Sylw

ID sylw: 5995

Derbyniwyd: 25/06/2026

Respondent ID: 2320

Ymatebydd: Dwr Cymru/Welsh Water

MAC 036 Policy INF4: Llanelli Wastewater Treatment Works Catchment Surface Water Removal
As highlighted in our original comments, we welcome the inclusion of Policy INF4 and are supportive of its principles to satisfy the requirements of the Burry Inlet Memorandum of Understanding (MoU) through compensatory surface water removal. We note that these amendments (MAC036) propose to define the threshold for major development sites and the possible requirement for surface water removal for minor developments. However, whilst we acknowledge this provision is to identify a mitigation measure for nutrient neutrality, the NRW/Welsh Government ‘Mitigation Measures Menu’ recognises that surface water removal (or SuDS) can only provide a modest removal rate. Therefore, whilst the principle may be acceptable, the Policy should recognise that surface water removal may not necessarily outright “secure nutrient neutrality”, in accordance with Policy CCH4, but could be utilised as part of its strategy.
Turning to Paragraph 11.205, we commend the Council’s inclusion of a ‘Burry Inlet’ SPG and welcome the reference to flow calculations in its supporting appendices. We are supportive of this text and would add that the quantifiable amount of surface water to be removed can be expressed as l/s or in terms of its area (sqm), for residential development, which aligns to the SPG appendices.

MAC 046 Policy PSD1: Effective Design Solutions: Principles of Placemaking
We acknowledge amendments (MAC 046) proposed to the criteria for Policy PSD1 and welcome reference to maximised opportunities for water resilience in criteria (g). We agree that water efficiency in new developments can offer multiple benefits and we recognise it can positively contribute to nutrient neutrality provided it forms part of a wider package of mitigation, as referenced in Paragraph 11.284. Similar to the above (MAC 036), we would highlight that water efficiency measures may not secure nutrient neutrality, in accordance with Policy CCH4, but could be utilised as part of its strategy.

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.

MAC 125 Appendix 9
We note that a new appendix is included to provide site information for the regeneration and mixed-use sites, including the infrastructure requirements. DCWW has made representations at the Deposit Plan consultation stage to highlight sewerage and water infrastructure requirements associated with proposed sites. The appendix will need to accurately reflect our representations and recognise that the demands on our infrastructure changes over time, and the capacity of existing infrastructure to accommodate the proposed allocations may change over the course of the LDP period. Notwithstanding this information, we have made comments on specific sites below:
• PrC1/MU2 Pibwrlwyd Hydraulic Modelling Assessment (HMA) of the water supply network will be required.
• PrC3/MU1 Emlyn Brickworks Hydraulic Modelling Assessment (HMA) of the water supply network will be required.
• SeC16/MU1 Beechwood, Llandeilo Reinforcements will be required at Ffairfach Wasterwater Treatment Works (WwTW).
• PrC1/MU3 Nant y Caws There are no public sewers nearby therefore the provisions of WG Circular 008/2018 “Planning requirements in respect of the use of private sewerage in new development, incorporating septic tanks and small sewage treatment plants” apply.

MAC 126 Appendix 10
We note that a new appendix is included to provide site Information on allocated sites, including the infrastructure requirements DCWW has made representations at the Deposit Plan consultation stage to highlight sewerage and water infrastructure requirements associated with proposed sites. The appendix will need to accurately reflect our representations and recognise that the demands on our infrastructure changes over time, and the capacity of existing infrastructure to accommodate the proposed allocations may change over the course of the LDP period. Notwithstanding this information, we have made comments on specific sites below:
• SUV11/h1 Alltwallis Reinforcements will be required at Alltwallis WwTW
• PrC2/h20 Harddfan, Bryn A scheme has been delivered, and capacity is available at Llangennech WwTW
• PrC2/(v) Heol y Mynydd, Bryn Hydraulic Modelling Assessment (HMA) of the water supply network will be required.
• SeC6/(iii) Forest Rd, Hendy Llannant WwTW limited capacity, AMP8 scheme being delivered by 2030
• SEC7/h3 Golwg yr Afon, Llangennech A scheme has been delivered, and capacity is available at Llangennech WwTW

• SEC7/h4 Opposite Parc Morlais Llangennech A scheme has been delivered and capacity is available at Llangennech WwTW

• PrC3/(i) Emlyn Brickworks Hydraulic Modelling Assessment (HMA) of the water supply network will be required.

• SeC12/h1 Trem y Ddol Newcastle Emlyn Reinforcements will be required at Adpar WwTW

• SeC12/h3 Rear of Dolcoed Newcastle Emlyn
Reinforcements will be required at Adpar WwTW

• SeC19/h1 Land at Park View, Trevaughan Whitland
WwTW has limited capacity, AMP8 scheme being delivered by 2030

• SeC19/h2 Land at Whitland Creamery Whitland WwTW has limited capacity, AMP8 scheme being delivered by 2030

• SeC20/h3 Land off Clifton Street Laugharne WwTW has limited capacity, AMP8 scheme being delivered by 2030

• SuV55/h2 Glandy Cross There are no public sewers nearby therefore the provisions of WG Circular 008/2018 “Planning requirements in respect of the use of private sewerage in new development, incorporating septic tanks and small sewage treatment plants” apply.

• SuV56/h1 Efailwen There are no public sewers nearby therefore the provisions of WG Circular 008/2018 “Planning requirements in respect of the use of private sewerage in new development, incorporating septic tanks and small sewage treatment plants” apply.

Noted. The Council considers that the sites highlighted within the representation can be updated to reflect the most up to date information.