Sylw

ID sylw: 6017

Derbyniwyd: 26/06/2026

Respondent ID: 645

Ymatebydd: Ms Zoe Aubery

Asiant : Boyer Planning

Policy INF4 (Llanelli Wastewater Treatment Works Catchment Surface Water Removal). “In order to protect the water quality of the Carmarthen Bay and Estuaries European Marine Site, proposals for major development that would drain directly into the Llanelli Waste Water Treatment Works will be required to remove a quantifiable amount of surface water from the combined sewer
system.

Minor development which drains directly into the Llanelli Wastewater Treatment Works may also introduce the removal of surface water as a mitigation measure to secure nutrient neutrality where required in accordance with Policy CCH4.”

BR supports the principle of the proposed amendments and acknowledges that Dŵr Cymru Welsh Water (DCWW) have confirmed there is sufficient capacity exists within the Llanelli Wastewater Treatment Works (WwTW) to accommodate the level of growth identified within the RLDP.

It is also noted that DCWW has requested that major development proposals draining directly to the Llanelli WwTW should be required to remove a quantifiable amount of surface water from the combined sewer network. This requirement is reflected within the proposed policy wording.

The rationale for this approach is understood to be associated with the fact the majority of the sewerage network within the Llanelli WwTW catchment comprises a combined system conveying both foul and surface water flows. Therefore, requiring major development proposals to undertake compensatory surface water removal as part of the planning process remains consistent with Welsh Government guidance and is intended to ensure that development does not give rise to adverse effects on the Carmarthen Bay and Estuaries SAC and/or the Burry Inlet SPA.

Supporting text explains that, as part of the determination of planning applications for relevant major developments, CCC will require the removal of a quantifiable amount of surface water from the combined sewer system. Whilst this figure is not expressly contained within the proposed policy wording, it is understood that the amount of new foul flow identified within Policy INF4 has been calculated at 0.013 litres per second per residential property. BR raises no objection in principle to this approach on the basis that further guidance will be produced in the form of the emerging Burry Inlet Supplementary Planning Guidance (SPG). In the interest of soundness clear and robust guidance must be provided setting out the Council’s expectations in respect of the details needed considered at the planning application stage via drainage reports.
It is recognised that the removal of surface water from the combined sewer network is likely to require bespoke solutions, dependent upon the scale, characteristics and location of individual developments. BR therefore supports the approach whereby mitigation measures are considered on a site-specific basis. As identified within the Council's Habitats Regulations Assessment – Additional Sites Addendum (March 2025), the site at Land off Heol y Mynydd, Bryn (Ref. PrC2/(v)) is located approximately 1.4km from the Carmarthen Bay and Estuaries SAC and approximately 2 km from the Burry Inlet SPA. Whilst the Council concludes that localised effects associated with the site's proximity to these designated sites are unlikely. BR remains committed to ensuring that appropriate mitigation measures are secured where necessary. Such measures may include a combination of:
• design-led mitigation measures;
• utilisation of existing headroom and permit capacity associated with the relevant WwTW;
and
• strategic mitigation solutions capable of addressing any additional nutrient loading arising from future development.

By virtue of the above BR supports the principle of the proposed amendments, subject to further information being provided by the emerging Burry Inlet SPG. In that regard it will be important that the requirements are clearly set out and applied proportionately through the development management process to provide certainty for applicants and ensure that the delivery of much needed housing is not unnecessarily delayed or constrained, whilst continuing to secure appropriate environmental safeguards.

Noted. The Council is preparing Supplementary Planning Guidance to support the implementation of its policies in respect of the Burry Inlet.