Gwrthwynebu

Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin

ID sylw: 5385

Derbyniwyd: 14/04/2023

Respondent ID: 4879

Ymatebydd: Barratt David Wilson Homes

Asiant : Boyer Planning

Cydymffurfio â’r gyfraith? Heb nodi

Cadarn? Nac Ydi

Crynodeb o'r Gynrychiolaeth:

In addition to the above, BDW Homes wholly object to a number of additional housing allocations which fall within Phosphate Sensitive Catchment Areas. A detailed list of these housing allocations have been provided in Table 1: List of Housing Allocations in Phosphates areas, as well as our detailed response to each of the proposed housing allocation. A number of the sites have been included as housing allocations as they have gained planning permission. We do not agree with the inclusion of these sites as they should be listed as commitments. Similarly, those allocations included as they have a planning application submitted and pending should not be automatically included as an allocation. This is contrary to the tests of soundness, as those allocations being rolled forward within phosphate sensitive areas are currently not suitable nor deliverable owing to NRW phosphorous guidance.
With regards to CCC’s efforts to solve the phosphate issue within the County, investigative work has been undertaken which forms part of the LDP evidence base. From reviewing this work, it is evident that CCC have no agreed mitigation measure to tackle the phosphate issue. A nutrient budget calculator has been constructed which calculates the phosphate levels that a proposed residential development in Carmarthenshire could produce. This is not a mitigation measure and so Carmarthenshire are yet to find a suitable phosphate solution.
In addition, a Nutrient Mitigation Options Technical Review (2022) has been prepared by Ricardo Energy & Environmental, outlining guidance on phosphorous mitigation options for use in Carmarthenshire. Although the report provides a short list and review of possible mitigation options no set option has been agreed upon. The report concludes ‘it is likely that all schemes will require engagement with/by CCC, Natural Resources Wales, the Nutrient Management Board and developers. Other stakeholders like landowners/land managers, Dwr Cymru Welsh Water and environmental NGOs are likely to also have a role in delivery of specific solutions.’
To this end, BDW Homes wholly object to the allocation of sites within Phosphate Catchment areas owing to the County having no established mitigation solution for development in phosphate areas. As such, all housing allocations which fall within phosphate sensitive areas should be discounted from the LDP, as these suits are not suitable nor deliverable. Additional more suitable sites should be sought which are located outside of the phosphate sensitive areas. Land off Heol-y-Mynydd, Bryn is a suitable location for development, being located adjacent to the settlement of Bryn/Llanelli and located outside a phosphate sensitive area.

Atodiadau:


Ein hymateb:

The strategy of the revised LDP seeks to support the distribution of housing and economic growth which is of a scale and nature appropriate to its cluster and has taken into account SAC riverine phosphate constraints. In this respect the revised LDP seeks to ensure that development is appropriate to the settlement and reflective of its ability to accommodate growth and the services and facilities available. As part of a future planning application an applicant will need to satisfy the requirements to reduce phosphate levels associated with their development. The evidence base has been developed to ascertain the position with regards the phosphate affected SACs and will facilitate the delivery of the housing allocations within these areas.