MAC 126

Sylw

ID sylw: 5969

Derbyniwyd: 25/06/2026

Respondent ID: 2320

Ymatebydd: Dwr Cymru/Welsh Water

The appendix will need to accurately reflect our representations and recognise that the demands on our infrastructure changes over time, and the capacity of existing infrastructure to accommodate the proposed allocations may change over the course of the LDP period. Notwithstanding this information, we have made comments on specific sites

Noted. The Council considers that the sites highlighted within the representation can be updated to reflect the most up to date information.

Sylw

ID sylw: 5995

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.

MAC 046 Policy PSD1: Effective Design Solutions: Principles of Placemaking
We acknowledge amendments (MAC 046) proposed to the criteria for Policy PSD1 and welcome reference to maximised opportunities for water resilience in criteria (g). We agree that water efficiency in new developments can offer multiple benefits and we recognise it can positively contribute to nutrient neutrality provided it forms part of a wider package of mitigation, as referenced in Paragraph 11.284. Similar to the above (MAC 036), we would highlight that water efficiency measures may not secure nutrient neutrality, in accordance with Policy CCH4, but could be utilised as part of its strategy.

MAC 080 CCH4: Water Quality and Protection of Water Resources
As highlighted in our original comments, we welcome the inclusion of Policy CCH4 and acknowledge that these amendments (MAC 080) propose to amalgamate the impact of development on nutrient sensitive protected sites, to substitute phosphorous sensitive riverine SACs. We defer to NRW’s ‘Advice to planning authorities for planning applications affecting nutrient sensitive Special Areas of Conservation’ to determine which development will be required to achieve nutrient neutrality and remind that DCWW is a statutory consultee for most planning applications.
With reference to the amendments to Paragraphs 11.513 to 11.515 (‘Riverine’), we acknowledge the variety of strategic and developer-led mitigatory actions and welcome the continued collaborative partnership work with NMBs. DCWW remain committed to the ‘fair share’ approach, as defined by Welsh Government’s practical guidance for public authorities (DTA Ecology), through our phosphorus investment plan to remove 90% of the phosphorous load from WwTWs discharging to failing SAC rivers. In accordance with NRW’s planning advice, we will continue to comment on the capacity of WwTWs to treat foul water flows alongside confirmation of its compliance with permit conditions, including effective dates as identified by the review of permits. Aside of the permit headroom capacity, we defer to the Council’s Action Plan to identify any further measures to mitigate against any increasing nutrient loads in the river.
We acknowledge a separate sub-heading for ‘Marine’, including requirements to achieve nutrient neutrality within the Burry Inlet Inner and Milford Haven Inner freshwater catchments. We would advise the Council that most site locations within are likely to discharge into these catchments; however, it should also be noted that some sites may be located outside but ultimately drain via a sewerage network into the affected freshwater catchment. For example, Burry Port is located outside but comprises of a sewerage network which drains to Llanelli Coastal WwTW and therefore discharges into the Burry Inlet Inner. Similarly, albeit rarely, there are site locations located within but discharge to a sewerage network outside of the freshwater catchment and examples of sites that are on the periphery of networks within and outside. For completeness, we refer to NRW’s latest planning advice and recognise DCWW’s duty to confirm which WwTW the site would connect to and its compliance with permit conditions.
We acknowledge the Council’s intention to produce “multilayered” guidance for strategic and developer led mitigation for developments in the freshwater catchments and we would advocate for close collaboration with DCWW on this approach, particularly if it relates to any public sewerage assets. On this point, DCWW is undertaking its source apportionment modelling programme which is programmed to conclude in Spring 2027 and will be important to ensure any mitigation measures are aligned with the modelling findings. As highlighted above (MAC 036), we remind that surface water removal may not secure nutrient neutrality but could be considered as part of the mitigation strategy. We note the Council’s proposal to produce a library of resources to assist developers in this matter, alongside external sources, and welcome the intention to regularly update the library which can align to any further updates in NRW’s planning advice.
Lastly, we welcome the addition of a new paragraph to reflect the requirements of TAN 15 and advocate for early engagement with the SAB and any other stakeholder, including DCWW, where the drainage proposals will have an impact on their interests. We also welcome the production of an SPG to support this Policy, in relation to a nutrient mitigation toolkit alongside the aforementioned ‘Burry Inlet’ SPG to consider sustainable management of surface water drainage.

MAC 125 Appendix 9
We note that a new appendix is included to provide site information for the regeneration and mixed-use sites, including the infrastructure requirements. DCWW has made representations at the Deposit Plan consultation stage to highlight sewerage and water infrastructure requirements associated with proposed sites. The appendix will need to accurately reflect our representations and recognise that the demands on our infrastructure changes over time, and the capacity of existing infrastructure to accommodate the proposed allocations may change over the course of the LDP period. Notwithstanding this information, we have made comments on specific sites below:
• PrC1/MU2 Pibwrlwyd Hydraulic Modelling Assessment (HMA) of the water supply network will be required.
• PrC3/MU1 Emlyn Brickworks Hydraulic Modelling Assessment (HMA) of the water supply network will be required.
• SeC16/MU1 Beechwood, Llandeilo Reinforcements will be required at Ffairfach Wasterwater Treatment Works (WwTW).
• PrC1/MU3 Nant y Caws There are no public sewers nearby therefore the provisions of WG Circular 008/2018 “Planning requirements in respect of the use of private sewerage in new development, incorporating septic tanks and small sewage treatment plants” apply.

MAC 126 Appendix 10
We note that a new appendix is included to provide site Information on allocated sites, including the infrastructure requirements DCWW has made representations at the Deposit Plan consultation stage to highlight sewerage and water infrastructure requirements associated with proposed sites. The appendix will need to accurately reflect our representations and recognise that the demands on our infrastructure changes over time, and the capacity of existing infrastructure to accommodate the proposed allocations may change over the course of the LDP period. Notwithstanding this information, we have made comments on specific sites below:
• SUV11/h1 Alltwallis Reinforcements will be required at Alltwallis WwTW
• PrC2/h20 Harddfan, Bryn A scheme has been delivered, and capacity is available at Llangennech WwTW
• PrC2/(v) Heol y Mynydd, Bryn Hydraulic Modelling Assessment (HMA) of the water supply network will be required.
• SeC6/(iii) Forest Rd, Hendy Llannant WwTW limited capacity, AMP8 scheme being delivered by 2030
• SEC7/h3 Golwg yr Afon, Llangennech A scheme has been delivered, and capacity is available at Llangennech WwTW

• SEC7/h4 Opposite Parc Morlais Llangennech A scheme has been delivered and capacity is available at Llangennech WwTW

• PrC3/(i) Emlyn Brickworks Hydraulic Modelling Assessment (HMA) of the water supply network will be required.

• SeC12/h1 Trem y Ddol Newcastle Emlyn Reinforcements will be required at Adpar WwTW

• SeC12/h3 Rear of Dolcoed Newcastle Emlyn
Reinforcements will be required at Adpar WwTW

• SeC19/h1 Land at Park View, Trevaughan Whitland
WwTW has limited capacity, AMP8 scheme being delivered by 2030

• SeC19/h2 Land at Whitland Creamery Whitland WwTW has limited capacity, AMP8 scheme being delivered by 2030

• SeC20/h3 Land off Clifton Street Laugharne WwTW has limited capacity, AMP8 scheme being delivered by 2030

• SuV55/h2 Glandy Cross There are no public sewers nearby therefore the provisions of WG Circular 008/2018 “Planning requirements in respect of the use of private sewerage in new development, incorporating septic tanks and small sewage treatment plants” apply.

• SuV56/h1 Efailwen There are no public sewers nearby therefore the provisions of WG Circular 008/2018 “Planning requirements in respect of the use of private sewerage in new development, incorporating septic tanks and small sewage treatment plants” apply.

Noted. The Council considers that the sites highlighted within the representation can be updated to reflect the most up to date information.

Cefnogi

ID sylw: 6001

Derbyniwyd: 02/07/2026

Respondent ID: 3410

Ymatebydd: Persimmon Homes West Wales

Persimmon Homes supports the inclusion of SeC6 (iii) Land at Fforest Road and will deliver in line with the trajectory

Support welcomed.

Gwrthwynebu

ID sylw: 6015

Derbyniwyd: 26/06/2026

Respondent ID: 645

Ymatebydd: Ms Zoe Aubery

Asiant : Boyer Planning

Cadarn? Nac Ydi

As part of the Matter Arising Changes (MACs), it is understood that an additional paragraph has been inserted explaining that:

"Development limits are a key mechanism for helping to manage future growth by defining the area within which development would normally be permitted, subject to material planning considerations.

The development limits have been applied to the Principal Centres, Service Centres and Sustainable Villages as defined in Strategic Policy SP3: Sustainable Distribution – Settlement Framework."

Barratt Redrow supports the principle of amending the settlement boundary but maintain that the proposed changes should be further revised to ensure a sustainable pattern of growth is achieved at Bryn. In turn this approach will better contribute towards meeting identified housing
needs, including the provision of homes for local people in an accessible and sustainable location. For the purposes of soundness, BR strongly believe that the proposed allocation at Land off Heol y Mynydd, Bryn should be extended to account for the site in its entirety. This would
require a corresponding amendment to the development limits to include the full 5.4 hectares of land under Barratt Redrow's control, thereby avoiding any potential reliance upon the adjoining parcel of undeliverable white land to contribute to future housing supply.

By contrast Barratt Redrow notes that, as a consequence of the revised development limits, an area of unallocated "white land" immediately to the south of the proposed allocation (also accessed from Heol y Mynydd, Bryn) would, by default, be incorporated within the settlement boundary. In procedural terms, the inclusion of this land within the development limits creates the potential for it to come forward as a windfall site during the plan period. However, the land is understood to be landlocked, unregistered in terms of ownership and, as such, cannot
presently be considered deliverable or developable.

Barratt Redrow therefore requests that the additional land, directly to the west of the allocation, which has continuously been promoted for residential development should be incorporated within the allocation boundary. The land is available, within the control of the developer, and
capable of being delivered during the early years of the Plan period. Moreover, its inclusion would provide greater certainty that future residential development in this location will be delivered in a more comprehensively, coherent and ultimately sustainable manner. Thereby avoiding piecemeal or speculative proposals coming forward on adjacent land. This approach would be more closely aligned with national policy and in particular WG’s principles of good placemaking in order to contribute towards achieving sustainable development in accordance with Test 2 of the DPM.

In addition to the above, there appears to be some technical inconsistencies relating to site reference numbers and the physical extent of the development limits shown within the current Matters Arising Consultation document.

Firstly, the settlement boundary illustrated within the PDF version of the Matter Arising Changes documents (Figure 3) appears to be at odds with the boundary presented within the Council's interactive online mapping (Figure 2). As mentioned above whilst we understand that the intention is to amend the development limits of Bryn to incorporate Phase 1 of the site known as 'Land off Heol y Mynydd, Bryn' and, by virtue of which the unregistered parcel of white land located immediately to the south (BR maintains concerns regarding this approach). Currently
there are discrepancies between the two plans which creates uncertainty as to the physical extent of the defined urban area and in turn adds an unnecessary layer of complication when interpretating the proposed changes. It is therefore essential that the Council clarifies the proposed arrangements on the PDF version (Figure 3) and rectifies any inconsistencies to ensure that all interested parties are able to make informed decisions based on an accurate and robust evidence base.

Secondly, there also appear to be inconsistencies in the allocation reference numbers relating to Land off Heol y Mynydd, Bryn. Throughout the Revised LDP, the allocation is generally referred to as PrC2/(V). However, within the Matter Arising Changes documentation, the site is identified as (MACM)PrC2/c, with the land to the south-east of Land off Heol y Mynydd, Bryn is allocated as
(MACM)PrC2/v. Similar to the above these inconsistencies create ambiguity and have the potential to undermine effective interpretation and implementation of the Plan.
For completeness it is important that both of these matters are rectified for the purposes of accuracy/ transparency, and that the Revised LDP and all associated documentation consistently reflect the Council's intended position. Notwithstanding Barratt Redrow's continuing concerns regarding the appropriateness of extending the settlement boundary to include the unregistered parcel of white land, priority should instead be given to extending the proposed allocation at Heol y Mynydd, Bryn so as to provide a more coherent and defensible settlement edge.

Noted. The site in question is included within the development limits as 'white land' with no designated proposed uses. Whilst it is noted that there would be potential for the site to be brought forward for potential development this would only be possible subject to access, amenity and infrastructural constraints being overcome. Consequently the site makes no contributions towards the Council's housing supply.

The potential for misinterpretation to site reference is noted, however these site references were only to the MAC consultation and a final adopted Revised LDP will contain a separate / new site reference for the new allocated site, therefore removing any potential confusion that may have occurred.

Cefnogi

ID sylw: 6085

Derbyniwyd: 27/05/2026

Respondent ID: 65

Ymatebydd: Llanllawddog Community Council

The Community Council is also supportive of that included within the Key Considerations and Constraints affecting the site, particularly the need for the development requiring a Commuted Sum towards community benefits in line with Policy INF1 and that a planning obligations will be sought to ensure that the effects of developments are fully addressed in order to make the development acceptable. This is a key point as the developer within phase 2 of the development was only required to provide a small (165sqm) play area and was not required to provide any play equipment.

Support welcomed.