Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
Chwilio sylwadau
Canlyniadau chwilio Natural Resources Wales
Chwilio o’r newyddCefnogi
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
11.1
ID sylw: 5716
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
11.1 We note the intention that the strategic policies reflect the core elements of sustainability and sustainable development and the four themes of the Carmarthenshire Well-being plan.
No change
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.
Noted
Cefnogi
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
SG1: Adfywio a Safleoedd Defnydd Cymysg
ID sylw: 5717
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
SG1: Regeneration and Mixed-Use Sites Provision for mixed use allocations have been made for ten sites across the county. Our detailed comments on all the allocations can be found in Annex 2 and 3. We have not provided comments on those allocations which have already secured full planning.
No change to the Plan
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.
Comments Noted
Cefnogi
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
11.16
ID sylw: 5718
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
Paragraph 11.16 states that where appropriate the allocated sites and their identified uses will be considered further through Supplementary Planning Guidance (SPG) in the form of development briefs. We are happy to be involved in their production and can offer advice on the assessments and considerations required to support any subsequent planning application submission.
No change to the Plan
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.
Noted.
Cefnogi
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
SG3: Penrhyn Pen-bre
ID sylw: 5719
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
Strategic policy SG3: Pembrey Peninsula
This is a new policy that has been included since the first draft. We can understand the significance of the area regarding the economy of the county but in addition to respecting the area’s role, function and sense of place it is imperative that proposals do not have a negative impact on the sensitive ecology of the area and that consideration is given to the risks from coastal flooding and erosion.
Pembrey is a particularly sensitive area with regard to ecology and habitat loss, disturbance, light pollution and hydrological impacts. Some of the UK's rarest species can be found in this area including Vertigo angustior and Dactonys aquatus, in addition to numerous other Sitte of Special Scientific Interest (SSSI) and Special Area of Conservation (SAC) features. Water voles have been reintroduced to the Pembrey area in recent years and it also provides a haven for Dormice and Greater horsehoe bats. The area is also adjacent to the Burry Inlet Special Protection Area (SPA) and Ramsar site.
No change to the Plan
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.
Noted. The Pembrey Peninsula will be subject to Supplementary Planning Guidance.
Cefnogi
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
11.25
ID sylw: 5720
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
11.25 We note that SPG will be produced to elaborate upon the provisions of this policy and the future opportunities within the Peninsula. We advise that careful consideration should be given to the sensitivities of the area especially those outlined above, and we are happy to offer our input into the production of the SPG.
No change to the Plan
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.
Noted.
Cefnogi
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
PSD1: Atebion Dylunio Effeithiol: Cynaliadwyedd a Chreu Lleoedd
ID sylw: 5721
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
PSD1: Effective Design Solutions: Sustainability and Placemaking
We support the intention of the policy to ‘maximise opportunities for; enhancement to the quality and extent of existing; and the creation of new, landscape and ecological elements and features, as Green and Blue Infrastructure assets’. However, connectivity needs to be considered in the design to ensure that existing habitats/biodiversity is not isolated. We therefore advise that as a point of clarity specific mention of connectivity is detailed within Policy PSD1 (d).
No change to the Plan
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.
Comments noted. Matter to be further considered at examination.
Gwrthwynebu
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
PrC3/h33
ID sylw: 5722
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Heb nodi
The following sites are identified by the Flood Map for Planning as being at risk of flooding and therefore their allocation within the plan fails to meet the tests of soundness.
As confirmed in the letter from Welsh Government dated 15 December 2021, ‘when plans are reviewed, the flood risk considerations that feed into the settlement strategy and site allocations must be in accordance with the new TAN 15 and the Flood Map for Planning’. When proposing an allocation within a flood risk area your Authority should undertake sufficient background evidence to demonstrate that the development is appropriate for the flood zone and that the consequences of flooding can be acceptably managed.
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.
The site has been delivered and its the allocation within the LDP for residential purposes is to reflect this.
Gwrthwynebu
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
PrC3/h19
ID sylw: 5723
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Heb nodi
The following sites are identified by the Flood Map for Planning as being at risk of flooding and therefore their allocation within the plan fails to meet the tests of soundness.
As confirmed in the letter from Welsh Government dated 15 December 2021, ‘when plans are reviewed, the flood risk considerations that feed into the settlement strategy and site allocations must be in accordance with the new TAN 15 and the Flood Map for Planning’. When proposing an allocation within a flood risk area your Authority should undertake sufficient background evidence to demonstrate that the development is appropriate for the flood zone and that the consequences of flooding can be acceptably managed.
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.
The site is under construction with most dwellings completed.
Gwrthwynebu
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
SeC19/h1
ID sylw: 5724
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Heb nodi
The following sites are identified by the Flood Map for Planning as being at risk of flooding and therefore their allocation within the plan fails to meet the tests of soundness.
As confirmed in the letter from Welsh Government dated 15 December 2021, ‘when plans are reviewed, the flood risk considerations that feed into the settlement strategy and site allocations must be in accordance with the new TAN 15 and the Flood Map for Planning’. When proposing an allocation within a flood risk area your Authority should undertake sufficient background evidence to demonstrate that the development is appropriate for the flood zone and that the consequences of flooding can be acceptably managed
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.
The allocation of the site within the LDP for residential purposes has been subject to full consideration through the site assessment methodology. As part of this assessment process a detailed site pro forma has been prepared.
Gwrthwynebu
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
SeC19/h2
ID sylw: 5725
Derbyniwyd: 25/05/2023
Ymatebydd: Natural Resources Wales
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Heb nodi
The following sites are identified by the Flood Map for Planning as being at risk of flooding and therefore their allocation within the plan fails to meet the tests of soundness.
As confirmed in the letter from Welsh Government dated 15 December 2021, ‘when plans are reviewed, the flood risk considerations that feed into the settlement strategy and site allocations must be in accordance with the new TAN 15 and the Flood Map for Planning’. When proposing an allocation within a flood risk area your Authority should undertake sufficient background evidence to demonstrate that the development is appropriate for the flood zone and that the consequences of flooding can be acceptably managed.
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.
The allocation of the site within the LDP for residential purposes has been subject to full consideration through the site assessment methodology. As part of this assessment process a detailed site pro forma has been prepared.
