Sylw

ID sylw: 6022

Derbyniwyd: 26/06/2026

Respondent ID: 645

Ymatebydd: Ms Zoe Aubery

Asiant : Boyer Planning

BR supports the principle of the proposed amendments and acknowledges that development will only be permitted where it can be demonstrated that there would be no adverse effect on the integrity of nutrient-sensitive protected sites and, where necessary, proposals may be
required to achieve nutrient neutrality.

It is noted that the supporting text confirms that the Council is preparing developer-led mitigation guidance/toolkits together with strategic mitigation guidance and a focused Action Plan to assist in addressing nutrient impacts arising from future development. BR supports this solution orientated
approach, recognising that suitable nutrient mitigation is most effectively achieved through a layered and flexible mitigation strategy. Whilst this work remains ongoing, it is
important that opportunities to bring forward strategic mitigation measures are progressed as quickly as possible, drawing upon public capital programmes and other available funding mechanisms where appropriate. The timely delivery of strategic solutions will provide greater certainty to developers, support confidence in the planning process and help facilitate the delivery of much-needed housing without unnecessary delay.

BR welcomes the Council's commitment to preparing mitigation guidance and considers it essential that this provides applicants with access to a broad range of mitigation options that can be considered on a case-by-case basis. In particular, opportunities to achieve nutrient mitigation should be considered through a combination of different options. Whilst not intending to repeat information above this should include but not limited to:
• design-led mitigation measures;
• utilisation of existing headroom and permit capacity associated with the relevant Wastewater Treatment Works (WwTW); and
• strategic mitigation solutions capable of addressing additional nutrient loading arising from future development.

From a practical perspective, this approach should theoretically enable applicants to identify and implement the most appropriate mitigation measures, either individually or as part of a package of interventions, incorporating both on-site and off-site opportunities, including surface water removal where appropriate.

In circumstances where development drains directly to a Wastewater Treatment Works that discharges into a nutrient-sensitive freshwater catchment and nutrient neutrality is required, the removal of surface water from the combined sewer network should also be recognised as a potential mitigation measure capable of assisting in reducing nutrient loading. It is important that the proposed policy aligns with the requirements of Policy INF4 to ensure consistency across the Plan, avoid duplication and provide sufficient flexibility to demonstrate the RLDP is capable of meeting local housing need in accordance with Test 2 of the DPM.

Comments noted.