Amend Plan

I write due to concerns over the removal of Special Landscape Areas from the 2nd Deposit rLDP (rLDP2) and the potential harmful impact this would have on these unique landscapes.

Paragraph 6.3.13 of Planning Policy Wales (PPW) states that Special Landscape Areas (SLAs) are non-statutory designations that define local areas of high landscape importance, which may be unique, exceptional or distinctive to the area. It goes on to state that planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.

Carmarthenshire Local Development Plan 2006 - 2021 (LDP) designated a number of SLAs. Within the LDP it states that the SLAs represent a non-statutory designation which were identified following a formal assessment of the landscape qualities of the County. The SLAs are largely assessed as outstanding or high in NRWs LANDMAP with regards to scenic quality. The LDPs policy EQ6 specifically related to SLAs and sought to ensure that proposed development enhanced or improved SLAs.

In monitoring policy EQ6 the Annual Monitoring Reports (AMR) noted that either no or less than 5 developments were approved contrary to NRW or Landscape Officer advice. This demonstrated that the policy was working and was protecting the SLAs.

From reviewing the evidence base and supporting documents for the rLDP2 I can find no reasoning or evidence as to why the SLAs have been removed from both the written statement and proposals maps. No information has been provided to detail why the Council now consider that such designations should not apply nor why they consider that normal planning policies would offer the necessary protection. No formal reassessment of the landscape has been undertaken. This is particularly important when the AMR has confirmed that policy EQ6 was working and meeting its required targets. The SLAs identified in the LDP and supported by their own policy safeguarded unique areas of landscape that are of high and outstanding scenic quality.

I attended one of the rLDP2 drop-in sessions where I raised concerns over the removal of the SLAs. I was advised that a Supplementary Planning Guidance (SPG) would be produced to cover the matter of SLAs. I note however, that it was an intention of the LDP for an SPG to be produced on SLAs (para 6.6.40) however, this has never transpired, which leads me to be concerned that the proposed SPG will never emerge, leaving these important landscapes unprotected.

Importantly, an SPG does not have the same status or weight as adopted Development Plan policies, and can only be taken into account as a material consideration in determining planning applications. A specific policy regarding SLAs should be produced, along with relevant maps, in order to safeguard these valued landscapes.