MAC 036

Cefnogi

ID sylw: 5964

Derbyniwyd: 25/06/2026

Respondent ID: 2320

Ymatebydd: Dwr Cymru/Welsh Water

The Policy should recognise that surface water removal may not necessarily outright “secure nutrient neutrality” but could be utilised as part of its strategy.
We commend the Council’s inclusion of a ‘Burry Inlet’ SPG and welcome the reference to flow calculations in its supporting appendices.

Reference is made to MAC036 and the insertion of the paragraph after 11.205 which clearly references the opportunity for surface water removal to contribute to nutrient neutrality.

The Council welcomes the support relating to the SPG and flow calculations

Sylw

ID sylw: 5991

Derbyniwyd: 25/06/2026

Respondent ID: 2320

Ymatebydd: Dwr Cymru/Welsh Water

MAC 036 Policy INF4: Llanelli Wastewater Treatment Works Catchment Surface Water Removal
As highlighted in our original comments, we welcome the inclusion of Policy INF4 and are supportive of its principles to satisfy the requirements of the Burry Inlet Memorandum of Understanding (MoU) through compensatory surface water removal. We note that these amendments (MAC036) propose to define the threshold for major development sites and the possible requirement for surface water removal for minor developments. However, whilst we acknowledge this provision is to identify a mitigation measure for nutrient neutrality, the NRW/Welsh Government ‘Mitigation Measures Menu’ recognises that surface water removal (or SuDS) can only provide a modest removal rate. Therefore, whilst the principle may be acceptable, the Policy should recognise that surface water removal may not necessarily outright “secure nutrient neutrality”, in accordance with Policy CCH4, but could be utilised as part of its strategy.

Turning to Paragraph 11.205, we commend the Council’s inclusion of a ‘Burry Inlet’ SPG and welcome the reference to flow calculations in its supporting appendices. We are supportive of this text and would add that the quantifiable amount of surface water to be removed can be expressed as l/s or in terms of its area (sqm), for residential development, which aligns to the SPG appendices.

Comments Welcomed.

Sylw

ID sylw: 6017

Derbyniwyd: 26/06/2026

Respondent ID: 645

Ymatebydd: Ms Zoe Aubery

Asiant : Boyer Planning

Policy INF4 (Llanelli Wastewater Treatment Works Catchment Surface Water Removal). “In order to protect the water quality of the Carmarthen Bay and Estuaries European Marine Site, proposals for major development that would drain directly into the Llanelli Waste Water Treatment Works will be required to remove a quantifiable amount of surface water from the combined sewer
system.

Minor development which drains directly into the Llanelli Wastewater Treatment Works may also introduce the removal of surface water as a mitigation measure to secure nutrient neutrality where required in accordance with Policy CCH4.”

BR supports the principle of the proposed amendments and acknowledges that Dŵr Cymru Welsh Water (DCWW) have confirmed there is sufficient capacity exists within the Llanelli Wastewater Treatment Works (WwTW) to accommodate the level of growth identified within the RLDP.

It is also noted that DCWW has requested that major development proposals draining directly to the Llanelli WwTW should be required to remove a quantifiable amount of surface water from the combined sewer network. This requirement is reflected within the proposed policy wording.

The rationale for this approach is understood to be associated with the fact the majority of the sewerage network within the Llanelli WwTW catchment comprises a combined system conveying both foul and surface water flows. Therefore, requiring major development proposals to undertake compensatory surface water removal as part of the planning process remains consistent with Welsh Government guidance and is intended to ensure that development does not give rise to adverse effects on the Carmarthen Bay and Estuaries SAC and/or the Burry Inlet SPA.

Supporting text explains that, as part of the determination of planning applications for relevant major developments, CCC will require the removal of a quantifiable amount of surface water from the combined sewer system. Whilst this figure is not expressly contained within the proposed policy wording, it is understood that the amount of new foul flow identified within Policy INF4 has been calculated at 0.013 litres per second per residential property. BR raises no objection in principle to this approach on the basis that further guidance will be produced in the form of the emerging Burry Inlet Supplementary Planning Guidance (SPG). In the interest of soundness clear and robust guidance must be provided setting out the Council’s expectations in respect of the details needed considered at the planning application stage via drainage reports.
It is recognised that the removal of surface water from the combined sewer network is likely to require bespoke solutions, dependent upon the scale, characteristics and location of individual developments. BR therefore supports the approach whereby mitigation measures are considered on a site-specific basis. As identified within the Council's Habitats Regulations Assessment – Additional Sites Addendum (March 2025), the site at Land off Heol y Mynydd, Bryn (Ref. PrC2/(v)) is located approximately 1.4km from the Carmarthen Bay and Estuaries SAC and approximately 2 km from the Burry Inlet SPA. Whilst the Council concludes that localised effects associated with the site's proximity to these designated sites are unlikely. BR remains committed to ensuring that appropriate mitigation measures are secured where necessary. Such measures may include a combination of:
• design-led mitigation measures;
• utilisation of existing headroom and permit capacity associated with the relevant WwTW;
and
• strategic mitigation solutions capable of addressing any additional nutrient loading arising from future development.

By virtue of the above BR supports the principle of the proposed amendments, subject to further information being provided by the emerging Burry Inlet SPG. In that regard it will be important that the requirements are clearly set out and applied proportionately through the development management process to provide certainty for applicants and ensure that the delivery of much needed housing is not unnecessarily delayed or constrained, whilst continuing to secure appropriate environmental safeguards.

Noted. The Council is preparing Supplementary Planning Guidance to support the implementation of its policies in respect of the Burry Inlet.

Gwrthwynebu

ID sylw: 6039

Derbyniwyd: 26/06/2026

Respondent ID: 5973

Ymatebydd: City & County of Swansea

Cadarn? Heb nodi

Broadly supportive of the policy with objections to aspects of Policy INF4. The detail are considered within Swansea's other representations to INF4

Noted. Support is welcomed for the policy. Reference is made to other responses submitted by the respondent. These are dealt with through separate representations.

Gwrthwynebu

ID sylw: 6040

Derbyniwyd: 26/06/2026

Respondent ID: 5973

Ymatebydd: City & County of Swansea

Cadarn? Heb nodi

“…the interest that compensatory surface water removal in fact serves is the shellfish water protected areas of the Burry Inlet, designated under the Water Framework Directive — a bacteriological water-quality interest… That is a distinct matter from the nutrient-enrichment interests of the European Marine Site under the Habitats Regulations. Consequently… it is proposed to replace the reference to ‘Carmarthen Bay and Estuaries European Marine Site’ with ‘Water Framework Directive’.”

Noted. The Council recognises the point of clarity and accuracy made by the respondent and is supportive of this change to make sure the policy is clear in its purpose and meaning

Gwrthwynebu

ID sylw: 6041

Derbyniwyd: 26/06/2026

Respondent ID: 5973

Ymatebydd: City & County of Swansea

Cadarn? Heb nodi

The reference is limited to minor developments whilst the first paragraph relates to major developments. The omission of major from the second paragraph would seem at odds with the overall approach in relation to nutrient mitigation. It is proposed to add ‘major’ alongside minor within the second paragraph.”

Noted. The Council recognises the point of clarity and accuracy made by the respondent and is supportive of this change to make sure the policy is clear in its purpose and meaning by including the word 'major' alongside minor within the second paragraph

Gwrthwynebu

ID sylw: 6043

Derbyniwyd: 26/06/2026

Respondent ID: 5973

Ymatebydd: City & County of Swansea

Cadarn? Heb nodi

The term ‘will be required to remove’ surface water — this suggests that there are no examples where on a case by case basis that requirement will not need to be applied. It also leaves no route to the use of surplus betterment (paragraph 11.209) … It is proposed to amend the policy through the replacement of ‘will’ with ‘may’.

Noted. The Council recognises the point of clarity and accuracy made by the respondent and is supportive of this change to make sure the policy is clear in its purpose and meaning through the inclusion of the word 'may' instead of 'will'. This ensures there is consistency of approach with that set out within the reasoned justification and reflects the collaborative cross border approach which underpins the Burry Inlet strategy applied by the authorities.

Gwrthwynebu

ID sylw: 6044

Derbyniwyd: 26/06/2026

Respondent ID: 5973

Ymatebydd: City & County of Swansea

Cadarn? Heb nodi

“the proposed inclusion of the ‘quantifiable amount calculated as 0.013 litres/second’… does not reflect how this is calculated in practice. This is typically done on a case-by-case base, using the latest evidence available to determine likely foul flows.”

Noted. In the interest of clarity and consistency MAC036 would benefit from the inclusion of an additional statement to reflect the case by case nature of such calculations in practice and the contribution made by the latest evidence in determining flow rates.

Further information in relation to such calculations and their application will also be set within the Burry Inlet SPG.

Sylw

ID sylw: 6046

Derbyniwyd: 26/06/2026

Respondent ID: 5973

Ymatebydd: City & County of Swansea

'it may well be the case that over the Plan period, potential future DCWW investment may mean that the position in respect of the need for surface water removal to be undertaken by developers will be no longer applicable, therefore again – flexibility is key.

Comments noted. The Council recognises that the position will change over the plan period. This will continually be under review.

Sylw

ID sylw: 6047

Derbyniwyd: 26/06/2026

Respondent ID: 5973

Ymatebydd: City & County of Swansea

We appreciate that the above proposed changes may result in the requirement for some consequential amendments to the reasoned justification but hope that such amendments are not extensive. Also, with reference to the proposed SPG, we would welcome the opportunity to contribute and comment at the appropriate time

Comments noted.

Gwrthwynebu

ID sylw: 6048

Derbyniwyd: 26/06/2026

Respondent ID: 2315

Ymatebydd: Natural Resources Wales

Cadarn? Ydi

We have one further comment with regards to MAC 036 and the proposed amendments to Policy INF4. Again, this comment relates to further edits to the proposed text for reasons of clarity / accuracy.

In regard to the new paragraphs added after paragraph 11.205, we suggest that the third sentence is amended as follows:

‘It is acknowledged that the removal of surface water may offer wider benefits including making a contribution towards achieving nutrient neutrality where required’.

The Council agrees with the changes suggested by the respondent in the interest of clarity and meaning.

In the interest of consistency the Council's proposes to insert the word 'and minor' after the words 'major' within the first sentence of the new paragraph after paragraph 11.205.