Gwrthwynebu
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
ID sylw: 5739
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Heb nodi
We welcome the principle of ‘multifunctionality by bringing green infrastructure functions together’, in some circumstances securing wildlife interests would not be compatible with other Green and Blue Infrastructure (GBI) functions. However, to ensure the soundness of the plan in respect of Test 1 and having regard to national policy we advise the following amendments.
4. Maximise opportunities to achieve multi-functionality by integrating GBI functions to deliver combined objectives which benefit Biodiversity, Climate Change and Sustainability, Health and Wellbeing, Sense of Place, and
Economy; and where this will not compromise the purpose of the GBI;
6. Where significant wildlife interests are associated with the site, GBI provides a resilient ecological network which adequately conserves the respective wildlife interests;
7. Avoid illumination of GBI provided for the purpose of wildlife conservation.
All planning applications for major developments will be required to submit a Green Infrastructure Statement to demonstrate how GBI design solutions have been considered and accommodated as part of the proposed development particularly to conserve the site’s biodiversity. As noted previously any design plans should involve native species of local provenance. Consideration of the end uses of the sites is needed regarding species
e.g., hedgerow connectivity across a housing development would not benefit Dormice due to increase predation by household pets.
Amend Plan if necessary
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.
Comments noted.
It should be noted that given subsequent changes to Chapter 6 of PPW, a green and blue infrastructure statement will now be required on all planning applications (not just major developments).
Consideration will be required at the examination.