SeC7/h3

The remaining green areas in llangennech need to be protected. The amount of houses proposed to be built is too much for the area. We should be investing in protecting green space, not destroying it.

This proposed development will have a detrimental effect to the area. The destruction of the green area on such a big scale is unacceptable. The extra vehicles the housing will bring is unacceptable as is the demand on the existing infrastructure.

No more trees or public enjoyment of quiet green areas should be sacrificed for the residential housing which will cause greater pollution in the village.

The proposed residential area is on an area where there are several TPO’s in place. A large amount of this woodland has already been felled in Aberllwchwr, drastically reducing wildlife habitat. Surely the council can’t consider felling more trees and destroying more wildlife habitats. Especially trees under TPO’s - otherwise the TPO system becomes a farce. There is a popular public footpath which would be negatively impacted by this development. The village is already over-developed with housing and not enough green areas to combat the increasingly polluted environment. I strongly object.

I cannot see how any changes can be made that would not have an impact on the loss of trees, traffic or the public footpath.

I am strongly opposed to the development of this site. The main reason being that there are several tree protection orders (TPO’s) in place along this site and I cannot see how it can be justified to fell the trees for such a development. This would not only ruin the area for local residents who enjoy walking the footpath, but also the wildlife that call it their home. This development would have a negative affect on the local landscape and the environment with the loss of the beautiful trees and the extra traffic that it would bring to the area.

The proposed development for this area should be scrapped several years ago, the council destroyed gorse bushes covering this site, causing no end of biodiversity damage to feeding bats etc. they also failed to treat Japanese knotweed, that springs back up every year. A children's park was also removed (despite requests for the community council to manage) this was in anticipation of selling the land to a contractor ( no one was interested)
In my view developing on this land would be an act of Environmental Vandalism and should be halted.

This area is heavily wooded ,which hosts a wide variety of wildlife,including,bats and woodpeckers. The road leading to this site has subsidence due to old mine workings. Carmarthenshire council has declared an environmental & nature emergency, which goes against this development, which would chop down trees, and disperse wildlife.It also goes against The environment of Wales Act 2016 which gives "A duty to enhance Biodiversity in their community". Llangennech has a poor road network, pollution monitors at AFON rd has already demonstrated high levels, more developments will only add to it. congestion high at junction 48.

Remove allocation SeC7/h3 and concentrate new housing in more built up areas, away from habitat rich sites like this.

There are cracks in the walls of my home due to movement already, construction work and machinery travelling back and forth will potentially cause more damage to my home, such as subsidence. With the trees removed, wildlife such as bats in the area will be lost. The wildlife in that area which includes small birds, bats, and squirrels need to be protected. The extra vehicles in the area will bring pollution to a relatively clean environment. Amenities such as Schools, the Doctors surgery would be under a lot more strain than they already are with more houses in the Village.

Remove housing allocation SeC7/h3 from the Revised LDP.

I am writing to express my concern regarding the proposed development in Llangennech.

The access to the area is already a very busy road, with access not being great with cars parked on the side of the road, allowing traffic for cars on one side of the road only.

Woodland would be lost. Also there is Japanese knotweed in the proposed area for development.

This area is already overpopulated, and adding to it would cause issues for the local community which includes pressures for schooling for example.

Kind Regards,

Sian Ajzan.

Remove housing allocation SeC7/h3 from the Revised LDP.

I have some concerns on this proposal being:

1. I understand that Carmarthenshire Council have declared a climate and nature emergency, this proposal will result in the loss of a wooded area and a loss of habitat for wild life which I feel goes against the declared emergency.
2. Our village is already overdeveloped with a poor infrastructure and this development will only add to the current problems.
3. Our road backs on to the site and if used as an access road will create more traffic on a road which already has a large volume of cars, some of which are speeding dangerously. There is also the cemetery at the end of Golwg Yr Afon to be taken into consideration which effects access on the occasions when funerals are taking place, due the number of cars being parking by attendees.

I would be grateful if these concerns can be taken into consideration for this proposal

Remove housing allocation SeC7/h3 from the Revised LDP.

I wish to register my objection to plans to build housing on the green and forested area behind Clos Plas Isaf, Llangennech. There has been dreadful destruction already alongside the lane leading to the estuary , ruining a beautiful area used by hundreds of walkers and fishermen daily. In these days when people cannot afford to pay for entertainment it is these walks that keep people sane , healthy and communicating. To ruin another green area would be the final straw.
Christine Thomas
Gerald Thomas

Remove housing allocation SeC7/h3 from the Revised LDP.

Sirs/Madam
I wish to strongly object to the proposed planning development below Plas Isaf Llangennech, shown as SeC7/h3.
Whilst everyone would welcome the introduction of new homes, particularly 'affordable' homes being built in Carmarthenshire, to essentially "wedge" them in on a plot of land in an already bursting village is short of incompetent. The infrastructure in the area is completely inadequate to deal with the influx of road traffic alone. Heol Plas Isaf, the access road to the site has already been dug up and replaced TWICE due to subsidence and even now, should you care to take a site visit, has the road dipping for a third time. The exit form Heol Plas Isaf onto Hendre Road, via a 'T' junction is on a bend in the main road where vehicles are accelerating driving up hill. An alternative exit from the proposed site via Heol Y Parc would offer dangers just as precarious onto Hendre Road just opposite The Bridge Inn.
Wildlife in this precious area, includes Oak, Hazel, Ash, Horse Chestnut, Yew, Sycamore, and Pine trees. The wildlife that inhabit these trees includes Squirrels, multiple nesting bird species, Woodpeckers as well as birds of prey such as red kites, buzzards and anyone living near this site will be well aware of the Owls calling each other most nights.
The area is home to roosting bats that are seen most summer evenings whilst walking along the public footpath towards the estuary, and im sure the Bat Conservation trust would welcome the opportunity to confirm their presence.
Ground life include Foxes, Hedgehogs, Rabbits, field mice and numerous other invertebrates along with insect life including bees that feed on the wild flowers and grasses that have been left, untouched, for many decades to naturally thrive.
The devastating recent 'deforrestation' of the area opposite this site, that went unchallenged by the council and unknown by the Enviroment Agency and Resources Wales, when i called to challenge this action, was allowed to proceed and has driven even more wildlife into the proposed site. I implore you to visit this area behind Aber Llwchwr to see the devastation that was allowed to happen, the effect it would have on the wildlife, and where that wildlife will be displaced to would be crystal clear!
I would also suggest that 50 houses, sitting only a few feet above the height of a high spring tide, would lead to its own issues regarding sewage and land drain water.
i'm told that Llangennech school, both junior and senior are at maximum capacity with nothing available in pre school facilities either.
I would suggest, if Carmarthenshire council really want to build more affordable housing, that they look at far more suitable sites than SeC7/h3 and common sense would prevail and stop yet ANOTHER 'Blitzkreig' of wildlife habitat be averted in Llangennech.

Remove housing allocation SeC7/h3 from the Revised LDP.

I just wanted to raise concerns regarding the proposal to build in the wooded area ofClos plas Isaf in Llangennech,
ref no SeC7/h3

I don’t think that the village can cope with the building of more houses, it will destroy the woodland area which is vital for the wildlife that live there, with the increase in houses will come the increase of vehicles in the village, which will not be good for the environment, the village at certain times of the day is very busy already.
I hope that these considerations will be taken on board and some of the concerns that have been risen regarding the proposal.

Remove the allocation.

I am emailing you with regards the proposal to build 50 houses on the wooded area below Clos Plas Isaf and adjacent to Golwg yr Afon, Llangennech, the land designation being SeC7/h3. This is deeply concerning to me, a resident of Golwg yr Afon.

To start off with, devleoping this area would mean loss of woodland and habitat for an array of wildlife, inlcuding birds, plants and insects. The area is very secluded. If development will go ahead, the area would be very congested with the machinery needed for the development, polluting the area for the duration of the construction. This will also have an effect on traffic in the area.

Parking is already an issue on Golwg yr Afon, with many residencies having 2 cars, meaning 1 has to be parked on the roadside. If this The whole length of this road has vehicles lining it on both sides. If this road is to be used as a means of access this could, potentially, be dangerous with heavy development machinery having to pass through narrow areas on this road. Damage to cars, accidents involving the neighbourhood's young children could be a worrying factor.

More cars driving through Llangennech is a worry, with Bridge Street being a very precarious main avenue through the town due to residents parking their cars on the roadside. Drivers often find themselves in very narrow gaps on this road. I have witnessed many drivers having to mount the pavement to allow cars to safely pass. More cars in the town will make this worse. Llangennech is already overdeveloped, with a poor infrastructure. Adding to this is nonsensical.

Remove housing allocation SeC7/h3 from the Revised LDP.

Regarding land designated for social housing in Llangennech, I feel I am obliged to object on the following grounds.

1. The land has various coal mine shafts under it and would take a “substantial” amount of TAX PAYERS money to make it safe before building could commence. (Safety concern).
2. How in all seriousness would you build more houses under the air ambulance flight path. (Safety concern).
3. The sewage system is already under considerable strain as it is. (Safety concern).
4. The land in question is on a flood plain and any building on this land would render the new home owner with questions about whether they could get house insurance as they are so close to the river loughor. (Legal concern).
5. It has been noticed there are wild bees nesting on this site. (Environmental concern).
6. It has been noticed there are foxes also on this site. (loss of habitat concern).
7. The doctors surgery and local schools are already saturated with patients and school placements. (Infrastructure concern).
8. Additional car and domestic heating pollutuion to the village (environmental concern).
9. The railway track is way to near to the proposed housing site (remember diesel spillage a few years ago and how many of llangenech’s residents had to be evacuated, this estate would have the nearest houses to the track in all of llanelli.) (safety concern).
10. The river loughor has been designated a place for wetlands and wildlife, what effect will another housing site have on the local fauna and flora.

Surely if you want to use the land for anything wouldn’t a leisure centre be better. You could use the hot water from the coalmines under the land to heat up an olympic size swimming pool!

Remove allocation SeC7/h3 from the Revised LDP.

Re: Proposed Develpment ref: SeC7/h3

As a resident of Llangennech whose property is adjacent to the wooded area where development SeC7/h3 is proposed I wish to make the following comments:
I have lived here for the last 26 years and witnessed an exponential growth in the village. Unfortunately, this has not been accommpanied by a corresponding growth in infrastructure, which continues to be poor.

Loss of a large wooded area and natural habitat seems to be contrary to both local, national and universal efforts re climate change. The erection of 50 houses and accompanying vehicles etc will add considerably to the above. The access roads to this area cannot accommodate this increase in traffic and the extra exhaust fumes would cause more pollution.

On a more personal level, I have to follow strict guidelines regarding TPOs on trees on my property and I know that TPOs exist on many trees in the proposed development. I sincerely hope that the Council will be equally strict in this regard.

• Is the Council aware that all the storm water from Clôs Cae Fainc is piped into this area and allowed to drain naturally into the land. I discovered this many years ago when this drain was blocked and I had about 3 feet of water at the entrance to my property.

I hope that the above comments will be seriously considered when the above development proposal is next considered by the planning committee.

Remove housing allocation SeC7/h3 from the Revised LDP.

Dear Sir/Madam

SeC7/H3 (wooded areas adjacent to Golwg yr Afon,llangennech/SR/086/027

I have been advised by my local Councillor that the land mentioned above is being looked at under the LPD plan 2018-2033

I'd like to comment as I live in this area under consideration and bring the following points to be noted - Our village is already overdeveloped with little infrastructure, over the last 20 years around 60 new large houses have been built in the area,and no road widening schemes have been put in place to get too to the main road, every morning and every evening, there is lots of traffic congestion leading to the main road ,this therefore leads to more noise and longer term pollution in the village and surrounding areas on a constant basis,

The road leading (Morlais rd) to the main road (Hendre Rd) is simply not wide enough to accept more traffic, as home owners cars are parked on the road, and drivers are having to weave amongst parked cars with on coming traffic heading towards them,

There are already 5 roads with houses on converging onto Morlais Rd ,to gain access to the village and beyond,more new houses would simply make things worse.

if the commuting times are wrong I can take up to 40 mins to get to the m4 junction some 2 miles away, and also queuing in the evening on the hard shoulder of the m4 to get off on the Llanelli junction, I;m amongst many other home owners whom travel to work out of the Llanelli area

The current large wooded area provides a natural area for multiple species of wildlife and the trees assist in the drainage of the surrounding areas, where trees have historically been felled, pools of water have started to accumulate on high tides and after heavy rain fall

There is no English speaking school in the village anymore, and the next school Bryn was not designed to expand beyond the original design limits, so would need to be expanded at extra cost to the council.
No 5/Sa14 8ah

Remove site

With reference to the proposal for increased housing at the following SeC7/h3 I
would like to make a comment on the proposed overdevelopment at this site for
the following reasons,

Loss of a highly regarded and critical habitat for numerous wild species as this
contradicts the climate and nature emergency statements made on our behalf .

An overdeveloped infrastructure which has already borne witness to high
development which can only serve to stretch an already poor infrastructure to
support further pressures from traffic - again contradictory to the councils stated
aims for decreased traffic re pollution.

Remove site from the Plan

I would like to put my objection to the proposed housing at clos plas isaf Llangenech. We have got wonderful wildlife around this area and building would have a detrimental effect when we are constantly reminded that our wildlife is being desecrated ,also the loss of beautiful woodland . Also i thought Barr are a protected species and we here are load in this area.this is one of the reasons I moved to this area having woodland behind me is beautiful and listening to all the different birds if you built this will all be lost. We need to keep our I like the privacy of having this by me and also the traffic will be horrendous

Remove the site from the Plan

Land and woodland adjacent to Llangennech estuary

SeC7/h3

The land marked out for development is habitat to a range of wildlife, with many
woodland birds breeding in the area.
Adjacent to that marked land is another area of mixed woodland, which itself leads on to
the marsh and estuary fed by the River Loughor.
The undisturbed woodland attracts such birds as Great Spotted Woodpecker, Blue, Great
and Long tailed Tits, Tree Creepers, Nuthatch, Sparrowhawk, Blackcap, Wren, Dunnock,
Song and Mistle Thrush, to name but a few. There have also been reports of Tawny Owl
calling, probably therefore roosting or nesting in the taller trees covered in Ivy.
The nearby undisturbed estuary is a haven for good numbers of wading and other birds,
such as Redshank, Little Egret, Lapwing, Cormorant, Shelduck, Greylag and Canada
Geese (in the right season), and raptors such as Peregrine Falcon and Buzzard.
Also near the proposed development you will often find Grey Heron, Curlew, Common
Sandpiper, occasionally the scarce Great White Egret and shy Water Rail.
Importantly, the area attracts some Schedule 1 birds, protected under the Wildlife and
Countryside Act 1981. These include, in, around or above the woodland, Redwing (in
winter) Cetti`s Warbler, and fly-over Red Kite, and on the nearby estuary Greenshank,
Peregrine, Merlin, Kingfisher, and under certain weather stormy conditions Spoonbill
coming up to shelter from strong south-westerlies from further down the estuary . Marsh
Harrier and Hen Harrier have also been recorded on the estuary marsh-land. All
Schedule 1 birds are to be protected from disturbance.
During the late autumn and early winter season, the woodland floor and lower parts of
trees are home to a wide variety of fungi, including inkcaps and turkeytail. The
undergrowth is habitat to numerous insects, and by the Spring the woodland and path
come alive with a variety of moths and a wide range of butterflies, including the early
Orange Tips, Gate Keeper, Small Tortoiseshell and many others.
All these species are subject to disturbance, whether directly within the woodland, or
close by on the adjoining marsh and estuary.
Being so close to the proximity of the marsh and the abundance of insects, there is a
high chance that this area is also used by a variety of bats. Although this would need to
be surveyed professionally from the spring onwards, to include using bat echo-detecting
equipment, it is highly likely bats using the edge of the woodland and marsh to feed off
midges as well as moths.
Nature, green spaces, and the environment generally, need to be protected from
disturbance and destruction.

Infrastructure

The area has a road from Llangennech through Bryn that already required the building of
the relief road to ease traffic some 30+ years ago, and is a two-way speed-bump road to
help cut down the risk of accidents. The area does not have a road infrastructure for
more housing development, and this would only add to traffic accident risk, build up of
local traffic generally, congestion “both ways”, particularly the narrow access through
Llangennech toward the M4.
Current buses would become insufficient for additional residential developments, and
`additional` buses would only add to the congestion as mentioned above.
Both Llangennech and Bryn schools are at capacity, and may be unable to cope with
additional children from proposed development of new homes. Any forced increase to
school places would affect the safety of children and parents alike, already very busy at
`school run` times, plus more congestion again at the school gates.
Llangennech is currently serviced by a small GP Practice, which again would struggle to
take on more proposed patients. Any attempt to overload the GP service further would
have a detrimental affect on the physical workload of the GP, Locums and staff of the
small Practice, plus of course the fact that local residents that might not be able to be
seen that day if `overbooked`.
With the massive impact on the local environment, both natural and human, plus the
devastation to wildlife and habitat, the land should not be destroyed to make way for yet
more houses that will only create more problems with local roads and village life.
Damage to the environment on the land would see woodland lost forever, and the
proposed developments will only have a detrimental impact on local services and safety.
Disturbance to some wildlife and protected (Sch.1) birds would be catastrophic, and
probably illegal.
I request that the proposed developments be rejected on the numerous grounds
summarised above, and that the environment be protected for future generations.

Remove site from Plan

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so we consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan in relation to the allocation for residential development at land at Golwg
yr Afon, Llangennech (LDP Ref. No. SeC7/h3) under the provisions of Policy HOM1. The
proposed allocation has been fully assessed and in considering its context and background
(summarised below) it is considered that its continued inclusion will lead to the Plan failing
the 3 Tests of Soundness for the reasons set out below.

Site Background and Context
The allocation relates to the land shaded brown on the Proposals Map extract below and is
proposed for allocation in the 2nd Deposit LDP for the purposes of 50 residential units.

Plan A
(Extract of Proposals Map for Golwg yr Afon Allocation)

As part of the current consultation process into the 2nd Deposit LDP, the Council have again published a “Site Assessment Table” (2023), which provides details of the Council’s analysis of each received Candidate Site submission and existing allocations within the current adopted LDP. Proposed allocation SeC7/h3 was considered as part of this process and as a result the Council concluded as follows:
“Site to be retained as a residential allocation as per candidate site area. Site to be allocated with reference SeC7/h3.”
It is clear from the above that the Council considers that the site is deliverable for the purposes of 50 houses, although it is not clear on what basis this conclusion has been made, especially given the important biodiversity features as well as the Tree Protection Orders that surround the site boundary.

The allocation is greenfield in nature with its topography being generally level. The entire site is covered by mature vegetation and trees. The northern, southern and western perimeters of the site are bordered by residential properties. The eastern boundary is bordered by further mature vegetation, hedgerows and trees as can be seen from the aerial photograph below (outlined in red below).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently unknown, however, the site adjoins Golwg yr Afon that being a residential site west of the allocation (see below).

Photograph 2
(Streetscene of Aber Llwchwr)

There have been no planning applications made relating to residential development at the allocation site. The eastern and southern boundaries of the allocation are lined with Tree
Protection Orders (TPO). This could indicte that the site is potentially undeliverable due to expanse and need to intergrate with those protected specimines and consequently the biodiversity features of the immediate area.
The site is allocated in the Carmarthenshire Local Development Plan (2014) under allocation GA2/h52 (as can be seen below).

Plan B
(Extract of Current Carmarthenshire LDP Proposal Map for Allocation Site (Adopted 2014))

Despite having almost 10 years of support for the principle of residential development at the historic allocation from the Council, not a single housing unit has been delivered to date.
The site is not being actively marketed by its owners (County Council), which is surprising since the location where executive housing has seen much sought in the last 10 years.

Tests of Soundness
Based on the above information and the guidance documents provided by the Welsh Government and Council itself, it is considered that the inclusion of the adoption of the LDP
in its current form with the inclusion of the allocation in question, would result in it failing to meet the requirements of the Tests of Soundness, for the reasons summarised below.

Test 1 – Does the Plan Fit?
The allocation fails the test of soundness as its inability to be delivered is in conflict with Paragraph 4.2.2 of Planning Policy Wales (Edition 11) requirements of national planning policy.

Test 2 – Is the Plan appropriate?
The allocation fails the test of soundness as its inability to be delivered would fail to address key issues set out by the Plan (housing supply). The Council’s decision to allocate the land appears to not have been done so on credible or robust evidence.

Test 3 – Will the Plan deliver?
The allocation fails to test the soundness as the site is clearly unable to deliver any new housing. The Welsh Governments Development Plans Manual (Edition 3) is quite clear with regard to rolling forward allocations and states that allocations “… rolled forward from a previous plan will require careful justification for inclusion in a revised plan, aligning with PPW. There will need to be substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered”. No evidence has been presented to demonstrate a change in circumstances to indicate the allocation will now be deliverable and so its continued allocation would lead to the plan being deemed unsound on this basis.

In summary, we object to the inclusion of the allocation in question on the basis of the above and that its inclusion within the Plan would result in the document being ‘unsound’.

We therefore respectfully request that this Representation be given careful examination, and that the allocation be removed to ensure that the document passes all the relevant tests of soundness.

Remove site from Plan

SeC7/h3

I am writing with regards to the above proposed development plan for the woodland area below Clos Plas Isaf and adjacent to Golwg Yr Avon for 50 houses.
I am a resident of Clos Cae Fainc and this wooded area backs on to my garden along with many of my other neighbours.
Firstly my objections would be that it would cause a great loss of habitat as we have Foxes, numerous varieties of birds of which I keep a log. We have nut hatches, woodpeckers, sparrow hawks, blue tits, great tits, to name just a few. In the summer months we have bats flying round the garden. It is so wonderful the amount of nature on our doorstep. All of this habitat would be lost, there were also black nesting boxes on some of the trees but unfortunately a lot of these were torn down the first time the land was cleared about 4 years ago you could quite clearly see that this had been done deliberately when the land was cleared and the japanese knotweed was not cleared in the correct way ie the machinery just plowed through everything. I have photographic evidence of this along with the nesting boxes that were destroyed in the process. Our wildlife is struggling. The last thing we need is 50 houses on this totally unsuitable building land.
The road at the bottom of Plas Isaf is sinking and the sewage structure would not cope, let alone the chaos it would cause on the already struggling roads in the overdeveloped village. This land is boggy and in the winter months the water builds up and ends up flooding the bottom of Station Road and the park and is impassable. It has happened a couple of times this year already.

I hope you will take all this into consideration.

Remove site from Plan

SeC7/h3

We live in Heol Morlais, Llangennech and would like to pass on our comments regarding the above proposal.

We are against this proposal for a number of reasons. Llangennech is already overdeveloped with a poor infrastructure. It is one of the most populated villages in Carmarthenshire and this new development will mean more cars in our village, therefore creating more pollution. Our two young sons attend the local school which currently needs better facilities for the amount of pupils that go there e.g a new kitchen, better cabins. I feel that Carmarthenshire Council should prioritise providing better facilities for the children and families that already live in the village, before funding brand new housing.

This new development would mean a loss of wooded areas and loss of habitat. The council has already declared a Climate and a Nature Emergency therefore this would significantly make the situation worse.

Thank you for taking the time to read our comments and views against this proposal.

No change to the Plan

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

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

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

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

Change to Plan if necessary.

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

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

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

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

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

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

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