11.514

Yn dangos sylwadau a ffurflenni 1 i 1 o 1

Gwrthwynebu

Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin

ID sylw: 5761

Derbyniwyd: 25/05/2023

Respondent ID: 3253

Ymatebydd: Natural Resources Wales

Cydymffurfio â’r gyfraith? Heb nodi

Cadarn? Heb nodi

Crynodeb o'r Gynrychiolaeth:

11.514 The explanatory text states: To facilitate delivery of development which may be affected by this policy, the Council have prepared 'the 'Afon Tywi and Afon Teifi Phosphorus Reduction Strategy'. The document sets out the strategic approach for delivering phosphorus reductions in these catchments while also facilitating LDP growth and demonstrating that mitigation can be delivered in practice. The document sets out a range of measures, which have been agreed in consultation with NRW.
The 'Afon Tywi and Afon Teifi Phosphorus Reduction Strategy' are living documents that will develop during the lifetime of the LDP, in consultation with NRW.

We are aware from discussions with Officers at the Council that the Afon Tywi and Afon Teifi Phosphorus Reduction Strategy has not yet been prepared. In its absence, an Interim Action Plan, dated March 2023, has been prepared for the Council by Arcadis. The document is presented as ‘…a “living document”, i.e., a document that will be updated regularly as uncertainties are removed and understanding is improved’.

Further comments on the Interim Action Plan and HRA Addendum Report are provided within Annex 2.

Newid wedi’i awgrymu gan ymatebydd:

Amend Plan if necessary

Testun llawn:

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.

Atodiadau:

Ein hymateb:

Comments noted. The Council has undertaken further work relating to excess nutrient levels within riverine SACs.

Built on the basis of the IAP, the ensuing Action Plan (previously referred to as the "Afon Tywi and Afon Teifi Phosphorus Reduction Strategy ") sets out technical calculations that underpin the quantum of mitigation required and contains detail pertaining to feasibility studies that have substantially progressed the maturity of the identified solutions.