding priorities for the future management of Exmoor’s landscapes. The feedback from the workshops was incorporated into the first draft report (issued internally December 2016).
The second stage of consultation was an internal review of the first draft report by the project steering group, as well as the Landscape Advisory Group and specialist team members within Exmoor National Park Authority. This was to check for factual accuracy and to make sure that the steering group members were happy for the document to be made available for wider public consultation. This took place in January 2017.
The third phase of consultation was the public consultation which took place in the summer of 2017.
Overall, the methodology for the preparation of the Exmoor Landscape Character Assessment 2018 is in line with the current best practice guidance, namely An Approach to Landscape Character Assessment (Natural England, 2014). This has followed four key stages of work: project start up; desk studies; fieldwork; and writing up.
The Draft Exmoor National Park Landscape Character Assessment Supplementary Planning Document was approved by the Authority on 4 July 2017 for consultation. An eight-week consultation period was held from 15 July – 8 September 2017. There were 16 representations received during this period, which generated 193 separate comments on the document. These representations are set out in the schedule below in order of respondent, including the Authority’s consideration of the representation and any necessary actions.
Responses were received from the following:
001R Briden009Exmoor Society
002Cutcombe Parish Council010Natural England
003B Lane011Winsford Parish Council
004North Devon AONB012West Somerset Flood Group
005 North Devon Council013T Bridgeman
006Somerset County Council014Woodland Trust
007Old Cleeve Parish Council015R Watts
008Exmoor Rivers and Streams Group016Exmoor Uprising
1
Exmoor National Park Draft Landscape Character Assessment Supplementary Planning Document –
Consultation Response Schedule APRIL 2018
ID / Rep no. / Para. / Map / Page / Section / Whole LCA / Comment / RESPONSE / ENPA Comments / Actions001 / 01 / Yes / Object / On watching George Monbiot at the UK National Parks Conference 2015, who appears to speak eminently on the subject and makes a strong case, I am troubled that much of what is termed or implied as ‘natural’ in the planning document is misrepresentation and should be expunged as it is very likely to mislead the ill-informed. / Both the Executive Summary and Introduction sections of the report outline the Exmoor landscape is a living and working landscape that is the result of both geological, geomorphological processes combined with millennia of human exploitation and interaction. / Review of the use and context of the term 'natural' in document.
002 / 01 / Yes / Support / The Parish Council has full confidence that ENPA will work sympathetically to assess and preserve the landscape of Exmoor, paying particular regard to the needs of people who live and work on Exmoor, in particular the farming community. / The planning guidelines should help in providing a balance between the NP purposes and duties. / Noted.
003 / 01 / 55 / Support / NP is affected by neighbouring developments. Wind farms need to be severely controlled – they have ruined many landscapes in the UK already / Part 3 of the LCA addresses the impact of development beyond the NP boundaries. / Noted.
003 / 02 / 56 / Support / These need to be foundational to all decisions re: developments, especially to conserve the nature of large open spaces without intrusive light pollution / Noted.
003 / 03 / 57 / Support / These need to be foundational to all decisions re: developments, especially to conserve the nature of large open spaces without intrusive light pollution / Noted.
003 / 04 / 58 / Support / These need to be foundational to all decisions re: developments, especially to conserve the nature of large open spaces without intrusive light pollution / Noted.
003 / 05 / 54 / Support / Evidence must be provided to ensure such procedures have been rigorously followed / Proposed use of 'Advice for Developers' in reviewing the Requirements for the Submission of Planning and Other Applications / ENPA to action.
003 / 06 / 51 / Support / Lynton especially needs to have economic life – the current level of second homes is unsustainable to maintain the character of Exmoor. Jobs must be encouraged and supported e.g. agriculture engineering etc. I support particularly the reopening of the L&B railway as one way to help achieve this and reduce car journeys. / Noted.
004 / 01 / Yes / General comment / In the first instance it is a very thorough and comprehensive guide to the landscapes of Exmoor National Park. I particularly liked the introduction of Planning Guidelines to be found in Part 3 of the document. Its covered most bases, so whilst the below appears critical, there are the only things which possibly could be improved. As previously mentioned we are disappointed to see the document in a format that is not in step with the more recent Devon County Landscape Character Assessments and the universal hierarchy that it tried to implement. That being a natural progression from National Landscape Character Areas composed of a number of County Landscape Character Areas (LCA), which in turn are comprised of a number of Landscape Character Types (LCT) and in the case of the AONB a layer of Landscape Description Units sitting below that. Therefore, the methodology used in the Exmoor LCA is not in line with that adopted in most of Devon, certainly all of North Devon District Council and that of the North Devon AONB, this is considered by us to be a missed opportunity. That said, given that it is comprehensive in its coverage of Exmoor National Park and that this methodology has been used elsewhere in the country it may not be such a big issue. However, to avoid confusion I think that it is important to qualify your statement about what a Landscape Character Area is, given that your summary is only one statement about what an LCA is and there are others. In fact I would go further and suggest that somewhere in the introduction you mention that other methodologies have been used in Devon (and elsewhere in the country) and why you chose to follow this one and not the Devon example. Mention of the recent Seascape Character Assessment is a bit lightweight in my opinion and given Exmoor NP’s participation in the project to develop it, should be increased. It would be useful to provide maps showing its visual relevance to the LCA and how developers should look at both documents when considering development. The SCA should be summarised and included in the list of documents mentioned in the Planning Guidelines. I haven’t had time to see if some of the issues mentioned in the SCA have been carried through into the relevant LCAs but someone should do this to ensure compatibility and that the two Assessments complement each other. (relevant SCA’s are 1, 2, 4, 5, 6, 7, 8) / This update to the 2007 Exmoor LCA has elected to retain the established methodology for continuity and clarity, but acknowledges this does not accord with the Devon wide LCA methodology. Greater reference to the Seascape Character Assessment has now been made. / Extra Appendix added, with explanation of the Exmoor methodology in relation to the Devon methodology, and why the Exmoor methodology was chosen. Also maps and descriptions of the LCAs/ SCAs which abut or adjoin Exmoor. Explanation of NCA and associated special qualities added to section 1.7
004 / 02 / 56 / Support with changes / To re-inforce the point, I would list the new LCA and the SCA as guidelines for new development in open countryside. (i.e. “Use the LCA to understand the key characteristics, unique features, forces for change affecting the particular LCA you are proposing to develop in”) / Noted / The SCA will be referenced in paragraph 3.5.2
004 / 03 / 1 / Support with changes / In Part 1, I would also mention the effect/potential impact of large scale renewables as it is not mentioned as a current threat, even though it is mentioned in the text later. / Acknowledged and addressed. / Added to 1.8.4 (now renumbered as 1.9.4)
004 / 04 / 2.5.12 / 25 / General comment / Page 25 (2.5.12) It’s a bit misleading to mention limekilns in this part of the text. Whilst it is acknowledged that lime-burning was in existence in Roman times, most structures on Exmoor date from the late 17th, 18th/19th centuries and the product was certainly responsible for helping to reclaim much of the acidic moorland on Exmoor. I am no expert but I’d say that lime burning was as important as the beech hedge on Exmoor. / Acknowledged and addressed. / Reference to limekilns removed from 2.5.12 and added to 2.5.14 instead.
004 / 05 / 4 / General comment / Landscape Character Areas tend to be unique with names that represent a sense of place. Therefore the use of “Northern”/”Southern”/Eastern LCA is a bit generic and it could do with a more specific name, as you have done with other LCA’s (i.e. Holdstone Down and Trentishoe) / Noted and acknowledged but the LCAs are quite large and don't have a single settlement to be identified with. Therefore compass directions have been used. / No change made.
004 / 06 / 62 / General comment / "In this assessment Landscape Character Areas are described as..." (see previous comments - Landscape Character Areas tend to be unique with names that represent a sense of place. Therefore the use of “Northern”/”Southern”/Eastern LCA is a bit generic and it could do with a more specific name, as you have done with other LCA’s (i.e. Holdstone Down and Trentishoe)) / Noted and acknowledged but the LCAs are quite large and don't have a single settlement to be identified with. Therefore compass directions have been used.
004 / 07 / 65 / Object / LCT High Coastal Heath:Nowhere in the text does it say that some of the LCT contains some of the highest cliffs in England, which is surely a key characteristic. The Trentishoe/Holdstone Down area forms an impressive high backdrop to the eastern edge of the North Devon AONB when viewed anywhere from elevated land between Morte Point and Combe Martin (North Devon High Coast LCA). Also from this LCA there are long views of the North Devon High Coast area of the AONB. From Holdstone/Hangman’s you get a great sense of looking down on the AONB and the sea. You can also see Lundy Island out to the west, giving a strong sense of place. Also quite unique in this LCA is the remote feeling of being well above the sea. Unlike other parts of the North Devon Coast, where you feel you can touch/hear the sea, sometimes in this LCA you are very high up and on the coast path do not get the feeling of being on the “cliff edge” at all. It’s difficult to put into words, but it is a totally different experience to other cliff walks on the coast path in North Devon. I think the importance of mining (non-silver) above Combe Martin (Hangmans) is an underplayed in this LCT (Hangman’s/Trentishoe LCA). / Noted. / Added to text (profile A).
004 / 08 / 73 / Object / Valley of the Rocks: I am no expert but I struggle to see the similarity between the High “wind swept” coastal heathland and the impressive valley of the rocks, which from a geological/geomorphological perspective is quite unique. It doesn’t fit your current divisions, so difficult to move, but in our Landscape Character assessment it would probably be an LCT in its own right. On balance I think it should not be in the LCT you currently have it in. / The cricket pitch area is certainly unique, but the wider LCA has many coastal heath features in common with other parts of the LCT. In terms of management, it fits quite comfortably. / No change made.
004 / 09 / 79 / Object / Under "protect", not enough is made of the views out of the park and the potential threads that renewables pose to this. This LCT is all about expansive views out of the Park, especially in the west and looking across the Bristol Channel, westwards towards Lundy, down on the northern part of the AONB. “Protect” should include something more about the potential harm of light pollution from South Wales and Ilfracombe (especially in light of the Ilfracombe southern extension 1,000 houses planned above Ilfracombe). Under "Plan" – I’d recommend being proactive and looking to develop a Wind and Solar Sensitivity Study (as Torridge and North Devon have done) based on the new LCA. This aspiration could be included in the “Plan” part of the LCA. / Wind/solar sensitivity study undertaken to inform policy approach for wind/solar development in the Local Plan / New bullet added to 'protect' -“Protect the expansive views out of the LCT over both land and sea, which contribute to its unique character and sense of place. Pay particular regard to the potential impacts of new development, renewable energy projects and light pollution within the setting of the LCT.”
004 / 10 / 97 / Support with changes / LCT B High Wooded Coast and Combes: Page 97. Coastal squeeze is mentioned but not as a threat to the coastal woodland itself. The importance of bringing woods into active management is a bit underplayed and lack of woodland management could be included in issues and forces for change. / Noted. / Added to text (profile B). Also impact of coastal squeeze on woodlands added to general forces for change (natural processes and climate change table).
004 / 11 / 159 / LCT FEnclosed Farmed Hills with Commons: Page 159 There are pronounced demarcation areas between the enclosed/improved land and the moorland above, giving the appearance of the reclamation marching up the hillside, this is to me one of the defining features of Exmoor. Together with a patchwork of regular fields some with neatly laid hedges and some with overgrown/mature hedges that have become a landscape feature in their own right, I am not sure if this comes through strongly enough in the descriptive text. / Noted. / Text amended (LCT F summary description and perceptual qualities).
004 / 12 / 161 / Object / In LCA F1: No mention is made of some quite unique landscape features on Knap Down above Combe Martin. The Tithe map (1840) and 1st Edition O/S comparisons (1880) show enclosure/reclamation of open moor above Combe Martin (just north of Vellacott lane) as traditional strip fields. The locals say that this was done to ensure people in the village got an equal share of good and bad land. It is unique, as it is an example of 19th century enclosure in a Medieval style. Surely worth a mention? See enclosed maps. Also no mention of the Medieval farmstead at West Challacombe Farm (NT owned) just to the east of Combe Martin, this has a fine example of a medieval hall with surviving roof dated at around 1470, parts of the outbuildings/building are even older than this. Close by in there are the West Challacombe Silver mines. Both are culturally/historically very significant and should be mentioned. (we have more information if you need it). / Noted. / Text amended (LCT F)
004 / 13 / 166 / Support with changes / Loss/poor maintenance of field boundaries due to a decline in rural skills such as walling and hedge-laying, so not just a grants issue. / Noted. / Text amended (LCT F issues table)
004 / 14 / 166 / Support with changes / Is this an issue for you? It is for us. This is the loss of Highway maintenance by Devon County Council due to the austerity cuts. This is both positive and negative, on the one hand, things are becoming less urbanised, but also there are issues regarding lack of road management/maintenance for example non-replacement or dilapidated signs, etc. Hartland Parish in our AONB have just been told there is to be no signpost replacement either traditional wooden signs or the more modern polycarbonate and aluminium signs. The LCA mentions signs but doesn’t really say what the issues are. / References to dilapidatedroad signs throughout document. / No change made.
005 / 01 / 1.2.1 / 4 / General comment / It would have been better if the Landscape Character Assessment was directly compatible with the LCA methodology and LCTs covering the rest of Devon. This would ensure that LCAs do not stop automatically at the National Park boundary, but would continue cross boundary where applicable. The use of standard LCTs would also recognise similar LCAs outside the National Park. Nevertheless, the joint North Devon and Exmoor Seascape Character Assessment will help ensure compatibility along the coastline. / This update to the 2007 Exmoor LCA has elected to retain the established methodology for continuity and clarity, but acknowledges this does not accord with the Devon wide LCA methodology. Greater reference to the Seascape Character Assessment has now been made. / See comments above. New appendix sets out methodology in relation to Devon system, and also describes adjacent/ overlapping LCAs.