Sylw

ID sylw: 5993

Derbyniwyd: 25/06/2026

Respondent ID: 2320

Ymatebydd: Dwr Cymru/Welsh Water

MAC 080 CCH4: Water Quality and Protection of Water Resources
As highlighted in our original comments, we welcome the inclusion of Policy CCH4 and acknowledge that these amendments (MAC 080) propose to amalgamate the impact of development on nutrient sensitive protected sites, to substitute phosphorous sensitive riverine SACs. We defer to NRW’s ‘Advice to planning authorities for planning applications affecting nutrient sensitive Special Areas of Conservation’ to determine which development will be required to achieve nutrient neutrality and remind that DCWW is a statutory consultee for most planning applications.
With reference to the amendments to Paragraphs 11.513 to 11.515 (‘Riverine’), we acknowledge the variety of strategic and developer-led mitigatory actions and welcome the continued collaborative partnership work with NMBs. DCWW remain committed to the ‘fair share’ approach, as defined by Welsh Government’s practical guidance for public authorities (DTA Ecology), through our phosphorus investment plan to remove 90% of the phosphorous load from WwTWs discharging to failing SAC rivers. In accordance with NRW’s planning advice, we will continue to comment on the capacity of WwTWs to treat foul water flows alongside confirmation of its compliance with permit conditions, including effective dates as identified by the review of permits. Aside of the permit headroom capacity, we defer to the Council’s Action Plan to identify any further measures to mitigate against any increasing nutrient loads in the river.

We acknowledge a separate sub-heading for ‘Marine’, including requirements to achieve nutrient neutrality within the Burry Inlet Inner and Milford Haven Inner freshwater catchments. We would advise the Council that most site locations within are likely to discharge into these catchments; however, it should also be noted that some sites may be located outside but ultimately drain via a sewerage network into the affected freshwater catchment. For example, Burry Port is located outside but comprises of a sewerage network which drains to Llanelli Coastal WwTW and therefore discharges into the Burry Inlet Inner. Similarly, albeit rarely, there are site locations located within but discharge to a sewerage network outside of the freshwater catchment and examples of sites that are on the periphery of networks within and outside. For completeness, we refer to NRW’s latest planning advice and recognise DCWW’s duty to confirm which WwTW the site would connect to and its compliance with permit conditions.

We acknowledge the Council’s intention to produce “multilayered” guidance for strategic and developer led mitigation for developments in the freshwater catchments and we would advocate for close collaboration with DCWW on this approach, particularly if it relates to any public sewerage assets. On this point, DCWW is undertaking its source apportionment modelling programme which is programmed to conclude in Spring 2027 and will be important to ensure any mitigation measures are aligned with the modelling findings. As highlighted above (MAC 036), we remind that surface water removal may not secure nutrient neutrality but could be considered as part of the mitigation strategy. We note the Council’s proposal to produce a library of resources to assist developers in this matter, alongside external sources, and welcome the intention to regularly update the library which can align to any further updates in NRW’s planning advice.

Lastly, we welcome the addition of a new paragraph to reflect the requirements of TAN 15 and advocate for early engagement with the SAB and any other stakeholder, including DCWW, where the drainage proposals will have an impact on their interests. We also welcome the production of an SPG to support this Policy, in relation to a nutrient mitigation toolkit alongside the aforementioned ‘Burry Inlet’ SPG to consider sustainable management of surface water drainage.

Noted and support welcomed