BHE2: Cymeriad y Dirwedd

Retain all 18 special landscape areas to recognise the high value and unique beauty of the landscapes in these areas.

I am concerned about the potential removal of the special landscape area designation from the LDP. The SLAs give protection within the Council's planning system to unsuitable development within these areas. In the absence of detailed information about the new land development policy, such areas could be vulnerable to inappropriate pressure for development.

Recognise that the Tywi Valley needs protected status in the LDP.

As a resident of the Tywi Valley I wish to strongly express my view that the Tywi Valley should be designated as an AONB and retained in the Local Development Plan. The habitat is rich in biodiversity and a special natural environment which is vital for both wellbeing of residents and for tourism. It has historical significance with part of the area in a National Park and the Coed Tregib an important visitor area. The planned cycle track evidences its significance and it is surprising that it has not yet been recognised as an area with protected status.

Dyffryn Tywi should be designated as an AONB in the Local Development Plan
along with the whole of the Towy Valley from its source in the Cambrian mountains to the sea in Carmarthen Bay

As a resident of the Towy Valley I wish to express my view that Dyffryn Tywi should be designated as an AONB in the Local Development Plan. The habitat is rich in biodiversity and a special natural environment which is vital for both wellbeing of residents and for tourism. It has historical significance with part of the area in a National Park and the Coed Tregib an important visitor area. The planned cycle track for the Tywi Valley evidences its significance and it is surprising that it has not yet been recognised as an area with protected status.

1. Retain this as a Special Landscape area. If previously considered Special why not now when beauty, tranquility and wonder are in such short supply?

2. Re Consider the retention of all other 17 Special Landscape Areas.

3. Protect these as key landscape views and vistas. Essential to the Welsh culture that has been and is to be handed down through the history of time.

You completely fail to acknowledge the value of the beauty of the Carmarthenshire countryside, particularly that surrounding this often neglected part of the County i.e. Llandovery and its backdrop of rolling uplands and valleys. The Towy valley is unsurpassed in peaceful unspoiled beauty. The heritage, history and culture of this part of Wales is of tremendous value and needs to be preserved and celebrated. I think of future generations who have a right to see the land as it is and with their own eyes thus to learn the continuity and values passed down the generations since even before the Roman occupation.
Llandovery is not the most enlightening town in which to grow up and today's youngsters often are not able to experience travel and its enrichment. However, by looking outwards and even walking for ten minutes they are within the most breathtaking and beautiful environment that mankind could ever imagine. From this, very few will fail to experience a gasp of wonder whilst opening their minds and imaginations to what has come before and is now constant. Each will grasp a sense of security and even magic.

This learning and bond with nature will remain with a child long into adulthood and ensure Wales' nature and uniqueness is handed on with pride from generation to generation.

The Special Landscape Areas should be retained as an important element of the LDP.

The proposed LDP has excluded the Special Landscape Areas (SLAs) that are currently defined.

It has been indicated by Councillors that this is because the SLAs do not provide "concrete" protection against undesirable development.

However they do offer some protection and can be used by local planning committees to oppose unsuitable development and to help to preserve the special characteristics of these areas.

It would be absurd to remove the limited protection provided and replace it with no protection at all.

These areas are under dire threat from mobile network and wind farm development and need MORE protection, not less.

The Special Landscape Area designations should be kept in the Local Development Plan for all 18 SLA regions currently protected. This would reassure Carmarthenshire residents that the Council are formally committed to the objective of protecting the aesthetic beauty of our unique historical and natural landscape, as an evidenced, formal policy position of the council. It Would also demonstrate a joined-up, long-term approach that recognises the beauty of the area is inherently linked to the Carmarthenshire's economic strategy based on leisure and tourism. Otherwise, our area will be at risk of costly and wasteful retrospective investment in 'future landscape enhancement' projects after aesthetically damaging developments (e.g. pylons network), as is currently the case in the Dwyryd Estuary and North Wessex Downs.

The Special Landscape Area (SLA) designation provides protection for locally significant and attractive landscapes that are of comparable quality to Areas of Outstanding Natural Beauty (AONB). They should be protected and enhanced, particularly through planning processes in Carmarthenshire. I object to Carmarthenshire County Council's proposals to remove the SLA designations in the proposed revisions to the LDP, as doing so is an expression that Carmarthenshire County Council are actively de-prioritising the protection of the landscape in its local plan. This is particularly concerning given these proposals coincide with current proposals for a distribution network of pylons and potential for further wind farms across the Tywi valley. Removing SLA designations at the same time that plans are being proposed for pylons across the county indicates to Carmarthenshire residents that the Council are paving the way to approve the pylon network, as they will not be in contradiction with the removed SLA status. While SLAs are more of a policy position than a statutory protection, they nevertheless remain an important protection in any planning process, as National Resources Wales have indicated their concerns in writing to you at the proposed removal of SLAs. I therefore strongly object to any removal of SLA for all 18 SLA regions currently protected, and would reassure residents that Carmarthenshire County Council seek to protect our special historical and natural environment.

The use of ‘overall’ in the policy substantively weakens its protection of the landscape character. We request that this word is removed. It is unclear in the current presentation of the policy if the onus is on the applicant to identify the landscape character of the ‘local area’ through their own assessment, or if NRWs LANDMAP data is to be used, or if the LPAs own Landscape Character SPG is to be used. This should be more explicitly set out and clarified. If the expectation is that the Landscape Character SPG is the baseline then it would be beneficial for this to be published in advance of the Revised LDPs adoption, preferably at the time of Examination. Reference to the Landscape Character Assessment should also be made in the Policy text.

It is also unclear where the key landscape views and vistas mentioned in point e. are set out, in order for them to be protected in the policy. If these are due to be identified in the Landscape Character SPG then, again, this would benefit publication prior to plan Examination.

We object to the Second Deposit LDP on the basis of the removal of the SLAs and request that SLAs are reintroduced into the Revised LDP, either as a standalone policy or that provision is made within the new Policy BHE2: Landscape Character.

This could be achieved by an amendment to Policy BHE2: Landscape Character to add wording as follows:

Proposals must take account of Carmarthenshire’s locally designated Special Landscape Areas (as set out in Appendix X (Appendix 4 of the Current LDP) and shown on the Policies Map). Development proposals will only be permitted where there is no significant adverse impact, including cumulative impact, on the character and quality of the landscape. Development proposals should aim to protect and enhance the features for which the SLA has been designated.

Where appropriate, a Landscape Impact Assessment will be required to assess and justify the impact of the development on Landscape Character and/or the designated area.

In exceptional circumstances, where development is necessary and could result in a significant landscape impact, appropriate mitigation and enhancement measures should be provided, including the undergrounding of associated infrastructure where possible.

Our suggested wording is similar to the City of Swansea LDP which was successfully adopted following Examination in February 2019. Appendix 4 of the Current LDP would remain relevant to the Revised LDP and could be brought across, with edits as necessary to increase the robustness of the assessment of the area’s character. SLAs could be added back into the Policies Map, with minor boundary edits as necessary.

1. Objection to the removal of the Special Landscape Areas from the Revised LDP

‘The use of non-statutory designations such as Special Landscape Areas to protect areas of landscape value has long been a policy tool within the UK planning system. They have been seen by local planning authorities as a means of protecting sensitive landscapes and in developing an understanding and awareness of those features and characteristics that give a locality its sense of place.’

Carmarthenshire’s 18 Special Landscape Areas (‘SLAs’) listed under Policy EQ6 in the Current LDP have not been carried forward into the Revised LDP.

We recognise that SLAs are a local non-statutory designation, however these areas are an acknowledged designation which carries weight within the Current LDP as a standalone policy. SLAs are also acknowledged and given weight within neighbouring Local Planning Authority (‘LPA’) LDPs. The weight given to the SLA designations is recognised across Appeal decisions by the Planning Inspectorate and in Planning Inspectorate recommendations with regard to Development Consent Order applications.

We object to the Second Deposit LDP on the basis of the removal of the SLAs and request that SLAs are reintroduced into the Revised LDP, either as a standalone policy or that provision is made within the new Policy BHE2: Landscape Character.

This could be achieved by an amendment to Policy BHE2: Landscape Character to add wording as follows:

Proposals must take account of Carmarthenshire’s locally designated Special Landscape Areas (as set out in Appendix X (Appendix 4 of the Current LDP) and shown on the Policies Map). Development proposals will only be permitted where there is no significant adverse impact, including cumulative impact, on the character and quality of the landscape. Development proposals should aim to protect and enhance the features for which the SLA has been designated.

Where appropriate, a Landscape Impact Assessment will be required to assess and justify the impact of the development on Landscape Character and/or the designated area.

In exceptional circumstances, where development is necessary and could result in a significant landscape impact, appropriate mitigation and enhancement measures should be provided, including the undergrounding of associated infrastructure where possible.

Our suggested wording is similar to the City of Swansea LDP which was successfully adopted following Examination in February 2019. Appendix 4 of the Current LDP would remain relevant to the Revised LDP and could be brought across, with edits as necessary to increase the robustness of the assessment of the area’s character. SLAs could be added back into the Policies Map, with minor boundary edits as necessary.

Reasons for retention

The retention of the SLAs in the Revised LDP is well supported, with 438 people resident within the county signing Carmarthenshire Residents’ Action Group’s petition.

We argue that the retention of the SLAs is important to fulfil to objectives of the LDP and question if the SLAs are removed if the plan meets its Sustainability Objectives on Landscape set against the baseline criteria. We do not consider that a robust, proportionate and credible case has been set out by the LPA for the removal of this landscape designation. We consider that the removal of the SLAs significantly weakens the Revised LDP’s SO9 regarding sense of place and impacts Carmarthenshire’s planning framework in terms of delivering on sustainable development on the basis of the Well-being of Future Generations Act.

By designating SLAs it is easier for communities, visitors and tourists to engage with the highest value landscapes of Carmarthenshire. The SLA designations are reflective of the local value communities place on these landscapes in a manner not captured in the replacement Policy BHE2: Landscape Character. This revised policy places too much reliance on LANDMAP assessment. Whilst LANDMAP is an excellent tool for those engaged with the planning process, it is harder to engage with than the specifically designated SLAs which have clear and geographical boundaries capturing the outstanding and high quality landscapes of Carmarthenshire. The removal of the SLAs, and their removal from the Polices Map, invariably makes it makes it harder for specific communities and the wider public to engage with the LDP and weakens community representations as part of the planning consultation processes for individual development applications.

We consider that the SLAs improve the delivery of the Revised LDP objectives. Natural Resources Wales (‘NRW’) states that ‘there may be more than one role for an identified SLA: To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place / bro; To influence positive landscape planning. […]; To raise understanding and appreciation of the importance of local landscapes by communities, visitor and the wider public.’ The SLAs currently provide these roles and retaining them in the Revised LDP would better meet the LDP and ISA Objectives.

The developmental pressures on the landscape have not weakened in the time between the Current LDP adoption and the Revised LDP drafting. The Current LDP Appendix 4 assessment of SLAs specifically states in relation to the Tywi Valley, that ‘Inappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation.’ We do not see that these reasons for designation have weakened. However, if the LPA consider otherwise, then the evidence of this decision making process should be published.

Planning Policy Wales 11 (‘PPW11’) paragraphs 6.3.12 and 6.3.13 relate to the characteristics of local landscapes. These paragraphs highlight the ability for LPAs to designate SLAs. Paragraph 6.3.13 states that ‘Planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.’ Given that pressures on the landscape have not weakened and that the existing SLAs have proven weight in the planning determination process, we consider that the removal of the SLAs in the Revised LDP runs contrary to this part of PPW11.


Compatibility with Policy and Guidance

In addition to the point with regard to PPW 11 above, our view is that the SLAs are wholly compatible with the Revised LDP, the proposed Policy BHE2: Landscape Character and can be seamlessly incorporated into this policy, or alternatively, the existing policy could be retained in the Revised LDP.

NRW LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, endorses a dual approach to landscape management, in line with our suggested edits to the Revised LDP Policy BHE2: Landscape Character. On page 3 of the document, it is stated that ‘in this dual approach, all landscapes will be underpinned equally by LANDMAP […] but in addition to this, landscapes of high local importance will be specifically identified as a SLA with additional guidance being produced for these key landscapes’.

We recognise that there is potential tension between the SLA designation of Llanllwni Mountain SLA and the Cothi Valley SLA, and that these areas are also within the Pre-Assessed Area for Wind Energy in Future Wales 2040 the National Development Plan (‘NDP’). We argue that the SLA designation of these areas is not in conflict with the NDP, including Policies 17 and 18. However, we recognise that this is an area of the Revised LDP which may benefit from further exploration at Examination and we would appreciate an invitation to make representations on this issue.



2. Inadequate Evidence Base

The Issues, Vision and Options paper makes it clear that this 2018-2033 LDP is a review of the previous LDP and not a new local plan (para 1.3, page 2, Issues, Vision and Options Topic Paper, February 2023). There is a general expectation in plan making that evidence is front-loaded. As the Revised LDP revises the Current LDP, it is reasonable to expect that the entire removal of locally designated SLA from the plan should be carried out on a sound, evidence backed, basis. Statements by the LPA during the plan making process did not indicate that SLAs would be removed from the plan at Review or Preferred Strategy stages. The weakening of the landscape policies and the removal of SLAs was not revealed until the publication of the First Deposit LDP in early 2020. Prior to the publication of the First Deposit LDP, the LPA indicated that further evidence would be published if the policy were to be changed.

The 2006-2021 LDP Review Report 2018 did not raise concerns about the effectiveness of the SLA Policy, giving it a green colour coding indicating the policy target was being achieved or exceeded. The report stated in paragraph 9.141 that ‘The Plan identifies Special Landscape Areas (SLAs) within Policy EQ6. These were identified following a formal assessment of the landscape qualities of the County and are a non-statutory designation. It is noted that the policy places an emphasis on enhancement and improvement. There may be opportunities to supplement and/or review the supporting evidence for this policy and explore those wider linkages (e.g. the renewable energy policies and those design related policies).’

Further, Appendix 1 of the Review Report reviewing specific policies states that in relation to Policy EQ6 SLAs that ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy.’ This wording is a standard response to policies which were expected to be kept in the Revised LDP close to their current form. It is difficult to ascertain how the removal of the SLAs does not constitute a fundamental change, to a degree where evidence justifying this change would reasonably be expected to be published.

Following on from the review, the Preferred Strategy was published in 2019. The Preferred Strategy gave no indication of the intention to remove the SLAs from the Deposit Plan and gave significant indication that landscape policies would remain strong within the Revised LDP. Issue 8 of the LDP issues is ‘Rich landscape or townscape qualities’; the Vision states that ‘rich cultural and environmental qualities are valued and respected’; paragraph 10.19 states that ‘the LDP will promote the principles of sustainability by: Protecting and enhancing biodiversity, townscapes and landscapes’; ‘A New Strategy – Key Components’ paragraph 10.20 states that ‘the key components of the strategy are as follows:’ one of which is to ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes’.

Given these statements, it would not be unreasonable to expect that the SLA policy would remain in the Revised LDP, particularly given specific reference to the protection of high value landscapes. The means of recognising and protecting the areas of outstanding and high value landscapes in the LPA’s geographical area is specifically the Current LDP’s SLA policy.

Furthermore, in response to a representation made on the Preferred Strategy, the LPA stated ‘The consideration of whether any Special Landscape Areas will be identified in the Revised LDP, along with any resultant evidential facets, will be a matter for the deposit LDP.’ [our emphasis].

In our view, it is reasonable to consider that prior to the First Deposit Plan publication that the full SLA policy, or a slightly revised version of it, would remain in place in the new LDP; or that evidence would be published alongside the Deposit Plan to justify removal of the SLA policy given the LPAs statements in the Plan Review and the response to the Preferred Strategy public consultation. Therefore, given the above timeline indicates a very late decision to remove the SLAs from the Revised LDP, we question whether the decision has been carried out with robust, proportionate and credible evidence.

What evidence has been used?

At the date of this letter, the LPA have not provided information within the Plan Evidence Base, as accessed online, for the decision to remove the SLAs from the LDP; nor the evidence that the new landscape Policy BHE2: Landscape Character sufficiently delivers on the aims of the New Strategy which includes the key component to protect and enhance high-value landscapes.

Assessments which have been published by the LPA in relation to Landscape Character are due to expire when the new LDP is adopted. These comprise existing assessments of the SLA areas in Appendix 4 of the Current LDP; there is a reference to NRW’s 48 broad scale, not locally specific, National Landscape Character Areas (NLCA), and the SLAs within the Placemaking and Design SPG (adopted 2016); and consideration of landscapes in the Carmarthenshire Wind Turbine Development Landscape Sensitivity and Capacity Study, prepared by Anthony Jellard Associates.

The SLAs are removed from the Revised LDP. The Placemaking and Design SPG is not slated to be carried forward with the new Revised LDP . The current status of the Anthony Jellard study is unclear, it is referenced within the current Wind and Solar SPG; however this SPG is not intended to be carried forward as part of the Revised LDP. The removal of these assessments is likely to leave a gap with regard to the protection and enhancement of landscapes when the new Revised LDP is adopted.

Given the anticipated expiry of these assessments, it is not credible that they can form part of an evidence base for the creation of the Revised LDP policies. No evidence has been provided that any other assessments have been carried out in forming the LPAs landscape character policy or that NRW’s LANDMAP has been utilised to inform revised policy preparation. The Revised LDP states that a Landscape Character Assessment SPG is proposed to be adopted by Summer 2025, but as no draft has been published this does not form part of the evidence base. The target Revised LDP adoption date is Autumn 2024 and with the SPG proposed for Summer 2025, this leaves a significant gap around landscape policy guidance in the interim, even if the Landscape Character SPG is published on time.

The LPAs Cabinet Member for Planning has responded to a question on the evidence base by discussing assessment of development proposals utilising information contained within NRWs LANDMAP. However, this is an existing means of assessment in the Current LDP and will be retained as a means of assessing change to landscape in the Revised LDP, as such it does not make a difference to the baseline. Notably, the question asked to the Cabinet Member for Planning was with regard to the evidence around the formation of new Policy BHE2 and the removal of the SLAs, to which she did not furnish an answer.

Finally, the lack of published evidence relevant to the landscape policies of the Revised LDP appears to be in conflict with paragraph 6.3.21 of PPW 11, which states ‘Planning authorities should draw upon LANDMAP in the preparation of landscape plans and assessments needed to inform development plans, SPGs and the development management process. LANDMAP assessments should be published.’ [our emphasis]

In our view, the evidence base for the Revised LDP in terms of Landscape Policy is not sufficiently substantiated and we request that this is interrogated by the Inspector appointed for the Examination.

The removal of the SLA designations from the LDP cannot but be an adverse change. The failure to take account of this substantive change and substantiate why this is not a significant weakening of the LDP from its current form is of great concern.

We encourage Carmarthenshire’s Forward Planning Department to set this right before the LDP is examined and re-introduce the SLA designations into the Plan to address the issues raised in this letter, re-providing a substantive part of the means to protect and enhance our outstanding and high valued landscapes for future generations.

Please see letter in full as attached.

Carmarthenshire Residents’ Action Group: Representations to the public consultation of the Second Deposit Revised Carmarthenshire Local Development Plan 2018-2033 and the Integrated Sustainability Assessment

We, Carmarthenshire Residents’ Action Group, are responding to the public consultation on the Carmarthenshire Local Development Plan 2018-2033 (Second Deposit) (‘Revised LDP’) to raise concerns with regard to the plan making process in relation to landscape(s) within the LDP’s geographical area. We request several changes to the plan on the basis that we consider the plan not to be sound and request the opportunity to make representations during the examination process.

This letter contains a series of comments and objections in relation to landscape policies, and approach to policy making with regard to landscapes, within Carmarthenshire’s Revised LDP drafting process, including the Integrated Sustainability Appraisal (‘ISA’).

This letter also consolidates a series of comments made via the online comments portal on the proposed Revised LDP. It refers Carmarthenshire’s Forward Planning Department and, in due course, the appointed Examination Planning Inspector, to Carmarthenshire Residents Action Group’s petition to maintain the Special Landscape Areas within the 2018-2033 LDP. This petition has raised 438 signatures, details of which are contained within Appendix 1 of this letter.

A strong objection is raised, backed by significant local support, to the removal of Carmarthenshire’s locally designated Special Landscape Areas within the Revised LDP. Objections are also raised with regard to the replacement landscape related policies in the second Deposit Revised LDP with materially weakened policies compared to the existing 2006-2021 LDP (‘Current LDP’). The letter also raises concerns with regard to the assessment carried out in the ISA as it pertains to the Sustainability Objective on Landscape.

The 18 Special Landscape Areas should be reinstated in the LDP and more detailed and nuanced rules put into place to managed the competing desires of renewable energy production and the ecological, heritage, tourism, employment, farming and residential needs. If a new alternative form of landscape protection is desired this should be devised, created and approved alongside the adoption of this LDP, not afterwards to avoid areas being left without protection in the meantime. Full disclosure of why areas are and aren't selected should be provided.

What grounds are there to remove all 18 of Carmarthenshire's Special Landscape Areas? Has the condition and 'special' nature of these areas suddenly degraded? Removing the SLA status leaves these areas unprotected by the extra planning sensitivity & consideration and care that their uniqueness requires. The current SLAs help safeguard the landscape and preserve it's character for the future. Why is this no longer an aim and commitment of Carmarthenshire's councillors? The only apparent benefit appears to be to large non-Welsh renewable companies who wish to build large scale developments with as few restrictions and little expense as possible.

If these areas aren't protected from large scale developments, Carmarthenshire will lose some of it's most valuable natural and historical assets. Other sections of the LDP highlight the importance of encouraging and preserving Carmarthenshire's tourism economy - these SLAs are the special and unique areas that attract visitors to Carmarthenshire.

Given the move towards renewable energy and the inevitable indelible costs such developments would have on Carmarthenshire's landscapes we need a more detailed, more granular, more nuanced approach to Carmarthenshire's landscapes, to ensure such developments only go ahead in areas that are not highly sensitive or special. This LDP does the opposite, by stripping all protection and offering a signed blank check for the whole of Carmarthenshire. It is not following the county's, the land's or the residents' best interests.

This plan should be changed immediately to retain these Special Landscape Areas. It is plain common sense to keep this in place until it is seamlessly superceeded, if necessary, by an equivalent designation.

I strongly believe that the Special Landscape Areas should be kept, and I worry that without this protection many of our beatiful areas could be exploited by wind and solar farm developers. This has become an urgent issue in the SLA designated Tywi valley, with proposals by Bute Energy / GreenGen to construct massive metal pylons from New Radnor to Llandyfaelog.
There may well be a gap between replacing this Special status with something else that could potentially allow these developers to push through their planning proposal.

The Special Landscape Area designations should be kept in the Local Development Plan for all 18 SLA regions currently protected. This would reassure Carmarthenshire residents that the Council are formally committed to the objective of protecting the aesthetic beauty of our unique historical and natural landscape, as an evidenced, formal policy position of the council. It Would also demonstrate a joined-up, long-term approach that recognises the beauty of the area is inherently linked to the Carmarthenshire's economic strategy based on leisure and tourism. Otherwise, our area will be at risk of costly and wasteful retrospective investment in 'future landscape enhancement' projects after aesthetically damaging developments (e.g. pylons network), as is currently the case with the National Grid in the Dwyryd Estuary.

I do not believe there should be any time frame where the Special Landscape Area that has been designated is removed without something more robust being put into place.
The Special Landscape Area (SLA) designation provides protection for locally significant and attractive landscapes that are of comparable quality to Areas of Outstanding Natural Beauty (AONB). They should be protected and enhanced, particularly through planning processes in Carmarthenshire. I object to Carmarthenshire County Council's proposals to remove the SLA designations in the proposed revisions to the LDP, as doing so is an expression that Carmarthenshire County Council are actively de-prioritising the protection of the landscape in its local plan. This is particularly concerning given these proposals coincide with current proposals for a distribution network of pylons and potential for further wind farms across the Tywi valley. Removing SLA designations at the same time that plans are being proposed for pylons across the county indicates to Carmarthenshire residents that the Council are paving the way to approve the pylon network, as they will not be in contradiction with the removed SLA status. While SLAs are more of a policy position than a statutory protection, they nevertheless remain an important protection in any planning process, as National Resources Wales have indicated their concerns in writing to you at the proposed removal of SLAs. I therefore strongly object to any removal of SLA for all 18 SLA regions currently protected, and would reassure residents that Carmarthenshire County Council seek to protect our special historical and natural environment.

I request that the 18 Special Landscape Areas are reincorporated into the Revised LDP before adoption.

I object to weakening of landscape protection through removal of the Special Landscape Area designations contained in the 2006-2021 Local Development Plan ('Current LDP'). I further submit that the plan-making process is unsound – lacking transparency with an absence of explanation or justification of the decision.

The Current LDP recognises 18 Special Landscape Areas: ‘landscapes in Carmarthenshire that are considered to be of greatest importance, and which are worthy of the protection that the designation of Special Landscape Area provides’. (See: http://www.cartogold.co.uk/CarmarthenshireLDP/english/text/Appendix-4.htm)

As Natural Resources Wales explains: Special Landscape Areas are ‘designated for intrinsic physical, environmental, visual, cultural and historical value in the contemporary landscape. Designated SLAs may be unique, exceptional or distinctive to the area and included in a Local Development Plan (LDP) to apply an extra level of protection through special landscape policies’. (See: https://naturalresources.wales/media/680613/landmap-guidance-note-1-landmap-slas-2017.pdf)

In the case of the Tywi Valley, for example, the Current LDP highlights that ‘[i]nappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation’ . (See: http://www.cartogold.co.uk/CarmarthenshireLDP/english/text/Appendix-4.htm)

The current LDP was adopted in 2014. Almost a decade on, inappropriate development continues to threaten this outstanding landscape: not least in proposal for construction of 27m-high pylons through the Valley as part of the Green GEN Towy-Usk project and to which Carmarthenshire County Council has expressed its opposition. Likewise, our Community Councils are alert to the conservation threats – opposing inappropriate development and pointing to the ‘significant detrimental effect ... on the natural beauty of the Valley and its rich history’ . (see: https://manordeilosalemcc.org.uk/minutes.php)

We challenge the timing of removal of the Special Landscape Area designation, when needed most to protect and enhance our special landscapes in Carmarthenshire for present and future generations.

We also question the rationale and evidence base for this decision, which has not been made explicit in the published Written Statement or accompanying Evidence Base of the Revised LDP.

As Natural Resources Wales indicates, there are several reasons for SLA designation :

• To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place/bro.
• To influence positive landscape planning. For example by producing design guidance to enhance landscape character or to target land management grants towards the conservation of special landscape features recognised within the SLA.
• To raise understanding and appreciation of the importance of local landscapes by communities, visitors and the wider public.

In light of which, it is reasonable to ask:

Is the Bran Valley no longer considered of importance and worthy of protection afforded by Special Landscape Designation? If so, why?

Has the intrinsic physical, environmental, visual, cultural and historical value of Mynydd y Betws declined in the past decade so as to warrant removal of an extra level of protection? Again, if so, why?

What of the locally valued landscape of the Teifi Valley and its distinctive character, qualities and sense of place? Why are these less important in 2023 than hitherto?

Is it really no longer desirable to use SLA status to raise understanding and appreciation by communities, visitors and the wider public of Carmarthen Bay and associated estuaries?

… and so on for each of the respective 18 Special Landscape Areas so designated in the Current LDP but removed in the Revised LDP.

The rationale for removal in the Revised LDP of the SLA designation – wholesale in principle and individually in practice for each of the 18 landscapes – is unclear. Evaluation of implementation of the Current LDP has not questioned the effectiveness of SLA Policy EQ6: quite the opposite, indicating that targets have been achieved or exceeded, placing implementation in the ‘green’ in assessment using a traffic light reporting tool . Indeed, at the time of the LDP Review (published in 2018), the report indicates: ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy’ . (See: https://www.carmarthenshire.gov.wales/media/1213042/ldp-review-report-english-version.pdf?v=201802051058510000)

What, therefore, are the contextual, factual and evidential circumstances that have resulted in this fundamental change resulting in removal of the 18 Special Landscape Area designations in Carmarthenshire?

Welsh Government planning policy continues to seek to maximise environmental protection and to limit environmental impact in respect of distinctive and special landscapes - encouraging local authorities to develop ‘policies for landscape features, characteristics and qualities of local significance, and the designation of Special Landscape Areas (SLAs)’ . (See: https://www.gov.wales/sites/default/files/publications/2021-02/planning-policy-wales-edition-11_0.pdf)

Welsh Government policy in respect of SLAs has not changed: why has that of Carmarthenshire Council?

I therefore ask that Carmarthenshire Council makes public the evidence base for this fundamental policy change.

As remedy, I request that the 18 Special Landscape Areas are reincorporated into the Revised LDP before adoption.

Further to provisions in Welsh Government procedural guidance , I also request opportunity to speak on this representation at a hearing session of the LDP examination. (See: https://www.gov.wales/local-development-plan-examinations-procedure-guidance-html)

Include SLAs in the Plan

I write on behalf of the Llangadog Community Council, who attended the Drop-In Session on 7th March 2023, at Llangadog Community Centre.

On checking the current Revised Local Development Plan, it was clear that the Special Landscape Areas in the LDP, for Llangadog had been omitted? And not only omitted for the Llangadog area but omitted on all of the original 18 areas in the previous LDP. On questioning the reasons as to why, it was given that the SLAs would be “ replaced with policy BHE2- intended to maintain, protect and where appropriate enhance the character and quality of the landscape – The intention is to strengthen our policies on landscapes.”

We are greatly concerned about these changes were not in place before the Revised Plan was published. Until the Carmarthenshire County Council can produce a stronger policy to protect ANOB both locally in Llangadog and throughout the county, we therefore urgently request that all the Special Landscape Areas on the previous LDP are re-instated into the Revised Local Development Plan before it is finalised.

Amend Plan

I write due to concerns over the removal of Special Landscape Areas from the 2nd Deposit rLDP (rLDP2) and the potential harmful impact this would have on these unique landscapes.

Paragraph 6.3.13 of Planning Policy Wales (PPW) states that Special Landscape Areas (SLAs) are non-statutory designations that define local areas of high landscape importance, which may be unique, exceptional or distinctive to the area. It goes on to state that planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.

Carmarthenshire Local Development Plan 2006 - 2021 (LDP) designated a number of SLAs. Within the LDP it states that the SLAs represent a non-statutory designation which were identified following a formal assessment of the landscape qualities of the County. The SLAs are largely assessed as outstanding or high in NRWs LANDMAP with regards to scenic quality. The LDPs policy EQ6 specifically related to SLAs and sought to ensure that proposed development enhanced or improved SLAs.

In monitoring policy EQ6 the Annual Monitoring Reports (AMR) noted that either no or less than 5 developments were approved contrary to NRW or Landscape Officer advice. This demonstrated that the policy was working and was protecting the SLAs.

From reviewing the evidence base and supporting documents for the rLDP2 I can find no reasoning or evidence as to why the SLAs have been removed from both the written statement and proposals maps. No information has been provided to detail why the Council now consider that such designations should not apply nor why they consider that normal planning policies would offer the necessary protection. No formal reassessment of the landscape has been undertaken. This is particularly important when the AMR has confirmed that policy EQ6 was working and meeting its required targets. The SLAs identified in the LDP and supported by their own policy safeguarded unique areas of landscape that are of high and outstanding scenic quality.

I attended one of the rLDP2 drop-in sessions where I raised concerns over the removal of the SLAs. I was advised that a Supplementary Planning Guidance (SPG) would be produced to cover the matter of SLAs. I note however, that it was an intention of the LDP for an SPG to be produced on SLAs (para 6.6.40) however, this has never transpired, which leads me to be concerned that the proposed SPG will never emerge, leaving these important landscapes unprotected.

Importantly, an SPG does not have the same status or weight as adopted Development Plan policies, and can only be taken into account as a material consideration in determining planning applications. A specific policy regarding SLAs should be produced, along with relevant maps, in order to safeguard these valued landscapes.

Amend plan to include SLAs

I just want to express my concern that the new LDP (BHE2) makes no provision for special landscape areas. I live in the valley which is rich in wildlife, beautiful scenery & historical sites. I do not want to see this spoiled by new units with developments or structures like electricity pylons. It will not only spoil the landscape & environment but also be disruptive to the tourism in the area that many peoples' businesses depend on.
Please please make sure that our historical & unique landscapes are not spoiled.

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’

Reinstate Special Landscape Areas as set out in the current LDP.

Carmarthenshire Residents’ Action Group: Representations to the public consultation of the Second Deposit Revised Carmarthenshire Local Development Plan 2018-2033 and the Integrated Sustainability Assessment
We, Carmarthenshire Residents’ Action Group, are responding to the public consultation on the Carmarthenshire Local Development Plan 2018-2033 (Second Deposit) (‘Revised LDP’) to raise concerns with regard to the plan making process in relation to landscape(s) within the LDP’s geographical area. We request several changes to the plan on the basis that we consider the plan not to be sound and request the opportunity to make representations during the examination process.1
This letter contains a series of comments and objections in relation to landscape policies, and approach to policy making with regard to landscapes, within Carmarthenshire’s Revised LDP drafting process, including the Integrated Sustainability Appraisal (‘ISA’).
This letter also consolidates a series of comments made via the online comments portal on the proposed Revised LDP. It refers Carmarthenshire’s Forward Planning Department and, in due course, the appointed Examination Planning Inspector, to Carmarthenshire Residents Action Group’s petition to maintain the Special Landscape Areas within the 2018-2033 LDP. This petition has raised 438 signatures, details of which are contained within Appendix 1 of this letter.
A strong objection is raised, backed by significant local support, to the removal of Carmarthenshire’s locally designated Special Landscape Areas within the Revised LDP. Objections are also raised with regard to the replacement landscape related policies in the second Deposit Revised LDP with materially weakened policies compared to the existing 2006-2021 LDP (‘Current LDP’). The letter also raises concerns with regard to the assessment carried out in the ISA as it pertains to the Sustainability Objective on Landscape.
Our representations are set out as follows:
1. Objection to the removal of Special Landscape Areas from the Revised LDP;
2. Inadequate Evidence Base;
3. Revised LDP Policies;
4. Specific suggested amendments to Revised LDP Policies;
5. Adequacy of the assessment Integrated Sustainability Appraisal as it concerns Landscape; and,
6. Conclusion
1 It is noted that Welsh Government Local development plan examinations: procedure guidance (28 November 2022) states in paragraph 1.7 that ‘Those who have sought changes to the submitted plan or plan revisions and have indicated that they would like to speak must be invited to the hearings.’

1. Objection to the removal of the Special Landscape Areas from the Revised LDP
‘The use of non-statutory designations such as Special Landscape Areas to protect areas of landscape value has long been a policy tool within the UK planning system. They have been seen by local planning authorities as a means of protecting sensitive landscapes and in developing an understanding and awareness of those features and characteristics that give a locality its sense of place.’2
Carmarthenshire’s 18 Special Landscape Areas (‘SLAs’) listed under Policy EQ6 in the Current LDP have not been carried forward into the Revised LDP.
We recognise that SLAs are a local non-statutory designation, however these areas are an acknowledged designation which carries weight within the Current LDP as a standalone policy. SLAs are also acknowledged and given weight within neighbouring Local Planning Authority (‘LPA’) LDPs.3 The weight given to the SLA designations is recognised across Appeal decisions by the Planning Inspectorate and in Planning Inspectorate recommendations with regard to Development Consent Order applications.4
We object to the Second Deposit LDP on the basis of the removal of the SLAs and request that SLAs are reintroduced into the Revised LDP, either as a standalone policy or that provision is made within the new Policy BHE2: Landscape Character.
This could be achieved by an amendment to Policy BHE2: Landscape Character to add wording as follows:
Proposals must take account of Carmarthenshire’s locally designated Special Landscape Areas (as set out in Appendix X (Appendix 4 of the Current LDP) and shown on the Policies Map). Development proposals will only be permitted where there is no significant adverse impact, including cumulative impact, on the character and quality of the landscape. Development proposals should aim to protect and enhance the features for which the SLA has been designated.
Where appropriate, a Landscape Impact Assessment will be required to assess and justify the impact of the development on Landscape Character and/or the designated area.
In exceptional circumstances, where development is necessary and could result in a significant landscape impact, appropriate mitigation and enhancement measures should be provided, including the undergrounding of associated infrastructure where possible.
Our suggested wording is similar to the City of Swansea LDP which was successfully adopted following Examination in February 2019.5 Appendix 4 of the Current LDP would remain relevant to the Revised LDP and could be brought across, with edits as necessary to increase the robustness of the assessment of the area’s character. SLAs could be added back into the Policies Map, with minor boundary edits as necessary.
2 Bridgend County Borough Council, Designation of Special Landscape Areas, March 2010
3 City of Swansea LDP (adopted February 2019), Ceredigion LDP (adopted 2013)
4 Including, but not solely, APP/M6825/A/12/2189697, APP/M6825/X/13/515763 & APP/M6825/X/13/515764; and Brechfa Forest Connection DCO application ref EN020016;
5 https://www.swansea.gov.uk/article/9914/Swansea-Local-Development-Plan-2010-2025-LDP

Reasons for retention
The retention of the SLAs in the Revised LDP is well supported, with 438 people resident within the county signing Carmarthenshire Residents’ Action Group’s petition.
We argue that the retention of the SLAs is important to fulfil to objectives of the LDP and question if the SLAs are removed if the plan meets its Sustainability Objectives on Landscape set against the baseline criteria. We do not consider that a robust, proportionate and credible case has been set out by the LPA for the removal of this landscape designation. We consider that the removal of the SLAs significantly weakens the Revised LDP’s SO9 regarding sense of place and impacts Carmarthenshire’s planning framework in terms of delivering on sustainable development on the basis of the Well-being of Future Generations Act.
By designating SLAs it is easier for communities, visitors and tourists to engage with the highest value landscapes of Carmarthenshire. The SLA designations are reflective of the local value communities place on these landscapes in a manner not captured in the replacement Policy BHE2: Landscape Character. This revised policy places too much reliance on LANDMAP assessment. Whilst LANDMAP is an excellent tool for those engaged with the planning process, it is harder to engage with than the specifically designated SLAs which have clear and geographical boundaries capturing the outstanding and high quality landscapes of Carmarthenshire. The removal of the SLAs, and their removal from the Polices Map, invariably makes it makes it harder for specific communities and the wider public to engage with the LDP and weakens community representations as part of the planning consultation processes for individual development applications.
We consider that the SLAs improve the delivery of the Revised LDP objectives. Natural Resources Wales (‘NRW’) states that ‘there may be more than one role for an identified SLA: To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place / bro; To influence positive landscape planning. […]; To raise understanding and appreciation of the importance of local landscapes by communities, visitor and the wider public.’ The SLAs currently provide these roles and retaining them in the Revised LDP would better meet the LDP and ISA Objectives.
The developmental pressures on the landscape have not weakened in the time between the Current LDP adoption and the Revised LDP drafting. The Current LDP Appendix 4 assessment of SLAs specifically states in relation to the Tywi Valley, that ‘Inappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation.’ We do not see that these reasons for designation have weakened. However, if the LPA consider otherwise, then the evidence of this decision making process should be published.
Planning Policy Wales 11 (‘PPW11’) paragraphs 6.3.12 and 6.3.13 relate to the characteristics of local landscapes. These paragraphs highlight the ability for LPAs to designate SLAs. Paragraph 6.3.13 states that ‘Planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.’ Given that pressures on the landscape have not weakened and that the existing SLAs have proven weight in the planning determination process, we consider that the removal of the SLAs in the Revised LDP runs contrary to this part of PPW11.

Compatibility with Policy and Guidance
In addition to the point with regard to PPW 11 above, our view is that the SLAs are wholly compatible with the Revised LDP, the proposed Policy BHE2: Landscape Character and can be seamlessly incorporated into this policy, or alternatively, the existing policy could be retained in the Revised LDP.
NRW LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, endorses a dual approach to landscape management, in line with our suggested edits to the Revised LDP Policy BHE2: Landscape Character. On page 3 of the document, it is stated that ‘in this dual approach, all landscapes will be underpinned equally by LANDMAP […] but in addition to this, landscapes of high local importance will be specifically identified as a SLA with additional guidance being produced for these key landscapes’.
We recognise that there is potential tension between the SLA designation of Llanllwni Mountain SLA and the Cothi Valley SLA, and that these areas are also within the Pre-Assessed Area for Wind Energy in Future Wales 2040 the National Development Plan (‘NDP’). We argue that the SLA designation of these areas is not in conflict with the NDP, including Policies 17 and 18. However, we recognise that this is an area of the Revised LDP which may benefit from further exploration at Examination and we would appreciate an invitation to make representations on this issue.

2. Inadequate Evidence Base
The Issues, Vision and Options paper makes it clear that this 2018-2033 LDP is a review of the previous LDP and not a new local plan (para 1.3, page 2, Issues, Vision and Options Topic Paper, February 2023). There is a general expectation in plan making that evidence is front-loaded. As the Revised LDP revises the Current LDP, it is reasonable to expect that the entire removal of locally designated SLA from the plan should be carried out on a sound, evidence backed, basis. Statements by the LPA during the plan making process did not indicate that SLAs would be removed from the plan at Review or Preferred Strategy stages. The weakening of the landscape policies and the removal of SLAs was not revealed until the publication of the First Deposit LDP in early 2020. Prior to the publication of the First Deposit LDP, the LPA indicated that further evidence would be published if the policy were to be changed.
The 2006-2021 LDP Review Report 2018 did not raise concerns about the effectiveness of the SLA Policy, giving it a green colour coding indicating the policy target was being achieved or exceeded. The report stated in paragraph 9.141 that ‘The Plan identifies Special Landscape Areas (SLAs) within Policy EQ6. These were identified following a formal assessment of the landscape qualities of the County and are a non-statutory designation. It is noted that the policy places an emphasis on enhancement and improvement. There may be opportunities to supplement and/or review the supporting evidence for this policy and explore those wider linkages (e.g. the renewable energy policies and those design related policies).’
Further, Appendix 1 of the Review Report reviewing specific policies states that in relation to Policy EQ6 SLAs that ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy.’ This wording is a standard response to policies which were expected to be kept in the Revised LDP close to their current form. It is difficult to ascertain how the
removal of the SLAs does not constitute a fundamental change, to a degree where evidence justifying this change would reasonably be expected to be published.
Following on from the review, the Preferred Strategy was published in 2019. The Preferred Strategy gave no indication of the intention to remove the SLAs from the Deposit Plan and gave significant indication that landscape policies would remain strong within the Revised LDP. Issue 8 of the LDP issues is ‘Rich landscape or townscape qualities’; the Vision states that ‘rich cultural and environmental qualities are valued and respected’; paragraph 10.19 states that ‘the LDP will promote the principles of sustainability by: Protecting and enhancing biodiversity, townscapes and landscapes’; ‘A New Strategy – Key Components’ paragraph 10.20 states that ‘the key components of the strategy are as follows:’ one of which is to ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes’.6
Given these statements, it would not be unreasonable to expect that the SLA policy would remain in the Revised LDP, particularly given specific reference to the protection of high value landscapes. The means of recognising and protecting the areas of outstanding and high value landscapes in the LPA’s geographical area is specifically the Current LDP’s SLA policy.
Furthermore, in response to a representation made on the Preferred Strategy, the LPA stated ‘The consideration of whether any Special Landscape Areas will be identified in the Revised LDP, along with any resultant evidential facets, will be a matter for the deposit LDP.’ [our emphasis].
In our view, it is reasonable to consider that prior to the First Deposit Plan publication that the full SLA policy, or a slightly revised version of it, would remain in place in the new LDP; or that evidence would be published alongside the Deposit Plan to justify removal of the SLA policy given the LPAs statements in the Plan Review and the response to the Preferred Strategy public consultation. Therefore, given the above timeline indicates a very late decision to remove the SLAs from the Revised LDP, we question whether the decision has been carried out with robust, proportionate and credible evidence.
What evidence has been used?
At the date of this letter, the LPA have not provided information within the Plan Evidence Base, as accessed online, for the decision to remove the SLAs from the LDP; nor the evidence that the new landscape Policy BHE2: Landscape Character sufficiently delivers on the aims of the New Strategy which includes the key component to protect and enhance high-value landscapes.
Assessments which have been published by the LPA in relation to Landscape Character are due to expire when the new LDP is adopted. These comprise existing assessments of the SLA areas in Appendix 4 of the Current LDP; there is a reference to NRW’s 48 broad scale, not locally specific, National Landscape Character Areas (NLCA), and the SLAs within the Placemaking and Design SPG (adopted 2016); and consideration of landscapes in the Carmarthenshire Wind Turbine Development Landscape Sensitivity and Capacity Study, prepared by Anthony Jellard Associates.
The SLAs are removed from the Revised LDP. The Placemaking and Design SPG is not slated to be carried forward with the new Revised LDP7. The current status of the Anthony Jellard study is unclear,
6 These parts of the Preferred Strategy are carried into the Second Deposit LDP, February 2023, and are found across Chapters 5-9.
7 See Appendix 3, Second Deposit LDP 2018-2033
it is referenced within the current Wind and Solar SPG; however this SPG is not intended to be carried forward as part of the Revised LDP. The removal of these assessments is likely to leave a gap with regard to the protection and enhancement of landscapes when the new Revised LDP is adopted.
Given the anticipated expiry of these assessments, it is not credible that they can form part of an evidence base for the creation of the Revised LDP policies. No evidence has been provided that any other assessments have been carried out in forming the LPAs landscape character policy or that NRW’s LANDMAP has been utilised to inform revised policy preparation. The Revised LDP states that a Landscape Character Assessment SPG is proposed to be adopted by Summer 2025, but as no draft has been published this does not form part of the evidence base. The target Revised LDP adoption date is Autumn 2024 and with the SPG proposed for Summer 2025, this leaves a significant gap around landscape policy guidance in the interim, even if the Landscape Character SPG is published on time.
The LPAs Cabinet Member for Planning has responded to a question on the evidence base by discussing assessment of development proposals utilising information contained within NRWs LANDMAP. However, this is an existing means of assessment in the Current LDP and will be retained as a means of assessing change to landscape in the Revised LDP, as such it does not make a difference to the baseline. Notably, the question asked to the Cabinet Member for Planning was with regard to the evidence around the formation of new Policy BHE2 and the removal of the SLAs, to which she did not furnish an answer. 8
Finally, the lack of published evidence relevant to the landscape policies of the Revised LDP appears to be in conflict with paragraph 6.3.21 of PPW 11, which states ‘Planning authorities should draw upon LANDMAP in the preparation of landscape plans and assessments needed to inform development plans, SPGs and the development management process. LANDMAP assessments should be published.’ [our emphasis]
In our view, the evidence base for the Revised LDP in terms of Landscape Policy is not sufficiently substantiated and we request that this is interrogated by the Inspector appointed for the Examination.

3. Revised LDP Policies
We argue that the Revised LDP policies are substantively weaker with regard to landscape protection and enhancement than the Current LDP Policies. Comparison of similar policies in relation to placemaking, sustainability, high quality design, landscapes and features of importance, landscape character and renewable energy, between the Current LDP and the Revised LDP, show fewer mentions of the need to ‘preserve or enhance’, that development ‘must’ meet certain criteria, that development ‘will only be permitted’ if specific criteria are met, and the clear setting out of designated Special Landscape Areas with the expectation that development should enhance or improve these areas.
This is in contrast to the Revised LDP which uses wording such as ‘should relate to’, maintaining ‘overall integrity’, ‘development shall demonstrate’, that ‘development must acknowledge’ and ‘demonstrate a clear understanding’. Whilst it is acknowledged that this can be a more positive way of forming LDP policies and there are good reasons for this approach, it would be erroneous to suggest
8https://democracy.carmarthenshire.gov.wales/ieListDocuments.aspx?CId=131&MId=6351&Ver=4 [accessed 14 April 2023]
that these changes do not make the Policies easier for development to be consented and weaker in some instances. In our view, this is notably the case with regard to landscape protections and most significantly the removal of a whole policy layer designating Special Landscape Areas. With regard to landscape there is a question if the Policies as currently drafted are sufficiently robust to deliver on the Issues, Vision and Objectives of the plan, as well as key components of the Strategy.
We appreciate that Policies SP12: Placemaking and Sustainable Places and BHE2: Landscape Character, do contain some landscape protections. However, with the removal of the designated SLAs the Revised LDP remains materially weaker with regard to the protection of Carmarthenshire’s highest quality landscapes (outstanding and high value). This is especially the case prior to the publication of the promised Landscape Character SPG, and without publication of this SPG in draft form before examination it is difficult to fully consider the likely strength of these policies.

4. Specific suggested amendments to Revised LDP Policies
In addition to the objection to the removal of the SLA policy and suggestions for its reintroduction, we have the following additional comments on the Revised LDP.

Object. Strategic Policy – SP12: Placemaking and Sustainable Places
Policy point f) ‘Exhibit and demonstrate a clear understanding of the existing local landscape context, natural and built heritage, local character and sense of place.’
Proposed change to ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’
This change would deliver the key components of the New Strategy more convincingly in relation to this Policy, one of which is ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes.’ It would also deliver Strategic Objective 9 (SO9) more convincingly. SO9 aims ‘To protect and enhance the diverse character, distinctiveness, safety and vibrancy of the County’s communities by promoting a place making approach and a sense of place.’ Currently the specific phrase ‘protect and enhance’ only features in Strategic Policy SP14: Maintaining and Enhancing the Natural Environment which is only one component of the County’s diverse character. Variations of protect and enhance feature elsewhere in the written statement and there is benefit in bringing SP12 more into line with these.

Object. PSD1: Effective Design Solution: Sustainability and Placemaking. Policy point d) states ‘Quality landscapes design solutions’, this appears to be a typo where ‘landscape’ fits better. In our view, for policy point d) to work effectively, either reference to a published Landscape Character SPG, or reference to NRW LANDMAP (especially the Visual and Sensory assessment layer) should be made within this Policy or in the accompanying notes. This would benefit from explicitly stating that it applies to all development, including infrastructure, Renewable and Low Carbon developments, as well as buildings, transport, excavation sites, and smaller scale landscape proposals in the private and public realm.

Object. BHE2: Landscape Character. The use of ‘overall’ in the policy substantively weakens its protection of the landscape character. We request that this word is removed. It is unclear in the current presentation of the policy if the onus is on the applicant to identify the landscape character of the ‘local area’ through their own assessment, or if NRWs LANDMAP data is to be used, or if the
LPAs own Landscape Character SPG is to be used. This should be more explicitly set out and clarified. If the expectation is that the Landscape Character SPG is the baseline then it would be beneficial for this to be published in advance of the Revised LDPs adoption, preferably at the time of Examination. Reference to the Landscape Character Assessment should also be made in the Policy text.
It is also unclear where the key landscape views and vistas mentioned in point e. are set out, in order for them to be protected in the policy. If these are due to be identified in the Landscape Character SPG then, again, this would benefit publication prior to plan Examination.
We also request that reference to SLAs are added into this policy, as set out in section 1 of this letter.

Object. Policy CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and presumption of consent for renewable development proposals by communities, as well as those already set out for large scale wind farms. We suggest that the following are added to the policy:
d. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
e. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
f. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
g. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Policy CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and explicit presumption of consent for renewable development proposals from communities. We suggest that the following are added to the policy:
b. [add]… , including SLAs;
g. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
h. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
j. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
k. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Table 9 Resource Summary for Renewable Electricity. The Onshore Wind Target to deliver 588.5 MW of additional installed capacity by 2033 is in our view unrealistic given there has not been a call for sites for wind power. By our calculations, extrapolating from the evidence base document, AECOM Renewable and Low Carbon Energy Assessment Section 4.3, delivery of this target may require 75% of the area unconstrained by features such as buildings, roads and rivers in the Pre-Assessed Area in north Carmarthenshire to be developed for onshore wind.9 Given the mix of landowners and small scale farms across this area, delivery of the target may be challenging without large scale land purchases, which would not be feasible or desirable for smaller scale community wind developers. This policy is likely to result in more large scale multi-national corporation wind farm developments across Carmarthenshire. This is notwithstanding the scale of significant adverse impacts, including cumulative impacts, on the landscape a target like this will create.

Object. Policy CCH6: Renewable and Low Carbon Energy in New Developments. This policy could be more ambitious helping to deliver Net Zero targets by requiring all new housing or commercial development to fit solar panels to roofs, unless it is demonstrated by the applicant that to do so would not be viable, or if by doing so would conflict with other policies in the Revised LDP (such as built heritage, townscape or landscape policies).
Object. Policy CCH7: Climate Change – Forest, Woodland and Tree Planting. Specific reference should be made in the policy text to native trees and that planting schemes much be appropriate to the cultural and ecological character of the locality. This is referenced in paragraph 11.534, however due to the large ecological and landscape impacts that can arise from non-native tree planting, in our view the wording should be directly within the policy text.
The AECOM assessment estimates that the Pre-Assessed Area in Carmarthenshire, identified in Future Wales 2040, covers an area of 687 km2. The report assumes a maximum of 5 2MW turbines per 1km2 of land. Applications for new onshore wind at scale is more likely to be focused within the Pre-Assessed Areas due to the favourable planning framework for these locations. The Revised LDP target for installed capacity is an additional 588.5 MW, which using AECOM’s calculations would need to cover a land area of 58.85 Km2, or, 14,542 acres, equivalent to 8.5% of the Pre-Assessed Area. Taking into account the expected delivery of the remaining capacity in the former TAN 8 SSA, there is the expectation that 54.83 km2 will be delivered on a total possible unconstrained area of 73.1km2, or 75% of the unconstrained land in the Pre-Assessed Area. For the purposes of the AECOM study the constrains are National Parks, Natura 2000 sites, Buildings, Roads, Rivers, the TAN8 SSA and Topple Distance buffers applied to buildings, roads and rivers. Calculations taken from data within page 29 and 30 of the AECOM Renewable and Low Carbon Energy Assessment published in the LDP Evidence Base.

5. Adequacy of the Integrated Sustainability Appraisal assessment as it concerns Landscape
We are raising substantive concerns with regard to the robustness of the assessment carried out in the Integrated Sustainability Appraisal (‘ISA’).
The Sustainability Appraisal Scoping Report (published July 2018) set out the parameters of the Sustainability Appraisal, identifying Sustainability Issues and Opportunities, Sustainability Assessment Objectives and Decision Making Influences. This identified Landscape as number 9 of a total of 15 equal issues. Issue 9 is set out as follows: ‘There are several sites designated as of landscape or townscape value within the county. These features need to be protected, and where possible enhanced.’ In the Decision Making Influences, the question, ‘Will the LDP have a positive or negative impact on designated landscapes?’ is posed.
Linking these two quotes is the specific mention of ‘designated landscapes’, not statutory designated, nor ‘Designated’ noun. Special Landscape Areas are considered designated landscapes in this definition. This is the case in comparable LPAs in Wales, PPW11 para 6.3.12 refers to ‘the designation of Special Landscape Areas’ and the Current LDP Policy EQ6 states that ‘Special Landscape Areas are designated…’. Thus, references to designated landscapes in the Sustainability Appraisal, must take into account local as well as statutory designations, including SLAs. The question ‘will the LDP have a positive or negative impact on designated landscapes?’ and that the Revised LDP removes some of these designated landscapes, is an important consideration for the assessments in the Sustainability Appraisal.
Sustainable development is defined in the Well-being of Future Generations (Wales) Act 2015 as the ‘process of improving the economic, social, environmental, and cultural wellbeing of Wales by taking action.’ A change to the development plan which removes some designated landscapes should be considered carefully and assessed robustly on the terms that those designations have been removed, to demonstrate that the change is not an impairment to sustainable development.
Turning to the latest version of the ISA, published February 2023. The prediction of the effects of the plan involves identifying changes to the environmental baseline. The baseline for sustainability objective ISA9 – Landscape is set out in ISA Appendix B (pp.61-67) with the other baseline assessments. This baseline constitutes an introductory paragraph explaining that the Brecon Beacons National Park sits outside the LDP boundaries, along with a copy of the Current LDP Appendix 4 Special Landscape Areas assessment in full, then proceeds to state the ‘Predicted effect without implementation of the LDP’.
In our view, this assessment of predicted effects has been carried out incorrectly. The predicted effects mention protected habitat and species and biodiversity, which are assessed under ISA2 Biodiversity, and fails to comment adequately on changes to landscape as a characteristic in and of itself. Crucially, this assessment fails to note that the locally designated landscapes, SLAs, will continue to be in effect once the Plan period expires. This is, in our opinion, a substantive omission especially given that the baseline text is comprised of Special Landscape Area descriptions and assessing areas noted as being ‘worthy of the protection that the designation of SLAs provides.’
Section 4 of the ISA sets out a summary of the environmental baseline and predicted effects, noting that the future baseline for landscape is declining. This summary has a stronger summarisation of the likely effect on landscape than that set out in the ISA Appendix and states clearly that ‘landscape
protection measures should be strengthened’. As this assessment is provided on the basis that the Current LDP continues to remain in place, the need to have measures strengthening landscape protection must be considered to be in addition to those already in place, including the designated SLAs.
As the ISA needs to take into account the effect of the Revised LDP being adopted, against the baseline of the Current LDP remaining, some assessment of the removal of the local designated SLAs would be expected in the ISA. However, Special Landscape Areas are not mentioned in the main text of the ISA, nor the ISA Appendices, outside of the Baseline and list of Abbreviations. Failure to take account of the loss of this designation from the LDP is, in our view, a major error and questions the credibility of the appraisal of predicted effects on ISA9 – Landscape, throughout the ISA document and brings into question the soundness of the Plan.
There are also other concerning errors and omissions. One example is the review of SP16: Climate Change and associated specific policies CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas and CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas, in Appendix F and G. The appraisal considers the effects on landscape to be ‘neutral’ and with ‘positive and negative effects’. This is not credible given the scale of change proposed to the landscape on the basis of the targets for new wind power generation by 2033, and this target set in the context of the removal of the SLAs from the LDP. A negative effect should be identified. Whether the negative effect should be acceptable on balance is a test that is separate to this specific part of the ISA. The ISA should credibly take into account the high magnitude of the changes, the Plan’s intention to remove the SLA designated landscapes, and the effect characteristics including the scale of cumulative effects, their special extent and their probability; all of which is high impact and likely.
Another example is the review of SP14: Maintaining and Enhancing of the Natural Environment, where the Appraisal comments against ISA9 state that ‘This policy directly refers to the protection and enhancement of Carmarthenshire’s landscape’ (ISA Appendix F, p.46). This policy does not do as the Appraisal states. The protection and enhancement is directed at the natural environment more generally, it is not a policy linked back to ISA9 in its monitoring objectives, and points more generally to a confusion throughout the Revised LDP between the character of landscape as a visual and integral whole vs smaller scale aspects which make up the natural environment, which are nonetheless important, but fundamentally different.

6. Conclusion
The removal of the SLA designations from the LDP cannot but be an adverse change. The failure to take account of this substantive change and substantiate why this is not a significant weakening of the LDP from its current form is of great concern.
We encourage Carmarthenshire’s Forward Planning Department to set this right before the LDP is examined and re-introduce the SLA designations into the Plan to address the issues raised in this letter, re-providing a substantive part of the means to protect and enhance our outstanding and high valued landscapes for future generations.
We re-iterate our request to make representations on the LDP examination on the subject of landscape, with regard to relevant policies.
We appreciate your, and the appointed Planning Inspector’s, consideration of this letter.

Amend policy

Re: Second Deposit Revised Local Development Plan Consultation – objection to weakening of landscape designations in Carmarthenshire

This submission is made as residents, in a family capacity, in response to public consultation on the Carmarthenshire Local Development Plan 2018-2033 (Second Deposit) (hereafter ‘Revised LDP’) to express objection to weakening of landscape protection through removal of the Special Landscape Area designations contained in the 2006-2021 Local Development Plan (hereafter ‘Current LDP’). On which issue, we further submit that the plan-making process is unsound – lacking transparency with an absence of explanation or justification of the decision.

The Current LDP recognises 18 Special Landscape Areas: ‘landscapes in Carmarthenshire that are considered to be of greatest importance, and which are worthy of the protection that the designation of Special Landscape Area provides
As Natural Resources Wales explains: Special Landscape Areas are ‘designated for intrinsic physical, environmental, visual, cultural and historical value in the contemporary landscape. Designated SLAs may be unique, exceptional or distinctive to the area and included in a Local Development Plan (LDP) to apply an extra level of protection through special landscape policies.
In the case of the Tywi Valley, for example, the Current LDP highlights that ‘[i]nappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation’3. The current LDP was adopted in 2014. Almost a decade on, inappropriate development continues to threaten this outstanding landscape: not least in proposal for construction of 27m-high pylons through the Valley as part of the Green GEN
1 Carmarthenshire Local Development Plan 2006-2021: Appendix 4 – Special Landscape Areas
2 LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, p2
3 Carmarthenshire Local Development Plan 2006-2021: Appendix 4 – Special Landscape Areas
Towy-Usk project and to which Carmarthenshire County Council has expressed its opposition4. Likewise, our Community Councils are alert to the conservation threats – opposing inappropriate development and pointing to the ‘significant detrimental effect ... on the natural beauty of the Valley and its rich history
We challenge the timing of removal of the Special Landscape Area designation, when needed most to protect and enhance our special landscapes in Carmarthenshire for present and future generations.
We also question the rationale and evidence base for this decision, which has not been made explicit in the published Written Statement or accompanying Evidence Base of the Revised LDP.
As Natural Resources Wales indicates, there are several reasons for SLA designation:
• To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place/bro.
• To influence positive landscape planning. For example by producing design guidance to enhance landscape character or to target land management grants towards the conservation of special landscape features recognised within the SLA.
• To raise understanding and appreciation of the importance of local landscapes by communities, visitors and the wider public.
In light of which, it is reasonable to ask:
Is the Bran Valley no longer considered of importance and worthy of protection afforded by Special Landscape Designation? If so, why?
Has the intrinsic physical, environmental, visual, cultural and historical value of Mynydd y Betws declined in the past decade so as to warrant removal of an extra level of protection? Again, if so, why?
What of the locally valued landscape of the Teifi Valley and its distinctive character, qualities and sense of place? Why are these less important in 2023 than hitherto?
Is it really no longer desirable to use SLA status to raise understanding and appreciation by communities, visitors and the wider public of Carmarthen Bay and associated estuaries?
… and so on for each of the respective 18 Special Landscape Areas so designated in the Current LDP but removed in the Revised LDP.
4 Cabinet Meeting 27 March 2023 webcast, Leader Cllr Price: ‘[in the last meeting] this Council unanimously agreed to oppose the pylons that are proposed for the Towy Valley’.
5 Llangathen Community Council Minutes 21 March 2023
6 Manordeilo and Salam Community Council Minutes 08 March 2023
7 LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, pp3-4
The rationale for removal in the Revised LDP of the SLA designation – wholesale in principle and individually in practice for each of the 18 landscapes – is unclear. Evaluation of implementation of the Current LDP has not questioned the effectiveness of SLA Policy EQ6: quite the opposite, indicating that targets have been achieved or exceeded, placing implementation in the ‘green’ in assessment using a traffic light reporting tool8. Indeed, at the time of the LDP Review (published in 2018), the report indicates: ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy
What, therefore, are the contextual, factual and evidential circumstances that have resulted in this fundamental change resulting in removal of the 18 Special Landscape Area designations in Carmarthenshire?
Welsh Government planning policy continues to seek to maximise environmental protection and to limit environmental impact in respect of distinctive and special landscapes - encouraging local authorities to develop ‘policies for landscape features, characteristics and qualities of local significance, and the designation of Special Landscape Areas (SLAs). Welsh Government policy in respect of SLAs has not changed: why has that of Carmarthenshire Council?
We therefore ask that Carmarthenshire Council makes public the evidence base for this fundamental policy change.
As remedy, we request that the 18 Special Landscape Areas are reincorporated into the Revised LDP before adoption.
Further to provisions in Welsh Government procedural guidance, we also request opportunity to speak on this representation at a hearing session of the LDP examination.

Many thanks for your time in considering our response to consultation on the revised LDP and our objection to weakening of landscape designations in Carmarthenshire.

Although not specifically stated, through reference to the "potential weakening of the Towi Valley status" it is implied that the Special Landscape Area status be retained for the Towy Valley.

The Towi Valley area including Llandovery and Llandeilo can be overlooked as a beautiful,
outstandingly breath taking countryside. Though it is unlikely that the area could be given a protection
as so much of the surrounding areas have designated status, this should not mean development in the
area. Everyone understands the need for sustainable development, and it is clear that renewable
energy is important. However when planning and reviewing plans the LA must consider the full
environmental and economic impact of development. For example the transportation of electricity from
the Welsh Boarder to Carmarthen could be installed at ground level along the existing railway line.
This could have additional economic benefits to Transport Wales and help sustain the railway. The
installation of Pylons to transport the electric is likely to impact the tourism potential of the area (which
already has to compete with two national parks and an AONB). The economies of the two towns need
the income from the tourism sector to make their businesses viable. It is important the any planning
documents or decisions reflect the need to protect the countryside and enhance its beauty not open it
up to development however sustainable it may appear. It is interesting that people wishing to achieve
off grid lifestyle development must submit complex applications whilst the potential weakening of the
Towi Valley status and the development of pylons appears to be linked, surprising as the community
appears strongly against this type of development in the area.

Amend Policy

Special Landscape Areas/Landscape Character Assessments

1) The existing LDP was adopted by the Council on 10.02.2014 for the period to 2021. Carms CC has been allowed by WG to continue to use the existing LDP until the second revised LDP is adopted by a resolution of elected councillors. WG has allowed a further period for consultation, as the first consultation was affected by Covid.
2) The current LDP will remain in place until the second revised LDP (2018-2022) is adopted by the Council.
3) The existing LDP contains a policy creating Special Landscape Areas. The policy is reproduced below:
Policy EQ6 Special Landscape Areas
Special Landscape Areas are designated in the following locations and as identified on the Proposals Map:
Tywi Valley
Carmarthenshire Limestone Ridge
Teifi Valley
Drefach Velindre
Bran Valley (North of Llandovery)
Mynydd Mallaen
Llanllwni Mountain
North Eastern Uplands
Mynydd y Betws
Gwendraeth Levels
Pembrey Mountain
Swiss Valley
Talley
Lwchwr Valley
Lower Taf Valley
Cwm Cathan
Cothi Valley
Carmarthen Bay and Estuaries
Proposals for development which enhance or improve the Special Landscape Areas through their design, appearance and landscape schemes will be permitted (subject to the policies and proposals of this Plan).
Strategic Objectives Supported: SO1, SO4, SO5, SO6, SO7, SO8 and SO12
This policy should be read in conjunction with other relevant policies and proposals of this LDP.
6.6.35Special Landscape Areas (SLAs) represents a non-statutory designation which were identified following a formal assessment of the landscape qualities of the County. Their designation utilised the former CCW’s Guidance Note in applying the results from the LANDMAP data. In this regard their designation reflects the aspect areas defined within LANDMAP and seeks to utilise ‘outstanding’ categorisations supported where appropriate by those classified as ‘high’.
6.6.36LANDMAP is a Wales wide approach to landscape assessment which describes and evaluates aspects of landscapes and can be used by authorities in informing policy and decision making. It identifies five ‘aspect areas’: geological landscape, visual and sensory, landscape habitat, cultural landscape, and historic landscape.
6.6.37Whilst not intended to necessarily preclude development, it is intended to reflect the emphasis placed upon the term ‘special’ in their definition. The design of developments should be sensitive enough to ensure that the scheme makes a positive contribution to the landscape. In this regard, proposals will be expected to show that they will not have an unacceptable impact on their specific distinctive features or characteristics of the SLA. Development proposals adjoining, or which impact upon a SLA will also be considered in accordance with the provisions of this policy.
6.6.38Those settlements defined as part of a SC, where surrounded by an SLA, are considered to form part of the designation. Those Growth Areas, Service Centres and Local Service Centres within a SLA will not be considered part of the designation, however their potential impacts will be duly considered in line with the above statement in relation to development proposals adjoining or which impact upon an SLA.
6.6.39The Council will, in determining appropriate planning applications, have regard to the LANDMAP information system as a material planning consideration in considering the impact of any proposal on the County’s landscape qualities. Consideration should be given to the enhancement of quality by means such as character creation and restoration as and where appropriate.
6.6.40A description of each SLA identifying its characteristics and landscape features is set out within Appendix 4. SPG will be prepared in respect of management considerations within SLA’s and general design advice. The use of the SLA policy will be monitored within the LDP monitoring framework.


4) The Towy Valley is one of 18 designated SLAs. The area of the Towy Valley SLA is as identified on the proposals map.
5) Appendix 4 of the existing LPA has the purpose of defining the characteristics of the SLA’s. The part of Appendix 4, relevant to the Tywi Valley SLA is reproduced below.

APPENDIX 4 - SPECIAL LANDSCAPE AREAS
INTRODUCTION
Following guidance from Natural Resources Wales, and using Landmap information, the Special Landscape Areas (SLAs) in Carmarthenshire have been reviewed and updated for the purposes of the emerging Local Development Plan. At the outset of this project it was established that the landscapes in Carmarthenshire that are considered to be of greatest importance, and which are worthy of the protection that the designation of Special Landscape Area provides are the:
• River valleys
• Upland landscapes
• Coastal landscapes
The proposed SLAs have been grouped according to these landscape types are described below.
Using Landmap information
All counties and National Parks in Wales have completed Landmap assessments. These assessments are based of five layers of landscape information and this information can be used to assist itnhe process of identifying SLAs. The data is map based and held within a Geographic Information System. For the purposes of identifying the landscapes that are considered to be important in the Carmarthenshire the visual and sensory information is particularly important, but the other sets of data have also been used. For example the historic landscape layer also identifies Llanllwni Mountain and Drefach Velindre as being important landscapes. The landscape habitats layer identifies the coastal landscapes as being of importance.
RIVER VALLEYS
Tywi Valley
The Special Landscape Area (SLA) includes the entire river valley apart from the Tywi estuary, which forms a part of the Carmarthen Bay and Estuaries SLA. The Tywi Valley SLA consists of the valley floor and associated slopes, and includes number of different landscapes. The upper Tywi Valley, north of Rhandirmwyn is typically narrow, rising steeply on either side to the more rugged upland landscapes of Mynydd Mallaen and the North Eastern Uplands, both of which are SLAs in their own right. The upper Tywi Valley is characterised by small fields, hedgerows, woodland, traditional farms, narrow roads, and the river itself, often bordered by trees, but in places by open meadows.
Moving down stream towards Rhandirmwyn and Llandovery, the mid Tywi valley opens out more, but the valley continues to rise up to the open hill land. The landscape is well wooded with a significant number of hedgerow and other individual trees. Here there is more open flat agricultural land, some small settlements - Rhandirmwyn and Cilycwm, both dominated by traditional buildings and vernacular architecture. These are harmonious unspoilt rural landscapes.
The lower Tywi valley down stream of Llandovery consists of the wide level flood plain, together with its northern and southern slopes which provide outstanding views over the valley and from the north towards the Brecon Beacons. Although dominated by agricultural land and larger fields than in the mid and upper valley, the flood plain also has a significant number of mature hedgerow and fields trees, and the valley slopes, particularly the steeper southern slopes are well wooded. Historic parklands and castles are also a feature of this part of the valley, e.g. Gelli Aur and Dinefwr Park, and Dinefwr and Dryslwyn castles. The castles in the valley have imposing locations on limestone outcrops, over looking the valley. Traditional farms in the valley have typically expanded and often now include large agricultural buildings. Most of the settlements in this part of the valley have also grown with an element of modern building around a more traditional core. Inappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation


6)The designation as a SLA would not of itself preclude the placing of new electric lines within or through an area designated as a SLA, as the designation is non-statutory .It could be taken into account, if WG consider an application for a DNS, but would not bind the decision maker. Mynydd y Betws is one of the 18 designated sites. Mynydd Y Betws is subject to a windfarm.

7) Policy EQ6, creating and defining special landscape areas, does not appear in the second revised LDP.
8) However, the second revised LDP would contain the Strategic Policy SP15, which is for the protection and enhancement of the built and historic environment i to safeguard the cultural integrity of the historic settlements, features and buildings. The revised LDP recognises that our historic assets are irreplaceable resources, and their conservation provides social, cultural, economic and environmental benefits.
9) Importantly, the second revised LDP also contains Policy BHE2 (paragraph 11.45), confirming that development proposals should relate to the specific landscape and visual characteristics of the local area, ensuring the overall integrity of landscape character is maintained by respecting and conserving specific landscape features and protecting key landscape views and visitors.
10 The second revised LDP confirms that Carmarthenshire is characterised by diverse and high-quality landscape resources and areas of notable visual value:
a) Paragraph 11.457- these provide significant environment, economic and social benefits and help to create a sense of place.
b) Paragraph 11.459- this policy (BHE2) will be supported by a landscape character assessment and supplementary planning guidance (SPG).
c) Paragraph 11.460-the SPG will identify and describe distinctive landscape character areas and types throughout the plan area.
d) Paragraph 11.461- in this respect the purpose of the policy is to reflect the specific distinctiveness, qualities and sensitivities of the counties landscape components.

11) It is important to understand the nature of a Land Character Assessment (LCA) – the process of identifying and describing variation in the character of landscape. It seeks to identify and explain the unique combination of elements and features (characteristics) that make landscapes distinctive. The process results in a landscape character assessment which describes the landscape with reference to the characteristics that make a place distinctive, to:
a) Inform understanding of key characteristics.
b) Inform judgements and decision making.
c) Inform re green infrastructure plans and strategies.
d)To provide baseline evidence at the appropriate scale to inform a range of decisions.
e) To provide an understanding of how a place is experienced, perceived and valued by people.
f)To identify the key characteristics that together create a sense of place and the unique character if an area.

12)The second revised LDP confirms it is Intended to define strategy, proposal, policies, and allocation for all of Carmarthenshire, save for the national park, that it is Intended to identify areas where policy /design are intended to protect and enhance the environment from inappropriate development , and to be used for assessing planning applications until 2033, as a foundation for clear and consistent decision making; ‘the objective is to include protection and enhancement of our environment’.

13)The second revised LDP also contains statements of intent and policy towards the need for renewable energy but with enhancement and protection of tourism/ visitor sectors and landscape and historic sites:
a)Policy SP16 ‘Climate Change’ – focuses more on reduction of energy use than energy generation.
b)Policy CCH1 and Policy CCH 2 – for renewable wind energy within pre-assessed and outside pre-assessed areas and local search areas – confirm that proposals should not have an unacceptable impact on electromagnetic interference with communication installations or other telecommunication systems and the proposals will not cause an unreasonable risk or nuisance to, and impact upon the amenities of, nearby residents and members of the public and, as to those developments proposed outside of pre-assessed areas, they will not have an unacceptable impact on visual amenity or landscape character through the number, scale, design or siting if turbines and associated infrastructure and the development will not have an unacceptable impact in areas designated for their landscape value.
c)Paragraph 11.48, Welsh ministers to determine as a DNS any application for onshore wind generation of 10Mw or more.
d)The LDP confirms the importance of rural economy. Paragraph 4.41, a buoyant rural economy is needed to support the overall growth of the county – to help sustain community life’. “Sustainable tourism provides a key means of delivering this growth and of providing good quality local jobs”. Paragraph 4.45, the natural beauty of the county is a major factor on which the local tourism and recreational industries depend. Biodiversity is fundamental to the physical, economic and spiritual wellbeing of all who live and work in Carmarthenshire. Paragraph 5.6- we want a buoyant visitor economy with potential to grow.
e)Paragraph 5.6 (12), beauty, peace and quiet, open green spaces and fresh air are also contributors to happiness in rural areas.
f)Paragraph S02 confirms the importance of wellbeing opportunities through acess to community, leisure and recreational facilities as well as the countryside.
g)Paragraph S05 confirms the need to safeguard and enhance the build and historic enviroment.

h)Paragraph S07 – to make a significant contribution towards tackling the cause and adopting to the effect of climate change, including promoting renewable energy and safeguarding resources.
I)Paragraph S09, to protect and enhance the diverse character, distinctiveness, safety and vibrancy of the counties communities, by promoting a place making approach and a sense of place.
j)Paragraph S013, to make provision for sustainable and high quality all year round tourism related incentives.
k)Paragraph 9.33, the LDP will promote sustainability by protecting and enhancing biodiversity, towns and landscapes.
l)Paragraph 9.57, the components of the strategy are to reflect the needs of rural areas and the rural economy. To provide opertunity to cater for the visitor community. To protect and enhance the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes.
m) Paragraph 11.22- tourism is a key component of the Carmarthenshire economy. It generates £400-500 million of revenue to the county’s economy annually.
n)Carmarthenshire is the cycling hub of Wales.
m)The counties heritage and activity tourism potential are renowned, whilst its natural enviroment can appeal to the wellbeing tourism sector.

There have been some comments directed towards Carms CC in the press, which could be considered, in the tone used and in nature ,as unhelpful. In consequence, some members of the community have raised questions regarding the proposal to replace SLA’s with Character Land Assessments.
The questions raised to me, and my replies, are set out below:
a. Is this a cause for concern, relevant to the pylons proposed or generally?
Ans – No. A SLA is a non-statutory landscape designation. As a non-statutory designation it cannot by itself defeat an application for grid structure determined as a DNS by WG. Also the SLA definition and characteristics in the current LDP seem brief and insufficient and could have far more relevance and weight if defined in greater detail by way of an Landscape Character Assessment. Whilst the SLA designation is available to be used by local planning authorities to define areas of high landscape importance, the Character Landscape Assessments could be far more effective.

b. Why have SLAs been dropped?
Ans – We are told to improve on the designation and protection of special areas by way of LCA, which should be more affective.

c. Is there a suitable alternative to SLA s.
Ans – The LCA should give far more detail as to the character and qualities to be preserved in each designated area and could be more effective than an SLA.

d. Will a suitable alternative (CLA) be implemented before or simultaneous with the second revised LDP?
Ans – The cabinet member responsible for planning has confirmed this will be the case.

e. Is there some form of conspiracy on the part of Carms CC to drop SLAs to lesson opposition or make it easier for energy developers to construct energy sources or associated infrastructure within or through the existing SLAs?
Ans – It is apparent from the second revised LDP that Carmarthenshire County Council places a high emphasis on protecting the natural beauty of Carmarthenshire and protecting historic sites and tourism/visitor activity which are identified as a key element of the local economy. This is consistent with the lead taken by Carmarthenshire County Council in responding to oppose the Green Gen proposals.

f. Is Carms CC in favour of and encouraging the Green Gen Tawy Usk proposal?
Ans –No. The elected council members passed a motion unanimously on 1 March 2023 which states: “That Carmarthenshire County Council supports residents' and local businesses' concerns regarding the proposal to erect pylons to link Nant Mithil Energy Park to the National Grid in Carmarthenshire; believes that Bute Energy should work with landowners to place the cables underground; and that we, as an Authority, write formally to the energy firm to support the concerns raised.”
Also, the Council has refused to allow Green Gen entry onto land owned by the Council which Green Gen had earmarked for pylons.
it is important to feedback to the Council, as part of the consultation process, in a way which is constructive, which is accurate, which reflects the importance of Carms CC as a landowner and statutory consultee in any DNS process, and which reflects the assurance confirmed by the Cabinet Minister for Planning, that removal of SLA’s is to allow replacement by CLAs which can provide improved protection and definition for those areas which are currently designated as SLAs and enhance their protection . The constructive feedback could be:
It would be better to define the CLA areas (to include the existing SLA areas) within the second revised LDP( including a plan as an appendix to define the extent and location of each area) and to include as an appendix to the second revised LDP the characteristics and qualities assessed by way of each Land Character Assessment .By including reference in the revised LDP to the LCAs by way of a specific policy directive, this is likely to have more weight than an SPG. This will enshrine the LCAs within the LDP and confirm the assurance that the LCA designation and descriptions will be in place immediately upon adoption of the LDP and will be implemented without the possibility, inadvertently, of an interval between termination of SLAs and adoption of LCAs. Further there should be a consultation process to allow observation and comment as to the areas designated within LCAs and the characteristics and features recorded.
It is for each person to arrive at their own subjective assessment, and this resume is not intended or provided by way of advice, but confirms the feedback I intend to provide within the consultation process and the reasons for that response.

Gary Jones 11/4/23