PSD3: Rhwydwaith Seilwaith Gwyrdd a Glas

Policy wording should be amended to split the green and blue infrastructure requirements and clarify what is required to be covered in any statement.

Suggest a threshold of 30 units for the requirement for a specific Statement to be submitted.

The Policy introduces requirements that are over and above National Policy, PPW11 and Future Wales, all of which only reference green infrastructure. Therefore they should not be included in the plan.

The policy requires a Green Infrastructure Statement to demonstrate Green and Blue Infrastructure this requires clarification.

The requirement for the policy to apply to all major developments is considered onerous and will be overly onerous on smaller developments.

Consider that many of the requirements of this policy are replicated in other policies such as Strategic Policy – SP 14

No change to the Plan

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’

No change to the Plan

Thank you for consulting Welsh Water, we welcome the opportunity to continue to engage in the LDP process and we offer the following representation for your consideration:
Issues Identification We note and welcome the inclusion of issue 23 regarding infrastructure capacity to support development. The availability of our infrastructure capacity is a key element – particularly in rural areas - in ensuring sustainable and viable development sites.
Strategic Objectives The availability or capacity of infrastructure is a key aspect in determining the sustainability of a settlement, therefore we support the inclusion of SO6 and SO14.
Strategic Growth and Spatial Options We note that the Council identifies a growth requirement of 8,822 new homes over the revised LDP period 2018-2033.
Preferred Spatial Option Whilst we are supportive of the hybrid option and are pleased to note that it acknowledges the need for development to be supported by a range of appropriate infrastructure, there will inevitably be certain areas – particularly in the more rural locations of the County – where water or sewerage infrastructure is limited in its availability.
Placemaking, Infrastructure and Cohesive Communities We welcome the sentiment of paragraph 9.43. Where there is insufficient infrastructure capacity and development wishes to connect in advance of our AMP capital investment, planning obligations or a commercial agreement are the most appropriate way in ensuring delivery of necessary supporting infrastructure. We also welcome the inclusion of paragraph 9.47 and further commentary can be found in respect of the policy INF4.
Policies
SG1: Regeneration and Mixed-Use Sites Please see appendix 1 for site allocation comments.
SG2: Reserve Sites We note that the reserve sites will only be released for development if the allocations fail to deliver the required growth, and that the decision to utilise the sites will be made as part of a formal plan review. As such we will be happy to provide comments regarding capacity to accommodate sites in due course.
SG3: Pembrey Peninsula Most of the peninsula is unsewered and does not have a water supply with only elements of the southeast of the peninsula currently served by either. As such, any proposals for development may require significant offsite water mains and sewers to connect to existing networks. Further to this, the Pembrey Wastewater Treatment Works (WwTW) that serves the southeast of the peninsula may require additional capacity to accommodate any further development and developers may need to fund reinforcement works at the WwTW.
HOM1: Housing Allocations Please see appendix 1 for site allocation comments.
SP6: Strategic Sites Given that both sites have extant planning permission we have nothing specific to advise.
EME3: Employment Proposals on Allocated Sites The following provisions are applicable to all individual development plots located within allocated employment sites:
• We will work with your authority to support sustainable economic development however your authority and potential developers should be aware that the obligations of a water and sewerage undertaker extends to ‘domestic’ supplies only. Where an employment allocation results in higher demands of water supply and/or trade effluent discharges we recommend and welcome early consultation with Dwr Cymru Welsh Water.
• The individual plots available for development can represent a substantial area of land for which the potential demands upon our assets are unknown at present. It is essential that we understand these demands to allow us to assess the impact on our assets. It may be necessary for water and/or sewerage hydraulic modelling assessments (HMAs) to be undertaken at the developer’s expense to establish where the proposed development could connect to the existing networks, and to identify any required infrastructure improvements.
• Water mains and/or sewerage infrastructure required for any potential development site can be acquired through the requisition provisions of the Water Industry Act 1991 (as amended).
• Welsh Water always has rights of access to its assets. Where there are water mains and/or sewers crossing sites then protection measures in respect of these assets will be required, usually in the form of an easement width or in some instances a diversion of the asset.
• If any development site gives rise to a new discharge (or alters an existing discharge) of trade effluent, directly or indirectly to the public sewerage system, then a Discharge Consent under Section 118 of the Water Industry Act 1991 is required from Welsh Water. Please note that the issuing of a discharge consent is independent of the planning process and a consent may be refused despite planning permission being granted.
SP9: Infrastructure The availability or capacity of infrastructure is key in determining a settlement’s sustainability as such we welcome the provisions of this policy in requiring development to ensure sufficient capacity is available or if not, that suitable arrangements are in place to provide the necessary capacity.
With specific regard to water and sewerage infrastructure, where there is insufficient capacity and where no reinforcement works are programmed within the respective AMP Capital Investment Programme, the requisition provisions can be entered into for water and sewerage network infrastructure. The requisition provisions do not apply to wastewater treatment works (WwTW) and planning obligations, or a commercial agreement, may be necessary.
We welcome the reference in the supporting text to Drainage and Wastewater Management Plans (DWMPs). Welsh Water is embarking on the preparation of developing Drainage and Wastewater Management Plans (DWMP) which Welsh Government may be minded making statutory in due course. Growth information is built into our DWMP and forms an important element of our planning which aims to understand how we will continue to deliver effective sewerage services and manage the proactive development of natural flood management for a growing population in the face of climate change and other challenges.
Critically the DWMP considers the impact of changing population on our assets and the subsequent effect to customers and on the environment. As such we believe that the DWMPs will play a role in delivering a holistic, prioritised approach to the management of our drainage and sewerage network in the years ahead, and will complement other planning documents including LDPs, the NDF, and SDPs. To maximise the potential benefits, we are continuing to work closely with our stakeholders and LPAs in the continued development of our DWMP.
INF1: Planning Obligations Where there is insufficient infrastructure capacity available to accommodate a site and development wishes to connect in advance of any AMP capital investment, planning obligations or a commercial agreement are the most appropriate way in ensuring delivery of necessary supporting infrastructure.
INF4: Llanelli Wastewater Treatment Surface Water Disposal We are supportive of the provisions of this policy and the supporting text; moreover, we are pleased to note that the matter has been given its own specific policy. We have also prepared a consultation response to the Burry Inlet SPG which provides further detail on this matter.
SP10: Gypsy and Traveller Provision - Please see appendix 1 for site allocation comments.

SP12: Placemaking and Sustainable Places We specifically welcome the inclusion of criteria k) in Policy SP12. Disposing of surface water in a sustainable manner ensures that it will not communicate with the public sewerage network, which protects the environment and ensures that there is sufficient capacity in the public sewerage network for foul-only flows from development sites. On the theme of SuDS, we welcome the inclusion of the supporting text at paragraphs 11.273 to 11.275 regarding the recently established SuDS Approval Boards (SABs).
PSD3: Green Infrastructure Network We welcome the provisions of this policy and the supporting text. The integration of SuDS as a Green Infrastructure asset is something that we are particularly supportive of.
SP16: Climate Change We are supportive of the inclusion of SuDS in new development and as such welcome the provisions of criterion b) of this policy.
CCH4: Water Quality and Protection of Water Resources we welcome the requirement in supporting paragraph 11.510 that the necessary infrastructure needs to be in place or will be provided to serve development however we would highlight that in cases where there are no plans in place for infrastructure improvements in our AMP investment programme, developers can pay for the necessary infrastructure themselves through the requisition provisions of the Water Industry Act (WIA) 1991 or via Planning Obligations Agreements under the TCPA 1990. It should be noted that the requisition provision of the WIA 1991 only applies to sewerage network reinforcement works, not to WwTW schemes. Funding to deliver reinforcement works at a WwTW can be delivered via Section 106 of the Town and Country Planning Act 1990.
In relation to improving water quality, we are investing an additional £60m specifically to reduce phosphate in the five failing Special Area of Conservation (SAC) rivers in our operating area. This includes schemes at Lampeter and Llanybydder WwTWs that are due for completion by March 2025. In the next investment period 2025 to 2030 (AMP8) we will target investment with the ambition that none of our WwTWs are the cause of ecological failure. Through our phosphorus investment plan, we will have removed 90% of the phosphorus load from our WwTWs discharging to failing SAC rivers, playing our part in allowing these special rivers to meet their water quality targets and to relieve pressure on development restrictions. We expect to complete this programme of work by 2032. Whilst our investment will remove a significant amount of phosphorus from our sewage, in most cases it will not result in SACs complying with the water quality targets on its own. This is not something that Welsh Water can do on its own and it will take the combined efforts of all the contributing sectors to achieve this.

We will be engaging with our regulators and local planning authorities through the Tywi and Teifi Nutrient Management Boards (NMB) which can provide the governance, strategic direction and local intelligence/decision making needed if we are to be successful in relieving the pressure on planning restrictions and restoring river quality.
With regard to supporting text in paragraph 11.516, there are several locations within the County where we abstract water that is treated prior to entering the public water supply network. As such, we fully support the provisions in the supporting text of this policy in preventing the degradation of water resources.

TRA1: Transport and Highways Infrastructure Improvements There may be locations where proposed developments / routes pass over public sewers and water mains. Under the Water Industry Act 1991 we have rights to always access our apparatus and protection measures in respect of these assets will be required either in the form of an easement width or a possible diversion of the asset. We welcome early engagement once further detail is available.
MR1: Minerals Proposals We welcome the inclusion of criterion e) and k) of this policy.
We hope that the above information will assist you as you continue to progress the LDP2 and would encourage the LPA to continue to liaise with Welsh Water at each stage of the process. In the meantime, should you require any further information please do not hesitate to contact us at Forward.Plans@dwrcymru.com or via telephone on 0800 917 2652.

Amend Plan if necessary

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.