Matters Arising Changes 2026

Cefnogi

ID sylw: 6023

Derbyniwyd: 26/06/2026

Respondent ID: 2315

Ymatebydd: Natural Resources Wales

We note and support the various policy amendments to include specific cross referencing to Policy CCH4 within the MACs. This approach is consistent with the point raised for consideration in the WG Examination Statement i.e. the ‘need to signpost other policy areas within the RLDP that are necessary to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites’.

Support welcomed

Cefnogi

ID sylw: 6024

Derbyniwyd: 26/06/2026

Respondent ID: 2315

Ymatebydd: Natural Resources Wales

We note that Policy CCH4, as proposed by the MACs, would retain a generic Habitats Regulations approach, requiring that development does not adversely affect the integrity of European sites. Previously this approach was proposed specifically for riverine SACs; MAC 080 proposes to extend coverage to ‘nutrient sensitive protected sites’. We are satisfied that this approach remains appropriate in principle.

Support welcomed

Gwrthwynebu

ID sylw: 6025

Derbyniwyd: 26/06/2026

Respondent ID: 2315

Ymatebydd: Natural Resources Wales

Cadarn? Ydi

The Afon Tywi and Afon Teifi Nutrient Neutrality Plan is referred to in paragraph 11.514 and others that follow. Paragraph 11.514 states ‘The document sets out a range of measures, which have been agreed in consultation with NRW’. We wish to clarify that to date we have not provided any formal comments on the Plan. Recent correspondence from your Authority confirms that the Plan is ‘…background evidence to support policy CCH4 and the Revised LDP and has not formed part of an LDP consultation itself’. Therefore, to avoid confusion, the reference to agreement with NRW should be removed from this paragraph.

Noted. The Nutrient Neutrality Action Plan represents a component of the Plan's evidence base as set out in para 11.514 and was not subject to formal consultation as part of the preparation of the revised LDP. However, as part of evidence and given the technical and regulatory components underpinning the issue of nutrients it was prepared with reference to, and engagement with various partners including the regulators. The authority recognises the consultation / engagement was not part of the LDP process therefore endorses the removal of the reference from paragraph 11.514.

Gwrthwynebu

ID sylw: 6027

Derbyniwyd: 26/06/2026

Respondent ID: 2315

Ymatebydd: Natural Resources Wales

Cadarn? Ydi

With regards to the Plan itself, your authority has provided us with two web links for this document. However, neither links to a document titled ‘Afon Tywi and Afon Teifi Nutrient Neutrality Plan’. One link leads to a document titled Carmarthenshire County Council Nutrient Neutrality Action Plan Technical Report dated March 2024. The other link is to a document titled Carmarthenshire Nutrient Management Strategy - Achieving Nutrient Neutrality & Beyond dated March 2024. Although both documents were produced by Arcadis, they have different authors and differ in length. For the purposes of the LDP, it is vital to ensure that the document referenced in the explanatory text is correct, to avoid confusion in future. We therefore advise that all references to the Plan in the supporting
text are checked, and amended as needed, to refer to the correct document.

Noted. In the interest of accuracy the Council recognises that paragraph 11.514 should be amended to reflect the name of the correct document.

Gwrthwynebu

ID sylw: 6028

Derbyniwyd: 26/06/2026

Respondent ID: 2315

Ymatebydd: Natural Resources Wales

Cadarn? Ydi

We are concerned that the new paragraph after 11.512 may not provide adequate explanation regarding the issues of capacity at wastewater treatment works and could be misunderstood. To provide greater clarity, we suggest the new paragraph is amended as follows:

‘Within the hydrological catchment area designated for Riverine SACs, development will be required to demonstrate no adverse effect on the integrity of nutrient sensitive SACs. For development creating wastewater discharges, there will be a requirement to demonstrate there is capacity within the environmental permit limits set at the Wastewater Treatment Works to which it drains, taking account of fair share principles within the catchment into which the Works discharges. In doing so, development should not lead to any deterioration to a SAC failing to meet phosphorus targets or delay the achievement of meeting its conservation objectives.’

'Where evidence demonstrates that adverse effects on the integrity of SAC can be avoided or mitigated, this must be agreed with the planning authority on a case-by-case basis, in consultation with NRW.'

Agreed.

Gwrthwynebu

ID sylw: 6031

Derbyniwyd: 26/06/2026

Respondent ID: 2315

Ymatebydd: Natural Resources Wales

Cadarn? Ydi

In relation to the phasing of development (Burry Inlet Inner and Milford Haven Inner catchments), We believe there should be additional clarity provided in the explanatory text regarding the need to align delivery of development with environmental capacity. This would be consistent with the point raised for consideration in the WG Examination Statement i.e.
‘…phasing and delivery of growth contained within the RLDP to ensure it is within sustainable locations and reflects the ‘lead in times’ necessary to ensure compliance with achieving NN targets’.

The Council notes the point that delivery of development should be aligned with environmental capacity and the timing of mitigation. The Council acknowledges that the strategic mitigation Action Plan in relation to the marine SAC remain under development, however this will also be supplemented by developer-led mitigation packages that are designed to release development. It is implicit given the relationship between mitigation, environmental capacity, and the delivery of development that phasing may on certain sites be required. In this respect phasing in itself will be on a case-by-case basis and the inclusion of a blanket statement would be superfluous and unnecessary.

Gwrthwynebu

ID sylw: 6032

Derbyniwyd: 26/06/2026

Respondent ID: 2315

Ymatebydd: Natural Resources Wales

Cadarn? Ydi

Amend policy wording of CCH4 in the following paragraph:

The second sentence should read: ‘Where appropriate, development will be required to…’

Noted. The Council would accept the inclusion of the comma after the words 'Where appropriate'

Gwrthwynebu

ID sylw: 6033

Derbyniwyd: 26/06/2026

Respondent ID: 2315

Ymatebydd: Natural Resources Wales

Cadarn? Ydi

Amend wording in the last sentence of paragraph 11.513 to read:
“Updated NRW Guidance now advises on constraints to development planning in relation to both phosphorus and nitrogen impacts within river SAC catchments.”

The Council agrees that NRW’s suggested rewording would improve the accuracy of the supporting text by reflecting that updated NRW Guidance now addresses both phosphorus and nitrogen impacts within river SAC catchments.

Gwrthwynebu

ID sylw: 6034

Derbyniwyd: 26/06/2026

Respondent ID: 2315

Ymatebydd: Natural Resources Wales

Cadarn? Ydi

We suggest paragraph 11.515 is updated to refer to the West Wales NMB.

The Council agrees that reference to the West Wales NMB at paragraph 11.515 would improve accuracy.

Gwrthwynebu

ID sylw: 6035

Derbyniwyd: 26/06/2026

Respondent ID: 2315

Ymatebydd: Natural Resources Wales

Cadarn? Ydi

For the first new paragraph proposed in the section titled ‘Marine’, we suggest the following edits:

'The marine SACs in Wales have a number of qualifying features including estuaries, coastal lagoons, large shallow inlets and bays and mudflats/sandflats that are sensitive to high levels of nutrients. The updated condition assessments undertaken by NRW and published in June 2025 identified that nutrient sensitive features at some designated sites had reached an unfavourable condition for Dissolved Inorganic Nitrogen [DIN], phytoplankton and opportunistic macroalgae. These are chemical and biological indicators of nitrogen enrichment.’

The Council agrees that NRW’s suggested edits would improve the accuracy and clarity of the first paragraph of the ‘Marine’ section.