11.471

Amend Policy

Thank you for consulting Cyfoeth Naturiol Cymru/National Resources Wales (NRW) on the above, which was received on 17 February 2023.

We welcome the opportunity to provide comments on your Second Deposit Revised
LDP.

We support the intent of the plan’s policies and proposals to enable the delivery of sustainable development and ensure social, economic, environmental and cultural
well-being goals are all suitably balanced in the decision-making process, so the right development occurs in the right place.

We also acknowledge that you have taken on board advice from our previous correspondence which has enabled positive provisions in the second Deposit Plan
both in policy terms and regarding allocation of sites. However, there are issues with the latest draft which we feel challenge the Soundness of the Plan. These key
issues are highlighted below:
• SAC rivers / Habitats Regulations Assessment (HRA)
• Flood risk regarding the following sites allocated for housing under Strategic Policy 4: A Sustainable Approach to Providing New Homes
PrC3/h33 Llys Dolgader
PrC3/h19 Land off Llys y Nant
SeC19/h1 Land at Park View, Whitland
Sec19/h2 Land at Whitland Creamery
• Flood risk regarding allocation - PrC2/GT1 – Land at Penyfan, Trostre, Llanelli, under Strategic Policy SP 10: Gypsy and Traveller provision.
• Biodiversity and ecosystem resilience regarding six allocations (two housing and four employment).
In addition, to matters of soundness we also advise that some refining/clarity be made to the plan in respect of several policies and supporting text to ensure the
robustness of the plan.

Our detailed comments on the plan and supporting documents can be found in the annexes to this letter.

Please note that our comments are without prejudice to any comments we may wish to make when consulted on any subsequent formal planning application submissions
to develop any of the land identified within the plan. At the time of any other consultation there may be new information available which we will need to consider
in providing our formal advice.

Finally, we look forward to continuing to work closely with you to progress the plan and trust these comments are of assistance. If you have any queries, or if you require any further information, please do not hesitate to contact us at the above address.

Comment

Please find below my concerns regarding the proposed LDP.
Particularly focusing on urgent measures we will need to take to address our ecological emergenicies.

Please let me know if you’d like to discuss further.

Overview P364:
3.6. Well Being and future Generation Act (Wales) 2015 refocused National planning Policy Wales and the South West Wales Area statement.
Particularly in response to WG Climate emergency declaration.
3.7 Also influenced by Future Wales 2040.
3.12 Renewable energy gets a first mention.
3.12 Links RE to the Ten Towns

We therefore need to be “Globally Responsible”
4.9 A presumption in favour of sustainable development
4.11 “without compromising the ability of future generations to meet their own needs
4.48 27 conservation areas which includes many of the Ten Towns.
Therefore a clear conflict of ideas that always falls in favour of aesthetics of buildings?

e.g. In the case of Llandovery/Newcastle Emlyn-where shall we accommodate our stated renewable energy ambitions?
Not windy enough and prime farmland. Has to be rooves.

5.6 33 Energy efficiency in proposed and existing developments.
This won’t be able to set standards higher than current building regs-which are woefully inadequate due to lobbying and corruption by developers in Westminster.
“We continue to build crappy houses”-Lord Deben-Chair of Climate Change Committee UK GOV.

5.7 Updated Contextual Issues.
UCI 3 is the Climate Emergency.
UCI 4 is the Nature Emergency

What powers does this bring?

ONE CARMS.
6.4 Need to balance conflicting demands.
Do UCI 3&4 hold sway in Conservation Areas?

Policy CCH3 P592
Electric Vehicle Charge Points
1. Every new home with dedicated off road space must have a charge point. As I recently stated when giving evidence at the Senedd-this is misguided and wasteful.
New homes should have three phase to accommodate EVs and heat pumps BUT passive provision of EVCP is sufficient.
This enables the resident to install the latest technology once they need it. Putting charge points that rust on walls is ludicrous if residents don’t have EVs.
Also encouraging car ownership.
2. Installing charge points at 10% of car parking space at non-residential developments is similarly OTT-passive provision and ensuring adequate supply is what should be required.

11.495 Rural challenges for public transport. Clearly a significant challenge. Too many empty buses running infrequently.

11.496 Provision of rapid chargers at new flats a ludicrous idea. Too expensive and unrequired.

SP16 Climate Change P582

11.471-WG is committed to using planning to optimise renewable energy (Llandovery?)
Furthermore Planning Policy Wales states that the Local planning Authority CAN make a +ve provision by considering the contribution that their area can make re. Renewables.

11.476 p586
“Particular support will be given to community renewables which will benefit the host community.
Why has CCC failed to engage with Ynni Sir Gar? And Energy Local?

11.493-embrace new low carbon technology-This would be an opportunity to specifically mention EV Car clubs.
Shared ownership to reduce cars and increase transport options.
Furthermore, Local organisations could allow community to use their vehicles via Community Car Clubs.

11.538 LDP seeks to +vely promote solutions which encourage access to technology changes.
Another opportunity to promote shared ownership to reduce emissions, Increase social inclusion and access to services through EV Car clubs.
This is an ambition of the current transport Minister.
This can replace the aforementioned expensive diesel buses.

I would very much ask that the potential for Community Car clubs is proposed in our LDP to 2033.
This is stated WG policy.