Carmarthenshire County Council / Cyngor Sir Gâr

Gwrthwynebu

Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin

ID sylw: 5737

Derbyniwyd: 25/05/2023

Respondent ID: 3253

Ymatebydd: Natural Resources Wales

Cydymffurfio â’r gyfraith? Heb nodi

Cadarn? Heb nodi

Crynodeb o'r Gynrychiolaeth:

PrC2/GT1 – Land at Penyfan, Trostre, Llanelli has been identified by the Flood Map for Planning as being at risk of flooding and therefore its allocation within the plan fails to meet the tests of soundness.
As confirmed in the letter from Welsh Government dated 15 December 2021, ‘when plans are reviewed, the flood risk considerations that feed into the settlement strategy and site allocations must be in accordance with the new TAN 15 and the Flood Map for Planning’. When proposing an allocation within a flood risk area your Authority should undertake sufficient background evidence to demonstrate that the development is appropriate for the flood zone and that the consequences of flooding can be acceptably managed.

Newid wedi’i awgrymu gan ymatebydd:

Amend Plan if necessary

Testun llawn:

Thank you for consulting Cyfoeth Naturiol Cymru/National Resources Wales (NRW) on the above, which was received on 17 February 2023.

We welcome the opportunity to provide comments on your Second Deposit Revised
LDP.

We support the intent of the plan’s policies and proposals to enable the delivery of sustainable development and ensure social, economic, environmental and cultural
well-being goals are all suitably balanced in the decision-making process, so the right development occurs in the right place.

We also acknowledge that you have taken on board advice from our previous correspondence which has enabled positive provisions in the second Deposit Plan
both in policy terms and regarding allocation of sites. However, there are issues with the latest draft which we feel challenge the Soundness of the Plan. These key
issues are highlighted below:
• SAC rivers / Habitats Regulations Assessment (HRA)
• Flood risk regarding the following sites allocated for housing under Strategic Policy 4: A Sustainable Approach to Providing New Homes
PrC3/h33 Llys Dolgader
PrC3/h19 Land off Llys y Nant
SeC19/h1 Land at Park View, Whitland
Sec19/h2 Land at Whitland Creamery
• Flood risk regarding allocation - PrC2/GT1 – Land at Penyfan, Trostre, Llanelli, under Strategic Policy SP 10: Gypsy and Traveller provision.
• Biodiversity and ecosystem resilience regarding six allocations (two housing and four employment).
In addition, to matters of soundness we also advise that some refining/clarity be made to the plan in respect of several policies and supporting text to ensure the
robustness of the plan.

Our detailed comments on the plan and supporting documents can be found in the annexes to this letter.

Please note that our comments are without prejudice to any comments we may wish to make when consulted on any subsequent formal planning application submissions
to develop any of the land identified within the plan. At the time of any other consultation there may be new information available which we will need to consider
in providing our formal advice.

Finally, we look forward to continuing to work closely with you to progress the plan and trust these comments are of assistance. If you have any queries, or if you require any further information, please do not hesitate to contact us at the above address.

Atodiadau:

Ein hymateb:

The allocation of the site within the LDP has been subject to full consideration through the site assessment methodology. As part of this assessment process a detailed site pro forma has been prepared. Further evidential work will be submitted as part of the submission documents to inform the examination.