INF5: Dyraniadau Gwledig y tu allan i Ddalgylchoedd Systemau Carthffosiaeth Gyhoeddus
Gwrthwynebu
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
ID sylw: 5736
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Heb nodi
We welcome the requirement for sites of five or more dwellings in settlements where there is no connection to the public sewer to be served by a single private treatment system. This will prevent proliferation of small private treatment systems in rural areas and reduce risk of system failure if appropriate management controls are in place.
However, Paragraph 4.2.11 of the HRA Addendum Report (February 2023) advises this policy should be amended by ‘…directly referencing in the policy wording that ‘such infrastructure will only be permitted if it can be demonstrated that there is no adverse effect on the integrity of phosphorus sensitive riverine SACs’’.
Despite this recommendation, no change has been made to the policy and there is no explanation given for this.
Amend Policy
Thank you for consulting Cyfoeth Naturiol Cymru/National Resources Wales (NRW) on the above, which was received on 17 February 2023.
We welcome the opportunity to provide comments on your Second Deposit Revised
LDP.
We support the intent of the plan’s policies and proposals to enable the delivery of sustainable development and ensure social, economic, environmental and cultural
well-being goals are all suitably balanced in the decision-making process, so the right development occurs in the right place.
We also acknowledge that you have taken on board advice from our previous correspondence which has enabled positive provisions in the second Deposit Plan
both in policy terms and regarding allocation of sites. However, there are issues with the latest draft which we feel challenge the Soundness of the Plan. These key
issues are highlighted below:
• SAC rivers / Habitats Regulations Assessment (HRA)
• Flood risk regarding the following sites allocated for housing under Strategic Policy 4: A Sustainable Approach to Providing New Homes
PrC3/h33 Llys Dolgader
PrC3/h19 Land off Llys y Nant
SeC19/h1 Land at Park View, Whitland
Sec19/h2 Land at Whitland Creamery
• Flood risk regarding allocation - PrC2/GT1 – Land at Penyfan, Trostre, Llanelli, under Strategic Policy SP 10: Gypsy and Traveller provision.
• Biodiversity and ecosystem resilience regarding six allocations (two housing and four employment).
In addition, to matters of soundness we also advise that some refining/clarity be made to the plan in respect of several policies and supporting text to ensure the
robustness of the plan.
Our detailed comments on the plan and supporting documents can be found in the annexes to this letter.
Please note that our comments are without prejudice to any comments we may wish to make when consulted on any subsequent formal planning application submissions
to develop any of the land identified within the plan. At the time of any other consultation there may be new information available which we will need to consider
in providing our formal advice.
Finally, we look forward to continuing to work closely with you to progress the plan and trust these comments are of assistance. If you have any queries, or if you require any further information, please do not hesitate to contact us at the above address.
Regard should be had to the emerging nature of this impact pathway, the associated development in scientific understanding, and the subsequent advent of mitigative solutions and relevant guidance – factors which do not align well with the development plan process. As clarified within the HRA 2nd Addendum (Ref 61, Appendix A), the recommendations made in paragraph 4.2.11 were in the interest of specificity, and are not considered to impact the soundness of the plan whether subsequently heeded (or not)."
This matter will be further considered during examination.