Polisi Strategol - SP 2: Adwerthu a ChanolTrefi

2nd Deposit Revised LDP – Commentary

Reference and Comment

A. Spatial Strategy
The National Park Authority has no comment on the spatial strategy proposed.

No comment.

Reference and Comment Support/Object/
Other
B. Employment
The Spatial Strategy commentary above sets out where there is consistency of approach on where employment undertakings can take place in the County along with notes of clarification.

The employment and economic development strategy of Carmarthenshire County Council’s Preferred Strategy focusses on the Swansea Bay City Deal, and other Carmarthenshire-specific strategies. Carmarthenshire County Council and this National Park Authority are stakeholders in a Regional Strategic Economic study along with Pembrokeshire County Council and Brecon Beacons National Park Authority. The final report was published in October 2019. The study broadly concludes that there is sufficient strategic land available to meet demand across the area. The policy approach across the Pembrokeshire County Council, Carmarthenshire County Council and Pembrokeshire Coast National Park Authority is to protect strategic and smaller employment sites for employment use.
Support the general conformity of approach.

C. Housing Growth
Pembrokeshire Coast National Park Authority has no comment on the anticipated scale of growth proposed.

D. Affordable Housing
The National Park Authority has no comment.
No comment.

Climate Change
The Authorities have a shared understanding of the need to plan for climate change and to mitigate its impacts and to provide for high quality design to ensure that new development is adaptable to climate change.

This National Park Authority supports the approach taken to future-proofing communities in light of predicted sea-level rise and the identification of a Coastal Change Management Area, supported by the South Wales Shoreline Management Plan. Support in principle. Support Policy PSD1 Placemaking and sustainable places, Policy NE5 Coastal Management NE6: Coastal Development; and NE7 Coastal Change Management Area and SP16 Climate change.
Note: See comment across.

Visitor Economy
Both Authorities recognise the importance of the visitor economy to west Wales and aim to support the sector and attract visitors all year round. Both also recognise that some attractions require a countryside setting but that this should be the exception, and the majority of tourism related development being sustainably located. Support SP11 The Visitor Economy, VE1 Visitor Attractions and Facilities; VE2 Holiday Accommodation; VE3 Touring Caravan, camping and Non-Permanent Alternative Camping Accommodation; VE4 Static Caravan and Chalet Sites and Permanent Alternative Camping Accommodation.

Retail
Both Authorities’ strategies focus on the need to maintain / create vibrant and diverse town, district, and local centres. Retail provision in both Authorities is identified through the retail hierarchy with Carmarthenshire’s hierarchy being based on Sub Regional- High Order Town Centres, Mid Order Town Centres and Lower Order Town Centres. Support SP 2 Retail and Town Centres

Renewable Energy
Both plans have regard to the need to generate more electricity from renewable sources. Pembrokeshire Coast National Park Authority has a renewable energy strategy policy seeking the delivery of appropriate renewable energy developments.

Both Authorities implement joint guidance on assessing the cumulative impact of wind turbines

It would be useful to confirm if Carmarthenshire intends to bring forward the Cumulative Impact of Turbine Guidance in the replacement Local Development Plan.

Carmarthenshire includes renewable energy as part of Strategic Policy 16: Climate Change (parts c and d), and both CCH1: Renewable Energy within Pre-Assessed Areas and Local search Areas and CCH”: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. Whilst Pembrokeshire does not have Local Search Areas, these policies are broadly in line with this Authority’s Renewable and Low Carbon Energy policy.
LSA for solar is shown on the Proposals map and it is considered that none of these are likely to have an impact on the Pembrokeshire Coast National Park.
Support SP 15 Climate Change and CCH1 / CCH2

Environment
Both Plans seek to ensure that their Plan areas natural and historic environment and landscape will be protected from inappropriate development and, where possible, enhanced.

The Welsh language which continues to be an important component in the social, cultural and economic life of many communities will be protected and supported by managing development sensitively in areas where it has a significant role in the community. Support SP8 Welsh Language and WL1 Welsh Language and New Developments, SP14
PSD3: Green and Blue Infrastructure Network
Maintaining and Enhancing the Natural Environment. SP 15 Protection and Enhancement of the Built and Historic Environment and BHE2 Landscape Character. SP14 Maintaining and Enhancement of the Built and Historic Environment

Note See across for comment.

Regional Working
Strategic Policy – SP 14: Maintaining and Enhancing the Natural Environment: Reasoned Justification: 11.409 In addition, and reflecting the duties placed upon Local Authorities, the Plan has regard to the National Park designation and the purpose for which it is designated, where it may affect the consideration of planning proposals.
BHE2: Landscape Character Development proposals should relate to the specific landscape and visual characteristics of the local area, ensuring that the overall integrity of landscape character is maintained by: …. b) protecting international and national landscape designations including National Parks and Areas of Outstanding Natural Beauty (AONB) and their settings;

11.456 Carmarthenshire is characterised by diverse and high-quality landscape resources and areas of notable visual value. It also includes or borders a range of landscape designations, including the Brecon Beacons and Pembrokeshire Coast National Parks and Gower AONB.

Appendix 2 Regional and Local Strategic Context:
Regional working: Pembrokeshire Coast National Park Authority’s adopted LDP is broadly compatible with a hierarchical settlement structure and a consistency in the broad planning policy approach with Carmarthenshire. Continuing liaison will ensure a mutual understanding of the respective approaches including through regional arrangements and the scope and progress of the Strategic Development Plan. A proactive approach towards regional and sub-regional working is implicit on policy matters, evidence gathering and strategic considerations.

Minerals
The terrestrial sand and gravel landbank and the apportionment of provision to meet future needs is now considered on a regional basis with the RTS Second Review setting out the contribution that each constituent local authority should make towards meeting the demand for aggregates. There is no requirement for a landbank to be maintained within National Park (PPW 11)

Although Carmarthenshire is now in a separate sub-region to Pembrokeshire, previous combined working arrangements with regard to future apportionments and allocations for sand and gravel as suggested in the RTS1 as recommended to continue in RTS2 with the production of a Statement of Sub-regional Collaboration between Pembrokeshire, Carmarthenshire and Ceredigion to meet the allocation requirement of 3.626 million tonnes.

The Area of Search for Sand and Gravel is located to the west as shown on the Proposals Map, the northern end of which lies approximately 4.3km south east of the Pembrokeshire Coast National Park.
Support the compatibility of approach between the two Plans.
Support SP 18: Mineral Resources.

Waste
Both authorities’ policies on waste management are broadly aligned. Carmarthenshire acknowledges TAN 21 and the need for collaboration between local planning authorities to progress towards an integrated and adequate network for waste management.
Support
Support SP 19: Sustainable Waste Management

Sustainability Appraisal/Strategic Environmental Appraisal

Appendix E: Growth Options
1st Deposit LDP Preferred Growth Option: check shading for ISA3. The appraisal is ‘+/-‘and the shading is that of minor negative effect rather than the yellow of positive and negative effect.

Appendix F: ISA Strategic Policies
SP 2: Retail and Town Centres: ISA Objective 1 has a positive assessment but no commentary.

SP 10: Gypsy and Traveller Provision: ISA Objective 8 is neutral. Could this be a positive since providing sites sustains Gypsy and Traveller culture?

Habitats Regulations Assessment

Comments:

Thank you for considering and incorporating PCNPA’s comments on the Habitat Regulations Assessment Report (2020) as detailed in the appendices to the Habitats Regulations Assessment Addendum report.

4.3 Interim action plan – land available for constructed wetlands.
It is suggested that it would be beneficial to include discussion of the identified lands current use (e.g. to eliminate land of existing or other potential nature conservation value from consideration).
Other discussion points:
The long-term use of wetlands as nutrient sinks is not well understood.
The ability of wetlands to remove nutrients may be influenced by climate change scenarios, e.g. drying out, flood events.

Page 8 (PPP) – while not yet adopted, we note that consultation recently (February 2023) closed on Dŵr Cymru Welsh Water’s draft Water Resources Management Plan 2024
Typos
“3.2.15 ‘screened out screened out’
3.3.2 ‘unlikely to have a significant effects’
4.2.17 ‘there are important’
4.2.20 ‘which can demonstrate not cause the failure’
4.3.1 ‘ready in conjunction’

Amend Town Centre Plan

BROWNFIELD SITES -policy
In respect of all unused sites , particularly brown field but not ruling out Housing/retail sites , that have been vacant for more than eg. 25 years then the planning allocation should automatically be mixed use or white land. There is no reason such sites cannot be used for allotments, parking, leisure, innovative trendy housing even built with containers for example.

The former creamery site in Whitland SR/163/007 is an example of such central dereliction and a shameful waste of an area close to services that could have been useful to the town and surrounding areas. It is an eysore and affects visual amenity and the wellbeing of residents.
The inspector, as I understand, removed the lower part of the site from the development line due to a flood plain. Given that the reason for the great flood of 1986 in Whitland is rectified and there are further flood barriers this decision was unfortunate and the site could not even be used for allotments, community car parking, retail and even much needed Housing. Going forward if climate change may impact any parts of the site then it is up to the owners of such sites to provide the requisite studies to suit the proposed uses.
Whitland has excellent transport infrastructure and good work opportunities but needs something exciting doing with this disused site.


RURAL TRANSPORT
There is only a remote chance of rural buses that can be run economically and sustainably on a daily basis at times to suit people who would otherwise use a car.
Disused railway lines such as that was formerly in the UDP as a route from Whitland to Cardigan ( Cardi Bach ) should be protected as these routes were instrumental in the sustainibility and economic generation of rural hamlets. Following closure these villages en route became stagnant. Old railway routes use as pathways and cycle routes enables safe connections between communities and these can used by young people to prevent rural isolation and reliance on parental taxis.. With the increase in the use of electric bikes it ebables Community for less athletic persons as well as potential tourism. Cafes or local historic features along the routes enable rural enterprise supporting the circular economy.

WHITLAND TOWN CENTRE
This designated outline is inaccurate in my view as it omits various very longstanding retail units of half a century or more.see attached map for proposal as a matter of fact.


LOCAL CONCERN
SR/163/010 Residents are concerned about the velocity of the off flow from the hill above this development and indeed this velocity lifted tarmac off a bridge and it does cause localised flooding. The site lacks footways and any such development requires very careful management of downward water flows on both sides of this allocation in case homes here suffer from such velocity and mud spills from the hillside above as do current residences.




HOUSING
Rural needs are greatly restricted by the policies related to affordable Housing. There is a greater level of self employment in rural areas and to provide work life balance homes of sufficient size are resticted by WAG Policy. A home Office, utility area sufficient to manage outerwear from rural surroundings, workshop are essentials to manage rural living in a fast paced environment. Some young people do return after study or working away but much of this depends upon availibility of skilled employment and the possibility of creating a home for life and self employed or remote work in one unit. Affordibility of a larger build size is a restriction but does not take into account that the build may be incremental and if budget is restricted (according to figures presented for build size) then persons can complete the more expensive internal works as budget becomes available.
People (and animals) are healthier in well ventilated, well designed spaces.
Affordable homes generally do not have sufficient garden size as did the old council homes and Commercial estates, in my view, are too uniform. Whilst budgets can be restrictive there is no excuse for inadequate design.
There has not been a housing needs survey for this revision and reliance on the Housing register is not a reflection of the many aspirations of those who wish to return home to contribute to the Community raise families or retire on their family farms.
The same applies to rural enterprise which is essential to the circular economy. Supporting SMEs to thrive where they can find a niche keeps a rural area vibrant and innovative.
Land banking that is tied up in pension schemes perhaps is another issue that restricts potential from none allocated sites.
I recognise this may not be as concise or eloquent as other submissions but there seems to be a mismatch of understanding between urban and rural living needs.