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Page 1: Brecon Beacons National Park Authority Biodiversity Paper · Brecon Beacons National Park Authority Biodiversity Paper 5 caused by the loss of biodiversity are avoided”. The mission
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Contents List of Tables & Figures ..................................................................................................................................................... 3

1.0 Introduction .......................................................................................................................................................... 4

1.1 Purpose of this document ............................................................................................................................. 4

1.2 Aims of this paper ......................................................................................................................................... 4

2.0 Policy Context ....................................................................................................................................................... 4

2.1 International / European Policy ........................................................................................................................ 4

2.1.2 EU Biodiversity Strategy to 2020 – Towards Implementation (2011) .......................................................... 4

2.1.3 EU Habitats Directive (92/43/EEC, 1992) ...................................................................................................... 5

2.2 National Planning Policy.................................................................................................................................... 5

2.2.1 The Water Environment (Water Framework Directive) (England and Wales) Regulations 2017 ................. 5

2.2.2 The Wildlife and Countryside Act (1981) (as amended) ............................................................................... 6

2.2.3 The Conservation of Habitats and Species Regulations (2017) .................................................................... 6

2.2.4 Environment Act (Wales) 2016 ..................................................................................................................... 6

2.2.5 Convention on Biological Diversity ............................................................................................................... 7

2.2.6 The National Parks and Access to the Countryside Act (1949) ..................................................................... 8

2.2.7 Valued and Resilient: The Welsh Government’s Priorities for Areas of Outstanding Natural Beauty (AONB)

and National Parks (2018) ......................................................................................................................................... 8

2.2.8 Wellbeing of Future Generations (Wales) Act 2015 ..................................................................................... 9

2.2.9 Planning Policy Wales Edition 10 (December 2018) ..................................................................................... 9

2.2.10 Technical Advise Note 5 (TAN 5): Nature Conservation and Planning (2009) ........................................ 10

2.3 Local Policy ...................................................................................................................................................... 11

2.3.1 Brecon Beacons National Park Authority Management Plan 2015 – 2020 ................................................ 11

2.3.2 Brecon Beacons National Park Local Development Plan (2013) ................................................................. 11

2.3.3 Brecon Beacons National Park Authority Supplementary Planning Guidance – Biodiversity and

Development (2016) ............................................................................................................................................... 13

2.3.4 Brecon Beacons National Park Authority Supplementary Planning Guidance – Biodiversity in and around

the towns of the National Park SPG (March 2015 & September 2016).................................................................. 14

3.0 Situation and Trend ............................................................................................................................................. 15

3.1 State of Natural Resources Report (SoNaRR) ............................................................................................. 15

3.2 Biodiversity in the National Park ................................................................................................................. 16

3.3 Special Areas of Conservation (SACs).......................................................................................................... 17

3.4 Sites of Special Scientific Interest ............................................................................................................... 18

3.5 Sites of Importance for Nature Conservation ............................................................................................. 18

3.6 Protected and Important Wild Species ....................................................................................................... 19

3.7 Ancient Woodland and Veteran Trees ........................................................................................................ 19

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3.8 Climate Change ........................................................................................................................................... 20

3.9 Nature Recovery Action Plan for the Brecon Beacons National Park ......................................................... 24

3.10 Projecting Land Use Change in the Brecon Beacons National Park ............................................................ 25

4.0 Conclusion ........................................................................................................................................................... 26

5.0 References .......................................................................................................................................................... 28

6.0 Appendix ............................................................................................................................................................. 30

6.1 Appendix 1 – Welsh Government’s List of Priority Habitats and Species ....................................................... 30

List of Tables & Figures Table 1: 5 Strategic Goals for Aichi Biodiversity Targets for 2020, Convention on Biological Diversity 7

Table 2: Table 2: Page 137, Planning Policy Wales, Edition 10 (2018) 10

Table 3: Brecon Beacons National Park Authority Supplementary Planning Guidance –

Biodiversity and Development (2016) 13

Table 4: Figures provided by the Biodiversity Information Service for Powys and the Brecon Beacons (2018) 17

Table 5: Key objectives for the Nature Recovery Action Plan, BBNPA (February 2019) 25

Figure 1: SAC’s and SSSIs Designations within BBNP, Lle Mapping Welsh Government 18

Figure 2: Ancient Woodland (dark green) within BBNP, QGIS 20

Figure 3: Infographic on Climate Change in the UK (The Committee on Climate Change, May 2019) 22

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1.0 Introduction

1.1 Purpose of this document 1.1.1 Welsh Government’s Local Development Plan (LDP) Manual Edition 2 (2015) states the following: ‘Section

69 of the 2004 Act requires a Local Planning Authority to undertake a review of an LDP and report to the

Welsh Government at such times as prescribed. To ensure that there is a regular and comprehensive

assessment of whether plans remain up-to-date or whether changes are needed an authority should

commence a S69 full review of its LDP at intervals not longer than every 4 years from initial adoption and

then from the date of the last adoption following a review under S69 (Regulation 41). A plan review should

draw upon published AMRs, evidence gathered through updated survey evidence and pertinent contextual

indicators, including relevant changes to national policy’.

1.1.2 This paper has been prepared to provide an evidence base and to examine the biodiversity within the

Brecon Beacons National Park (BBNP) to inform policy for the replacement LDP. Biodiversity is fundamental

to the functioning of ecosystems and these, in turn, provide ‘ecosystem services’ which include food, flood

management, pollination and the provision of clean air and water, and contributing directly and indirectly to

people’s health and well-being.

1.2 Aims of this paper

To establish an understanding of the Policy Context underpinning Biodiversity within the National Park

To understand the success of the existing policy though providing evidence relating to the protection of

biodiversity within the National Park

To set out the current situation in the BBNPA through analysis of data

To assist in identifying threats and forces for change in the natural environment and opportunities for

enhancement, and

To recommend how to best adapt policy so it ensures sufficient protection of the Park’s biodiversity and

identifies opportunities to enhance it in the future.

2.0 Policy Context 2.0.1 In order to meet the requirements of National Policy it was important to establish an understanding of the

Policy underpinning biodiversity as is shown below:

2.1 International / European Policy 2.1.1 The UK is one of 189 signatory to the Convention on Biological Diversity (2010) which outlines a conservation

plan to protect global biodiversity, and an international treaty to establish a fair and equitable system to

enable nations to co-operate in accessing and sharing the benefits of genetic resources. They set out their

global vision as “by 2050, biodiversity is valued, conserved, restored and wisely used, maintaining ecosystem

services, sustaining a healthy planet and delivering benefits essential for all people.”

2.1.2 EU Biodiversity Strategy to 2020 – Towards Implementation (2011) 2.1.2.1 The European Commission adopted the above strategy in 2011 to help deliver the EU vision and 2020

mission for biodiversity which includes “by 2050, EU biodiversity and the ecosystem services it provides – its

natural capital - are protected, valued and appropriately restored for biodiversity’s intrinsic value and for

their essential contribution to human wellbeing and economic prosperity, and so that catastrophic changed

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caused by the loss of biodiversity are avoided”. The mission is to “halt the loss of biodiversity and the

degradation of ecosystem services in the EU by 2020, and restore them insofar as is feasible, while stepping

up the EU contribution to averting global biodiversity loss”.

2.1.2.2 The strategy provided a framework for action over the next decade and covers the following key areas:

Conserving and restoring nature;

Maintaining and enhancing ecosystems and their services;

Ensuring the sustainability of agriculture, forestry and fisheries;

Combating invasive alien species; and

Addressing the global biodiversity crisis.

2.1.3 EU Habitats Directive (92/43/EEC, 1992) 2.1.3.1 The Habitats Directive is set out to ensure the conservation of a wide range of rare, threatened or endemic

animal and plant species. Some 200 rare and characteristics habitat types are also targeted for conservation

in their own right.

2.1.3.2 The Directive takes account of economic, social, cultural and regional requirements and forms the

cornerstone of Europe’s nature conservation policy. The policy also coincides with the EU Birds Directive

which together include measures to maintain and restore important natural habitats and species including

through the designation of Special Areas of Conservation (SACs) and Special Protection Areas (SPAs); the

Natura 2000 network (N2K). These Directives are transposed into British law through a number of

regulations and planning policy documents.

2.2 National Planning Policy

2.2.1 The Water Environment (Water Framework Directive) (England and Wales) Regulations 2017 2.2.1.1 The 2017 Regulations revoke and replace the 2003 Regulations which have been amended by several

instruments although it continues to transpose the Water Framework Directive for England and Wales as set

out by European Parliament. The Regulations outline the duties of regulators in relation to environmental

permitting, abstraction and impoundment of water.

2.2.1.2 There are seven parts to the new Regulations, Regulation 3 imposes duties on the Secretary of State, Welsh

Ministers, the Environment Agency (EA) and Natural Resources Wales (NRW) to carry out certain functions

so as to ensure compliance with the Water Framework Directive (WFD), Groundwater Directive (GWD) and

Environmental Quality Standards Directive (EQSD), in particular when deciding whether to grant vary or

revoke certain permits and licences which affect water quality, and to co-ordinate their actions relating to

these three European Parliament Directives.

2.2.1.3 The remaining Regulations consists of the following seven parts:

Part 2: Requires the identification of river basin districts, and a number of other assessments to be

carried out by the EA and NRW to characterise and classify the status of water bodies in those districts,

and assess the economic aspects of water use;

Part 3: Makes provision for certain protected areas;

Part 4: Sets out what monitoring of water quality the EA and NRW must undertake in relation to water

bodies, including protected areas;

Part 5: Provides for the establishment of environmental objectives for each water body, and

programmes of measures to meet those objectives. The remainder of Part 5 provides for the content

and application of programmes of measures.

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Part 6: Deals with river basin management plans (RBMPs) which must be established for each river basin

district, and applies in relation to the most recent plans published under the 2003 Regulations, or (once

plans have been revised) under these Regulations; and

Part 7 contains miscellaneous provisions.

2.2.2 The Wildlife and Countryside Act (1981) (as amended) 2.2.2.1 The above Act is the main UK legislation relating to the protection of named animal and plant species and

includes legislation relating to the UK network of nationally protected wildlife areas i.e. Sites of Special

Scientific Interest (SSSIs).

2.2.2.2 The Act is transpired into national law and subsequently makes it an offence (subject to exceptions) to

intentionally kill, injure or take any wild animal listed on Schedule 5 within the Act, and prohibits

interference with places used for shelter or protection, or intentionally disturbing animals occupying such

places. The Act also prohibits certain methods of killing, injuring or taking wild animals and releasing certain

types of plants and animals into the wild.

2.2.3 The Conservation of Habitats and Species Regulations (2017) 2.2.3.1 The above regulations transpose the EU Habitats Directive and the EU Birds Directive, on the conservation of

natural habitats and of wild fauna and fauna into national law. The regulations came into force on the 30th

November 2017 and provided for the designation and protection of ‘European Sites’ and to impost local

authorities to evaluate the impact on such sites or species in regards to planning permission applications.

2.2.4 Environment Act (Wales) 2016 2.2.4.1 The Environment Act responds to the EU Biodiversity Strategy 2020 and sets out the requirement for

maintaining and enhancing the resilience of ecosystems and the benefits they provide, together with new

ways of working to achieve this. Part 1 of the Act sets out Wales’ approach to planning and managing natural

resources at a national and local level with a general purpose linked to statutory ‘principles of sustainable

management of natural resources’. There are 3 main constituents to Part 1 of the Environment Act as

outlined below:

1) The State of Natural Resources Report (SoNaRR) – A report produced by Natural Resources Wales (NRW)

that gives an assessment of natural resources and how well Wales is doing to manage them in a

sustainable way.

2) Natural Resources Policy – A policy produces by Welsh Government (WG) that sets out the policy that

takes into account the findings of the SoNaRR and priorities, risks and opportunities for managing

natural resources sustainably. The priorities for action to tackle the challenges include:

a) Delivering nature-based solutions , with a particular focus on the following which have been

identified in SoNaRR and the NRP as delivering the greatest benefit for both building the resilience

of our ecosystems and delivering wider benefits across the well-being goals;

b) Developing resilient ecological networks;

c) Increasing green infrastructure in and around urban areas;

d) Coastal zone management and adaptation;

e) Increasing canopy cover and well located woodland for greatest ecosystem service value;

f) Maintaining, enhancing and restoring floodplains and hydrogeological systems to reduce flood risk

and improve water quality and quantity;

g) Restoring of uplands and managing them for biodiversity, carbon, water, flood risk, energy and

recreational benefits;

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h) Increasing resource efficiency (including moving towards a circular economy) and renewable

energy;

i) Taking a place-based approach (Natural Resources Wales, 2016).

3) Area Statements – A local evidence base produced by NRW which helps to implement the priorities, risks

and opportunities identified in the National Policy and how NRW intends to address these.

2.2.4.2 Section 6 of the Environment Act places a duty on public authorities to ‘seek to maintain and enhance

biodiversity’ in the proper exercise of their functions. Public authorities must also seek to ‘promote the

resilience of ecosystems’ in the following ways:

Diversity between and within ecosystems;

The connections between and within ecosystems;

The scale of ecosystems;

The condition of ecosystems (including their structure and functioning);

The adaptability of ecosystems.

Section 6 also requires a public body to publish a report by the end of 2019, and every three years

thereafter, on what it has done to maintain and enhance biodiversity.

2.2.4.3 Section 7 of the Environment Act requires the Welsh Ministers to publish, review and revise lists of living

organisms and types of habitat in Wales, which they consider are of key significance to sustain and improve

biodiversity in relation to Wales. This is known as the S7 list.

2.2.5 Convention on Biological Diversity 2.2.5.1 The Convention on Biological Diversity (CBD) entered into force on 29th December 1993 with 3 main

objectives:

1. The conservation of biological diversity

2. The sustainable use of the components of biological diversity

3. The fair and equitable sharing of the benefits arising out of the utilisation of genetic resources.

2.2.5.2 The CBC has set out a Strategic Plan for 2011-2020 which consists of 5 strategic goals, including 20 Aichi

Biodiversity Targets. The goals and targets comprise both aspirations for achievement at the global level, and

a flexible framework for the establishment of national or regional targets. It also includes an invitation to

parties to set their own targets within the flexible framework, taking into account national needs and

priorities, whilst bearing in mind national contributions to the achievement of the global targets. There is a

variety of implementation and monitoring methods included within the Plan which are outlined on their

website.

2.2.5.3 The 20 headline Aichi Biodiversity Targets for 2020 are organised under the five strategic goals, as outlined

in Table 1:

Strategic Goal A Address the underlying causes of biodiversity loss by mainstreaming biodiversity across government and society

Strategic Goal B Reduce the direct pressures on biodiversity and promote sustainable use

Strategic Goal C To improve the status of biodiversity by safeguarding ecosystems, species and genetic diversity

Strategic Goal D Enhance the benefits to all from biodiversity and ecosystem services

Strategic Goal E Enhance implementation through participatory planning, knowledge management and capacity building

Table 1: 5 Strategic Goals for Aichi Biodiversity Targets for 2020, Convention on Biological Diversity

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2.2.5.4 The introduction of the Environment Act (Wales) in 2016 was also in response to the CBS Strategic Plan and

the 12 Ecosystem Approach Principles which indicates the support by Wales in setting their own targets in

their flexible framework and incorporating the information provided by CBD in Wales’ national biodiversity

strategy and action plan.

2.2.6 The National Parks and Access to the Countryside Act (1949) 2.2.6.1 The 1949 Act set out the law on the aims and purposes of national parks. The Environment Act (1995)

revised the original legislation and outlines the two statutory purposes for National Parks (NP) in England

and Wales, which include:

Conserve and enhance the natural beauty, wildlife and cultural heritage

Promote opportunities for the understanding and enjoyment of the special qualities of NP by the

public

2.2.6.2 When National Parks carry out these purposes, they also have a duty to ‘seek to foster the economic and

social well-being of local communities within the NP’ in partnership with those organisations responsible for

these matters.

2.2.7 Valued and Resilient: The Welsh Government’s Priorities for Areas of Outstanding Natural Beauty

(AONB) and National Parks (2018) 2.2.7.1 Following a review of Designated Landscapes in Wales, key priority areas were identified from the review

and outlined within the ‘Valued and Resilient’ report which provides clarity of purpose for the National Parks

and AONBSs in the context of the UKs exit from the European Union. The Report calls on the designated

landscapes managing bodies to deliver on a number of Welsh Government priorities, including the Nature

Recovery Plan, a refreshed woodland strategy, the decarbonisation agenda, and Cymraeg 2050.

2.2.7.2 The 10 cross-cutting themes aim to improve resilience and realise the full value of Wales’ landscapes:

Landscapes for everyone

Exemplars of the sustainable management of natural resources

Halting the loss of biodiversity

Green energy and decarbonisation

Realising the economic potential of landscape

Growing tourism and outdoor recreation

Thriving Welsh language

All landscapes matter

Delivering though collaboration

Innovation in resourcing

2.2.7.3 The Minister of Environment, Hannah Blython announced in the beginning of 2018 that over £3.4 million in

additional funding for the AONBs and National Parks to support a wide range of projects, including

improving access to the outdoors, promoting conservation and regeneration some of the most fragile areas

with be provided. An additional £1.5 million has been allocated to reinstate the National Park Authorities’

budgets over years 2018 and 2019 to demonstrate the commitment to these aims.

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2.2.8 Wellbeing of Future Generations (Wales) Act 2015 2.2.8.1 The Well-being of Future Generations Act establishes the sustainable development principle and requires the

public sector to make Wales a better place to live in now and for the future. It imposes a ‘well-being duty’ on all public bodies to achieve ‘economic, social, environmental and cultural well-being for Wales’. The 7 well-being goals are as follows:

1. A globally responsible Wales 2. A prosperous Wales 3. A resilient Wales 4. A healthier Wales 5. A more equal Wales 6. A Wales of cohesive communities 7. A Wales of vibrant culture and thriving Welsh language

2.2.8.2 This act ensures that public bodies, including the National Park Authorities have to think about long term to

achieve a sustainable Wales. It requires organisations to adhere to five ways of working: long term, prevention, integration, collaboration and involvement.

2.2.9 Planning Policy Wales Edition 10 (December 2018) 2.2.9.1 Planning Policy Wales (PPW) outlines the importance of biodiversity for the structure and functioning of

ecosystems. The Environment (Wales) Act 2016 placed a duty (Section 6 Duty) for enhancing biodiversity and

resilience of ecosystems on public authorities throughout Wales to help maximise contributions in achieving

the well-being goals and they must demonstrate that they have sought to fulfil these duties and

requirements.

2.2.9.2 Paragraph 6.4.2 (page 134) states “The Nature Recovery Action Plan [for Wales] supports this legislative

requirement to reverse the decline in biodiversity, address the underlying causes of biodiversity loss by

putting nature at the heart of decision-making and increasing the resilience of ecosystems by taking specific

action focused around the 6 objectives for habitats and species.”

2.2.9.3 PPW states that the planning system has a key role in helping to reverse the decline in biodiversity and

increasing the resilience of ecosystems by ensuring that any proposed development does not have an

adverse effect on the environment. Where adverse effects cannot be avoided or mitigated, PPW advises that

it will be necessary to refuse planning permission. Addressing climate change should also be a central part of

any measure to conserve biodiversity within the BBNPA in particular. “Development plan strategies, policies

and development proposals must consider the need to (para 6.4.3, page 134):

Support the conservation of biodiversity, in particular the conservation of wildlife and habitats;

Ensure action in Wales contributes to meeting international responsibilities and obligations for

biodiversity and habitats;

Ensure statutorily and non-statutorily designated sites are properly protected and managed;

Safeguard protected and priority species and existing biodiversity assets from impacts which directly

affect their nature conservation interest and compromise the resilience of ecological networks and

the components which underpin them, such as water and soil, including peat; and

Secure enhancement of and improvements to ecosystem resilience by improving diversity,

condition, extent and connectivity of ecological networks.

2.2.9.4 One of the seven goals of the Well-being of Future Generations Act states the following about biodiversity:

‘A Prosperous Wales can be realised by valuing the quality of our own landscapes and historic environment

as important for tourism, in attracting inward investment and to be accessed and enjoyed by local

communities. By protecting and enhancing biodiversity, and other components of our natural environment, it

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will be possible to future proof economic assets both in response to the challenges presented by climate

change and in promoting low carbon and appropriate resource choices which address the causes of climate

change.’

2.2.9.5 Planning authorities have the responsibility to protect designated sites and secure and enhance green

infrastructure and should also have regard to the relative significance of international, national and local

designations in considering the weight to the attached nature conservation interest, as set out in Table 2:

Tier Name Statutory/Non Statutory

International Special Area of Conservation (SAC) Statutory

Special Protection Area (SPA) Statutory

Ramsar Sites Statutory

UNESCO Biosphere Reserve Non-Statutory

International Sark Sky Reserve Non-Statutory

National Sites of Special Scientific Interest (SSSI) Statutory

National Nature Reserve (NNR) Statutory

Local Sites of Interest for Nature Conservation (SINC)

Non-Statutory

Local Nature Reserve (LNR) Non-Statutory Table 2: Page 137, Planning Policy Wales, Edition 10 (2018)

2.2.9.6 Statutory designated sites do not necessarily prohibit development, but proposals for development within or

surrounding the designated area must be carefully assessed for their effect on those nature conservation

interests which the designation is intended to protect. Statutorily designated sites should be protected from

damage and deterioration with their important features conserved and enhanced by appropriate

management. The contribution of the designated site to a wider network of resilient ecosystems should be

recognised and captured as part of policy and decision making.

2.2.9.7 Further advice for maintaining and enhancing biodiversity and detailed information about each statutory

and non-statutory designations can be found in Planning Policy Wales Edition 10.

2.2.10 Technical Advise Note 5 (TAN 5): Nature Conservation and Planning (2009) 2.2.10.1 TAN 5 provides advice on how the land use planning system should contribute to protecting and

enhancing biodiversity and geological conservation. Biodiversity conservation and enhancement is integral

to sustainable development and nature conservation. The TAN 5 demonstrates how local planning

authorities, developers and key stakeholders in conservation can work together to deliver more sustainable

development that does not result in losses from the natural world but instead takes every opportunity to

enhance it.

2.2.10.2 TAN 5 outlines key principles of positive planning for nature conservation as follows (2.1, page 4):

Work to achieve nature conservation objectives through a partnership between local planning

authorities, NRW, voluntary organisations, developers, landowners and other key stakeholders.

Integrate nature conservation into all planning decisions looking for development to deliver social,

economic and environmental objectives together over time.

Ensure that the UK’s international and national obligations for site, species and habitat protection are

fully met in all planning decisions.

Look for development to provide a net benefit for biodiversity conservation with no significant loss of

habitats or populations of species, locally or nationally.

Help to ensure that development does not damage, or restrict access to, or the study of, geological sites

and features or impede the evolution of natural processes and systems especially on rivers and the coast

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Forge and strengthen links between the town and country planning system and biodiversity action

planning particularly through policies in local development plans and the preparation of supplementary

planning guidance.

Plan to accommodate and reduce the effects of climate change by encouraging development that will

reduce damaging emissions and energy consumption and that help habitats and species to respond to

climate change.

2.3 Local Policy

2.3.1 Brecon Beacons National Park Authority Management Plan 2015 – 2020 2.3.1.1 The National Park Management Plan is the single most important document for the National Park. It

coordinates and integrates other plans, strategies, and actions in the National Park that affect the two

National Park purposes and the Authority’s duty. No major decisions should be taken affecting the future of

the National Park without reference to the National Park Management Plan.

2.3.1.2 The Management Plan (MP) has a whole theme on conserving and enhancing biodiversity as it provides

numerous benefits to the National Park.

2.3.1.3 “Agriculture relies on soil formation, nutrients, water flow and pollination. The uplands play a significant role

in water storage, quality and release, providing a natural defence against both drought and flood. As long as

they are free from the effects of heavy grazing, upland peat bogs store carbon and combat atmospheric

pollution and illegal fires. They capture atmospheric carbon which helps mitigate the effects of climate

change. Improved biodiversity enhances enjoyment and recreational opportunities. All of these services

contribute to the social and economic well-being of the Park” (para 87, page 27).

2.3.1.4 The following actions will assist in delivering the aims and objectives for conserving and enhancing

biodiversity (para 94, page 30):

Positively influence policies to enhance the rich biodiversity of the Park.

Champion an awareness and understanding of biodiversity.

Undertake site monitoring work.

Develop monitoring of key habitats, soils and water.

Develop Research Partnerships.

Establish fixed point photography and remote sensing.

Ensure biodiversity information is made available.

Implement an area-based land management project.

Restore and enhance habitat connectivity along river valleys.

Manage the Authority’s land assets for biodiversity.

Implement a living landscapes approach to landscape, habitat and wildlife management.

Establish the environmental pollution baselines in the National Park.

Prioritise understanding of water and carbon resources management.

2.3.2 Brecon Beacons National Park Local Development Plan (2013) 2.3.2.1 The Local Development Plan (LDP) aims to be strategic in nature and locally distinctive, centring around a

cohesive Spatial Strategy which aims to address issues associated with land use planning within the National

Park (NP) context. The MP has a vision that by 2030, the BBNP will be “widely acclaimed for its natural

beauty, geodiversity, biodiversity, and cultural heritage which are being conserved and enhanced by its

stakeholders through traditional and innovative means.”

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2.3.2.2 The LDP sets out the Strategic Objective to conserve and enhance the rich biodiversity of the Park. In order

to meet this objective, the LDP aims to ensure that all future development will not result in an unacceptable

adverse impact on biodiversity and therefore sets out the following policies:

Policy 3 – Sites of European Importance

Policy 4 – Sites of National Importance

Policy 5 – Sites of Importance for Nature Conservation

Policy 6 – Biodiversity and Development

Policy 7 – Protected and Important Wild Species

Policy 8 – Trees and Development

Policy 9 – Ancient Woodland and Veteran Trees

2.3.2.3 SP3 is the strategic policy for Environmental Protection and it states that ‘all proposals for development or

change of use of land or buildings in the NP must demonstrate that the proposed development does not

have an unacceptable impact on, nor detract from, or prevent the enjoyment of;

a) The special qualities of the NP as identified in the National Park Management Plan

b) Ecology and Biodiversity assets both within and beyond designated sites

c) The water environment

d) Geodiversity, including the Fforest Fawr UNESCO Global Geopark

e) Cultural and historic heritage, including Blaenavon Industrial Landscape World Heritage Site,

Registered Historic Parks Gardens and Historic Landscapes

f) The character of the built heritage, including listed buildings, conservation areas and archaeological

features

g) The important network of public open space and recreation facilities

h) Soil and air quality

i) Agricultural Land of Grade 1,2,3a

2.3.2.4 In terms of Policy 6 Biodiversity and Development, the LDP highlights that if there are over-riding material

planning considerations in favour of development, then it is reasonable for the NPA to secure measures from

developers that minimise or offset any impact of loss of habitat features or species present on a site prior to

the commencement of development.

2.3.2.5 To ensure the deliverability of future development proposals enabled through the LDP, the NP has identified

key areas of constraints which will need to be addressed in the formation of future development proposals.

Overcoming constraints identified form the planning application process may involve collaborative working

with developers and key stakeholders to ensure that developments can be achieved without unacceptable

adverse impact on the NP and its communities.

2.3.2.6 The first key issue that the LDP has identified is ‘Biodiversity Significance’ and states ‘Development has the

potential to impact upon priority habitat listed under Section 42 of the Natural Environment and

Communities Act 2006 (habitats and species of principal importance to Wales, now enshrined in Section 7 of

the Environment (Wales) Act). Full biodiversity survey and management plan may be required of the

development proposal. Potential planning obligations necessary to mitigate and enhance against potential

impact from development may be requested. There are further duties to compensate for the loss of habitat

and to enhance relevant habitats’. The key stakeholders that will help mitigate the impact of biodiversity for

future development are NRW and BBNPA Ecologists and developers.

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2.3.3 Brecon Beacons National Park Authority Supplementary Planning Guidance – Biodiversity and

Development (2016) 2.3.3.1 The Brecon Beacons National Park Authority (BBNPA) has a responsibility to protect, conserve and enhance

wildlife and the natural environment when considering development proposals. It has adopted

Supplementary Planning Guidance (SPG) to ensure that biodiversity and geodiversity issues are fully

considered as well as protected and enhanced through the development management process.

2.3.3.2 The SPG provided details of the designated sites and protected species around the Park that require

consideration when determining planning applications. Designated sites are those that are protected under

UK law. The BBNP is one such designation but smaller areas within the NP can have one or more

designations. Protected (or designated) sites within the BBNP include:

Special Area of Conservation (SACs) – Further details can be found in Section 3.3 of this paper

Sites of Special Scientific Interest (SSSIs) – Further details can be found in Section 3.4 of this paper

National Nature Reserve (NNRs)

Sites of Importance for Nature Conservations (SINCs) and Local Wildlife Sites (LWSs)

Regionally Important Geodiversity Sites (RIGS)

International Dark Sky Reserve (IDSR)

2.3.3.3 The following table provides a summary of the hierarchy of protected sites and priority habitats within the

Brecon Beacons National Park (Table 3):

Sites and Habitats

Level of Protection Designation Examples in the BBNP (not an exhaustive list)

Relevant Legislation, policy and guidance

Legislation implementing European Directives

Special Areas of Conservation (SACs)

River Usk

Llangorse Lake

Coedydd Nedd a Mellte

Conservation of Habitats & Species Regulations 2017

National legislation Sites of Special Scientific Interest (SSSIs)

Blorenge

Illtyd Pools

Mynydd Du (Black Mountain)

Wildlife & Countryside Act 1981 (as amended)

Countryside & Rights of Way Act 2000

Environment (Wales) Act 2016

Planning Policy Wales (2016)

Technical Advice Note 5 (2009)

National Nature Reserves (NNRs)

Cwm Clydach

Dan-yr-Ogof

Craig Cerrig- Gleisiad a Fan Frynych

National and local policy and guidance

UK Biodiversity Action Plan Priority Habitats

BBNP LBAP Priority Habitats (now superseded by NRAP for the BBNP)

Sites of Importance for Nature Conservation

Local Wildlife Sites

Ponds

Lowland meadows

Wood pasture & Parkland

Hedgerows

Upland oak woodland

Traditional orchards

Planning Policy Wales (2016)

Technical Advice Note 5 (2009)

UK Biodiversity Action Plan

BBNP Local Biodiversity Action Plan

Local Development Plan

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Local Nature Reserves

Ancient Woodland

Environment (Wales) Act 2016

Table 3: Brecon Beacons National Park Authority Supplementary Planning Guidance – Biodiversity and Development

2.3.3.4 In summary, the SPG raises the following key issues and the recommended courses of action to ensure the

protection and enhancement of biodiversity on development sites (page 28):

Seek pre-application advice from the Planning Department regarding the need for and type of

ecological survey information required.

Assess the existing biodiversity and geodiversity data for the site (designated sites and protected

species records).

Obtain up-to-date and appropriate ecological survey information.

Follow best practice guidance for survey effort and report writing.

Make sure the ecological consultant understands the nature of the proposals and is aware of any

changes.

Protect important biodiversity and geodiversity features, especially where they provide ecological

connectivity.

Seek opportunities to enhance habitats, habitat networks and green infrastructure. There will be

particular opportunities for biodiversity enhancement in landscaping schemes and sustainable

drainage systems.

Build in resilience to climate change.

2.3.4 Brecon Beacons National Park Authority Supplementary Planning Guidance – Biodiversity in and

around the towns of the National Park SPG (March 2015 & September 2016) 2.3.4.1 BBNPA has provided further Supplementary Planning Guidance (SPG) on biodiversity and development in

and around the key settlements of the BBNP which are as follows:

Brecon

Crickhowell

Hay

Talgarth

Sennybridge

2.3.4.2 BBNPA advises that the guidance is read in conjunction with the SPG above (Biodiversity and Development).

The guidance identifies habitats and species in around the key settlements and provides guidance on their

protection and enhancement as well as the following (page 4):

Relevant nature conservation legislation, policy and guidance

Analysis of the biodiversity assets in the Key Settlements

Biodiversity protection and enhancement measures

Opportunities for habitat creation

Additional sources of information and guidance.

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3.0 Situation and Trend

3.1 State of Natural Resources Report (SoNaRR) 3.1.1 Natural Resources Wales (NRW) carried out an assessment of the sustainable management of natural

resources in Wales and produced a State of Natural Resources Report in September 2016. The report is the

first of its kind in Wales and was the first statutory product coming out of the Environment (Wales) Act. The

report assesses and sets out the state of Wales’ natural resources and the extent to which the natural

resources are being sustainably managed.

3.1.2 The report highlights the value and importance of natural resources and healthy ecosystems and states

when natural resources flourish, the society and the economy thrive as well. Natural resources (NR) and

ecosystems can help reduce flooding, improve air quality and supply materials for construction, provide a

home for a variety of wildlife and produce iconic landscapes to enjoy and to boost the economy through

tourism.

3.1.3 The report explains that natural resources are under increasing pressure due to climate change, a growing

population and the need for energy production. Poorly managed natural resources and ecosystems increase

the long-term risks to our well-being and therefore any decisions that are made can have a knock-on effect

on the environment as a whole. Great care and attention, therefore, are required in decision-making.

3.1.4 The report evaluates many economic, social and cultural benefits that natural resources provide to us, for

example:

£385 million from agriculture to the Welsh Economy every year

951 million litres of drinking water per day.

1.5 million tonnes of green timber a year, making construction easier and cheaper.

£499.3 million from the forestry sector to the Welsh Economy.

14 million tonnes of aggregates per year, for construction and other uses.

8,919 gigawatt hours of energy from renewable sources, and rising, creating a renewable energy

industry that employs 2,000 people.

410 million tonnes of carbon stores in soil to soak up emissions and protect against climate change.

£2,870 million in tourism to Wales.

28% of adults meeting the recommended level of physical activity through outdoor pursuits.

£18.2 million of health benefits to people from walking the Wales Coast Path.

£840 million and 30,000 jobs from the historic environment sector.

3.1.5 Wales’ natural resources are said to be in a state of constant change in response to disturbance factors such

as pollution, climate change and damage to ecosystems. This is as a result of the choices people make every

day. The report identifies, therefore, that “to ease these pressures, we need to do things differently.”

3.1.6 Whilst Wales faces significant challenges, there are many improvements that can be made, for example,

safeguarding carbon stores to protect against climate change and soak up future emissions, maintaining

food-producing capabilities, reducing the risk of flooding, retaining the distinctiveness of the landscapes and

improve the quality of water and the connectivity of the habitats to enable species to move locations in

order to survive – “managing natural resources differently will enable us to improve their resilience.”

3.1.7 In summary, NRW identifies that there is a clear range of issues which are difficult to manage or regulate.

Consequently, this reduces the resilience of Wales’ ecosystems, which affects the delivery of ecosystem

benefits, which in turn impacts on people’s well-being. For society, this reduces quality of life for current

and future generations. The report states that ‘the full value of natural resources and ecosystems is not

being adequately taken into consideration in various decision-making processes, under the Environment Act,

Wales now has the opportunity to address this disjointed system and take a more integrated approach.”

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3.1.8 NRW has confirmed that the first SoNaRR is just the beginning and they will continue to improve the

management of natural resources and to fill the data gaps that currently are missing. They aim to take a

joined up approach to the sustainable management of natural resources that will help tackle old problems in

new ways and to find better solutions to the challenges in order to create a more successful, healthy and

resilient Wales, now and in the future.

3.2 Biodiversity in the National Park 3.2.1 Biodiversity in the BBNP is a tremendous natural asset as gives the national park its distinctive character,

supports farming, forestry, tourism and other businesses; and provides visitors and local people alike with

opportunities for spiritual refreshment and healthy exercise. The National Park comprises a semi-natural,

cultural landscape, moulded by nature but influenced by mankind’s management of the land over thousands

of years.

3.2.2 The Park is home to an array of nationally and internationally important habitats and species, as well as

species found nowhere else. From over 75% of Wales’ limestone pavement to the internationally important

freshwater systems of the Rivers Usk and Wye, to the various unique, endemic plant species (e.g. Ley’s

Whitebeam and Attenborough’s Hawkweed), the Park is of demonstrable ecological value (Nature Recovery

Action Plan, BBNPA, Feb 2019).

3.2.3 There is however a vulnerability to the Park’s biodiversity that requires constant monitoring and actions to

combat any potential threats. The main threats imposed on the National Park’s biodiversity is pollution,

development, water abstraction, agriculture, forestry, disturbance by humans and other factors. Climate

change is also a significant threat and will accelerate the rate of decline for habitats and species that are

already in a sub-optimal state across the Park.

3.2.4 Ecosystems are constantly changing and disappearing as they are no longer able to survive. This is a natural

process and happening over long periods of time which then allows new species to evolve and keep

ecosystems functioning. However, species are now reported to be disappearing more quickly than the

natural processes can replace them. The main cause of this is human activities. This decline then causes a

knock on effect with more and more gaps appearing, destabilising the entire ecosystem and causing other

species to disappear. This effect will have wide reaching social, economic and psychological consequences

on us all as human beings as we will struggle to live without the most basic and fundamental requirements

that all animal’s need, the building blocks of life on earth. It is therefore essential that all humans take action

to conserve the biodiversity around them now and for future generations.

3.2.5 To highlight the range of biodiversity that the Brecon Beacons National Park supports, Table 4 has been

extracted from the Biodiversity Information Service (BIS) for Powys and the Brecon Beacons (August 2018):

Table 4: Figures provided by the Biodiversity Information Service for Powys and the Brecon Beacons (BIS), August 2018

The Brecon Beacons National Park supports:

64 biological Sites of Special Scientific Interest (SSSI), covering 25,540 hectares of land 8 National Nature Reserves (NNR)

Over 75% of Wales’ limestone pavement habitat

11 Special Areas of Conservation (SAC), covering 3,211 hectares of land

Wales’ Southernmost breeding populations of red grouse and golden plover

The largest breeding population of lesser horseshoe bat in Western Europe

A range of rare and endemic plant species found only in the Brecon Beacons National Park

The largest natural lake in South Wales, at Llangors, supporting the largest breeding population of two-tone reed beetle in Wales

One of only a handful of locations in the UK which is home to the rare Silurian moth

The most Southerly known site for the scarce Welsh clearwing moth

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3.3 Special Areas of Conservation (SACs) 3.3.1 SACs, together with Special Protection Areas (SPAs) form a network of protected sites across Europe called

Natura 2000 sites. The designation provides another level of protection for sites that are also SSSIs. It is the

responsibility of Welsh Government (WG) through NRW to the European Union to ensure that SACs remain

in a condition favourable to the important habitats and species for which they have been designated.

Proposals likely to have an unacceptable impact on these designations will require an Habitat Regulations

Assessment and, if required, a full Appropriate Assessment on the Integrity of the SAC. A total of 2.38%

(3,211 ha) of Brecon Beacons National Park has been designated under 11 SACs which are as follows:

Blaen Cynon

Brecon Beacons

Coed Y Cerrig

Coedydd Nedd a Mellte

Cwm Cadlan

Cwm Clydach Woodlands

Llangorse Lake

River Usk

River Wye

Sugar Loaf Woodlands

Usk Bat Sites

3.3.2 Due to their sensitivity and importance even development located at a distance can have a negative impact

on SACs. Policy SP3 is the Authority’s existing strategic policy on the protection of the environment to

include biodiversity which requires all proposals for development or change of use of land or buildings in the

National Park to demonstrate that the proposed development does not have an unacceptable impact on,

not detract from, or prevent the enjoyment of a various environmental matters. SP3 Policy is consistent with

the requirements of statutory legislation and provides the highest level of protection to SACs.

3.3.3 Brecon Beacons National Park Authority is required to achieve the protection required by EU instruments

through strict compliance with Regulation 61 of the Habitats Regulation. The onus is on the applicant to

provide enough information in a planning application so BBNPA’s ecologists can assess the proposal’s likely

impact. The Authority is then required to consult with NRW on all planning applications which may affect an

SAC and their advice must be taken into account when determining an application. If required, the developer

will need to complete an appropriate assessment of the proposal on the integrity of the SAC(s) affected. If

the adverse effects to the integrity of an SAC are likely, the application must be refused unless there are

reasons of overriding public interest, for which a series of mandatory legislative tests must be met.

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3.4 Sites of Special Scientific Interest 3.4.1 There is approximately 26,540 hectares of land designated as 64 biological Sites of Special Scientific Interest

(SSSIs) within the BBNPA which is approximately 19.7% of the total land area within the Park. Many of the

Park’s SSSIs are also designated as SACs (Figure 1):

Figure 1: SAC’s and SSSIs Designations within BBNP, Lle Mapping Welsh Government

3.4.2 SSSIs have the primary protection by section 28 of the Wildlife and Countryside Act 1981 (as amended), each

SSSI is protected by law from damage through development or unsuitable management or other activities.

SSSIs help conserve and protect the best of Wales’ wildlife, geological and physiographical heritage for the

benefit of present and future generations. There are more than 1,000 SSSIs in Wales, covering about 12% of

the country’s surface area.

3.4.3 Current Strategic Policy SP3 and Policy 4 supplement the national legislative framework and seek to

conserve and enhance SSSIs in accordance with National Park purposes. Overall the combination of local

policy and legislative framework affords SSSIs a high level of protection commensurate with their status and

it is important that this local policy provision is retained.

3.5 Sites of Importance for Nature Conservation 3.5.1 Sites of Importance for Nature Conservations (SINCs) are non-statutory sites that identify priority habitats or

species within them. Any geological and geomorphological sites that do not merit notifications as SSSIs may

be identified as county Wildlife Sites and subsequently adopted as SINCs and there are several such SINCs

within the National Park. This supplements the network of statutory sites to help maintain biodiversity

within the countryside.

3.5.2 Policy 5 within the LDP provides consideration and protection of SINCs in the planning process.

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3.6 Protected and Important Wild Species 3.6.1 Species which are protected by UK law are listed in the Wildlife and Countryside Act 1981 (as amended) and

the Protection of Badgers Act 1992. European Protected Species (EPS) are listed in the Habitats Regulations.

NRW has identified the following plants occurring in Wales which are EPS, and are listed on Schedule 5 of the

Conservation of Habitats and Species Regulations 2017:

Fen Orchid, Liparis loeselii

Floating Water-plantain, Luronium natans

Killarney Fern, Trichomanes speciosum

Shore Dock, Rumex rupestris

Slender Green Feather Moss, Hamatocaulis vernicosus

3.6.2 Under the Habitats Regulations, it is an offence if you deliberately pick, collect, cut, uproot or destroy a wild

plant of an EPS. The presence of a protected or locally important species is a material consideration in

development decision. BBNPA have identified species that are of particular importance in the National Park

and a full list can be found in BBNPA’s SPG titled ‘Biodiversity and Development’. In terms of proposed

development, where protected species are present or likely to be present, the Authority will require an

ecological survey to be submitted by the applicant and an assessment of the likely impact of the

development on the protected species.

3.6.3 The list of priority habitats and species that have principal importance to help sustain and improve

biodiversity by the Welsh Government under Section 7 of the Environment (Wales) Act 2016 can be found in

Appendix 1 of this paper. Please note that the marine habitats have been excluded as they are not relevant

to the Brecon Beacons.

3.6.4 The Biodiversity Information Service for Powys and the Brecon Beacons National Park (BIS), is one of four

local environmental records centres, which together provide biological data management for the entirety of

terrestrial Wales and its inshore waters. It “holds a geodatabase of species records and habitat information,

constantly updated by maintaining strong links with public bodies, conservation organisations and individual

biological recorders. This enables the service to assist nature conservation by informing decision makers,

conservation organisations and the general public on the occurrence and locations of EU and UK priority

species and habitats, and those of Welsh and local importance in the region” (BBNPA LDP, page 22).

3.6.5 Within the LDP (page 22) it states that “Development which would harm EPS require a derogation granted by

NRW, which will only be granted for development for public health and safety or other reasons of overriding

public interest.” More information and consideration and protection of these species is found in Policy 7

within the LDP.

3.7 Ancient Woodland and Veteran Trees 3.7.1 Ancient Woodlands are a valued and irreplaceable resource. Ancient woodland takes hundreds of years to

establish and is important for its soils, irreplaceable biodiversity, recreational and cultural value, history and

contribution to wildlife habitat and landscapes. ‘Ancient semi-natural woodland’ is any wooded area that has

been wooded continuously since at least 1600 AD, and ‘Veteran trees’ are individual old trees that often

have local or national significance, owing to their age, size or condition. Usually these are found in ancient

woodland, wood pasture, landscaped gardens and old hedgerows.

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3.7.2 These woodlands and trees must be afforded protection from development which would result in their loss

or deterioration unless there are significant public benefits. PPW advises that LDPs should protect these

assets through strategic policies, through imposing conditions when granting planning permissions and/or by

making Tree Preservation Orders (TPOs). In BBNPA’s LDP, these have been protected by the Strategic Policy

SP3 and Policy 8 & 9. The Location of ancient woodland in the National Park is illustrated (Figure 2):

Figure 2: Ancient Woodland (dark green) within BBNP, QGIS

3.8 Climate Change 3.8.1 One of the biggest threats to biodiversity and ecosystems is Climate Change, presenting a significant risk not

only to the natural world but to people, property and infrastructure too. Mitigating and adapting to its

effects is both a global and local challenge. Approaches need to change now to reduce the exposure of our

natural world and society to its effects and to help build and restore an environment which enables all life to

adapt. The planning systems plays a significant role in responding to this challenge.

3.8.2 One of the main aims from PPW is to build resilience to climate change, however one of the key issues from

the ‘Distinctive & Natural Places’ theme is ‘long term and chronic decline of biodiversity and habitat loss that

will continue due to events which have already occurred and events associated with climate change and

habitat fragmentation in the future’ (page 121). Owing to historic and current impacts on biodiversity

already, Wales’ ecosystems are reported to be insufficiently resilient to the impacts of climate change: owing

to the in-combination effects of historic impacts and global warming, species are not recovering from

historic population declines and this will be exacerbated by continuing global warming. Consequently,

climate change is also likely to have a significant impact on landscape character, local distinctiveness and

quality due to changing land cover, migrating habitat and species ranges and indirectly by influencing land

use decisions.

3.8.3 The Special Report on Global Warming of 1.5°C by the Intergovernmental Panel on Climate Change (IPCC

2018) states that the World is completely off track for keeping the pre-industrial levels below 1.5°C and in

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fact is heading towards 3°C and keeping to the target levels would mean rapid far-reaching and

unprecedented changes in all aspect of society. In summary, they have posted five steps to get to 1.5°C:

1. Global emissions of CO2equ need to decline by 45% from 2010 levels by 2030

2. Renewables are estimated to be required to provide up to 85% of global electricity by 2050

3. Coal combustion is required to reduce to close to zero

4. Up to seven million sq km of land will be needed for energy crops (slightly less than the size of

Australia)

5. Global net zero CO2equ emissions by 2050.

3.8.4 The Committee on Climate Change (CCC) has published a report; ‘Net Zero - The UK’s contribution to

stopping global warming’ in May 2019. The report responds to a request from the Government of the UK,

Wales and Scotland, asking the Committee to reassess the UK’s long-term emissions targets. The report’s key

findings include:

The CCC recommends a new emissions target for the UK: net-zero greenhouse gases by 2050

In Scotland, they recommend a net-zero date of 2045, reflecting Scotland’s greater relative capacity

to remove emissions that the UK as a whole.

In Wales, they recommend a 95% reduction in greenhouse gases by 2050.

3.8.5 The CCC reports that the targets for 2050 will deliver on the commitment that the UK made by signing the

Paris Agreement. It is achievable with known technologies, alongside improvements in people’s lives, and

within the expected economic cost that Parliament accepted when it legislated the existing 2050 target for

an 80% reduction from 1990. This is however only possible if clear, stable and well-designated policies to

reduce emissions future are introduced across the economy without delay. The CCC state that current policy

is insufficient for even the existing targets. An infographic has been produced to illustrate the report’s

findings as shown in Figure 3:

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Figure 3: Infographic on Climate Change in the UK (The Committee on Climate Change, May 2019)

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3.8.6 In terms of the planning system, mitigating and adapting to the effects of climate change must be a central

part of any measures to conserve and enhance biodiversity and the resilience of ecosystems. According to

PPW (page 142) “planning authorities should protect trees and areas of woodland where they have

ecological value, contribute to the character or amenity of a particular locality, or perform a beneficial and

identified green infrastructure function. Planning authorities should consider the importance of native

woodland and vale trees, and should have regard, where appropriate, to local authority tree strategies or

SPG. Permanent removal of woodland should only be permitted where it would achieve significant and

clearly defined public benefits. Where woodland or trees are removed as part of a proposed scheme,

developers will be expected to provide compensatory planting.” The overriding challenge for the planning

system is to deliver sustainable development and make a significant contribution to both mitigating and

adapting to climate change.

3.8.7 It is inevitable that the Brecon Beacons National Park’s biodiversity will be affected adversely by climate

change and it is clear that we need to mitigate and adapt to this threat now. The upland areas will be

particularly vulnerable, given the extremes of climate experienced there. The Park’s natural environment is

vitally important to the future of farming and tourism. A summary of some of the predicted effects that

climate change will have within the Park (P. Sinnadurai, BBNPA 2005) are below:

Summers will become longer, hotter and dryer and the peat-rich blanket bogs across the uplands will

begin to dry, reducing their water-retention capacity and releasing stored carbon into the

atmosphere and streams.

Likely to be more uncontrollable grass and heath fires, damaging the underlying carbon-rich peat,

changing the patterns of vegetation across the uplands and encouraging more bracken.

As river levels drop, some species may disappear or fish such as salmon and trout may find difficulty

spawning.

Some tree species such as beech may be effected adversely by drought stress and a few bad years

could significantly reduce their numbers.

Mild winters may mean some seeds no longer germinate as they require frost or lower temperatures

to trigger their development.

Some migratory bird species might delay departure in autumn, putting more pressure on available

food supplies.

Milder temperatures might also lead to more wildlife species surviving in winter, leading to

population increases that might exert pressure between species and individuals competing for food

and breeding sites.

Heavy rains, particularly after summer droughts might increase the risks of flash-flooding and soil

erosion.

Wetter winters might lead to a net loss in available water supplies as annual storage capacities are

overwhelmed.

The extra sediment washed into rivers changes to water chemistry affecting every freshwater plant

and animal, while the settling of the sediment can bury gravel and stone river beds with mud,

depriving some species of the conditions they need.

Livestock might experience increased heat stress, lack of shade and water shortage.

Agricultural pests and diseases, as well as arrival of new ones, might benefit from milder winters and

warmer summers.

Seasonal availability and accessibility of pasture might be affected by drought or by prolonged

periods of wet weather.

3.8.8 The statement by Ecologists of the National Parks of England, Scotland and Wales (May 2008) titled ‘Britain’s

National Parks as test beds for ecological mitigation and adaptation to the impacts of climate change – an

agenda for action’ states that Britain’s National Parks are well positioned to make significant national and

regional contributions to mitigating and adapting to climate change: through flood control, water

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conservation, carbon conservation, woodland expansion, biodiversity conservation and sustainable farming.

The statement also explains that Britain’s organic soils and peatlands hold more carbon that the forests of

Britain and France together and Britain’s National Park hold most of them. Although the statement highlights

the key issues and threats of climate change to the biodiversity and natural environment in Britain’s National

Parks, it also sets out a range of short-term and mid-term opportunities and actions. A few examples of

these are as follows:

Through National Park’s purposes and duties, promote their roles as test-beds for ecosystem-led

responses to climate change at a national and regional level.

Develop action plans to maximise the efforts over the next 20 years to conserve and restore key

elements of ecosystem function in order that National Parks become the ‘healthy beating heart’ of

Britain’s ecosystems in the face of climate change.

In collaboration with the research institutes and conservation agencies, develop minimum

estimates of the volumes of organic soils, vulnerable soils, peat and important wetland ecosystems

within the National Parks, identifying those habitats and management practices that are most

critical to carbon conservation and ecosystem function.

Continue to work with the farming sector to secure biodiversity and ecosystem benefits.

In National Parks, consider accelerating the reversion of unproductive or uneconomic conifer

plantations to deciduous broadleaved woodland, heathland and moorland in order to provide

‘near-natural areas’ within and adjacent to the former plantations.

Where suitable and appropriate, maximise broadleaf woodland expansion within Britain’s National

Parks in order to provide wood fuel, reduce flooding by increasing infiltration, sequester carbon

and improve landscape richness and connectivity.

Develop joint projects by teams from across the National Park network on different themes, such as

montane or coastal biodiversity, peatland restoration, flood alleviation through wetland

conservation and expansion of unimproved grasslands and woodlands.

3.8.9 Climate change has also been recognised as one the most significant challenge facing the future of the

Brecon Beacons National Park within their LDP. The LDP includes a Climate Change Strategic Policy (SP4)

which aims to require all development (where relevant) to be subject to the requirements set out within the

policy and to also explain in detail how the development will incorporate the requirements of this Strategic

Policy within their Design and Access Statements. This illustrates that the National Park Authority is

committed to ensuring that all development mitigates and is able to adapt to the likely effects of climate

change beyond the LDP’s control.

3.8.10 The National Park Authority must take future risks into account when permitting development such as

flooding, intelligently sites, climate responsive, built with sustainable materials, resource efficient and

accessible to all for the lifetime of the development. The LDP makes this commitment to address the issue of

climate change with the acknowledgement that is just one mechanism by which the above practical

mediations can be enabled (page 40).

3.8.11 The following policies provide more details in applying SP4 to specific areas when permitting development:

SP11 Sustainable Development

Policy 23 Sustainable Design in the Adaption and Re-use of Existing Buildings.

3.9 Nature Recovery Action Plan for the Brecon Beacons National Park 3.9.1 The Nature Recovery Action Plan (NRAP) guides the work of the Brecon Beacons National Park (BBNP) Local

Nature Partnership (LNP) whose main aim is to achieve nature recovery as a principal means of conserving

and enhancing resilient ecosystems. The NRAP was adopted by the BBNPA in April 2019 as its principal

contribution to nature recovery.

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3.9.2 The Action Plan states that “we are in a period of ongoing resource constraints when biodiversity faces

increasing pressures from agricultural change, local development, climate change and the spread of invasive

non-native species” (page 6). The plan outlines that the biggest gains for nature recovery will depend upon

well-designed schemes that are implemented at a landscape scale. The State of Natural Resources Report

(Section 3.1 above) states that the biggest challenge to nature recovery is the gaps in the evidence base to

understand the National Park’s ecosystems and the habitats and species that are integral to them.

3.9.3 The core ambition of the Plan is to “help reverse the decline in biodiversity by focussing on developing

resilient ecological networks (in other words nature recovery networks) which are more diverse, greater in

extent, in better ecological condition and better joined up” (page 8). This aim is based upon the five

component attributes of ecological/ecosystem resilience: diversity, extent, condition, connectivity, and

adaptability, as described in the Environment (Wales) Act 2016.

3.9.4 The Action Plan also provides objectives that will guide efforts for nature recovery across the National Park

which are mindful of the principles within the Wales’ key environmental legislative and strategic drivers (as

above). The five key objectives for the NRAP are outlined in Table 3:

Table 5: Key objectives for the Nature Recovery Action Plan, BBNPA (February 2019)

3.10 Projecting Land Use Change in the Brecon Beacons National Park 3.10.1 Brecon Beacons National Park Authority met with representatives from The University of Reading (UoR) and

Natural Resources Wales (NRW) on the 30th November 2018 ‘to explore opportunities for evaluating land

use change to better inform the BBNP Nature Recovery Action Plan, and more directly, future management

of natural resources in the National Park’.

3.10.2 The meeting was split into 6 presentations from various representatives with the main overview on

projecting land cover and creating policy and schemes to create woodlands throughout Wales. The main

points from the discussion are as follows:

Nature Recovery Plan Objectives

Improve evidence gaps

Objective 1: To improve our evidence, understanding and monitoring of ecological resilience within the National Park.

Collaboration and co-operation

Objective 2: To work with partners at all levels to unify local action for nature recovery and ensure integration with relevant natural resources plans and strategies.

Protection, restoration and creation of habitats

Objective 3: To increase the resilience of our natural environment by protecting existing semi-natural habitats, restoring degraded habitats and creating new areas of habitat.

Deliver action for focal species and habitats

Objective 4: To identify and deliver targeted action for key species and habitats as part of a wider, integrated nature recovery action programme.

Inclusive and well-communicated

Objective 5: To increase the resilience of our natural environment by protecting existing semi-natural habitats, restoring degraded habitats and creating new areas of habitat.

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Natural Resources Wales (NRW) is developing the next Glastir Woodland Creation Scheme as an

umbrella programme under which will sit several projects as well as advice, guidance & regulatory

efficiencies which will also be steered by Welsh Government policy.

Wales is one of the least wooded countries in Europe at 14.8% compared to the EU average of 38%,

therefore woodland cover is a priority for Wales, in accordance with the WG’s Woodlands for Wales

Strategy and the needs of local communities.

There is a plantation woodland replacement scheme starting in 2019/20 for a minimum of 350 ha new

forestry to replace areas felled for renewable energy developments. The replacement woodland will be

for timber production and has been pinpointed to Pen y Cymoedd, Brechfa West and Clocaenog.

There are gaps in the evidence base for woodlands in Wales and the opportunities they present for

ecosystem resilience.

There is also a Centenary Planting Scheme project that will commemorate those who died during the

First World War which is expected to begin in 2019 and will be expected to take between three and five

years to complete.

Farmers would also like to be involved and to know what will change in the future so that they can

prepare for these upcoming opportunities.

4.0 Conclusion 4.0.1 The purpose of this paper is to examine the priorities for biodiversity conservation within the Brecon

Beacons National Park to inform policy for the replacement LDP. The National Park’s biodiversity is a

tremendous natural asset that helps give the Park its distinctive character and provides a vast variety of

‘ecosystem services’. Many of the Park’s habitats and species are internationally important with a number of

rare species which are protected by policies outlined in this paper. Conserving and enhancing the Park’s

biodiversity, and in particular achieving nature recovery, are entirely consistent with the Park’s first purpose

to conserve and enhance the natural beauty, wildlife and cultural heritage.

4.0.2 Biodiversity is however under threat from land management, climate change, pollution, development and

other factors. As species disappear, gaps appear in ecosystems that undermine their function and resilience.

These may be small at first but as more species and habitats are affected, and because species rely upon

other species, this has knock-on consequences, causing others to be adversely affected.

4.0.3 The Intergovernmental Panel on Climate Change (IPCC) has reported that the world is completely off track

for keeping the pre-industrial temperature levels below 1.5°C and is in fact heading towards 3°C which have

detrimental effects to the world’s climate and habitats. The main aims of Planning Policy Wales include:

building resilience to climate change, halting and reversing the loss of biodiversity, maintaining and

enhancing green infrastructure based on seeking multiple ecosystem benefits and solutions, ensuring

resilient locational choices for infrastructure and built development, taking actions to move towards a more

circular economy in Wales and facilitating the move towards decarbonisation of the economy (page 33).

4.0.4 This paper covers a range of policy topics and provides guidance on the biodiversity considerations which

have been taken at policy level and those considerations which can be made at planning application and

enforcement action level. This paper also provides guidance and analysis on how the biodiversity within the

National Park is protected and the opportunities on how to conserve and enhance biodiversity, and maintain

and enhance ecosystems and the benefits they provide within the NP.

4.0.5 The need for more evidence on the Park’s state of nature and the distribution, extent and resilience of the

Park’s ecosystems is a recurring issue. What is consistent, however, is the threat to the natural environment

and the continuous pattern of decline in the UK’s ecosystems and habitats. The effects of climate change

will accelerate this decline. Preventing further adverse consequences to the quality of the Park’s

environment therefore requires urgent attention now to rectify and reverse this trend.

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4.0.6 The current strategic policies within the Local Development Plan are currently being reviewed and there is

an emerging Environmental Protection policy that that prevents any proposed development having an

unacceptable impact on, nor detract from, or prevent the enjoyment of the Biodiversity and natural

resources both within and beyond designated sites. There is also an emerging Strategic Policy on Climate

Change that enacts for all development to be resilient and adaptable to the likely effects of climate change,

limit and mitigate the causes of climate change, contribute to carbon neutrality and reduce the need for

travel and transport, and in the case of Major Development schemes, achieve zero carbon in operation by

2023 and carbon neutral in construction and operation from then on.

4.0.7 These emerging strategies are essential in protecting and reversing the decline in biodiversity, as well as

doing our bit to help reduce greenhouse gases in the UK. As a National Park, it is our duty to conserve and

enhance the natural beauty, wildlife and cultural heritage of the National Park, and the current and

emerging strategic strategies within the Local Development Plan intends to fulfil and go above and beyond

this duty.

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5.0 References

- BBNPA (2019). Biodiversity in the National Park

http://www.beacons-npa.gov.uk/environment/understandbiod/bd-in-the-bbnp/

- BBNPA (2016). Brecon Beacons National Park Authority Supplementary Planning Guidance – Biodiversity

and Development (2016)

http://www.beacons-npa.gov.uk/wp-content/uploads/Final-Biodiversity-SPG-160907.pdf

- BBNPA (2015). Brecon Beacons National Park Authority Supplementary Planning Guidance – Biodiversity

in and around the towns of the National Park SPG (March 2015 & September 2016)

http://www.beacons-npa.gov.uk/planning/draft-strategy-and-policy/supplementary-planning-guidance/

- BBNPA (2013). Brecon Beacons National Park Local Development Plan (2013)

http://www.beacons-npa.gov.uk/wp-content/uploads/Brecon-Written-Statement.pdf

- BBNPA (2015). Brecon Beacons National Park Management Plan 2015 – 2020

http://www.beacons-npa.gov.uk/wp-content/uploads/BBNP-Management-Plan-PROOF-03-03-16-

English.pdf

- BBNPA (2019). Nature Recovery Action Plan for the Brecon Beacons National Park (February 2019)

chrome-extension://oemmndcbldboiebfnladdacbdfmadadm/https://governance.beacons-

npa.gov.uk/documents/s37911/Enc.%201%20Nature%20Recovery%20Action%20Plan%20for%20the%20

Brecon%20Beacons%20National%20Park.pdf

- Biodiversity Information Service (BIS) (2018). Biodiversity Information Service for Powys and the Brecon

Beacons (August 2018)

https://www.bis.org.uk/

- CBD (2019). Convention on Biological Diversity

https://www.cbd.int/intro/default.shtml

- EU (1979). EU Birds Directive (79/409/EEC, 1979)

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32009L0147

- EU (1992). EU Habitats Directive (92/43/EEC, 1992)

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31992L0043

- EU (2011). The EU Biodiversity Strategy to 2020 (2011)

http://ec.europa.eu/environment/nature/info/pubs/docs/brochures/2020%20Biod%20brochure%20fina

l%20lowres.pdf

- IPCC (2018). IPCC Global Warming of 1.5°C (October 2018)

https://www.ipcc.ch/2018/10/08/summary-for-policymakers-of-ipcc-special-report-on-global-warming-

of-1-5c-approved-by-governments/

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- National Parks UK (2008). National Parks Britain’s Breathing Spaces - Britain’s National Parks as test beds

for ecological mitigation and adaptation to the impacts of climate change – an agenda for action (May

2008)

http://www.beacons-npa.gov.uk/wp-content/uploads/oldsite/environment/climate-

change/Ecologists%20climate%20change%20statement_NMS%20amended%20May%202008%20followi

ng%20Cairngorms%20workshop_BBS(Vs2).pdf

- NRW (2016a). Natural Resources Wales – Priorities for Action (2016)

https://naturalresources.wales/about-us/area-statements/priorities-and-challenges/?lang=en

- NRW (2016b). Natural Resources Wales - State of Natural Resources Report (September 2016)

https://cdn.naturalresources.wales/media/682366/sonarr-summary-september-2016-edited-august-

2017.pdf

- The CCC (2019). The Committee on Climate Change: Net Zero – The UK’s contribution to stopping Global

Warming (May 2019)

https://www.theccc.org.uk/publication/net-zero-the-uks-contribution-to-stopping-global-warming/

- UK Government (2015). Biodiversity and Nature Conservation (Appendix B)

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/45

0880/2015-07-31_Appendix_B__2_.pdf

- UK Government (2017). The Conservation of Habitats and Species Regulations (2017)

http://www.legislation.gov.uk/uksi/2017/1012/contents/made

- UK Government (1949). The National Parks and Access to the Countryside Act (1949)

https://www.legislation.gov.uk/ukpga/Geo6/12-13-14/97

- UK Government (1981). The Wildlife and Countryside Act (1981)

https://www.legislation.gov.uk/ukpga/1981/69

- WG (2016). Environment (Wales) Act (2016)

https://gov.wales/topics/environmentcountryside/consmanagement/natural-resources-

management/environment-act/?lang=en

- WG (2018a ). Planning Policy Wales Edition 10 (December 2018)

https://beta.gov.wales/sites/default/files/consultations/2018-02/ppw-restructure-draft-ppw_en.pdf

- WG (2009). Technical Advise Note 5 (TAN 5): Nature Conservation and Planning (2009)

https://gov.wales/docs/desh/policy/100730tan5en.pdf

- WG (2015). Welsh Government’s Local Development Plan Manual Edition 2 (2015)

https://gov.wales/docs/desh/publications/151007local-development-plan-manual-edition-2-en.pdf

- WG (2018b). Valued and Resilient: The Welsh Government’s Priorities for Areas of Outstanding Natural

Beauty (AONB) and National Parks (2018)

https://gweddill.gov.wales/docs/desh/publications/180727-designated-landscapes-valued-and-resilient-

en.pdf

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6.0 Appendix

6.1 Appendix 1 – Welsh Government’s List of Priority Habitats and Species

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