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DRAFT EXMOOR NATIONAL PARK LANDSCAPE CHARACTER ASSESSMENTSUPPLEMENTARY PLANNING DOCUMENT

APRIL 2018

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.

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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:

001 R Briden 009 Exmoor Society

002 Cutcombe Parish Council 010 Natural England

003 B Lane 011 Winsford Parish Council

004 North Devon AONB 012 West Somerset Flood Group

005 North Devon Council 013 T Bridgeman

006 Somerset County Council 014 Woodland Trust

007 Old Cleeve Parish Council 015 R Watts

008 Exmoor Rivers and Streams Group 016 Exmoor Uprising

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LCA Comment RESPONSE ENPA Comments Actions

001 01 Yes Object On watching George Monbiot at the UK National Parks Conference 2015, https://www.youtube.com/watch?v=SYdm6k1tg3Y 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.


Noted.


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

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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

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

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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)

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


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

Noted and acknowledged but the LCAs are quite

No change made.

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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)

large and don't have a single settlement to be identified with. Therefore compass directions have been used.


"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

The cricket pitch area is certainly unique, but the

No change made.

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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.

wider LCA has many coastal heath features in common with other parts of the LCT. In terms of management, it fits quite comfortably.

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.”


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

Noted. Added to text (profile B). Also impact of coastal squeeze on

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issues and forces for change. woodlands added to general forces for change (natural processes and climate change table).

004 11 159 LCT F Enclosed 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

Noted. Text amended (LCT F)

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if you need it).004 13 166 Support with

changesLoss/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)


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 dilapidated road 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.


Check spelling of photo caption – should it be Hoaroak Water (?)

Noted. Text amended


Exmoor's Special Qualities: Check whether to amend “discrete” (meaning separate or distinct) to “discreet” (meaning subtle or hidden).

Noted but it is considered in this reference both 'discrete' and 'discreet' are applicable to the stone settings of Exmoor

Haven't changed, in order to be consistent with Exmoor's own text on Special Qualities, but I

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think the change should be made!

005 04 2.5.10

23 General comment

Amend to read “… were able to graze animals …” Text amended

005 05 2.5.15

26 General comment

Correct spelling of “century”. Text amended

005 06 2.5.22

29 General comment

Amend to read “… was used as a target at and flattened.”

Text amended

005 07 2.7.1 3 33 Support with changes

Whilst the range of nature and landscape designations across Exmoor is identified, is there any merit in identifying and referencing equivalent designations surrounding the National Park which help to contribute to its setting? The most obvious example is the AONB which adjoins the National Park at Combe Martin, or the nearby Quantock Hills AONB. The historic parks and gardens also provide an important landscape function as well as protecting heritage and could be referenced.

Noted. N Devon Coast AONB added to map 3. Quantocks AONB is outside the map area.

005 08 4 38 Support with changes

There are several conservation areas surrounding (or adjoining) the National Park which should be shown, as you have for other designations outside the Park boundary. The adjoining conservation area is at Combe Martin, with the closest surrounding ones at Berrynarbor, North Molton, South Molton, Molland and Knowstone.

Noted Designations amended to show only those within the National Park boundary

005 09 2.8 39 Support The reference to relevant ecosystem services throughout the assessment is welcomed and complements works integrated within the North Devon Biosphere Reserve Strategy.

Noted


Guidelines for vertical features (design structures): Check whether to amend “discrete” (meaning separate or distinct) to “discreet” (meaning subtle or hidden).

Noted Text amended


LCA A3: The Foreland - Amend to read “… between the towns of Porlock at and Lynton,”

Noted Text amended


Strength of Landscape Character: Amend “feint” to “faint”.

Noted Text amended

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Designated Nature Conservation Sites: The table indicates LCAs B1 & B2 are within the Biosphere Reserve. My records indicate that the Biosphere Reserve transition zone extends east of Lynton/Lynmouth which would also include B3. See also Map 3. It also seems odd that Heddon’s Mouth (B1) is not included within the Heritage Coast; the Local Plan policies map would suggest that part of B1 is within the Heritage Coast.

Noted Text amended


Urbanisation of road corridors: Amend “4B” to “B4”. Noted Text amended


Seascape Character Areas: For consistency with other LCTs, add: “Please refer to the Seascape Character assessment document for more detail”.

Noted Text amended


Key Characteristics of the Open Moorland: Correct spelling of “R.D.Blackmore”.

Noted Text amended


LCT D1: Northern Moorland: Correct “mostrity …” to either “Most …” or “The majority …”

Noted Text amended


Landscape sensitives and potential impacts: Suggest adding a further issue similar to that for LCT B: “Dark night skies and sense of relative wildness and isolation, away from development and human activity”.

Noted Text amended (incorporated into first row of Planning Guidance Table)


Key views, viewpoints and landmarks: Correct the spelling of “into the Vale …”.

Noted Text amended


Strength of Landscape Character: Correct “… and re are in good condition”.

Noted Text amended


Seascape Character Areas: Correct the spelling of “SCA10: Coombe Combe Martin and Ilfracombe Bays”.

Noted Text amended


Landscape sensitives and potential impacts: As above, suggest adding a further issue similar to that for LCT B: “Dark night skies and sense of relative wildness and isolation, away from development and human activity”.

Dark night skies already covered in final row. LCT F is not quite as divorced from development and human activities as other

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LCTs, so it has been retained.


Natural Landscape Features: Correct the spelling of “… Site of Special Scientific Interest …”.

Noted Text amended


LCT G5: Haddeo: Amend “LCTS” to “LCTs”. Noted Text amended

005 25 180/187

General comment

Page 187 states that “The River Barle itself has been assessed as being in ‘unfavourable declining’ condition due to the presence of invasive species and the presence of habitat modifications, whereas page 180 states that “The River Barle is particularly valuable for biodiversity and water quality as it is in such a natural state”. Is there an inconsistency here?

Both statements are relevant the River Barle's valuable qualities are identified, as are the issues associated with it.


PLAN: Check whether to amend “discrete” (meaning separate or distinct) to “discreet” (meaning subtle or hidden).

Both 'discrete' meaning separate and 'discreet' meaning subtle are applicable in the context of Exmoor's stone settings.

Review specifically in relation to 'Special Qualities'


Landscape Strategy: Delete rogue bracket ] at the end of the strategy.

Noted Text amended


The County Council Acoustics Specialist offers the following comments on the May 2017 draft Exmoor Landscape Character Assessment (ELCA) and has focused on issues relating to noise. The ELCA would contribute to the National Planning Policy Framework (NPPF) objective (paragraph 123) that ‘Planning policies and decisions should aim to identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason’. The consideration of unwanted noise would form a part of any consideration of tranquillity but NPPF Guidance indicates that there are no precise rules to defining areas that can be protected for their tranquillity stating that such areas are ‘likely to be relatively undisturbed

Noted - issues relating to noise pollution are addressed in the Exmoor National Park Local Plan 2011-2031 (adopted 4th July 2017).

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by noise from human caused sources that undermine the intrinsic character of the area. Such areas are likely to be already valued for their tranquillity, including the ability to perceive and enjoy the natural soundscape, and are quite likely to be seen as special for other reasons including their landscape’. As such the ELCA would appear to be identifying areas where tranquillity is an important feature and this, and the identified requirement to consider noise impact, can then assist in the planning protection of such areas. This is an important role as tranquillity has been identified as the main attribute attracting people to visit the countryside and one that is under growing treat from development, as shown by the 2007 CPRE report Developing an Intrusion Map of England. It is recognised that the ELCA should be read in combination with other planning documents but at this time the County Council Acoustics Specialist was not able to access an on-line version of the latest revision to the Exmoor Local Plan (ELP) and as such some of the points the County Council Acoustics Specialist raises concerning noise and tranquillity may have now been addressed in this document. However the County Council Acoustics Specialists draft ELP consultation response of 2/12/13 did note that the ELP ‘provided good opportunity to stress the importance of protecting tranquillity and consider noise impact from development’ but lacked definition of tranquillity or the way noise might be detrimental to tranquillity and the County Council Acoustics Specialist suggested several additions.

006 02 yes General comment

The County Council Acoustics Specialist considers that the ELCA has made many appropriate references to tranquillity but, as with the ELP, it may benefit by providing a full description of, or reference to, the environmental aspects that both contribute to, and threaten this subjective attribute. There has been considerable research undertaken by University of

Noted LI Technical Note added to reference list.

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Bradford's Centre for Sustainable Environments on this topic and they have developed a method of quantifying tranquillity known as TRAPT - Tranquillity Rating Prediction Tool and the basis of this may be helpful when planning needs to consider the impact of proposed development on areas with valued tranquillity. Further recent consideration of tranquillity is also provided in the Landscape Institute Technical Information Note 2017 : Tranquillity – An Overview.


When considering the preservation of tranquillity it’s common to draw attention to the need to minimise both unnatural visual and acoustic impacts from development. There may also be benefit in describing the less obvious need to preserve natural acoustic features that contribute to tranquillity by virtue of providing screening or masking of unwanted noise, as these features can extend the boundaries of tranquil space. In this respect the County Council Acoustics Specialist notes that the ELCA does not identify the acoustic screening and natural noise masking as an ‘ecosystem service’. As such these important acoustic features of wooded landscapes or the acoustic masking that running water might provide, may not be recognised as an enhancement to tranquil soundscapes or that they can become acoustic features that lead to the improvement of regions of new development. This consideration might influence proposed changes to water features or removal of trees and may conflict with visual benefits. There would therefore need to be a balanced judgement between acoustic and visual contributions to tranquillity and this becomes more significant if distant traffic noise were to become more prominent due to the removal of a natural source of masking sound. This point might be made within Part 2 content and ‘Examples of ecosystem services provided by Exmoor’s woodland’ or within other comments prior to part 4 references to tranquillity.

Noted Natural noise masking added to ecosystem services diagrams and illustrations.

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006 04 49 3 General comment

The County Council Acoustics Specialist notes Part 3 of the ELCA is intended to be used by planners, developers, land agents, and members of the public when submitting planning applications and by the National Park Authority Committee Members when decision-making. Part 3 describes the visual planning guidelines of the Exmoor Landscape Character Assessment but makes no direct reference to noise which can adversely impact on the tranquillity, and the landscape character of nearby areas or the site itself. The development land may also provide desirable noise attributes to surrounding landscape features and these may require consideration if change is to arise from development. While the County Council Acoustics Specialist notes that Section 3.3.2 (The Sensitivities of Exmoor’s Landscapes to Development) mentions special qualities and lists ‘Tranquillity’ further mention is only made of this in 3.5.6 (Guidelines for vertical features) to cover the consideration of wind turbines.

Noted Additional sentence added at end of para 3.5.5 which reads 'As well as visual impacts, detrimental impacts on tranquillity through noise or movement should also be considered'. Table 3.5.4 second row first bullet now amended to read 'avoid development within or which would impact on LCT A or D or cause loss of tranquillity.' Noise also added to 'tranquil areas' bullet in section 3.3.2 (planning guidelines). The role of rivers and woodland in providing natural noise

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masking and contributing to tranquillity has been added to the ecosystem services sections for LCTs B and G.


Noise from transport, farming and commercial development is identified to form part of several LCT and as such may require consideration if these noise impacts are not to degrade the current, or intended tranquillity of these areas. Unnecessary noise intrusion and erosion of tranquillity might arise if agricultural machinery is not maintained or silenced to manufactures specification or plant is permitted to use bleep tone reverse warning alarms that can be heard over a considerable distance and which can easily be averted by the use of broadband alarms. While development or the operation of plant that results in noise is generally undesirable there may be some cases where the ELCA might identify man made noise to be a landscape attribute. This might be the case with the noise from the steam trains of the West Somerset Railway and other instances may also be known to exist.

Noted Changes in sounds added to 'Forces for Change' section 2.9.3.


Section 4 provides detail on the nine Exmoor Landscape Character Types and defines the Areas exhibiting these LCTs. Existing noise impacts are identified in a few instances (A39 traffic - LCT A E & F, game shooting - LCT G) and there are many references made to the importance of retaining tranquillity. The perceptual qualities of LCT-B identify the sounds of running water, and as the County Council Acoustic Specialist noted earlier, this could be identified as an important component of tranquillity requiring protection and a feature that might be employed to mask unwanted

Noted Sound-based attributes added to LCT D (sound of wind in grasses) and G (running water).

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noise from traffic or development.006 07 5 General

commentSection 5 provides a list of technical terms and the County Council Acoustic Specialist considers that a full description of tranquillity and the influences on it might be included. If the ELCA is to include further consideration of noise then it would be worth including the term ‘masking (sound) – a sound capable of obscuring the presence of unwanted noise’. The County Council Acoustics Specialist considers that a reference should be made to further information contained in the Landscape Institute Technical Information Note 2017: Tranquillity – An Overview.

Noted Masking (sound) added to glossary, and LI Technical Note on Tranquillity added to reference list.

006 08 2.5.22

General comment

The County Council Acoustics Specialist notes a minor typo in 2.5.22 - (for example the Knight farm at Larkbarrow was used as a target at flattened).

Noted Text amended


Landscape Character Type I Brendon Hills: Part 4, Designated Nature Conservation Site. 1. Not mentioned - Treborough Quarry. As Treborough does not have a Parish Council, usually Old Cleeve Parish Council is consulted on certain matters connected with Treborough. Treborough Quarry has both significant geological and historical importance (slate extraction for over 600 years). This is now a wildlife reserve. 2. Mineral line condition and sites. This runs through Old Cleeve Parish as well as neighbouring Parishes. There is poor management and conservation of these historic sites and features. 3. Modern farming procedures requires large farm buildings which impact on the landscape, and increase in light pollution and neighbouring development (WS area). 4. Hedge management - It is noted that most local hedges are beech hedges and traditionally these would be cut and coppiced correctly. Currently it is noted that the majority of hedges are cut using mechanical flailing, which has a negative impact on the landscape. Management Recommendation: Mining heritage. Old Cleeve PC recognise the importance of the mining

As Treborough Quarry is not currently designated as a Local Geological Site, it is not included in the table. Hedge management and the conservation of heritage assets are both highlighted in the 'Forces for Change and Landscape Sensitivities' for LCT I.

Treborough Quarry has been referenced in the text.

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heritage however concerns are raised over the loss and poor maintenance of some of the structures. We feel that additional support from the National Park is required.


General: Old Cleeve Parish Council supports the document, findings and recommendations. However, we appreciate the biggest challenges will be financial, resources and enforcement. Perhaps more volunteer participation can be considered and encouraged e.g. similar to the current signpost project. Mineral Line Heritage: Volunteers require continuing support and backing of Exmoor National Park to ensure sustainability. Parking enforcement: boundary walls, hedges and local materials used must be considered to maintain the intrinsic character of the local vernacular. There may be reluctance from architects and designers particularly on new developments on Exmoor to consider restrictive design practices. Increase legislation from Central Government particularly towards carbon neutral development. To consider the increased demand for 'clean' electric power, solar installations and vehicle charging power distribution, especially due to the lack of public transport throughout Exmoor. Is the infrastructure in place to provide a long-term supply of 'clean' electricity, which will have a minimum impact on the local vernacular?

Noted - many of the issues raised such as sustainable transport, parking, local vernacular, and renewable energy, are addressed through the implementation of policies in the Exmoor National Park Local Plan. The LCA as a supplementary planning document will, once adopted, be a material consideration in all planning decisions.

No change made.


The landscape significance of rivers appears to be seriously understated. Rivers mostly formed Exmoor and they continue to influence both the natural and built landscape including historically important settlements and industrial sites. Rivers and streams are now a focus of visitor interest whilst providing key corridors for an immense range of wildlife – both flora and fauna. An unpolluted clear water stream is a vitally important landscape element per se and the native flora and fauna which inhabit rivers are themselves critical to a proper (and deeper) appreciation of

Noted. Introductory text amended to acknowledge the importance of rivers and streams.

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landscape.008 02 Yes Object The numerous risks to rivers and streams and the

remarkable flora and fauna to which they are essential, including vulnerable migratory fish, are inadequately represented. This has been the subject of much discussion between us and you will be aware of the serious and diverse nature of these risks including climate change, human interventions outside the National Park, and more local disregard for their condition and exploitation. Ostensibly a `dead’ or dying river might on the surface look much like a thriving habitat but to focus merely on the visual dimension is insufficient to safeguard their futures.

Noted. The landscape management guidelines and recommendations for LCT B High Wooded Coast Combes and Cleaves, and LCT G Incised Wooded River Valleys include references to the protection of watercourses for their visual, ecological and water quality values.

008 03 Yes Object The draft LCA, whilst purporting to be a guide to planning decisions, is seriously weakened because of this limited perspective. In order to address this perceived weakness we would hope to discuss with you ways in which the LCA planning guidance might be more explicitly linked to the other ENP planning documents where ecological concerns are more prominent.

Other plans policies and programmes will further address this issue including policies in the adopted Local Plan and ambitions in the adopted Partnership Plan.


In relation to the Landscape Character Types, tumbling rocky streams are a key characteristic of Type B, and the rivers themselves essentially define Type G. We therefore think this reality should be better represented.

Noted Title of LCT G amended to become 'Incised Wooded River Valleys'.

008 05 Exec Sum

General comment

P.1 para. 5 – include `species rich rivers and streams,’ after `steep valleys’P.2 para. 1 – amend landscape type `B’ to `High Wooded Coasts, Combes, Cleaves and Streams’; and type `G’ to `Rivers and Incised Wooded Valleys’.

Noted See comment above. Text of executive summary amended to include reference to rivers and streams.

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008 06 1.8.4 9 1 General comment

Insert as appropriate ‘the degradation of rivers through natural, especially climate change processes, the proliferation of non-native species, and as a result of human actions including poor sewage management, inappropriate land use, and recreational impacts;’

Noted Text added (1.9.4)


Insert under Exmoor’s special qualities 4th point after `deer’, `rivers providing important spawning grounds for migratory fish, especially the internationally vulnerable Atlantic salmon,’

This cannot be changed at present as it refers to the Special Qualities set out in the adopted Partnership Plan. The importance of rivers as spawning grounds for migratory fish will be included in the text for LCT B and LCT G.

Text added under Natural Landscape Features for LCT G and LCA B3: Lyn.


Include at end of paragraph Èxmoor’s rivers and streams remain vital for a rich diversity of flora and fauna.’

Noted Text added (2.3.9)


Include under Natural Processes 5th point include ànd localised American signal crayfish infestation potentially damaging river banks and fish stocks.’

Noted Text added


Under 6th point `Tranquil areas’ add ànd in-river and riverside recreational pressures altering character and adversely affecting tranquillity;’

Noted Additional bullet point added: Rivers and streams which are sensitive to in-river and riverside recreational pressures altering character and reducing tranquillity.


Include a specific box to consider impact on native flora and fauna of the site, and its context, during and as a

Noted - However, this is a matter that would be

Amend text to box under 3.4.1

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result of construction, referencing other relevant ENP planning documents.

considered through the implementation of policies in the Local Plan such as HC-S3 Biodiversity and Green Infrastructure. The text will be amended to include considerations such as landform, site orientation, elevation, existing vegetation, access etc.

Consider the Landscape Context of Your Site


Concerning the obligation of relevant off-park authorities to have regard to National Park purposes include reference to migratory fish and their passage.

Under Section 11A of the National Parks and Access to the Countryside Act 1949 relevant authorities must have regard to National park purposes when making decisions or carrying out activities relating to or affecting land within the National Park.

This will be addressed in future Partnership Plan actions.


amend LCTs B and G as above 008/05 Noted LCT G has changed to Incised Wooded River Valleys


amend LCT B as above 008/05 Noted LCT G has changed to Incised Wooded River Valleys



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Add at end of 1st main paragraph `with a traditional association, celebrated in literature, with game fishing.’

Noted Text added


Add at end of first paragraph `The East Lyn river, which in spate can transform from a rocky stream to a raging torrent, is an important habitat for migratory fish species, salmon and sea trout, which spawn throughout its length, and for the iconic otter.’

Noted Text added (to general description)


Amend 2nd point to `Work with riparian owners and permitted recreational groups to ensure etc.’

Noted Text amended


Add at end of 5th point `and do not impact adversely on the rich ecology of the rivers and streams.’

Noted Text added


amend LCT G as above 008/05 Noted LCT G has changed to Incised Wooded River Valleys






Add to 2nd paragraph after `species’ `It is particularly important for providing spawning grounds for migratory salmon and trout but is adversely affected in some stretches by invasive non-native plant species and

Noted Reference to spawning grounds added in description.

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by the alien American signal crayfish.’ Reference to non-native plant species and signal crayfish added to issues and forces for change.


Add under `Game shooting’ after `ground surfaces’ ànd consequently affect river water quality.’

Noted text added


Add under Ìnvasive species’ Àlien American signal crayfish are endemic in the river Barle though recently subject to control measures.’

Noted text added

009 01 Yes Support The Exmoor Society very much welcomes the Landscape Character Assessment for the following reasons: 1. It is a delightful report to read and look at. It celebrates Exmoor positively, bringing out its awesome and diverse beauty by using photographs, pictures, illustrations and diagrams. It shows how much research has been undertaken in the last ten years in relation, for example, to moorland and woodland landscapes, the archaeology and people’s perceptions of the different landscape types. It demonstrates how this information can be used to protect and promote national park purposes. Nevertheless, it reveals the need for more continuous monitoring of landscape change. 2. The Assessment shows the close relationship between people and place and the critical input of the farming community in maintaining and enhancing the different landscapes. Many of these are fragile, some because of their small scale extent and poor condition and inappropriate management restrictions. Local knowledge, honed over generations of land management, can now be utilised to improve this situation. 3. Importantly, it provides evidence for future agri-environmental schemes and the need for payments to land managers for the provision of public

Noted

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goods. At the same time, it gives guidance for future development proposals. 4. We need to regularly remind ourselves how the landscape continues to inspire a rich and distinctive culture and unique place which attracts a healthy tourist industry, contributing to the local economy and people’s wellbeing.

009 02 Yes Support with changes

The Society feels that there are ways in which the Assessment could be strengthened and made more balanced. This would be achieved: a) By reference to the maps produced by Lord Porchester in 1977. This would be help in setting the background of the Assessment. (i.e. Map 1; A Map of Moor and Heath and Map 2 Moorland Conservation on Exmoor). b) By adding more detail on the physical geography of the Park and how the geology, past and present climates, and soils have all inter-reacted to determine the shape of the landscape and the communities that developed, albeit subsequently changed by Man. c) By updating the geological data. Following revisions by the British Geological Survey some of the rock names and their dates are obsolete. A list of new a list of new names and dates is provided. d) By recognising that not all Landscape Character Types are all of equal importance in determining the character of the Park, for example; Type D: Open Moorland plays greater part than say C: Low Farmed Coast and Marsh. Limited resources it may be inevitably force a need to prioritise what can be done, however undesirable this might be. e) By encouraging landscape enhancement schemes such as woodland planting on less productive areas of farmland.

Noted with regard to geology of the National Park. With regard to the importance of LCTs we do not consider that they should be ranked as part of this study. A number measures are recommended in the assessment and will be considered as landscape actions in the Partnership Plan.

References to Porchester Inquiry and Porchester maps added to 2.5.24. An updated geological map for the National Park will be included (sourced from the British Geological Society) and additional soils map.


This is such an attractive document, and not just relevant to the planning process, that we believe it should be for sale and widely available to the public, both residents and visitors, and in such places as hotels, bed and breakfasts, visitor centres and libraries.

It is intended that the document will be publically available as a supplementary planning document.

Dissemination of the document to a number of potential users will follow its

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adoption and publication.


The Geology of Exmoor map, on page 16, contains one error in that the ‘Baggy and Marshwood Beds’ and should read Baggy and Marwood Beds’. Your Filex5 Internet information is correct. Nevertheless, most of the names used in the map are now out of date as the British Geological Survey is rationalising the names and has declared many of the old names ‘obsolete’. A new map in which all of the names are up-to-date should be used, if possible. The British Geological Survey Lexicon of Named Rock Units gives the following up-to-date names, though some are in the ‘pending upgrade’ category, but are likely to be adopted.

Noted Map to be replaced and names of the geological layers to be checked against British Geological Society definitions.


As techniques have improved the dates have changed. The Devonian Period is now given as 359-419 million years ago (MA). Giving the Period date in the Assessment is not always helpful when not all of the rocks of that Period are found in the National Park, for example the oldest Devonian rocks in the Park are the Lynton Formation (407-392 MA). But we do not have of the very oldest or the very youngest Devonian rocks. The missing oldest the rocks are from the Lochkovian period of the Devonian, specifically the St. Maughans Formation, found near Ross on Wye. The very youngest Devonian rocks are the Portishead Formation found in the Mendips. Nevertheless, most of the Devonian is well represented in the Park. So it might be most accurate to say that the Devonian rocks found in the Park extend from 407-345MA.

Noted Geological terms and dates corrected and updated throughout document (including glossary).


Section 2.3.3 gives the dates 250-145 MA for the Triassic and Jurassic Periods, but examination of the geology maps does not appear to show any Jurassic rocks in the Park. The Triassic rocks in the Park date from 251-200 MA and are given in the table below: Mercia Mudstone Group 251-200 MA; Luccombe Breccia Formation 251-200 MA; Budleigh Salterton

Noted Geological terms and dates corrected and updated throughout document (including

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Pebble Beds Formation 251-246 MA; Otter Sandstone (obsolete name) now called Heysham Harbour Sandstone Formation 246-229 MA.

glossary).


In sections 2.3.8 and 2.4.1 the Assessment refers to geology, landform, soils and climate because these factors play a part in determining the type of vegetation and landscape and this applies particularly to moorland. It is felt that more should be made of the fact that Exmoor’s moorland (Landscape Character Type D) is different from moorlands found elsewhere. This even applies to nearby Dartmoor where the geology is so different. The altitude is generally lower than in other moorland areas and the climate is strongly maritime and although the rainfall is high it is not as high as areas in the North West of England and in Scotland and there evapotranspiration is much lower. It is for this reason that iron pan formation, characteristic of Podsol soils, and which is the main cause of impeded drainage and waterlogging encouraging peat formation is not as well developed as in most other moorland areas. It is to a great extent this acidity which dictates the distribution of moorland and as Mr Knight found, to his cost, that changing the soil pH and the climate is remarkably difficult and expensive. Landscape Character Type D is the one that is most directly linked to geology, soils and climate. It is believed that a rainfall map along with a soils map would show how the distribution of this landscape character type is dictated by high rainfall and acidic soils. A soil map can be obtained using the UKSO Soil Map Viewer and using the Soilscapes Layer (a PDF attached as an example) or at www.landis.org.uk/soilscapes/ produced by Cranfield University.

Noted - text will be amended to incorporate some of suggested text relating to LCT D and its underlying geology and soils.

Extra paragraph written on soils and the circumstances which make Exmoor unique. 2.3.8 - 2.3.10. Soils data taken from online soilscapes map as suggested.


In sections 2.3.8 and 2.4.1 the Assessment refers to geology, landform, soils and climate because these factors play a part in determining the type of vegetation and landscape and this applies particularly to moorland.

Noted - text will be amended to incorporate some of suggested text relating to LCT D and its

Extra paragraph written on soils and the

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It is felt that more should be made of the fact that Exmoor’s moorland (Landscape Character Type D) is different from moorlands found elsewhere. This even applies to nearby Dartmoor where the geology is so different. The altitude is generally lower than in other moorland areas and the climate is strongly maritime and although the rainfall is high it is not as high as areas in the North West of England and in Scotland and there evapotranspiration is much lower. It is for this reason that iron pan formation, characteristic of Podsol soils, and which is the main cause of impeded drainage and waterlogging encouraging peat formation is not as well developed as in most other moorland areas. It is to a great extent this acidity which dictates the distribution of moorland and as Mr Knight found, to his cost, that changing the soil pH and the climate is remarkably difficult and expensive. Landscape Character Type D is the one that is most directly linked to geology, soils and climate. It is believed that a rainfall map along with a soils map would show how the distribution of this landscape character type is dictated by high rainfall and acidic soils. A soil map can be obtained using the UKSO Soil Map Viewer and using the Soilscapes Layer (a PDF attached as an example) or at www.landis.org.uk/soilscapes/ produced by Cranfield University.

underlying geology and soils.

circumstances which make Exmoor unique. 2.3.8 - 2.3.10. Soils data taken from online soilscapes map as suggested.


Map 3 Landscape and Nature Conservation Designations. The Key on the map refers to Regionally Important Geological Sites and Local Geological Sites, but none of these appear on the map. It might be too confusing to include them but then the references in the key should be deleted.

Addressed Map corrected. Now all shown as Local Geological Sites, with a triangle symbol.


Nash Point Lighthouse (near Bridgend) sweeping across the sea is a night-time feature’, perfectly true, but is not the ‘near Bridgend’ slightly misleading as Bridgend is 8 miles inland, would not near St Donat’s which is on the

Noted Text amended

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coast less than a kilometre away be a more useful locator?


We welcome the development of the Exmoor Landscape Character Assessment, as a valuable tool to help achieve sustainable development that is sensitive to the landscape character of Exmoor National Park. We would like to make the following general and detailed comments: General comments: The consultation states that the Landscape Character Assessment is a Supplementary Planning Document. Supplementary Planning Documents should build upon and provide more detailed advice or guidance on the policies in the Local Plan, and should specify which Local Plan policies they relate to. We assert that only Chapter 3, which sets out planning guidelines, plus the guidelines in Part 4, are the Supplementary Planning Document. The assessment of the landscape character, including the identification and description of landscape character types and landscape character areas is evidence and should be included as an annex. The Supplementary Planning Document should also set out the Local Plan policies to which it relates. The guidelines on the integration of development into the Exmoor landscape are very general and, apart from three references to landscape character types, could apply in most places. The planning guidelines for the different landscape character types (LCT) are a little more specific but are more difficult to find and may be overlooked by prospective applicants. A map on which prospective developers can search in which LCT their site is located, appears to be missing. We recommend that you bring together the general and LCT specific planning guidelines, which, together with a large scale searchable map, would form the SPD. This would mean that the SPD is short and user friendly to its target audience. All other information could form the associated landscape character assessment. The

The aim of the Landscape Character Assessment Supplementary Planning Document (SPD) is to ensure new development makes a positive contribution to the landscape, including its key characteristics and features in which it is located. It is considered that by providing the planning guidelines within the assessment of landscape character will ensure that the information to inform future development proposals is located in one document, providing the appropriate context of landscape character types and areas together with the relevant planning guidelines. To separate the LCA from the planning guidelines may result in a disparate and fragmented piece of guidance that would not achieve the desired objectives of conserving and enhancing landscape character across the National Park.

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Landscape Character Assessment is very thorough in describing the landscape, but is less specific about what development should look like to fit into the different Landscape Character Types and Areas. We would welcome the planning guidelines to be more positive and be more explicit about what development should seek to achieve in each area. Based on an assessment of landscape sensitivity to development (perhaps for varying cluster sizes etc.) the guidance on suitable design for particular landscape character areas could be clearer about the scale, massing, height, materials, orientation etc. that developers should aim for in their Landscape Character Area


This paragraph should mention the continuing losses of (especially small) hay meadows and species-rich pastures from agricultural intensification, ‘horsiculture’ and an increasing dominance of scrub. Mention could also be made here of the threat from invasive species in the landscape, for example from Montbretia in Barle, and from Rhododendron on heathland and at the coast.

Noted Reference to hay meadows added. Scrub and invasive species are already in the text.


‘which thrive in the clean sea air’ should say just clean air as inland sites often have better air quality than coastal sites, possibly because of historic pollution from the Welsh coast…

Noted Text amended

010 04 2.5.10

2 General comment

‘…stone-faced banks topped with beech trees, which marked the common boundaries.’ In its context this sentence implies that the beech trees are medieval which they are almost certainly not.

Noted Reference to beech trees removed

010 05 2.5.24

2 General comment

This paragraph could usefully mention that the ploughing of moorlands led in part to the Porchester Report and thus to the Wildlife and Countryside Act 1981, the foundation for much of current wildlife protection.

Amended Added to text

010 06 2.7 2 General comment

In the Landscape and Coastal Designations section (2.7 et seq) there is no mention of the NERC Act 2006 s.40 duty on public bodies and s.41 species and habitats of principal importance for biodiversity. This should be

The LCA focuses on species and habitats which contribute to landscape character. Text will be

Extra sentence added at and of para 2.7.1 stating Section

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addressed. The table of designations p.35 includes veteran trees. If these are listed then inclusion of section 41 habitats and species should also be considered.

amended to make reference to sections 40 and 41 of the NERC Act 2006.

40 of the Natural Environment and Rural Communities (NERC) Act 2006 requires all public organisations to have regard to conserving biodiversity. Section 41 lists habitats and species of principal importance for biodiversity.


p.34 table: There are three National Nature Reserves instead of two as stated in the text. Their total area is 1736 ha.

Noted Text amended


Table Forces for Change on the Exmoor Landscape: In the Changing Farming and Land Management section (page 45), the changes listed are generally negative. There are however many landscape changes that are positive, resulting from agri-environment schemes or other initiatives/actions. Examples include: better controlled grazing, introduction of cattle to moorland with abundant purple moor-grass; preventing ditches from eroding soil and scarring the landscape through restoration (via the Mires Restoration project), hedge management (before recent declines in funding); invasive species control. Purple moor-grass is referenced under ‘Changing Faming and Land Management’, but above in ‘Natural Processes and Climate Change’ it is referred to as ‘molinia’. This is confusing and should be amended. Under Shooting,

Noted Text amended and clarified to include 'Positive agricultural management initiatives' added to list of positive changes in 1.9.2 (formerly 1.8.2). New paragraph 2.9.5 added above 'before and after'

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mention should be made of tracks. images, stating: Not all changes currently happening in the Exmoor landscape are negative. Across the National Park, there are examples of positive change, many as a result of land management grants or other initiatives and actions. Examples include better controlled grazing; introduction of cattle to moorland with abundant purple moor grass; reduction of soil erosion; hedge management (before recent declines in funding) and control of

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invasive species. Exmoor National Park Authority has also instigated a number of projects, such as the enhancement of Porlock Marsh and the Valley of Rocks, which have had positive impacts on the landscape. First bullet under changing farming and land management- last sentence amended to read Future upland land management is likely to be significantly affected by changes to agricultural grant schemes. Reference to molinia under nat. processes and climate

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change amended to purple moor grass. Tracks added under shooting.


High Wooded Coast, Combes and Cleaves, Landscape Character Type B: p. 84, second para: ‘The streams within the valleys are mostly included within designated Sites of Special Scientific Interest’. It would be useful to add text in bold to clarify that not all streams are included. p. 84, third para: Please amend the text to ‘…contain endemic Devon whitebeams…’ as there are multiple endemic whitebeams (of which Devon Whitebeam is the least rare). The same applies also to text on p 91.

Noted Text amended


High Wooded Coast, Combes and Cleaves, Landscape Character Type B: p. 85, table should read ‘West Exmoor Coast and Woods (B1, B2)’.

Noted Text amended


High Wooded Coast, Combes and Cleaves, Landscape Character Type B: Please amend the text to ‘…contain endemic Devon whitebeams…’ as there are multiple endemic whitebeams (of which Devon Whitebeam is the least rare).

Noted Text amended

010 12 137 Object Open Moorland Landscape Character Type D: Planning guidelines – It is surprising to see the following guidelines: There should be a presumption against development within this LCT. Resist pressure for development of buildings, wind turbines, telecommunication masts and overhead wires which will impact on skylines. These appear to be planning policy and should be set out in the Local Plan, not in a Supplementary Planning Document. We advise that you revise these guidelines.

Policies within the Local Plan ensure that landscape and seascape character will be conserved and enhanced. Furthermore, the policy HC-S3 Biodiversity and Green Infrastructure ensures that sites designated for their international and national importance will be protected from

Wording amended for 'Specific Planning Guideline' table.

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development likely to have direct or indirect adverse effects.


Open Moorland Landscape Character Type D: p. 120 the statement that ‘Trees are limited to occasional lines of wind-sculpted beech trees along banks, or copses of non-native conifers planted in the 20th Century for timber, or as shelter belts’ probably understates the nature of some of the combes where stands of old hawthorns (Farley Water) or more mixed natives (Dunkery) occur in ribbons, or clothe the slopes (Badgworthy Water), or occasional clumps of willow and one larger area of alder (Butter Hill Plantation). We recommend that you reword this statement.

Noted - text amended to reflect this.

Sentence amended to read 'Tree cover is relatively sparse. It includes occasional lines of distinctive wind-sculpted beech trees along banks, as well as stands of old hawthorn such as at Farley Water. Other more mixed native species occur in ribbons such as at Dunkery or clothing the slopes as at Badgworthy Water. There are occasional clumps of willow and alder alongside streams and in the combes. There are also occasional

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copses and shelter-belts of non-native conifers planted in the twentieth century'.

010 14 151 Object Farmed and settled Vale – Landscape Character Type E: The planning guideline ‘Avoid land uses (e.g. horse jumps/paddocks and play areas) which create visual clutter and disrupt historic connections between settlement and setting’ reads like planning policy which should be set out in the Local Plan, not in an SPD. We advise that you revise this guideline.

Noted and amended. Examples removed and text revised.

011 01 Yes Support Winsford Parish Councillors welcomed the opportunity to study LCA SPD. It was well presented and very comprehensive and the authors are to be congratulated. It is very much appreciated that Exmoor National Park faces great challenges in carrying out the responsibilities laid upon it and these will no doubt be made more difficult in the years ahead with changes in funding, particularly following departure from the EU.

Support welcomed.


The areas of specific interest to Winsford Parish include D3 Winsford Hill and G4 Exe valley. Listed below are specific issues over which the Parish Council are already has concerns: * Air and ground pollution from increased visitor numbers, destruction of unique ecosystems. *Off road driving, camper vans, and shoot vehicles. *Pressure on SSSI's, and ancient historic sites. *Scrub encroachment and lack of swaling.* Deforestation due to the pressure to produce alternative fuel systems. * Loss of traditional farming methods and opportunities to produce food. *Loss of family farms to shoots, changing views including cover crop, pens, noise, lead pollution. * Absent owners leaving homes empty and in some cases unfinished. *Poor woodland and river

Issues highlighted will continue to further address through the ongoing work of the Authority and partners (including regulatory action where necessary) and through the delivery of the Partnership Plan.

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management. * Flooding caused by LWD, bridges blockages, fencing river banks in floodplains, change of water run off caused by new tracks. We are encouraged that all these subjects are included within the report, in one way or another. As a Parish Council we look forward, with interest, to see how things develop and will do all that we can to help and support.

012 01 Yes Support This is an impressive and substantial piece of work that is well-organised and easy to read.

Noted


On Exmoor, as ENPA planners are well aware, the specificity of our topography and development patterns generate a particular set of risks related to flooding. Three major contributing factors to this risk are rapid-response catchments with risk to life, settlements along river valleys, and land management practices across all catchments that can impact on the safety of settlements, not to mention the effects they have on fragile ecosystems and biodiversity. The NPPF is ill-suited to deal with this sort of situation which involves whole catchments. While locations in flood zones 2 and 3 for rivers and sea are relatively well protected, the issues of surface water and run-off only require consultation and advice from the Lead Local Flood Authority if over 10 properties or a significant surface area are involved. West Somerset Flood Group has been working with its partners on the West Somerset Flood Board (including ENPA) to address these issues. One way of reinforcing the message to developers and land-managers about flood risk management is to ensure that supplementary planning documents are consistent in referring to risks from all sources and catchment management. The Level 1 SFRA for Exmoor is, of course, the most significant document in this respect but, as a relatively high-level document it does not have sufficient granularity to help individuals to assess flood risk except in a restricted set of locations and conditions. There is no Level 2 SFRA for Exmoor. As

Noted. A Level 1 SFRA has been undertaken to inform policies within the Local Plan and the determination of planning applications. A Level 2 SFRA is usually carried out where sites are allocated for housing and employment use. The Exmoor National Park Local Plan does not contain any site allocations. There is a policy regarding flood risk. Flooding is also identified within the LCA as Forces for Change.

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a consequence, the Landscape Character Assessment has the capacity to be a significant supplementary tool to reinforce the message.


The following comments from West Somerset Flood Group do not suggest any major changes to the document. Their aim is to ensure consistency in the way the document deals with the challenges of flooding to the landscape across all LCTs and to suggest a few minor additions and modifications to the text. The particular focus of the comments concerns the way that flooding is presented across the different Landscape sensitivities tables and land management sections. While the general presentations of flood risk and climate change in the early parts of the document are important, we believe that the contents of each detailed LCT assessment will play a critical role in users’ approaches to land management and development sites. In the Flood Group’s comments, the main concern has therefore been to ensure that sensitivities and management issues related to flood risk are absolutely consistent across relevant LCTs. One LCT that in fact shares a number of the characteristics with other types where flooding is concerned is Local Character Type I and we suggest some minor modifications to bring this into line with them and give proper weight to the role of flooding in landscape management here. This is of particular interest as a number of the settlements in this LCT are likely to see development and much of this is likely to be on steep slopes where surface-water flow paths may be an issue. We also suggest a few small but important additions relating to land management, farming and forestry practices. The most common of these relate to the use of plastic sheeting over crops and the impacts of forest and woodland tracks.

Noted - further detailed comments by the West Somerset Flood Group are addressed below.


Changing Woodland and Forestry Management: Forestry tracks please add ‘flooding’ to list of what is increased.

Noted Text added regarding flooding

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Changing Farming and Land Management: Plastic sheeting please add ‘and cause run-off leading to flooding’.

Further advice sought and text has been amended to address this comment.

Text amended to 'plastic sheeting…. has potential to lead to increased surface water run-off'.


A HIGH COASTAL HEATHS management guidelines - Protect: Please add ‘Protect peat soils to encourage sequestration of carbon and flood regulation.’

Noted - text to be amended to address this comment.

Additional bullet added. Also ‘and may be detrimental to peat soils' added to second sentence of first issue in landscape sensitivities table.


B HIGH WOODED COAST, COMBES AND CLEAVES - landscape sensitivities and potential impacts: Please include Flooding on this list, whether under Climate Change or a separate heading (varies in other sections). Reasons: a. Threat of flooding from rivers (i.e. Horner, Hawkcombe Stream) is specifically mentioned in next LCT as a risk (112). But in fact, activities in LCT B have a very strong influence on risk further downstream. b. Holnicote project, described under LCT E, is x-referenced to Open Moorland but should also be x-referenced to this LCT. NB Lynmouth flood is illustrated under cultural associations, p. 89, and protection from flood risk is listed under ecosystem services.

Noted Issue now reads 'Climate change, flooding and sea level rise'


C LOW FARMED COAST AND MARSH: Can this description of Climate Change, with specific reference to rivers, also be linked to LCT B and E? Or used in those sections as well in modified form?

Noted Text amended in 'Forces for Change' in LCT B and LCT E to

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address the comment raised.


D. OPEN MOORLAND - Landscape sensitivities: Re-wetting of the mires, mentions flood damage reduction. This function might be added to other moorland settings in other LCTs.

Noted LCT H- extra sentence added to Landscape Sensitivities Table under Climate change, to read 'Land management within this LCT may affect the flood risk in surrounding LCTs.'


E. FARMED AND SETTLED VALE: Holnicote project. The Horner Catchment lies in LCT B as well. Please could you cross reference (see above 012/07)? 140 last para. ‘planting woodland alongside streams to slow water flows’. Not just planting, woody debris dams also a significant feature. Change ‘planting’ to ‘managing’, which would cover both? NB much of the description of the Holnicote project also applies to other locations where NFM is being introduced. Is there a way that these can also benefit from this longer description through cross references? In particular, Washford upper catchment multi-benefits project (begun 2015), and Monksilver and Doniford Streams NFM project (funding from central govt, working out financial case and talking to partners – Wildlife and Wetlands trust for e.g.). Work scheduled for 2018-2020. Both of these in LCT I.

Noted Paragraph rephrased. References to Washford and Monksilver projects added to LCT I (Landscape Condition section).


Under Landscape sensitivities there is a good description of Flooding which could be exported to

Noted Flooding description in

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other LCTs. Landscape Sensitivities section expanded in LCT G to match LCT E.


F. ENCLOSED FARMED HILLS WITH COMMONS - Landscape sensitivities: Changing agricultural cropping practices. Please mention that these practices, especially plastic sheeting, are a significant source of run-off potentially leading flooding (as well as erosion etc.)

Noted Text amended to include ‘plastic sheeting can potentially contribute to increased surface water run off'.


Good description of ecosystem services re flooding doesn’t translate into Landscape sensitivities under the Climate Change heading. Please include mention that greater attention to Natural Flood Management may affect this LCT in a minor way but will provide important services downstream, see Re-wetting of the mires under LCT D Landscape sensitivities (134). Cross-reference to LCTs G and I – any NFM projects in G and I will include F as well.

Noted and amended LCT F- extra sentence added to Issues table (climate change) to read 'Natural Flood Management projects may have minor effects on this LCT, but will provide important benefits downstream, and in other LCTs.'


Typo - remove brackets around ‘flooding’ para 1. Noted Text amended


G INCISED WOODED VALLEYS: Description - ‘take their names from the river’, actually from more than one, so

Noted Text clarified

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add ‘and its tributaries’, or similar?012 16 189 4 General

commentLandscape sensitivities: Changes in woodland management. – Could erosion of tracks be linked to flooding please?

Noted and amended Additional sentence added- erosion of tracks is also linked to increased run-off and flooding.


H PLANTATION (WITH HEATHLAND): Landscape sensitivities - Forestry management. Please mention link between forestry tracks, erosion and flooding.

Noted and amended Additional sentence added - erosion of tracks is also linked to increased run-off and flooding.


Climate Change. Please link clear-felling and erosion to flooding.

Noted and amended Text added - ''land management including clear felling within this LCT has the potential to affect the flood risk in surrounding LCT's'.


I WOODED AND FARMED HILLS WITH COMBES: Summary Description - Please mention fast-flowing streams and rivers. These behave in exactly the same way as Horner Water, Hawkcombe Stream and Aller River, noted in LCT E, affecting the settlements along their length. NB because a number of these settlements will see development, this is important.

Noted and amended Reference to fast-flowing streams and the location of settlements alongside streams added to summary description,

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key characteristics natural landscape features and cultural landscape features.


Key Characteristics: Again, please include fast-flowing rivers and streams under ‘low-lying, narrow valley floors’.

Noted and revised Additional point added to 'Key Characteristics' table - 'numerous fast flowing streams and rivers, often fed by springs'.


Please mention in para 2 that all tributaries and streams are fast flowing and flashy. Witness nationally-funded NFM projects on Washford, Monksilver and Doniford (see comments above re Holnicote in LCT E).

Noted and revised Additional text added: feed a network of 'fast flowing and flashy rivers and streams'.


Natural Assets and Ecosystem services: Please mention Washford Upper-Catchment Multi-Benefits project – both biodiversity, improvement of ecological condition of river and flood reduction (2015-2020) (Environment Agency and FWAG). Also, planned, Williton flood protection project in the Monksilver and Doniford catchments (Environment Agency, with partners, to be agreed).

Noted and added Additional text added at end of Landscape Condition section on Washford Upper Catchment project and Williton Flood Protection project.

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Landscape sensitivities: Forest Tracks. As in other LCTs, please including flooding as a result of track erosion. Changing Farming practices. Please include plastic sheeting (as in other LCTs) with both visual and flooding impacts.

Noted and amended Forest tracks added. Increased risk of surface water run off added.


Manor Mills is in Roadwater, right in the middle, at least if you are going to describe it in its current form as a single linear settlement (cf 216). Or you could say ‘north of the main historic nucleus of Roadwater’.

Noted Text amended


NB – is the description of the current state of the WSMR incline at the end of para 1 quite correct? CF work of WSMRA and check with Rob Wilson North?

Noted - text updated Comment omitted - the footpath at the top end has been fixed since the fieldwork was undertaken for the LCA.


The photograph of trees growing on the WSML are at the northern end of the incline. My understanding is that they are there to provide a protected habitat for dormice and not a sign of neglect (cf p. 221). See also under Protect.

Noted - confirmation that the trees at the bottom are managed for dormice habitat.

Photo removed


Defining quality: Roadwater is not more linear because of industrial influences although its existence is, of course, largely due to the mills along this part of the river. There used to be a series of separate nucleated groups of buildings (many of which were mills) along the river. It is really the subsequent residential infill that has produced its linear character, much of which postdates the closing of the WSML.

Noted and amended Text amended to 'Roadwater developed as a series of mills along the Washford River, which have subsequently been infilled by residential development, giving it a more

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linear feel. 014 01 Yes Support The Woodland Trust welcomes the references to the

protection and restoration of ancient woodland on Exmoor and to the effective management of woodland, trees and hedges. We would welcome stronger commitments to tree planting, both for new woodland and trees in hedges & open countryside, where this strengthens landscape character.

The LCA focuses on defining the key features of Exmoor landscapes. Actions around tree planting would be addressed by the Partnership Plan delivery programme in conjunction with the LCA.


Protection and effective management: Ancient woods are irreplaceable. They are our richest terrestrial wildlife habitats, with complex ecological communities that have developed over centuries, and contain a high proportion of rare and threatened species, many of which are dependent on the particular conditions that this habitat affords. For this reason, ancient woods are reservoirs of biodiversity, but because the resource is limited and highly fragmented, they and their associated wildlife are particularly vulnerable. Their long continuity and lack of disturbance means ancient woods are often also living history books, preserving archaeological features and evidence of past land use, from earthworks to charcoal pits. They are also places of great aesthetic appeal, making them attractive for recreation and the many benefits this can bring in terms of health and well-being. With only 2.4% of the land area in Great Britain covered by ancient woodland, it is essential that no more of this finite resource is lost through development pressure or mismanagement. This means that ancient woodland must be protected absolutely from permanent clearance, but also that it must be protected from damaging effects of adjacent and nearby land-use that could threaten the integrity of the habitat and survival of its special characteristics.

The Exmoor National Park Local Plan policy HC-S3 Biodiversity and Green Infrastructure recognises the importance of ancient woodlands as an irreplaceable habitat and aims to protect the loss of deterioration of ancient woodland (including ancient semi-natural woodland and plantations on ancient woodland sites) from development.

Continued recognition


Woodland Creation: The Woodland Trust believes that trees and woods can deliver a wide range of benefits,

The LCA landscape management

As noted

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and this is strongly supported by current national planning policy. Woodland creation is especially important because of the unique ability of woodland to deliver across a wide range of benefits: - these include for both landscape and biodiversity (helping habitats become more robust to adapt to climate change, buffering and extending fragmented ancient woodland), for quality of life and climate change (amenity & recreation, public health, flood amelioration, urban cooling) and for the local economy (timber and woodfuel markets). Trees & woods can play a significant role in sustaining the landscape scale connectivity that underpins ecological resilience and helps combat climate change effects. Protection of irreplaceable ancient and semi-natural woodland, restoration of degraded ancient woodland together, plus the addition of new and diverse woodland creation to buffer and extend our depleted and fragmented habitats can all significantly help resilience and help combat climate change effects. All of these issues have particular salience in the context of Exmoor’s diverse landscape character. Some ancient and veteran trees are reaching maturity and it is essential that a long term view is taken to plant, restore and manage the ‘ancients of the future’. The length at which ancient woodland takes to develop and evolve (centuries, even millennia), coupled with the vital links it creates between plants, animals and soils accentuate its irreplaceable status. The varied and unique habitats ancient woodland sites provide for many of the UK's most important and threatened fauna and flora species cannot be re-created and cannot afford to be lost. Approximately one quarter of priority UK Biodiversity Action Plan species are associated with woodland habitats. Forests, woods, and trees make a significant contribution to biodiversity, and ancient sites are recognised as being of particular value. Due to their longevity, ancient

recommendations in Part 4 for LCT's G, H and I identify the need to manage and plan for future woodland cover. Further new planting initiatives and opportunities will be addressed in the Partnership Plan delivery programme.

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woodlands are more species rich, and are often refuges for specialist woodland species that struggle to colonise new areas. Strong protection and good management of ancient trees is essential, as is the development of a succession of future ancient trees through new tree planting and new wood pasture creation, and to raise awareness and understanding of the value and importance of ancient trees.


Restoration: Conifer crops lead to low light levels which threaten the survival of native plants, fungi and animals that have established over hundreds of years. The Woodland Trust aims to promote restoration work with the aim of gradually letting the light back in to encourage plants to recover and reverse years of decline. We believe this work is essential on Exmoor to restore the biodiversity of ancient woodland. Our approach to the restoration of ancient woodland involves the gradual and selective thinning of the existing canopy over several years, to slowly allow light levels to increase without shocking the existing remnant features, or providing enough light for brambles to get a foothold. As light levels increase, broadleaved trees begin to germinate from the existing seed bank, grow new leaves and branches and gradually fill in the gaps left by the removal of the conifers, providing a continuous filter for the light that reaches the forest floor, while the canopy very slowly changes from being dominated by confers to being dominated by native broadleaved trees.

The LCA report recognises this approach to the restoration and management of woodland. This continuous cover approach is taken to manage ENPA's own woodland estate, and is also actively promoted to landowners across the national park via the Woodlinks Project initiative.

As noted


I note that a Landscape Sensitivity Study has also been undertaken for settlements within the National Park based on landform, vegetation, scale, historic character, materials, design styles, surrounding enclosure patterns, shape and form of the settlement, as well as landscape quality and condition. In addition I have also read the published summary of the State of the Park Report. My comments relate to all three

Noted. The Landscape Sensitivity Study was undertaken as evidence to inform policies within the Local Plan and has also been used to inform the LCA. The LCA as a supplementary planning

Future working in relation to forward and strategic planning continue to link these documents

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documents which it seems to me should be considered together? At present I’d suggest there is too big a distance between thinking and policy making about Exmoor’s settlements and that about Exmoor’s “landscape types”. The relationships between the two probably merit further study if the special qualities of Exmoor are to be successfully preserved?

document provides additional guidance to support policies in the Local Plan, particularly those regarding landscape character. The Local Plan and Partnership Plan also share a joint vision and objectives which aim to fulfil the National Park statutory purposes and conserve and enhance the special qualities of the National Park.

together with the Partnership Plan delivery programme.


My comments have been influenced by the ideas on Natural Capital put forward by Professor Dieter Helm. I am conscious that all this material will have a bearing on the forthcoming new Partnership Plan for Exmoor….and I hope that some of these issues might be explored further in that consultative process?

A project to produce Natural Capital accounts for Exmoor and Dartmoor National Parks is just commencing, led by Exeter University as part of the South West Economy and Environment Programme. The Exmoor Society has also commissioned some work to explore how to develop Natural Capital Assets Registers for Exmoor.

This will continue to be explored by ENPA and its partnering organisations.


Preserving Exmoor’s Renewable Resources: Tranquillity, remoteness and relative wildness remain among Exmoor’s most special qualities, and they are assets we ought to be worrying about. In terms of Dieter Helm’s book “Natural Capital” they are, I think, renewable resources? As Professor Helm says “renewables are fabulously valuable yet are valued at close to zero” Page 242). Each however is getting close to falling beneath their respective thresholds? Once

A project to produce Natural Capital accounts for Exmoor and Dartmoor National Parks is just commencing, led by Exeter University as part of the South West Economy and Environment Programme.

Natural Capital linked with the Special Qualities will continue to be explored by ENPA and partnering organisations.

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they are gone, they are gone forever. We ought to be acting as custodians to try to withstand the various pressures which threaten them.


While the Landscape Assessment is a valuable piece of work in many ways - and I found the description of the various landscape types illuminating - I didn’t come away with a clear view of the big picture? A previous English Nature National Character Area profile of Exmoor for example described how: “Much of the area [of Exmoor] remains undeveloped, unclutteredand free from recent development. Some detraction from the overwhelming sense of tranquillity has arisen due to developments such as the A361 North Devon link road, urban expansion of Barnstaple and localised coastal leisure facilities.”

Noted - reference has now been included to the National Character Area as assessed by Natural England. The entirety of Exmoor National Park is contained within the wider profile 146: Exmoor. The Landscape Character Assessment (LCA) for Exmoor National Park will sit beneath this in hierarchy, with the more detailed Landscape Character Types and Areas contained within the report providing a further level of specific and area based information across the National Park.

The key characteristics of the NE National Character Area: Exmoor are now included in the LCA report (see section 1.8) which should help to provide the overarching structure of the Landscape Character Assessment approach on a national and regional basis.


If I can offer a brief pen portrait it would run somewhat as follows. Exmoor has been fairly lucky so far but the pressures are growing. There are pressures on every side of Exmoor. The modern world is constantly lapping around the edges of Dunster. There is increasing traffic (particularly white vans) coming off the Devon link road through North Molton and Withypool causing problems to residents - and casualties to Exmoor ponies and other livestock. “On line” orders made to Amazon or to the supermarkets arebringing a lot more commercial vehicles on to the Moor. A significant number of visitors complain of being tailgated by speeding traffic. Larger lorries,

This comment is not directly applicable to the LCA. However, the LCA will be amended to reference large recreational events within the Forces for Change section. The Special Qualities of the National Park will continue to be recognised, protected and enhanced through the Partnership Plan and its delivery

Large recreational events added to Forces for Change section (Tourism and recreation-led change)

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coaches and caravans finding their way on to the Moor can cause various difficulties. Tourism, and particularly large outdoor recreational events, is having an impact. There has also been a marked increase in helicopters (with a landing site near Dulverton) and in light aircraft pleasure trips over the National Park. I understand that the National Park Authority has no jurisdiction for the airspace over Exmoor and its use....perhaps itshould? Walkers on Exmoor now frequently seek tranquillity not on the Moorland commons - where a fairly constant sound of traffic is now audible for much of the day for example on Winsford Hill - but rather on footpaths and bridleways across private land (although even here there is increasingly intrusive noise from helicopters and light aircraft).

programme.


In terms of capital infrastructure, increasing traffic has brought pressure to an area that has developed a transport network slowly over centuries to serve the local needs of its villages and hamlets. Many of Exmoor's roads are historic and attractive features in their own right....although there are voices wishing to “modernise” them. Villages have seen a gradual erosion of distinctiveness as highway measures are installed in response to such pressures. Traffic and parking problems in Exmoor's villages continue to be among the issues of greatest concern to local communities.

The Exmoor National Park Local Plan includes policies to promote the use of sustainable modes of transport and ensure that development proposals have regard to the hierarchy of roads shown on the Exmoor Route Network. Policy AC-S2 Transport Infrastructure seeks to ensure that the rural character of roads are maintained and where possible enhanced. Policy AC-S3 Traffic Management and Parking seeks to ensure appropriate measures are in place to provide appropriate small-scale parking provision and identify local solutions

Already mentioned in Forces for Change section of the LCA

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where possible in keeping with landscape character.


Exmoor’s bridges experience large volumes of modern heavy traffic and visitor pressure. Not surprisingly, many of these features are showing signs of physical deterioration as they are carrying volumes and weights of vehicles far greater than originally intended. Exmoor also enjoys an exceptional rights of way network, with historic routes that are often rugged and narrow in character, along with extensive areas of open country and permitted access, providing opportunities for walking, riding and cycling. Bycontinually improving these beyond a certain point - and seeking to widen the use of - footpaths we risk threatening both Exmoor’s historical legacy and Natural Capital qualities such as tranquillity? Upgrading footpaths to bridleways can have an undesirable impact on the amenities of local residents, and other visitors here to enjoy the quiet enjoyment of the National Park.

Exmoor National Park Local Plan Policy AC-S2 Transport Infrastructure seeks to ensure that works to traditional bridges reflect local character - it is recognised that many of these bridges are designated heritage assets and should be conserved. The rugged nature of some rights of way and tranquillity are both recognised as art of the Special Qualities of the National Park which are reinforced through the Exmoor National Park Local Plan, Partnership Plan and in the LCA. The distinct characteristics of historic greenways and paths are identified in the LCA.

Recognising and valuing the special landscape character of routes and paths needs to be considered in the delivery actions of the Partnership Plan.


Over Exploiting the Resource? In chapter nine of “Natural Capital” - “Protecting the Commons” - Professor Helm outlines the theory of the Tragedy of the Commons which predicts that in the case of National Parks - which are held in common and open to all - the values that visitors seekwill be steadily eroded, and overuse will lead inevitably to exhaustion or destruction. Such thinking has been adopted by the US National Parks Service: https://prezi.com/fe3bhm8fw9e8/tragedy-of-the-commons-nationalparks/.

The concept of Natural Capital and ecosystem services is included in the LCA. A project to produce Natural capital accounts for Exmoor and Dartmoor National Parks is just commencing, led by Exeter University as part of the South West Economy and Environment Programme.

Ongoing work by ENPA and partnering organisations will consider this further, outside of the LCA.

015 09 Yes General National Parks have an obvious appeal not only for Noted

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comment visitors but also for commercial businesses and charitable activities.


Who should be able to use the special qualities of the National Park to generate income? There seem clear distinctions, for example, between say (a) a farmer on Exmoor contributing to the National Park’s special qualities, and offering B and B as a side-line (b) a shop in one of the towns, whether locally owned or owned by outside interests, (c) a salaried fundraiser organising nationally advertised events (d) a multinational commercial enterprise?

Not applicable to the LCA


Perhaps we should encourage only commercial activities which respect the special nature of Exmoor's landscape and wildlife, and resist those which do not need to take place within the National Park? e.g. promote tourists who are interested more in the wildlife and cultural heritage of Exmoor rather than seeing it is a playground for outdoor activities? The former will probably also produce a higher level of income for local businesses with a smaller footprint in terms of numbers of people?

The Exmoor National Park Partnership Plan and Local Plan both support development and business activity that is compatible with Exmoor's special qualities. Exmoor National Park Local Plan economy and employment policies including SE-S1 A Sustainable Exmoor Economy ensures that business development should demonstrate that they will not have an adverse impact on landscape character, sensitive habitats and wildlife. Furthermore, policy RT-S1 Recreation and Tourism ensures that such development should enhance the understanding and enjoyment of Exmoor's special qualities and are

Ongoing consideration by ENPA.

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compatible with the quiet enjoyment of the National Park.


There is an understandable wish on the part of businesses to increase visitor numbers and to extend their business activity around the year. The biggest problem is perhaps that of scale? What is tolerable for residents on a small scale can be intolerable on a big scale. The 'polluters pays' principle holds that those who produce pollution of one sort or another should bear the costs of managing it? Can the principle help in the case of allocating the costs of tourism and large events? If a commercial enterprise (e.g. a caravan site) imposes costs on residents and settlements should they be charged, or held responsible for dealing with any problems they have created?

Exmoor National Park Local Plan economy and employment policies including SE-S1 A Sustainable Exmoor Economy ensures that business development should demonstrate that they will not have an adverse impact on local amenity, landscape character, sensitive habitats and wildlife. The Authority runs the CareMoor for Exmoor scheme that is designed to encourage local businesses and event organisers to donate to the scheme, which is then used to fund conservation and access projects.



It is tempting to try to make use of the special qualities of Exmoor to attract participants to events. Commercial interests (including bicycle manufacturers) are offering large scale recreational events and facilities. Many worthy charities are also taking on salaried fundraisers who are seeking to put such events together and are looking for venues. Scale again is usually one of the characteristics which distinguish these events from more traditional Exmoor events. With national advertising, and participants coming from further afield, car movements, parking and other facilities become

National legislation, (the General Permitted Development Order) sets out the circumstances where planning permission is automatically given in certain cases through "permitted development rights" which means that an application for planning permission is not needed.

Co-operative organisation of large events is being reviewed by the delivery programme of the Partnership Plan.

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significant issues. Existing facilities are rarely sufficient and events can seldom be managed within existing structures and resources. Mountain bike events are encouraging landowners to make available additional, temporary camping facilities under the 28 day loophole. If a campsite or caravan park has been operating without planning consent, it may be possible to apply to the National Park Authority for a Lawful DevelopmentCertificate (LDC) as an alternative to seeking planning permission? Again such developments are usually justified on the grounds that they “help the local economy” - but with no countervailing balance sheet adjustment for the fact that Exmoor’s traditional tranquility, beauty and wildness might be diminished?

Outdoor recreational events are recognised as an important way for many people to enjoy the special qualities of the National Park and can also bring valuable income for local business and charities.


Many larger events involve a national or international body. British Cycling is a company formed to encourage, promote, develop and control the sport and pastime of cycling in Great Britain. The World Triathlon Corporation (WTC) which organised the Ironman events is a for-profit corporation, owned by Dalian Wanda Group, headquartered in Beijing. Many worthy charities are also taking on salaried fundraisers who are seeking to put suchevents together and are looking for venues. The Calvert Trust is a charity located on Exmoor but also in the Lake District and Kielder. Most Members of the Lynton & Barnstaple Railway Trust “are not based in Devon and not just from the UK, but also the rest of the World”.

Outdoor recreational events are recognised as an important way for many people to enjoy the special qualities of the National Park and can also bring valuable income for local business and charities.

Co-operative organisation of large events is being reviewed by the delivery programme of the Partnership Plan.


Implications of a Natural Capital Regime: An asset based approach as advocated by Professor Helm seems to offer many advantages. Many questionable initiatives are currently justified on the grounds that they “help the local economy” - but with no countervailing balance sheet adjustment for the fact that Exmoor’s traditional tranquility, beauty and wildness might be diminished?

Work is being undertaken in relation to Exmoor’s natural and cultural capital through the Partnership Plan delivery programmes. The LCA introduces the future role of Natural Capital in assessing the natural and cultural capital

Further work on Natural Capital to be developed via the ENPA Partnership Plan and with partnering organisations.

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that the National Park offers.


The idea that decision making might be guided by an Aggregate Rule (i.e. that the aggregate level of renewable natural capital should not fall) raises intriguing questions about how a Natural Capital regime might relate to the current statutory purposes of National Parks?

Work is being undertaken in relation to Exmoor’s natural and cultural capital through the Partnership Plan delivery programmes.

This will be undertaken by the Partnership Plan delivery programme rather than LCA.


I’ve been puzzling in particular about the implications of such a rule for the National Park Authority’s second statutory purpose i.e. to provide opportunities for people to understand and enjoy the National Park's special qualities - which is relevant to National Park Authority policies on access, rights-of-way, outdoor recreation, large events and traffic management.

Noted. The National Park has two statutory purposes and the Sandford principle applies where there is conflict between these that cannot be reconciled, as set out in the Partnership Plan and the Local Plan policy GP1 Achieving National Park Purposes and Sustainable Development.

Continued review of large scale events via the delivery programme of the Partnership Plan.


The Natural Capital Committee (NCC) includes recreation, tourism and health benefits amongst the benefits from enhancing natural capital? On the other hand, as numbers of visitors and recreational and fund raising events increase, so does the possible negative impact on the National Park Authority’s current primary statutory purpose - the conservation and enhancement of the natural beauty, wildlife and cultural heritage of Exmoor National Park. The life of residents can also be made less pleasant, andthe fabric and everyday life of historic settlements can change for the worse?

Outdoor recreational events are recognised as an important way for many people to enjoy the special qualities of the National Park and can also bring valuable income for local business and charities. The Authority provides advice to organisers of large scale events to help ensure that these are of an appropriate scale and sensitive nature to provide for the continued conservation and


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enhancement of the National Park.


Exmoor’s Settlements: The character of Exmoorʼs hamlets, villages and towns are as much a part of what makes Exmoor special as its natural beautyand wildlife. They evolved during the colonisation of Exmoor’s uplands, and many retain rare and distinctive qualities. They are however continuing to come under pressure to accept further new development “to consolidate employment and services to help address the needs of the National Park as a whole”.

The character of Exmoor's settlements and built environment is recognised in the LCA. The Local Plan identifies a number of settlements in policy GP3 Spatial Strategy - the policy approach is clear that development should be proportionate to the settlement size, reflect the capacity of each settlement to accommodate new build development and positively respond to the surrounding landscape character.

Ongoing work by ENPA with regard to Conservation Area Appraisals and the register of non-designated heritage assets will further contribute to valuing and conserving these characteristics of the built environment.


I am not sure that we yet have the relationship between the settlements and the rest of Exmoor right? Under the local plan the larger settlements are seen as “service centres” to provide for the rest of the Moor. But I am not sure this is happening? What I see is commercial activity - increasingly with no particular connection to Exmoor - threatening the fabric and scale of the settlements….and thereby the conservation of Exmoor’s special qualities more generally? Parliament would have anticipated that development proposals within the boundaries of a National Park should be assessed equally on the basis of being compatible - or not - with the overriding objectives of the preservation and enhancement of the National Park?

The Exmoor National Park Local Plan is supported by robust evidence and has been through the formal process of examination by an independent Planning Inspector who has accepted the approach set out in Policy GP3 Spatial Strategy which identifies both Local Service Centres and Villages across the National Park. The policy approach is clear that development should be proportionate to the settlement size, reflect the

No action taken within LCA context.

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capacity of each settlement to accommodate new build development and positively respond to the surrounding landscape character.


The role of the National Park Authorities in the settlements seems at present to be restricted to planning approvals and designating Conservation Areas? Should National Park Authorities have additional powers for instance to offer funding and advice for enhancement and/or possibly town planning type advice in pursuit of National Park objectives.

The Landscape Character Assessment as a supplementary planning document provides planning advice in terms of Planning Guidelines for development consistent with policies in the Local Plan which are aligned with the achievement of the National Park statutory purposes.

Projects to provide for enhancement and advice would be delivered via the actions of the Partnership Plan and strategic planning priorities.


Conclusions: Forces for change are described in the Exmoor Landscape Character Assessment, along with recommendations to ‘protect, manage and plan’ to enhance Exmoor’s landscapes in the future e.g.- traffic impacting on perceptions of tranquility, remoteness and wildness;- concentrations of visitor facilities potentially changing the character of the landscape to one dominated by recreation; - a need for new housing to be well designed and sited to integrate into the landscape; - to manage valley-side areas which were formerly grazed but are now being encroached upon by scrub and bracken, or open to development.

Noted No action taken.


While the assessment points to some of the threats I find it less convincing on the answers. I recognise of course that some decisions may need to be taken at national level e.g. on purposes, charging/fees, targets for visitor numbers etc. Nor does it adequately describe

Noted. Forces for Change are included for individual Landscape Character Types in Section 4 of the LCA - these also address forces

Actions would be taken forward in implementing the Local Plan

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the forces for change acting on the settlements? for change on the built environment where appropriate. In the ‘Development led Change' table in the Forces for Change section of the LCA a range of pressures on the built environment are identified.

Policies or within the scope of the Partnership Plan programme.

016 01 9 1.8.4 General comment

Management of woodland is essential coppicing, clearing dead wood and keeping it away from rivers and generally maintain a gently expanding under cover part of it. As this chances with every rap coppiced. Like the seasons of the year follow one another so do raps of coppicing. Added to this hundreds of acres more need swaling which is the only thing that keeps them FREE OF gorse, bracken, birch and thorn and single trees growing on what was previously clear open moorland. Where there are areas of burnt gorse, particularly alongside roads, the burnt stalks should be mown the following year to discourage any bits still living. Farming: Small farms must be kept as farms and not given planning permission to turn them into riding establishments particularly no more dressage arenas unless surrounded by 4 to 5 ft. hedges of pleasant hedge types. Careful planning needs to be put in place and a limit to one per 6 square miles or some such. Also houses with electric gates and should need Planning permission. Game shooting associations should have a mediation discussion with the National Parks. These long straight strips could be curved or circular or placed down lower on the sides of the hills. Any tracks should have concrete water drainage at an angle to the track to take heavy rain down over the side thus prevent need for deeper or wider track. This should be discussed with them and put in as a matter of planning. With a mediator and a feeling of trying to

Some of the comments are not within the remit of the LCA to be able to address. Other issues regarding swaling and other land management issues are identified in the LCA Forces for Change and are also matters that have the potential to be addressed through partnership working with landowners and other organisations under the Partnership Plan ambitions. The Planning Guidelines set out in the LCA in conjunction with the adopted Exmoor National Park Local Plan policies provide the necessary tools to ensure that development proposals conserve or enhance landscape character.

Actions to be taken forward via the Partnership Plan programme of delivery or via the implementation of Local Plan policies.

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make it work on both sides is a better way of going about things. Not just saying those damned ugly shoots. Shoots should not be able to rent land on either side of theirs to add to the cut pieces. Leave hunting alone and discourage the National Trust to not stop trail hunting which is unnecessary and will give them grief they don't want. They are not the perfect little group they would have you believe. It this gets about there will surely be a back lash. Exmoor people are mainly pretty laid back but one of the things they don't like people messing about with the hunting even as it now, virtually non-existent. It is simply a matter of advising all hunting people to take back all permissive paths, to chain all gates on to the commons and put barbed wire around the top rail. To refuse entry given to Roman ruins and archaeological sites etc.


It is essential to encourage all tidal power schemes as the Bristol channel has the highest rise and fall of tide in the world. It need not be at intrusive like the large windmill farms off shore in so many places. Wind farms must not be encouraged inside the National Park. BUT SMALL PERSONAL WINDMILLS LIKE THE ONE AT ASHTON FARM AT COUNTISBURY. Which we fought for. When they applied to have one at Yenworthy where the only place you could see it was from the Bristol channel for a short time we assumed it would be passed so we didn't get involved. But the Exmoor Society demanded that it should be turned down because you could see the tips of the wings going around above the headland FROM THE CAR PARK ON NORTH HILL JUST ABOVE MINEHEAD. THAT MADE PEOPLE SICK WITH ANGER. WE WANTED GEORGE TO CLOSE ALL HIS PERMISSIVE PATHS TO THE ROMAN FORT AND OTHER AREAS OF OUTSTANDING BEAUTY BUT HE JUST SO "NO" AND SHOOK HIS HEAD. Keep your objections to within the Park. When the Exmoor Society got a go-cart racing track, just outside

The Exmoor National Park Local Plan includes policies for renewable energy technologies. Applications for tidal power schemes are generally under the remit of the Marine Management Organisation to determine, although any landfall (such as cabling) would be determined by the Authority and policies ensure that such applications are considered appropriately to ensure landscape and seascape character is conserved. Policies also identify areas where wind turbines are not permitted - within Landscape

Issues in relation to renewable energy technologies will be addressed through the implementation of the Local Plan Policies or within the scope of the Partnership Plan delivery programme.

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Simonsbath, Planning turned down, people around there assumed it was Exmoor National Park not the Exmoor society, as unfortunately they are seen as synonymous and you lost a lot of goodwill through that, as you have for a lot of other things INCLUDING OF COURSE BLACK PITS. It was the Exmoor society that started that.

Character Types A: High Coastal Heaths and D: Open Moorland. In all other areas the policy tests must be met - including that there is no unacceptable landscape or visual impact. the LCA planning guidelines also provide further advice.


Valuing Exmoor's capital. Not too much MANAGEMENT. Please have more discussions before embarking on anything. BUT NOT WITH THESE SO CALLED SPECIALISTS WHO HAVE READ A BOOK, OR THE EXMOOR SOCIETY, BUT WITH THE PEOPLE WHO HAVE BEEN BORN AND LIVED WITH THINGS AND SEEN THEM COME AND GO. ONCE AGAIN PLEASE ALLOW THIS TO BE YOUR MOTTO "IF IT AIN'T BROKE DON'T MEND IT."

Noted. A project to produce Natural capital accounts for Exmoor and Dartmoor National Parks is just commencing, led by Exeter University as part of the South West Economy and Environment Programme.

This will be addressed through the Partnership Plan delivery programme.


TO CONSERVE AND "ENHANCE" THE NATURAL WILDLIFE AND CULTURAL HERITAGE OF THE AREA. PLEASE BE CAREFULL WITH THE WORD "ENHANCE" BECAUSE IT CAN MEAN "CHANGE OR ALTER" IF IT AIN'T BROKE DON'T CHANGE IT. To allow you do this successfully you must keep long-time inhabitants on the moor by supplying with them with ways to build their own homes in the settlements where members of family and local friends live. Elderly and child amenities are a long way away these people can support one another. this help keeps the schools, the village shop, the social life and sports particularly cricket which has always been popular in the hills. This keeps up the traditions and cultures they have always lived by and without these people YOU CAN SAY GOODBYE TO EXMOOR AND SELL IT OFF FOR A FEW RICH PEOPLE TO WREAK HAVOC ON. IT IS NOTICEABLE THEY DO NOT SEEM TO HAVE MUCH TASTE IN RURAL

Noted. The Exmoor National Park Local Plan sets out policies to ensure that the housing needs of local communities are addressed, principally through local need affordable housing, which includes opportunities for self or custom build homes in the named settlements and other rural communities, in addition to the conversion of existing buildings on farmsteads or within hamlets.

Housing to meet local needs will be addressed through the implementation of the Local Plan Policies and within the scope of the Partnership Plan delivery programme.

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MATTERS. THIS SINGLE TIED LOCAL HOUSING FOR LOCAL INHABITANTS IS ABSOLUTELY ESSENTIAL FOR THE FUTURE OF EXMOOR.

016 05 2.3 18 General comment

When the river beds and banks were maintained regularly and annually by the River Board men there was very little flooding except at the times of very heavy rain. they also walked the side streams to check that there was no point where cow muck could run into the stream which kept the water very clean and it was full of trout and salmon. But not now that the Ministry of the Environment in all its glory says certain things do not need doing. they should be made to pay personally for all the damage they cause. A NEW FORCE IS NEED OF RIVERMEN TO GO BACK TO THAT WAY OF DOING IT.

Noted. Flooding is an issue that is identified by the LCA within certain landscape character types. However, this particular issue is not within the remit of the LCA to address. The Exmoor National Park Partnership Plan includes ambitions and strategies to address resilience and land management to provide flood alleviation through partnership working with land owners/managers and relevant organisations.

The current Headwaters of the Exe project is identifying and responding to issues of water quality relating to sediments.


This commons grazing worked well to get more food until there was no restriction of headage payments. Had this been reduced there would have been no overgrazing. Now they have gone the other way and putt these stupid scotch cows (to so-called save the species) on the moors are all the moors in Scotland kept for shooting. We should have our own Red Devons. GRAZING IS ESSENTIAL TO THE WELL BEING IS ESSENTIAL TO THE WELLBEING OF THE MOORLAND. WITH REGARD TO SWAYLING BEFORE NATURAL ENGLAND GOT ITS TAIL IN THE AIR. YOU THREW IN A MATCH AND IF IT BURNT IT WAS READY AND IF NOT IT WAS LEFT UNTIL NEXT YEAR. ALL THE COMMONERS DID THIS. YOU ALL KNOW THE HYMN "ALL THINGS BRIGHT AND BEAUTIFULL" IN WHICH MRS. ALEXANDER WHO WAS STAYING AT DUNSTER AT THE TIME WROTE ABOUT THE "PURPLE HEADED MOUNTAINS".THAT IS

Noted. Changes to management practices such as grazing regimes and reduction in swaling are stated in the Forces for Change section of the LCA.


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WHAT WE HAVE LOST THANKS TO INTERFERENCE AND "IF IT AIN'T BROKE DON'T MEND IT".


STONE SETTINGS. Stone circles and settlements showed up more clearly when more swaling was done as were the flints on Hawkcombe, when I was a kid the postman that worked Lillicombe Luccott, and Bromham lived next door and he used to collect them bring them home. I think when he died they went to Lynton Museum. Another interesting thing is that when it is deep snow AND WE LOOK AWAY TO MALMSMEAD Layiand the sun is shining the old field strips and farming systems and circular humps show up clearly. The last time we had a serious snow was in l983 when it was 7 or 8 weeks snowed up. It will happen again and perhaps when it does you could make use of drones to photo some of these things and then look closely at the ground when it has gone.

Noted. It is recognised that aerial photography and snowfall can help to identify important heritage assets.


Please note that you LAY A HEDGE about every 10 or 12 years or when they need it. You flail them more or less annually to keep a good solid bottom to the hedge to prevent the stock getting through. THIS IS AS IT ALWAYS HAS BEEN DONE AND SHOULD BE DONE.

Noted ENPA support traditional management of hedgerows via the Exmoor Landscape Conservation Grant.


Natural Processes and Climate Change (sentence 2): The coastal breach at Porlock was due to be filled in with large blocks of stone in which had been delivered together with a couple of large diggers. Then there were to be breakwater groynes placed in the correct place by the old fishermen's knowledge. Unfortunately the National Trust and ENP decided between them that this beautiful bird sanctuary WOULD MAKE A WONDERFULL SALT MARSH. With its reed beds and the black and grey pebbles on the edge of the beach nearest the land was heaving with birds laying their nests and we spent hours trying to find them but never

The LCA intention is to identify particular Forces for Change such as the dramatic event leading to the coastal breach at Porlock Marsh. Following the breach in the shingle ridge in 1996 the decision was to let natural forces take their course. The designation of the Marsh as Site of Special Scientific

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succeeded. There were kingfishers, and many breeds of ducks and all this was recorded in Professor Hendy's books. Wonderful irises and little cuts with hedges beside them where there were otters and many other water animals. THERE WERE DOZENS OF HARES ON THE MARSH AS WELL. Acres of the sweetest grass you ever met and Barley that won the barley championship at Toronto Trade Fair every year until those big headed know alls who should have been sent to the Hague decided it would make a perfect salt marsh if the sea came in and out. they threatened the landowners they would take them to court if they filled in the breach. that hatred will never go away due to that stinking old swamp which is only fit for dog fouling. IN l945 - 50 it was decided to renew the breakwaters running from the cottages towards the sea and then when it got over the rise it forked in to the sea. The fishermen kept telling the engineers that the Y shape was at the wrong angle and they just laughed, as they were important big headed engineers you see. Before this improvement the Harbour IS SLUICED by shutting the gates about every couple of years. It was unusual sight AT THAT TIME, but after that lot had done a BADLY CALCULATED job on it now has to be done several times a year, due to their inaccuracies of these so called EXPERTS. Listen to the very old local knowledge while it is still available.

Interest has been amended to reflect these changes and recognise its importance for studying active geomorphological changes. It is acknowledged that local knowledge provides an important basis for future strategies. A Vision for Porlock Marsh has been undertaken working with land owners and managers and the local community - see http://www.exmoor-nationalpark.gov.uk/Whats-Special/porlock-marsh-vision

016 10 Natural Processes and Climate Change (sentences 11-14): CLIMATE CHANGE will always go this way or that (just look at the three tornados in the West Indies the worst in 100 years). The best you can do for the rivers is to keep them clear. In the uplands go back to proper swaling because the lack of this has caused 90% of the trees and bracken and rhododendrons growing there now. When I was a little girl in Porlock we looked directly and Ley Hill was so clear of anything but heather you could even see calves walking along with the hinds. Now you would see an elephant. There

Noted. The LCA recognises the decline in traditional woodland management practices and new woodland planting in the Forces for Change section. The woodland / moorland transition is also mentioned in LCT G Incised Wooded Valleys. The LCA recommends that

Land, woodland, and river management will be addressed through the Partnership Plan delivery programme.

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should be a change of woodland management. Grants should be given to clear the areas where the Japanese larch was cut down. This should be replanted with mixed deciduous trees Oak, Ash,(we have no die back here) some sycamore but they can be bullies if not watched and some beech planted singly as herbs and flowers WILL NOT grow underneath them if Beech are planted are together over a large area.

opportunities to buffer / extend ancient woodland to compensate for loss through tree disease be investigated.


Changing Woodland and Forestry Management: Woodlands should receive running grants to maintain their woods. Annually with a set number of improvement requirements which would be checked. Also grants should be given to clear up the felling areas affected by Japanese larch infection. They should be cleared up and mixed deciduous trees planted there Oak, Ash which is no problem now in a lot of areas. With Beech mixed in as all Beech woods have nothing of interest growing underneath them but they are nice trees to have if mixed in. Deer and Grey squirrels. Grey squirrels are increasing rapidly, getting seriously out of hand and should be regularly disposed of by poison or shooting. It is a matter of balance. With regard to the deer. Where they are regularly hunted there is no problem, but in areas where they have so called sanctuary, they are in very poor condition and could become similar to badgers. Also they are more in danger of dying out because of poachers than being numbers causing damage. The farmers face most of the damage due to them getting into grass laid up for hay etc., and they will happily go and feed at feeders full of silage. That is when the farmers call the hunt to keep moving them around for a while and this works well.

The Exmoor National Park Partnership Plan ambition: Exmoor's woodlands are diverse, well managed, ‐productive and enhance the natural beauty, wildlife and cultural heritage of the National Park. There are a number of strategies to achieve this ambition including Woodlands for Landscape, Wildlife and History: woodlandmanagement conserves and reinforces landscape character, protects and enhances cultural heritage, and provides theconditions for Exmoor’s distinctive and special wildlifehabitats and species to thrive.Productive Woodlands: woodland owners are encouraged and enabled to increase the proportion of woodland that is

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actively and sustainably managed. The volume and quality of timber and wood harvested from Exmoor's woodlands increases and more value is added locally.


CHANGING WOODLAND AND FORESTRY MANAGEMENT. Woodlands should receive running grants to maintain their woods. Annually with a set number of improvement requirements which would be checked. Also grants should be given to clear up the felling areas affected by Japanese larch infection. They should be cleared up and mixed deciduous trees planted there Oak, Ash which is no problem now in a lot of areas. With Beech mixed in as all Beech woods have nothing of interest growing underneath them but they are nice trees to have if mixed in. Deer and Grey squirrels. Grey squirrels are increasing rapidly, getting seriously out of hand and should be regularly disposed of by poison or shooting. It is a matter of balance. With regard to the deer. Where they are regularly hunted there is no problem, but in areas where they have so called sanctuary, they are in very poor condition and could become similar to badgers. Also they are more in danger of dying out because of poachers than being numbers causing damage. The farmers face most of the damage due to them getting into grass laid up for hay etc., and they will happily go and feed at feeders full of silage. That is when the farmers call the hunt to keep moving them around for a while and this works well.

The Exmoor National Park Partnership Plan ambition: Exmoor's woodlands are diverse, well managed, ‐productive and enhance the natural beauty, wildlife and cultural heritage of the National Park. There are a number of strategies to achieve this ambition including Woodlands for Landscape, Wildlife and History: woodlandmanagement conserves and reinforces landscape character, protects and enhances cultural heritage, and provides theconditions for Exmoor’s distinctive and special wildlifehabitats and species to thrive.Productive Woodlands: woodland owners are encouraged and enabled to increase the proportion of woodland that is actively and sustainably

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managed. The volume and quality of timber and wood harvested from Exmoor's woodlands increases and more value is added locally.


Changing Farm and Land Management and grant incentives. The Stewardship Schemes are a disgrace. I suggest you find out officially under FOI how many have stopped having them. They are so badly handled by the Environment Agency and Natural England that the farmers are fed up with doing things which are wrong for conserving nature. i.e. One scheme made farmers clear all the gorse and thorn around the edges of the fields up on the moor. When they complained they were told they had to do it "to improve the look of the uplands landscape and make the fields clearly defined in the views". This altered the whole habitat of both farm animals and wild ones. This sort of nonsense must be stopped. See Construction of larger agricultural sheds coming up. When the farmers get wind, rain and snow and then all the places where the lambs, calves and a lot of wildlife and birds wintered had gone. THEN THE FARMERS WERE BLAMED FOR REMOVING THE SHELTER FROM THE RSPB ETC. AT THE SAME TIME THEY WERE BEING FORCED TO APPLY FOR MORE AND LARGER SHEDS TO ENABLE THEM TO KEEP THEIR YOUNG STOCK IN SHELTER. WHERE AS FORMERLY THEY WOULD EACH FIND THEIR OWN SNUG SPOTS AND MUM WOULD GO TO THEM AND FEED THEM. Just because we haven't had a long serious snow lately. They will come back. In l983 we were snowed in for over 8 weeks, but because we had always taken precautions every year since we started farming we were all right. THE SOONER NATURAL ENGLAND ARE ALL SENT TO THE SALT MINES THE BETTER THEY HAVE ACTUALLY READ A BOOK SO THEY MUST KNOW

Support for the paragraph in the LCA is welcomed. The Exmoor National Park Partnership Plan recognises the challenges and opportunities facing Exmoor including changes to farm practiceon Exmoor such as the numbers and breeds of grazing stock, land changes to how conservation funding has been targeted. This is driven primarily by European and national agricultural and environmental policy. As we leave the EU there is an opportunity to develop more locally tailored agri‐environment schemes.


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BETTER!!!!!!??????? Changes of farming structures. Go back to the land management and grant incentives at the beginning regarding This is a VERY GOOD SENSIBLE PARAGRAPH.


Changes of farming structures. Go back to the land management and grant incentives at the beginning regarding This is a VERY GOOD SENSIBLE PARAGRAPH.

Support for the text in the LCA is welcomed.


Farm diversification. As above this needs to be carefully considered. We would like to see a policy where old buildings can be turned into only holiday accommodation. We CONSIDER THIS SHOULD ONLY BE ALLOWED IF ONE LOCAL WORKING TIE IS PLACED ON A 2 TO 1 RATIO. ALL SECOND HOMES SHOULD PAY TRIPLE COUNCIL TAX AND THIS PUT FORWARD FOR LOCAL WORKING HOUSING. THE RENTS MUST BE THE £410 PER MONTH. NOT DISGRACEFULL £750 PER WEEK FOR BLACK PITS. THIS BLACK PITTS LETTING MUST HAVE AN INTERNAL REVIEW BECAUSE NOONE IS HAPPY WITH THE RENT REQUESTED OF £750 AND THE PEOPLE WHO FINALLY GOT IT. THIS IS URGENT.

The Exmoor National Park Local Plan policies enable existing traditional buildings on farmsteads, which are part of a building group around the main farmhouse, to be converted to residential accommodation including for holiday lets where it is part of farm diversification, or for homes for rural workers, succession farming, extended family members or for those in local affordable housing need.

Farm diversification and housing to meet local needs will be addressed through the implementation of the Local Plan Policies and within the scope of the Partnership Plan delivery programme.


Construction of larger agricultural sheds. See Stewardship Schemes and the lack of farmer participation. Which has also caused this even more than the phrase "intensification of methods"

Noted Proposals for larger agricultural buildings will be determined in accordance with policies in the Local Plan and planning guidelines in the LCA.

016 18 45 General Loss of landscape pattern: this is nonsense. you do not The term landscape

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comment need pretty little neat hedged fields. You have to have gorse, thorn, bracken etc., to keep the conservation of the farm stock and the wild stock and ground nesting birds and hedgehogs which are easy prey now these have been cleared and this is why their numbers of seriously dwindling.

pattern relates to the structure and form of the landscape and how different landscape elements (e.g. hedgerows, trees, buildings, etc.) relate to one another.


Traditional stone banks, walls and hedgebanks: Good farmers and their farmworkers will be prepared to regularly repair breaches in banks etc., as normal maintenance. But don't assume that just because there are piles of stones etc., and gaps in odd places there is anything wrong. Because there can be a variety of reasons. encourage good practice, but don't start paying too much because otherwise they will only do it is they are paid. Better to have a quiet word.

Noted


Loss of traditional rural buildings: LET ME STATE LOUD AND CLEAR THAT THE PRESENT PLANNING DEPARTMENT ARE SERIOUSLY FAILING TO TAKE CARE OF THIS. A recent case of someone from Barnstaple being given permission to build a house on a piece of land at Challacombe to breed Alpacas. Locals were livid. Several years ago I took a Planning person around to 3 sites in the settlement they were both born in and where their parents lived and they wanted to get married but due to the fact that Housing Groups stick to the ones with most kids etc., they didn't stand a chance. Also Father was getting on and needed help calving and maintaining his top class of Devon cattle. I took him round three sites all discreet. One on the very edge had had Planning Permission for it and building had started 20 or more years ago it also had a beautiful old thick walled cob barn with a thatched roof. Which would be ideal for them to bring the cows down to calve them. I was told that it would be better if they built a house in there and disposed of the remains of the building work. They would not do that saying it

The Exmoor National Park Local Plan includes policies that provide for local needs affordable housing within and well-related to identified settlements. To occupy a local need affordable dwelling a person and their dependents must meet the local occupancy criteria set out in the Local Plan policy HC-S3 which requires a person to have a local connection through living in the National Park for at least 10 years in the last 30 years or needing to live in a parish or adjoining parish to carry out paid work of value to the National Park

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was sacrilege. and its communities.016 21 45 General

commentEquestrian and small holding: Smallholdings. See the paragraph above about the house at Challacombe. Also THERE ARE FAR TOO MANY "ARENAS" FOR DRESSAGE APPEARING ETC., They are spoiling the landscape. They should be landscaped but with care. we do not want rows of pine trees etc., but hedges with flowers shrubs in them but this planning should be artistically done and produced at the time that Planning is requested. If it is done retrospectively then make sure it costs them serious money to produce and be accepted.

The Exmoor National Park Local Plan includes policy RT-D11 Equestrian Development for all types of development associated with the keeping and riding of horses - such development should not adversely affect the natural environment and must have regard to policies that aim to conserve or enhance landscape character. The planning guidelines in the LCA also aim to provide additional guidance to support the siting of new development in the open countryside.

Proposals for equestrian development will be determined in accordance with policies in the Local Plan and planning guidelines in the LCA.


Shooting. I think it is time for the National Park to sit down and mediate a better pattern for the shoots. It can be done, but only if the attitude is impartial. It is simple when you can see both sides of the argument and appreciate it.

Noted.


TOURISM AND RECREATION - LED CHANGE. Serious consideration must be given to things like the iron man races etc., which are allegedly along bridleways or paths. Farmers are having serious damages where they keep jumping over gates and breaking them down and leaving gates open and letting out stock and added to that the traffic on the roads are held up by marshals to let things through when there are people who are trying to get to their hotels. Farmers with Hay making, silage making and harvesting trying to get to their fields. This got worse this year when the race was

Outdoor recreational events are recognised as an important way for many people to enjoy the special qualities of the National Park and can also bring valuable income for local business and charities. Our procedures for monitoring, managing and supporting outdoor recreational


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changed from May to June because the swimmers complained that their bums were getting too cold because the water was still cold. HOW IS THAT FOR YOUR GROTTY LITTLE IRON MEN !!!!!!!!???????

events have recently been reviewed and we will continue to keep these under review as necessary.


A bi-law must be brought in banning motor vans of any sort spending the night on the moor. THIS GLAMPING CAN BE DONE AT THE LOCAL CAMPING PLACES ON FARMS. THESE PEOPLE WITH THEIR POSH VANS ARE TAKING IMPORTANT SEASONAL MONEY AWAY FROM LOCAL PEOPLE. ANYONE CAUGHT GLAMPING MUST RECEIVE AN ON THE SPOT FINE. WE HAVE SEEN THEN EMPTYING THEIR WASTE JUST ON THE EDGE OF THE HEATHER THAT SURROUNDS THESE PARKING AREAS. IT IS NOTHING BUT AN OPEN CESS PIT. ALSO THEY OFTEN HAVE 3 OR 4 DOGS TO EMPTY OUT AS WELL.

Noted. The Authority are aware of this issue.


THE CONSERVATION OF FORMER AGRICULTURAL BUILDINGS INTO RECREATIONAL USE ETC., The original idea was to make a barn clean, tidy and windproof with a toilet, hand basin, and kitchen sink. But once the Planners got hold of it became showers, stoves, sinks and all sorts of luxuries, we haven't even got. Get it back to what it should he.

The Exmoor National Park Local Plan sets out the policies for the change of use and conversion of buildings. It is recognised that traditional buildings are important features of the historic environment. Policy CE-S5 Principles for the Conversion or Structural Alteration of Existing Buildings ensures that the historic fabric and architectural interest of the buildings and its setting, including the retention of existing traditional and historic features, are conserved and enhanced.

Proposals to convert traditional buildings will be addressed through the implementation of the Local Plan Policies. Many of these buildings will be recorded or continue to be recorded on the Exmoor Historic Environment Record.


Potential reinstatement of Lynton and Barnstaple railway. This is a complete waste of time and space.

Noted. Applications for the reinstatement of the

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When it was originally running our Granny went to school on a Monday morning and back on a Friday afternoon and picked up by pony and trap from the station to up on the moor. It was so slow on the steeper parts the fireman used to get out and either check or relay his rabbit wires. The area they intend to compulsory purchase is enormous particularly at Blackmoor Gate. SO IF THIS DOES GO ON----------- THERE MUST BE A CAVEAT THAT THESE PIECES OF GROUND THEY HAVE COMPULSORY PURCHASED CANNOT UNDER ANY CIRCUMSTANCES BE CALLED A BROWN FIELD SITE AND ALLOWED FOR PLANNING. IF THIS DOES BECOME THE CASE THE OWNERSHIP OF THIS LAND MUST BE RETURNED TO IT'S ORIGINAL OWNER FOR THE SAME PRICE AS IT WAS PURCHASED. IT IS GENERALLY CONSIDERED THAT THIS IS THE INTENTION. THE RAILWAY AS IT IS A LOVELY EXTRA EXPERIENCE AND THERE IS NO VALUE EXTENDING IT EITHER WAY ?????????????????????????

Lynton and Barnstaple Railway have been determined.


CHANGES OUTSIDE THE PARK WHICH IMPACT ON ITS SETTING. As long as the developments are outside the park you can out forward a case but that's it. Inside the Park. If more people were allowed to put up "small" windmills like the one at Ashton then there would be no need for large ones inside. the Exmoor Society opposed one at Yenworthy, where the only place it would have been seen from was the Bristol channel. But the Exmoor society claimed that people in the Car Park 10 miles away on North Hill would be able to see the top of its wings going round. So they couldn't do it. But why was that monstrosity allowed at Exford on the road out towards the junction for Dulverton and Landacre. Let's look at a very interesting piece of planning. When we saved Black Pits from demolition one of the claims that it would have those electricity panels on it. What happened recently. Black Pits now has two electric panels. I am sorry about the crop

The Exmoor National Park Local Plan includes policies for renewable energy technologies. Policies also identify areas where wind turbines and solar panel arrays are not permitted - within Landscape Character Types A: High Coastal Heaths and D: Open Moorland. In all other areas the policy tests must be met - including that there is no unacceptable landscape or visual impact. The LCA planning guidelines also provide further advice.

Proposals for renewable energy development will be determined through the implementation of the Local Plan Policies.

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covers reflecting light. It the dear visitors can't put up with a few white fields occasionally in their views to enable people to get good crops to feed the country then I suggest they wear dark glasses completely black.

Plastic sheeting on crops is noted in the LCA as a valid force for change on the Exmoor landscape.


DEVELOPMENT-LED CHANGE: 1. New housing particularly local needs housing. This sentence is good but the LOCAL HOUSING MUST HAVE A LOCAL TIE TO IT. 2. the road markings etc., seem to have developed a mind of their own and should be cut down by the county councils. The old sign posts could be renovated by the villages concerned. 3. There has to be a balance you cannot stop all telecommunication masts. Local inhabitants and visitors are entitled in this day and age to have phone signal at least for their security and safety and calls for help. This must be balanced and not by the Exmoor society. 4. There are many large barns going up but they must prove the need for them. Say if you wanted to rear bought in calves. then light and airy is essential for their well being. 5. New Agricultural Workers dwellings. this is first class . One thing a farmer needs is a large back porch and we couldn't get them any way. 6. Small personal windmills a solar power if they do not impact is correct. 7. Oh yes there are some very serious and insensitive conifer hedging these should be LOOKED INTO VERY SERIOUSLY BECAUSE SOME OF THEM ARE NOT LEGAL. 8. Replacement PVC windows. There are some excellent ones now that you could not tell they are not wood unless you got your glasses out. Consideration should be given to the quality and the position they are to go in. Historic buildings would need serious consideration.

All new local need affordable housing has a local need occupancy tie to ensure that it can only be occupied by a person in housing need, who is unable to afford to rent/buy on the open market, and has a valid local connection. ENPA liaise with SCC Highways regarding proposals for new signage within the National Park. The current Historic Signposts Project is working with ENPA/ SCC/ volunteers to renovate many traditional signs across the National Park. Policies in the Local Plan encourage the improvement of telecommunications where there will be no unacceptable adverse impact on landscape or seascape character - the LCA Planning Guidelines also provide advice regarding the siting of vertical structures. Local Plan Policy SE-S4 sets out the policy tests for

Proposals for development will be determined through the implementation of the Local Plan Policies. The current Historic Signposts Project is working with ENPA/ SCC/ volunteers to renovate many traditional signs across the Park.

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proposals relating to agricultural buildings and ensures that there must be a functional need for such buildings. Policies relating to homes for rural workers have been found sound by an independent planning inspector. There are measures in place to provide for a larger dwelling where it can be justified by the needs of the holding. Further guidance will be produced to help provide the circumstances where a larger dwelling will be considered. With regard to wind turbines, the Local Plan policies enable the provision of small-scale turbines in certain areas (identified on the Policies Map) and where there is no unacceptable landscape or visual impact. The LCA Planning Guidelines also provide further advice on this type of development. The Local Plan addresses alternative materials for windows in the justification for policy CE-S6 Design and Sustainable Principles.

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