SeC18/h5

No change to the Plan

1 Introduction

1.1 This Candidate Site submission document for the Second Deposit Revised Local Development Plan for Carmarthenshire has been prepared in order to accompany the candidate site form completed in respect of land at Station Road, St Clears, Carmarthenshire. It is submitted on behalf of Mr Wynne Walters and Mr John Walters.
1.2 The wider site was previously submitted for the First Deposit Revised LDP in 2018 (Ref: SR/150/023) but only the road frontage portion was included as a residential allocation (LPA Ref: Sec18/h5 – Land adjacent to Gwynfa, Station Road for a total of 8 units within the plan period). This allocation is carried forward in the Second Deposit Revised Local Development Plan. Notwithstanding this, it is considered that the wider area the subject of the initial submission is also suitable for residential development and, therefore this document concerns the resubmission of the wider site on the land at Station Road, St Clears for future residential development.
1.3 The site is situated in the community of St Clears and is bordered by the communities of Meidrim, Newchurch and Merthyr, Llangynog, Laugharne Township, Llanddowror, Eglwyscummin, Llanboidy, and Llangynin which all lie within Carmarthenshire.
1.4 This submission will demonstrate that if the site proposed were given permission to be developed, provisions would be incorporated which would seek to ensure a high quality of design and layout, including retention and enhancement of peripheral vegetation in order to create a high quality form of development.
1.5 The Carmarthenshire Local Development Plan Review Report identifies the status of site allocations within current LDP. Within the adopted LDP 2006 - 2021 there are 8 housing allocations within St Clears, of some have been started or completed, including the Maes yr Hufenfa development for Wales & West Housing Association on Station Road. The total allocation for these sites equates to 98 dwellings. In the event that these allocations are not developed, it is considered the candidate site will offer a solution for short-term housing development. In comparison to several speculative land bank application provided within the plan, the applicant wishes to sell the site to a potential developer in the summer in order for the site to provide new dwellings to serve the area in the short term.
1.6 In terms of the content of the submission Section 2 of this report provides a brief description of the site; Section 3 discusses the overall planning policy context; Section 4 assesses the site in the context of criteria identified in Planning Policy Wales. Section 5 provides a summary and conclusions.

2 Site Description

2.1 This section discusses the site’s general location and provides a brief description of the application site and its immediate surroundings.
2.2 St Clears is a community and small town situated in the unitary authority of Carmarthenshire. It is located approximately 13km to the west of the county town of Carmarthen and approximately 28km to the north-west of Llanelli. The B4299 (Station Road) runs in a north-south alignment along the eastern boundary of the site, providing access to Meidrim to the north and St Clears to the south. Within the current LDP St Clears is categorised as a service centre, which are “well located on sustainable transport corridors and demonstrate a broad range of facilities and services which provide for the needs of the settlement and a wider local catchment. Their respective status within the County and their regional contribution is reflected within the WSP.”
2.3 The irregular shaped piece of land is roughly 3.5 acres in area and is currently used for agricultural purposes and is subject to an annual grazing agreement. Having considered the site and its characteristics, it is considered the site would be suitable for the allocation of approximately 42 residential dwellings. There is an existing electricity pylon located within the site, adjacent to the southern boundary. Consideration will be given to this constraint as part of any development that were to take place on-site.
2.4 The site is bounded to the north by greenfield land and existing residential dwellings fronting onto Station Road, to the east by Station Road, to the south by residential dwellings within the Rhyd-Y-Gors Estate, and to the west by greenfield land. In addition, the site is bounded on all sides with hedgerow (more defined on some boundaries of the site than others) and a very small element of tree coverage within the north-western area of the site.
2.5 In terms of local facilities, the site is located approximately a 600m walking distance from St Clears Town Centre (as defined within Policies RT4, RT5, and RT6 of the adopted Local Development Plan) to the south on Pentre Road. There are several amenities within the town centre boundary, including takeaways, cafes, convenience stores, and public houses. Moreover, Ysgol Griffith Jones and St Clears Leisure Centre are located approximately 250m to the south-east and 360m to the south of the site respectively. There is also a Co-op Food store located approximately 320m to the north.
2.6 The closest bus stops to the site is placed along Station Road, approximately 170m to the south of the site, providing services in both northbound and southbound directions. Service 224 runs from these stops, once every two hours, linking with settlements including Whitland, Pwll-Trap and Tavernspite. Other bus stops are located on Pentre Road to the south where a greater range of services are provided, connecting St Clears with destinations across Carmarthenshire and Pembroekshire including Carmarthen, Tanerdy, Haverfordwest and Pendine.
2.7 Another benefit in terms of public transport which has arisen since the first submission of the site is the proposed reopening of St Clears train station. The station last operated in 1964, however recent attempts have been made to re-open the station which has gained traction since 2021 when the station was selected as one of four station re-opening bids to go through to the final stage. The station will be located along the West Wales line, situated between Carmarthen and Whitland stations and is proposed to open in 2024. This will be of great benefit to the settlement of St Clears, and lies only 300 metres from
the candidate site. It will further encourage residents to travel in a sustainable manner and reduce car dependence in the area.

3 Planning Policy Framework

Overview
3.1 The policy basis for this submission derives from the content and scope of national planning guidance. It is submitted that the residential land use proposed would be in accordance with national advice and guidance, its associated Technical Advice Notes (TANs), together with the Development Plan for the local area.
3.2 The Well-Being of Future Generations (Wales) Act 2015
The Well-Being of Future Generations Act requires public bodies in Wales to think about the long-term impact of their decisions, to work better with people, communities and each other, and to prevent persistent problems such as poverty, health inequalities and climate change. To make sure we are all working towards the same purpose, the Act puts in place seven well-being goals. The Act makes it clear the listed public bodies must work to achieve all of the goals, not just one or two.
The seven well-being goals include:
1. A prosperous Wales
2. A resilient Wales
3. A healthier Wales
4. A more equal Wales
5. A Wales of cohesive communities
6. A Wales of vibrant culture and Welsh Language
7. A globally responsible Wales
Future Wales – The National Plan 2040
3.3 Published on the 28th February 2021, Future Wales comprises the first development plan of its kind within Wales. It is a development plan with a strategy for addressing key national priorities through the planning system, including sustaining and developing a vibrant economy, achieving decarbonisation and climate- resilience, developing strong ecosystems and improving the health and well-being of our communities. The National Plan notes that the planning system must respond to these changes and contribute to a sustainable recovery, shaping places around a vision for healthy and resilient places. The strategy blends the existing settlement patterns and the distribution of jobs and homes with a vision of managing change and future trends for the benefit of everyone in Wales. Planning Policy Wales is the primary source of detail on how the planning system will support reconstruction efforts.
3.4 Future Wales is the highest tier of development plan and is focused on solutions to issues and challenges at a national scale. Due to its strategic nature, it does not allocate development to all parts of Wales, nor does it include policies on all land uses. It is a framework which will be built on by Strategic Development Plans at regional level and Local Development Plans at local authority level. As set out on Page 52 of Future Wales, the 11 Outcomes are collectively a statement of where the Welsh Government aspire Wales to be in 20 years` time as follows:
A Wales where people live:
1. …and work in connected, inclusive and healthy places
2. …in vibrant rural places with access to homes, jobs and services
3. …in distinctive regions that tackle health and socio-economic inequality through sustainable growth
4. …in places with a thriving Welsh Language
5. …and work in towns and cities which are a focus and springboard for sustainable growth
6. …in places where prosperity, innovation and culture are promoted
7. …in places where travel is sustainable
8. …in places with world-class digital infrastructure
9….in places that sustainably manage their natural resources and reduce pollution
10. …in places with biodiverse, resilient and connected ecosystems
11. …in places which are decarbonised and climate-resilient
3.5 Page 60 notes that “In all parts of Wales the strategy supports sustainable growth. Any place without jobs, homes, community spaces and wildlife has no prospect of having a thriving and cohesive community, Welsh language or economy. There is such a thing as too much development or the wrong type of development, whereas sustainable development should foster a stable or growing population to ensure a healthy natural environment and economic and social stability”.
Planning Policy Wales
3.6 National planning policy is contained within the eleventh edition of Planning Policy Wales (PPW), published by the Welsh Government in February 2021. It is the principal document for planning considerations in Wales. PPW provides land use planning policy and should be taken into account when preparing planning applications. It is supplemented by a series of Technical Advice Notes (TANs), Welsh Government Circulars, and policy clarification letters, which together with PPW provide the national planning policy framework for Wales. The planning system is central to achieving sustainable development in Wales. It provides the legislative and policy framework to manage the use and development of land in the public interest which is consistent with key sustainability principles.
3.7 Sustainable Development is defined at Page 7 of PPW as follows: “the process of improving the economic, social, environmental and cultural well-being of Wales by taking action, in accordance with the sustainable development principle, aimed at achieving the well-being goals”. Paragraph 1.18 sets out that “legislation secures a presumption in favour of sustainable development in accordance with the development plan unless material considerations indicate otherwise to ensure that social, economic, cultural and environmental issues are balanced and integrated”. Paragraph 1.18 of PPW relates to sustainability which emphasises that the planning system should provide for a presumption in favour of sustainable development to ensure that social, economic and environmental issues are balanced and integrated (Para 4.2.2). In Paragraph 2.3 it goes on to state that “The planning system should create sustainable places which are attractive, sociable, accessible, active, secure, welcoming, healthy and friendly. Development proposals should create the conditions to bring people together, making them want to live, work and play in areas with a sense of place and well-being, creating prosperity for all.”
3.8 The Well-being of Future Generations (Wales) Act 2015 is brought up in PPW, which places a duty on public bodies (including Welsh Ministers) to carry out sustainable development. In carrying out this duty, actions which public bodies must take include:
 setting and publishing objectives (“well-being objectives”) that are designed to maximise its contribution to achieving each of the well-being goals; and
 taking all reasonable steps (in exercising its functions) to meet those objectives.
3.9 The Act puts in place seven well-being goals to help ensure that public bodies are all working towards the same vision of a sustainable Wales. These include the need for cohesive communities which are attractive, viable, safe and well-connected.
3.10 In addition, sustainable development should be achieved through the design which is described in Paragraph 3.3: “Good design is fundamental to creating sustainable places where people want to live, work and socialise. Design is not just about the architecture of a building but the relationship between all elements of the natural and built environment and between people and places. To achieve sustainable development, design must go beyond aesthetics and include the social, economic, environmental, cultural aspects of the development, including how space is used, how buildings and the public realm support this use, as well as its construction, operation, management, and its relationship with the surrounding area.”
3.11 In terms of housing, Paragraph 4.2.1 notes the following: “Planning authorities must understand
all aspects of the housing market in their areas, which will include the requirement, supply and delivery
of housing. This will allow planning authorities to develop evidence-based market and affordable housing policies in their development plans and make informed development management decisions that focus on the creation and enhancement of Sustainable Places. New housing development in both urban and rural areas should incorporate a mix of market and affordable house types, tenures and sizes to cater for the range of identified housing needs and contribute to the development of sustainable and cohesive communities”. In relation to housing, PPW states that the planning system ought to:
“recognise a supply of land to assist the delivery of the housing needs to meet the varying requirements of communities across all tenures; offer provision of a spread of well-designed, energy efficient, high quality market and affordable dwellings that contribute towards the formation of sustainable settings; and concentrate on delivery of the recognised housing requirement and associated land supply”.
Carmarthenshire Local Development Plan
3.12 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that planning application decisions should be made in accordance with the development plan unless material considerations indicate otherwise. The statutory development plan for this site is provided by Carmarthenshire Local Development Plan (LDP) 2006 – 2021 which was adopted by the County Council in December 2014.
3.13 The site is not allocated for development in the Adopted Plan, lying just beyond the settlement limits of St Clears, but should be considered through the review process as it lies within close proximity of facilities in the Sustainable Settlement of St Clears and is well related to the existing settlement pattern (as infill development).
3.14 The Carmarthenshire Local Development Plan Review will be required to make provision for future housing needs with an extended Plan Period to 2033, including those of individual settlements in accommodating necessary levels of growth to maintain communities and facilities. Within the current Second Deposit Revised Local Development Plan, the road frontage portion of the site is included as a residential allocation (LPA Ref: Sec18/h5 – Land adjacent to Gwynfa, Station Road for a total of 8 units within the plan period).
3.15 The following section will seek to establish that national planning guidance is broadly supportive of residential development taking place on the site. In these circumstances, therefore, it is submitted that these aspects should be taken into account when assessing the site through the LDP review site selection process.

4 Appraisal

4.1 This section examines how the submission site accords with prevailing planning policy in terms of identifying housing land allocations within development plans.
Availability of Previously Developed Land
4.2 The site is not brownfield land but is well-connected to the current settlement pattern of St Clears and its development for residential purposes represents a logical area for development and inclusion within the settlement boundary, at this location. As previously noted, Ysgol Griffith Jones and St Clears Leisure Centre lie circa 250m to the south-east and 360m to the south of the site respectively. In addition to this, a Co-op Food store lies roughly 320m to the north. These facilities being within walking distance underline the sustainable credentials of the site.
4.3 In order to achieve a sufficient range and choice of housing land opportunities, there will be a need to consider sites which represent viable urban extensions, especially those which could contribute to the Council’s housing land supply over a long period extending to 2033. This site can offer up to 42 residential units, and should therefore be seen as making an important contribution to land supply.
Accessibility
4.4 There is an existing gated access found along the eastern boundary of the site (roughly in a central position along the eastern boundary), fronting onto Station Road. The location of the existing gate would be considered to be the most appropriate point of access for any future development.
4.5 Station Road, within the vicinity of the candidate site, has a speed limit of 30mph which would require visibility splays of 43m in both directions from the site access. This would be achievable, however, an element of the hedgerow may need to be cut back to allow the visibility to be maintained. A drawing based on Ordnance Survey/Topographical based survey data will be able to definitively confirm that visibility is achievable at this access location.
4.6 As already discussed, there a number of facilities within close proximity of the site, including a number of amenities within the defined boundary of St Clears Town Centre. There is also a school and food store located within close proximity of the site on Station Road. The site also benefits from good access to public transport routes with bus stops located on Station Road and Pentre Road providing good connections with nearby towns/settlements, including Carmarthen. In addition to this, the proposed St Clears train station is within walking distance of the site and would enable users to travel to a host of destinations across South Wales including Milford Haven, Carmarthen, Swansea and Cardiff.
4.7 In terms of pedestrian infrastructure, there are already existing footways located along Station Road (on both sides of the carriageway) along the eastern side of the site. This will benefit any future residents that may occupy the site if built for the purposes of residential development.
Land Ownership
4.8 The land to which this Candidate Site Representation refers is within the joint-ownership of the Site Promoter – Mr Wynne Walters and Mr John Walters. Both landowners are fully committed to bringing forward the development of the site. As previously mentioned, both individuals are keen to sell site to a developer in the coming months and have had keen interest from regional developers who are interested in progressing the site towards development to meet the housing need of St Clears. This will help make
up for the fact that some of the housing allocation within the current plan for St Clears have not started or been completed.
Capacity of Infrastructure
Utilities
4.9 All utilities are readily available within the proximity of the site and discussions are underway with relevant utility providers to extend utility infrastructure as required. In addition, as the detailed design of the proposed development progresses, the provision of electric-charging on a plot-by-plot basis will be considered further.
Drainage
4.10 The site is not affected by a flood risk area (which would prevent vulnerable forms of development such as housing), and it is considered that foul surface water will connect with the existing mains sewer.
Access
4.11 Achieving sufficient widths and visibility at the site’s proposed access point would be achievable if an extent of the existing hedgerow were to be cut back. A detailed drawing on Ordnance Survey/Topographical survey data will provide clarity. The development will provide the necessary pedestrian and cyclist infrastructure within the site to encourage residents to walk and cycle, with 2m wide footways included on one or both sides of the carriageway for its entire length and, where appropriate, shared use private drives also included, prioritising the needs of pedestrians and cyclists over that of vehicles.
Impact on the Community/Welsh Language
4.12 A scheme at this location will provide a range and choice of house types and tenures, including affordable elements. It is not considered that the development of the site for housing will have any significant adverse impact upon the Welsh language or any local communities. Ysgol Griffith Jones is a bilingual primary school that has both Welsh and English streams, therefore the development of the site for residential purposes could lead to increased numbers of Welsh students at the school.
Physical and Environmental Constraints
Ecology
4.13 With the retention and enhancement of existing vegetation, there are considered to be no likely significant ecological issues conflicting with planning policy at any level and there are minimal legislative considerations as a result of potential impacts to legally protected species.
Visual Impact
4.14 Overall it is considered that the proposal would not have any significant adverse impact upon the visual amenities of the area. Separation distances, to prevent any adverse or overbearing impacts, between proposed dwellings and existing dwellings can easily be provided.
Coalescence of settlements
4.15 Development on the site would not result in the coalescence of settlements. Development of the site would result in a marginal extension of St Clears development limits, which makes sense as there is already existing development to the north, east and south. It would form a natural inclusion within the development limits of St Clears.
Flood Risk
4.16 The site is not identified in the TAN 15 Development Advice Maps as being at risk from flooding.
Site Contamination
4.17 In terms of ground conditions there are no known constraints that prevent the development of the site for residential uses.
Compatibility with Neighbouring Uses
4.18 It is anticipated that all of the proposed dwellings would respond well to the established character of the surrounding area. It is anticipated that a range of dwelling types and sizes would be incorporated ranging from 2 beds up to 5 beds which forms the basis for interesting street scenes and helps establish a balanced community. Overall it is considered that the proposal would not have any significant adverse impact upon the residential amenities of existing or future occupiers.
The Potential to reduce carbon emissions through co-location with other uses
4.19 The site is proposed for residential uses. However, an increase in population generated will allow help sustain local facilities and potentially increase demand for additional services to benefit the local community.
Relationship with Historic Environment
4.20 The site is not located within or adjacent to the boundary of a Conservation Area. In addition, there are no historic assets within or adjacent to the site (including Scheduled Ancient Monuments; Listed Buildings; and Registered Historic Park or Garden).
Delivery of Key Placemaking Objectives
4.21 Placemaking is at the heart of both ‘Future Wales’ and Planning Policy Wales (Edition 11, February 2021). As set out at Section 3 of ‘Future Wales’: “Future Wales’ Outcomes are overarching ambitions based on the national planning principles and national sustainable placemaking outcomes set out in Planning Policy Wales”. Preliminary investigations have identified that the candidate site can provide homes in the right place and create a sustainable, well-designed, and high-quality housing scheme, where people will want to live, in accordance with national placemaking objectives.

Conclusion

5.1 This Candidate Site representation is made by Asbri Planning Limited on behalf of Mr Wynne Walters and Mr John Walters and requests that land at Station Road, St Clears is brought forward as a housing land use allocation through the Carmarthenshire County Council Second Deposit Revised Local Development Plan 2018 - 2033.

5.2 Within the First Revised Deposit LDP, the site frontage (referred to as ‘Land adjacent to Gwynfa, Station Road) was allocated for residential use under Sec18.h5 for a total of 8 units within the Plan period.

5.3 Within the Second Revised Deposit LDP, the site continues to be identified as a housing allocation under Sec18.h5.

5.4 As per the representation submitted to the First Revised Deposit LDP, the wider site’s partial inclusion as a housing allocation in the Second Revised Deposit LDP is supported, and in particular the acceptance of the residential component of the allocation.

5.5 In summary, of Mr Wynne Walters and Mr John Walters continue to support the Second Deposit Revised Plan on the basis that the Council have accepted the principle of residential uses at the scale proposed, but would respectfully suggest that the wider site is also acceptable as an appropriate residential allocation to ensure the comprehensive redevelopment of the wider site.

5.6 The allocation of the wider site would be required to assist in ensuring the adequate delivery of housing in the sustainable community of St Clears, which may not be achieved by the current housing land allocations which are slow to come forward. The scale and nature of this site would be attractive to house builders, which would facilitate delivery in the short to medium term. The site promoters are keen to sell the land in the near future in order for work to commence on the site as soon as possible.

5.7 The site could potentially deliver a possible further 42 dwellings of various types and sizes which could be phased as appropriate and which would complement the existing form of the settlement. It will not give rise to any significant adverse impacts upon the character of the area, local amenities, residential amenity and highway safety whilst providing a significant contribution to the area’s housing land supply requirements as well as affordable housing. Furthermore, it is positioned in a sustainable location where several amenities lie nearby, and there are adequate public transport connections on offer.

5.9 This submission has assessed the site against prevailing planning policy in Wales. It is clear that the proposals are compatible with the relevant criteria. It is acknowledged that proposals will need to be refined on the basis of further comprehensive study information.
5.9 In light of the above, it is, therefore considered that Carmarthenshire County Council should, in its review of the Local Development Plan, identify the wider land at Station Road, St Clears as a larger housing land use allocation.

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.