Strategic Policy SP 18: Mineral Resources

No change.

Dear Sir/Madam

2nd DEPOSIT REVISED CARMARTHENSHIRE LOCAL DEVELOPMENT PLAN 2018 - 2033

The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and silica sand industries. With the affiliation of British Precast, the British Association of Reinforcement (BAR), Eurobitume, MPA Northern Ireland, MPA Scotland and the British Calcium Carbonate Federation, it has a growing membership of over 530 companies and is the sectoral voice for mineral products. MPA membership is made up of the vast majority of independent SME quarrying companies throughout the UK, as well as the 9 major international and global companies. It covers 100% of UK cement production, 90% of GB aggregates production, 95% of asphalt and over 70% of ready-mixed concrete and precast concrete production. In 2016, the industry supplied £18 billion worth of materials and services to the Economy. It is the largest supplier to the construction industry, which had annual output valued at £169 billion in 2018. Industry production represents the largest materials flow in the UK economy and is also one of the largest manufacturing sectors. For more information visit: www.mineralproducts.org.

Thank you for consulting us on the above document. Our comments are appended to this letter. For ease of reference where we have proposed amendments to the text, we have struck through text (xxxxxx) to be deleted and used bold underlined text (xxxxxx) for proposed insertions.

If you require clarification on any of the points made, please do not hesitate to contact us. We welcome future engagement on this matter. We should be grateful if you could forward future correspondence to the email below.

Yours faithfully

Nick Horsley

Director of Planning, MPA Wales

Section 7.6
SO5
The formatting of the document is confusing in that SO5 appears before SO3 and SO4
Amend the formatting of the document and ensure SO3, SO4 and SO5 appear in the correct order.

Section 7.6
Strategic Objectives
It remains unclear why the provision of a sustainable and adequate supply of minerals is not identified as a Strategic Objective. This is a fundamental requirement of PPW and the need for minerals is the thread which stiches together many of the strategic objective identified, providing raw materials to deliver and address issues such as employment, housing, climate change, infrastructure, transport and environmental aspirations.
Include a further Strategic Objective to reflect the need for a sustainable and adequate supply of minerals.

Policy BHE1: Listed Buildings and Conservation Areas
Subsections 2. & 3. State:
“2. Developments within or adjacent to a conservation area will be permitted, where it would preserve or enhance the character or appearance of the conservation area, or its setting.
3. New developments in conservation areas should be of a high standard of design which responds to the area’s special characteristics and features.”
It remains unclear how the requirements of these subsections will be achieved. Maintaining the characteristic fabric of these buildings and conservation areas routinely requires an indigenous supply of local stone and materials, sympathetic to the character of the area and its buildings. There are no policies within the plan supporting the development of indigenous sources of building stone/materials.
Clarify within the plan how the characteristics of conservation areas and listed buildings will be maintained using materials sympathetic to the area. Sources of indigenous building materials will be needed and reflected within the policies in the plan.

Strategic Policy SP 18: Mineral Resources
Subsection a) states “Ensuring an adequate supply of minerals, including maintaining an adequate landbank of permitted aggregate reserves (a minimum 10 years for hard crushed rock, and a minimum 7 years for sand and gravel) throughout the Plan period;”
We welcome the amendments now incorporated.

Strategic Policy SP 18: Mineral Resources
Subsection c) states “Safeguarding minerals infrastructure, and areas underlain by minerals of economic importance where they could be worked in the future, to ensure that such resources and infrastructure are not unnecessarily sterilised by other forms of development;”
We welcome the amendments now incorporated

Paragraph 11.564
“For crushed rock, Carmarthenshire forms part of the Swansea City Sub-region, along with the local authorities of Swansea and Neath Port Talbot. Although at present, Swansea is unable to demonstrate an inability to meet RTS2 apportionments, there are more than sufficient reserves within NPT and Carmarthenshire to take up the joint apportionment within this period without resulting in under provision. A statement of subregional collaboration (SSRC) has been produced which demonstrates how the constituent Authorities satisfy the requirements of RTS2 in respect of future crushed rock provision.”
We have concerns that the approach proposed does not accord with the RTS, not least that the concerns raised in our response to the draft Swansea SSRC, dated 19th November 2020 have not been addressed. Where authorities are seeking to “absorb” apportionments from neighbouring authorities, it is necessary that there is a corresponding increase in provision within those authorities, as required by MTAN 1. The receiving authorities will need to increase their apportionments (and, where necessary, allocations), to ensure that as a minimum, the overall requirements for ongoing supply within that sub-region, as set out in the RTS, are met (both numerically and in terms of aggregate type). It will not normally be appropriate to merely transfer apportionments to an LPA with sufficient existing reserves to arithmetically absorb the apportionment, without reference to the additional consideration of productive capacity. Whilst the shortfall in allocation relates primarily to Swansea, it is inappropriate for this flaw to be reflected in the Carmarthenshire RLDP.
Amend the text accordingly to reflect the RTS second review requirements (Annex A).

Paragraph 11.565
“…..Therefore, a joint approach is being pursued by Pembrokeshire, Ceredigion and Carmarthenshire for the provision of the allocation requirement for 3.626 million tonnes over the period up to 2038.”
The allocation specified in the RTS is a minimum. The wording should be amended accordingly.
“…..Therefore, a joint approach is being pursued by Pembrokeshire, Ceredigion and Carmarthenshire for the provision of the allocation requirement for a minimum 3.626 million tonnes over the period up to 2038.”

Paragraph 11.566
“In the event that the allocations for sand and gravel in the three constituent authorities are not sufficient to meet the 3.626 million tonnes over the period up to 2038, an ‘area of search’ for sand and gravel has been identified on the proposals map (with further areas being identified by Pembrokeshire and Ceredigion in their respective Revised LDPs). Furthermore, a statement of sub-regional collaboration (SSRC) is being produced which will demonstrate how the constituent Authorities will satisfy the requirements of RTS2 in respect of future sand and gravel provision.”
Firstly, the 3.626mt is a minimum allocation and this should be reflected in the text.
Secondly, the comments above apply equally to this paragraph. In addition, the wording in paragraph 11.566 conflicts with paragraph 11.564. Paragraph 11.564 states “A statement of subregional collaboration (SSRC) has been produced which demonstrates how the constituent Authorities satisfy the requirements of RTS2”. However, this paragraph (11.566) states “a statement of sub-regional collaboration (SSRC) is being produced. (our underlining).
The wording is confusing and needs to be rectified. It is imperative that the adoption of the SSRC must follow the process outlined in the RTS 2nd Review.
Amend the text accordingly, firstly to reference the “minimum” allocation and secondly to clarify the status of the RTS.
“In the event that the allocations for sand and gravel in the three constituent authorities are not sufficient to meet the minimum 3.626 million tonnes”…..

Paragraph 11.567
“In respect of working the resource within the area of search, this will not be carried out within 100m of residential properties. Proposals for extraction will also need to accord with the criteria set out within Policy MR1 Mineral Proposals. On those elements of the area of search that contain grade 3a agricultural land, the need for extraction will be considered in accordance with paragraph 3.59 of PPW Ed.11.”
This paragraph does not properly reflect MTAN1 and should be amended accordingly. MTAN1 states “that the following minimum
distances should be adopted unless there are clear and justifiable reasons for reducing the distance. An example may be that, because of other means of control, there is very limited impact from the mineral extraction site.” (Our underlining)
For Sand and Gravel this should be 100m.
The wording should be amended to reflect MTAN1.
Amend the text to read ““In respect of working the resource within the area of search, this will not be carried out within 100m of residential properties unless there are clear and justifiable reasons for reducing the distance. Proposals for extraction will also need to accord with the criteria set out within Policy MR1 Mineral Proposals. On those elements of the area of search that contain grade 3a agricultural land, the need for extraction will be considered in accordance with paragraph 3.59 of PPW Ed.11.”

Policy MR2: Mineral Buffer Zones
This Policy states: “Provision has been made for Buffer Zones around all sites with extant planning permission for mineral working.”
PPW requires that Buffer Zones are provided as “areas of protection around permitted and proposed mineral workings” also “buffer zones should be identified in development plans around existing or proposed minerals sites” (Our underlining). This is also reflected in MTAN1.
Amend the text to read: “Provision has been made for Buffer Zones around all sites with extant planning permission for mineral working and proposed mineral workings.” We note the amendment to para 11.571 to reflect this.

MR3: Mineral Safeguarding Areas
The policy states “Planning permission will not be granted for development proposals where they would permanently sterilise resources of aggregate….”
We note changes from the previous wording, but feel this does not reflect the wider requirements of PPW in terms of minerals resources and infrastructure. Minerals safeguarding is not solely about safeguarding aggregate resources. This should include a wider minerals base and minerals infrastructure.
Amend the wording to read “Planning permission will not be granted for development proposals where they would permanently sterilise mineral resources and minerals infrastructure.

Paragraph 11.573
The wording states “PPW stresses the importance of safeguarding mineral resources that meet society’s needs now and in the future.”
PPW also stresses the importance of safeguarding “minerals related infrastructure” (para 5.14.7). The wording should be amended to reflect PPW.
Amend the wording to read “PPW stresses the importance of safeguarding mineral resources that meet society’s needs now and in the future, together with minerals related infrastructure.”

No change.

Dear Sir/Madam

2nd DEPOSIT REVISED CARMARTHENSHIRE LOCAL DEVELOPMENT PLAN 2018 - 2033

The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and silica sand industries. With the affiliation of British Precast, the British Association of Reinforcement (BAR), Eurobitume, MPA Northern Ireland, MPA Scotland and the British Calcium Carbonate Federation, it has a growing membership of over 530 companies and is the sectoral voice for mineral products. MPA membership is made up of the vast majority of independent SME quarrying companies throughout the UK, as well as the 9 major international and global companies. It covers 100% of UK cement production, 90% of GB aggregates production, 95% of asphalt and over 70% of ready-mixed concrete and precast concrete production. In 2016, the industry supplied £18 billion worth of materials and services to the Economy. It is the largest supplier to the construction industry, which had annual output valued at £169 billion in 2018. Industry production represents the largest materials flow in the UK economy and is also one of the largest manufacturing sectors. For more information visit: www.mineralproducts.org.

Thank you for consulting us on the above document. Our comments are appended to this letter. For ease of reference where we have proposed amendments to the text, we have struck through text (xxxxxx) to be deleted and used bold underlined text (xxxxxx) for proposed insertions.

If you require clarification on any of the points made, please do not hesitate to contact us. We welcome future engagement on this matter. We should be grateful if you could forward future correspondence to the email below.

Yours faithfully

Nick Horsley

Director of Planning, MPA Wales

Section 7.6
SO5
The formatting of the document is confusing in that SO5 appears before SO3 and SO4
Amend the formatting of the document and ensure SO3, SO4 and SO5 appear in the correct order.

Section 7.6
Strategic Objectives
It remains unclear why the provision of a sustainable and adequate supply of minerals is not identified as a Strategic Objective. This is a fundamental requirement of PPW and the need for minerals is the thread which stiches together many of the strategic objective identified, providing raw materials to deliver and address issues such as employment, housing, climate change, infrastructure, transport and environmental aspirations.
Include a further Strategic Objective to reflect the need for a sustainable and adequate supply of minerals.

Policy BHE1: Listed Buildings and Conservation Areas
Subsections 2. & 3. State:
“2. Developments within or adjacent to a conservation area will be permitted, where it would preserve or enhance the character or appearance of the conservation area, or its setting.
3. New developments in conservation areas should be of a high standard of design which responds to the area’s special characteristics and features.”
It remains unclear how the requirements of these subsections will be achieved. Maintaining the characteristic fabric of these buildings and conservation areas routinely requires an indigenous supply of local stone and materials, sympathetic to the character of the area and its buildings. There are no policies within the plan supporting the development of indigenous sources of building stone/materials.
Clarify within the plan how the characteristics of conservation areas and listed buildings will be maintained using materials sympathetic to the area. Sources of indigenous building materials will be needed and reflected within the policies in the plan.

Strategic Policy SP 18: Mineral Resources
Subsection a) states “Ensuring an adequate supply of minerals, including maintaining an adequate landbank of permitted aggregate reserves (a minimum 10 years for hard crushed rock, and a minimum 7 years for sand and gravel) throughout the Plan period;”
We welcome the amendments now incorporated.

Strategic Policy SP 18: Mineral Resources
Subsection c) states “Safeguarding minerals infrastructure, and areas underlain by minerals of economic importance where they could be worked in the future, to ensure that such resources and infrastructure are not unnecessarily sterilised by other forms of development;”
We welcome the amendments now incorporated

Paragraph 11.564
“For crushed rock, Carmarthenshire forms part of the Swansea City Sub-region, along with the local authorities of Swansea and Neath Port Talbot. Although at present, Swansea is unable to demonstrate an inability to meet RTS2 apportionments, there are more than sufficient reserves within NPT and Carmarthenshire to take up the joint apportionment within this period without resulting in under provision. A statement of subregional collaboration (SSRC) has been produced which demonstrates how the constituent Authorities satisfy the requirements of RTS2 in respect of future crushed rock provision.”
We have concerns that the approach proposed does not accord with the RTS, not least that the concerns raised in our response to the draft Swansea SSRC, dated 19th November 2020 have not been addressed. Where authorities are seeking to “absorb” apportionments from neighbouring authorities, it is necessary that there is a corresponding increase in provision within those authorities, as required by MTAN 1. The receiving authorities will need to increase their apportionments (and, where necessary, allocations), to ensure that as a minimum, the overall requirements for ongoing supply within that sub-region, as set out in the RTS, are met (both numerically and in terms of aggregate type). It will not normally be appropriate to merely transfer apportionments to an LPA with sufficient existing reserves to arithmetically absorb the apportionment, without reference to the additional consideration of productive capacity. Whilst the shortfall in allocation relates primarily to Swansea, it is inappropriate for this flaw to be reflected in the Carmarthenshire RLDP.
Amend the text accordingly to reflect the RTS second review requirements (Annex A).

Paragraph 11.565
“…..Therefore, a joint approach is being pursued by Pembrokeshire, Ceredigion and Carmarthenshire for the provision of the allocation requirement for 3.626 million tonnes over the period up to 2038.”
The allocation specified in the RTS is a minimum. The wording should be amended accordingly.
“…..Therefore, a joint approach is being pursued by Pembrokeshire, Ceredigion and Carmarthenshire for the provision of the allocation requirement for a minimum 3.626 million tonnes over the period up to 2038.”

Paragraph 11.566
“In the event that the allocations for sand and gravel in the three constituent authorities are not sufficient to meet the 3.626 million tonnes over the period up to 2038, an ‘area of search’ for sand and gravel has been identified on the proposals map (with further areas being identified by Pembrokeshire and Ceredigion in their respective Revised LDPs). Furthermore, a statement of sub-regional collaboration (SSRC) is being produced which will demonstrate how the constituent Authorities will satisfy the requirements of RTS2 in respect of future sand and gravel provision.”
Firstly, the 3.626mt is a minimum allocation and this should be reflected in the text.
Secondly, the comments above apply equally to this paragraph. In addition, the wording in paragraph 11.566 conflicts with paragraph 11.564. Paragraph 11.564 states “A statement of subregional collaboration (SSRC) has been produced which demonstrates how the constituent Authorities satisfy the requirements of RTS2”. However, this paragraph (11.566) states “a statement of sub-regional collaboration (SSRC) is being produced. (our underlining).
The wording is confusing and needs to be rectified. It is imperative that the adoption of the SSRC must follow the process outlined in the RTS 2nd Review.
Amend the text accordingly, firstly to reference the “minimum” allocation and secondly to clarify the status of the RTS.
“In the event that the allocations for sand and gravel in the three constituent authorities are not sufficient to meet the minimum 3.626 million tonnes”…..

Paragraph 11.567
“In respect of working the resource within the area of search, this will not be carried out within 100m of residential properties. Proposals for extraction will also need to accord with the criteria set out within Policy MR1 Mineral Proposals. On those elements of the area of search that contain grade 3a agricultural land, the need for extraction will be considered in accordance with paragraph 3.59 of PPW Ed.11.”
This paragraph does not properly reflect MTAN1 and should be amended accordingly. MTAN1 states “that the following minimum
distances should be adopted unless there are clear and justifiable reasons for reducing the distance. An example may be that, because of other means of control, there is very limited impact from the mineral extraction site.” (Our underlining)
For Sand and Gravel this should be 100m.
The wording should be amended to reflect MTAN1.
Amend the text to read ““In respect of working the resource within the area of search, this will not be carried out within 100m of residential properties unless there are clear and justifiable reasons for reducing the distance. Proposals for extraction will also need to accord with the criteria set out within Policy MR1 Mineral Proposals. On those elements of the area of search that contain grade 3a agricultural land, the need for extraction will be considered in accordance with paragraph 3.59 of PPW Ed.11.”

Policy MR2: Mineral Buffer Zones
This Policy states: “Provision has been made for Buffer Zones around all sites with extant planning permission for mineral working.”
PPW requires that Buffer Zones are provided as “areas of protection around permitted and proposed mineral workings” also “buffer zones should be identified in development plans around existing or proposed minerals sites” (Our underlining). This is also reflected in MTAN1.
Amend the text to read: “Provision has been made for Buffer Zones around all sites with extant planning permission for mineral working and proposed mineral workings.” We note the amendment to para 11.571 to reflect this.

MR3: Mineral Safeguarding Areas
The policy states “Planning permission will not be granted for development proposals where they would permanently sterilise resources of aggregate….”
We note changes from the previous wording, but feel this does not reflect the wider requirements of PPW in terms of minerals resources and infrastructure. Minerals safeguarding is not solely about safeguarding aggregate resources. This should include a wider minerals base and minerals infrastructure.
Amend the wording to read “Planning permission will not be granted for development proposals where they would permanently sterilise mineral resources and minerals infrastructure.

Paragraph 11.573
The wording states “PPW stresses the importance of safeguarding mineral resources that meet society’s needs now and in the future.”
PPW also stresses the importance of safeguarding “minerals related infrastructure” (para 5.14.7). The wording should be amended to reflect PPW.
Amend the wording to read “PPW stresses the importance of safeguarding mineral resources that meet society’s needs now and in the future, together with minerals related infrastructure.”

No Change.

Dear Sir/Madam

2nd DEPOSIT REVISED CARMARTHENSHIRE LOCAL DEVELOPMENT PLAN 2018 - 2033

The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and silica sand industries. With the affiliation of British Precast, the British Association of Reinforcement (BAR), Eurobitume, MPA Northern Ireland, MPA Scotland and the British Calcium Carbonate Federation, it has a growing membership of over 530 companies and is the sectoral voice for mineral products. MPA membership is made up of the vast majority of independent SME quarrying companies throughout the UK, as well as the 9 major international and global companies. It covers 100% of UK cement production, 90% of GB aggregates production, 95% of asphalt and over 70% of ready-mixed concrete and precast concrete production. In 2016, the industry supplied £18 billion worth of materials and services to the Economy. It is the largest supplier to the construction industry, which had annual output valued at £169 billion in 2018. Industry production represents the largest materials flow in the UK economy and is also one of the largest manufacturing sectors. For more information visit: www.mineralproducts.org.

Thank you for consulting us on the above document. Our comments are appended to this letter. For ease of reference where we have proposed amendments to the text, we have struck through text (xxxxxx) to be deleted and used bold underlined text (xxxxxx) for proposed insertions.

If you require clarification on any of the points made, please do not hesitate to contact us. We welcome future engagement on this matter. We should be grateful if you could forward future correspondence to the email below.

Yours faithfully

Nick Horsley

Director of Planning, MPA Wales

Section 7.6
SO5
The formatting of the document is confusing in that SO5 appears before SO3 and SO4
Amend the formatting of the document and ensure SO3, SO4 and SO5 appear in the correct order.

Section 7.6
Strategic Objectives
It remains unclear why the provision of a sustainable and adequate supply of minerals is not identified as a Strategic Objective. This is a fundamental requirement of PPW and the need for minerals is the thread which stiches together many of the strategic objective identified, providing raw materials to deliver and address issues such as employment, housing, climate change, infrastructure, transport and environmental aspirations.
Include a further Strategic Objective to reflect the need for a sustainable and adequate supply of minerals.

Policy BHE1: Listed Buildings and Conservation Areas
Subsections 2. & 3. State:
“2. Developments within or adjacent to a conservation area will be permitted, where it would preserve or enhance the character or appearance of the conservation area, or its setting.
3. New developments in conservation areas should be of a high standard of design which responds to the area’s special characteristics and features.”
It remains unclear how the requirements of these subsections will be achieved. Maintaining the characteristic fabric of these buildings and conservation areas routinely requires an indigenous supply of local stone and materials, sympathetic to the character of the area and its buildings. There are no policies within the plan supporting the development of indigenous sources of building stone/materials.
Clarify within the plan how the characteristics of conservation areas and listed buildings will be maintained using materials sympathetic to the area. Sources of indigenous building materials will be needed and reflected within the policies in the plan.

Strategic Policy SP 18: Mineral Resources
Subsection a) states “Ensuring an adequate supply of minerals, including maintaining an adequate landbank of permitted aggregate reserves (a minimum 10 years for hard crushed rock, and a minimum 7 years for sand and gravel) throughout the Plan period;”
We welcome the amendments now incorporated.

Strategic Policy SP 18: Mineral Resources
Subsection c) states “Safeguarding minerals infrastructure, and areas underlain by minerals of economic importance where they could be worked in the future, to ensure that such resources and infrastructure are not unnecessarily sterilised by other forms of development;”
We welcome the amendments now incorporated

Paragraph 11.564
“For crushed rock, Carmarthenshire forms part of the Swansea City Sub-region, along with the local authorities of Swansea and Neath Port Talbot. Although at present, Swansea is unable to demonstrate an inability to meet RTS2 apportionments, there are more than sufficient reserves within NPT and Carmarthenshire to take up the joint apportionment within this period without resulting in under provision. A statement of subregional collaboration (SSRC) has been produced which demonstrates how the constituent Authorities satisfy the requirements of RTS2 in respect of future crushed rock provision.”
We have concerns that the approach proposed does not accord with the RTS, not least that the concerns raised in our response to the draft Swansea SSRC, dated 19th November 2020 have not been addressed. Where authorities are seeking to “absorb” apportionments from neighbouring authorities, it is necessary that there is a corresponding increase in provision within those authorities, as required by MTAN 1. The receiving authorities will need to increase their apportionments (and, where necessary, allocations), to ensure that as a minimum, the overall requirements for ongoing supply within that sub-region, as set out in the RTS, are met (both numerically and in terms of aggregate type). It will not normally be appropriate to merely transfer apportionments to an LPA with sufficient existing reserves to arithmetically absorb the apportionment, without reference to the additional consideration of productive capacity. Whilst the shortfall in allocation relates primarily to Swansea, it is inappropriate for this flaw to be reflected in the Carmarthenshire RLDP.
Amend the text accordingly to reflect the RTS second review requirements (Annex A).

Paragraph 11.565
“…..Therefore, a joint approach is being pursued by Pembrokeshire, Ceredigion and Carmarthenshire for the provision of the allocation requirement for 3.626 million tonnes over the period up to 2038.”
The allocation specified in the RTS is a minimum. The wording should be amended accordingly.
“…..Therefore, a joint approach is being pursued by Pembrokeshire, Ceredigion and Carmarthenshire for the provision of the allocation requirement for a minimum 3.626 million tonnes over the period up to 2038.”

Paragraph 11.566
“In the event that the allocations for sand and gravel in the three constituent authorities are not sufficient to meet the 3.626 million tonnes over the period up to 2038, an ‘area of search’ for sand and gravel has been identified on the proposals map (with further areas being identified by Pembrokeshire and Ceredigion in their respective Revised LDPs). Furthermore, a statement of sub-regional collaboration (SSRC) is being produced which will demonstrate how the constituent Authorities will satisfy the requirements of RTS2 in respect of future sand and gravel provision.”
Firstly, the 3.626mt is a minimum allocation and this should be reflected in the text.
Secondly, the comments above apply equally to this paragraph. In addition, the wording in paragraph 11.566 conflicts with paragraph 11.564. Paragraph 11.564 states “A statement of subregional collaboration (SSRC) has been produced which demonstrates how the constituent Authorities satisfy the requirements of RTS2”. However, this paragraph (11.566) states “a statement of sub-regional collaboration (SSRC) is being produced. (our underlining).
The wording is confusing and needs to be rectified. It is imperative that the adoption of the SSRC must follow the process outlined in the RTS 2nd Review.
Amend the text accordingly, firstly to reference the “minimum” allocation and secondly to clarify the status of the RTS.
“In the event that the allocations for sand and gravel in the three constituent authorities are not sufficient to meet the minimum 3.626 million tonnes”…..

Paragraph 11.567
“In respect of working the resource within the area of search, this will not be carried out within 100m of residential properties. Proposals for extraction will also need to accord with the criteria set out within Policy MR1 Mineral Proposals. On those elements of the area of search that contain grade 3a agricultural land, the need for extraction will be considered in accordance with paragraph 3.59 of PPW Ed.11.”
This paragraph does not properly reflect MTAN1 and should be amended accordingly. MTAN1 states “that the following minimum
distances should be adopted unless there are clear and justifiable reasons for reducing the distance. An example may be that, because of other means of control, there is very limited impact from the mineral extraction site.” (Our underlining)
For Sand and Gravel this should be 100m.
The wording should be amended to reflect MTAN1.
Amend the text to read ““In respect of working the resource within the area of search, this will not be carried out within 100m of residential properties unless there are clear and justifiable reasons for reducing the distance. Proposals for extraction will also need to accord with the criteria set out within Policy MR1 Mineral Proposals. On those elements of the area of search that contain grade 3a agricultural land, the need for extraction will be considered in accordance with paragraph 3.59 of PPW Ed.11.”

Policy MR2: Mineral Buffer Zones
This Policy states: “Provision has been made for Buffer Zones around all sites with extant planning permission for mineral working.”
PPW requires that Buffer Zones are provided as “areas of protection around permitted and proposed mineral workings” also “buffer zones should be identified in development plans around existing or proposed minerals sites” (Our underlining). This is also reflected in MTAN1.
Amend the text to read: “Provision has been made for Buffer Zones around all sites with extant planning permission for mineral working and proposed mineral workings.” We note the amendment to para 11.571 to reflect this.

MR3: Mineral Safeguarding Areas
The policy states “Planning permission will not be granted for development proposals where they would permanently sterilise resources of aggregate….”
We note changes from the previous wording, but feel this does not reflect the wider requirements of PPW in terms of minerals resources and infrastructure. Minerals safeguarding is not solely about safeguarding aggregate resources. This should include a wider minerals base and minerals infrastructure.
Amend the wording to read “Planning permission will not be granted for development proposals where they would permanently sterilise mineral resources and minerals infrastructure.

Paragraph 11.573
The wording states “PPW stresses the importance of safeguarding mineral resources that meet society’s needs now and in the future.”
PPW also stresses the importance of safeguarding “minerals related infrastructure” (para 5.14.7). The wording should be amended to reflect PPW.
Amend the wording to read “PPW stresses the importance of safeguarding mineral resources that meet society’s needs now and in the future, together with minerals related infrastructure.”

No change to the Plan

2nd Deposit Revised LDP – Commentary

Reference and Comment

A. Spatial Strategy
The National Park Authority has no comment on the spatial strategy proposed.

No comment.

Reference and Comment Support/Object/
Other
B. Employment
The Spatial Strategy commentary above sets out where there is consistency of approach on where employment undertakings can take place in the County along with notes of clarification.

The employment and economic development strategy of Carmarthenshire County Council’s Preferred Strategy focusses on the Swansea Bay City Deal, and other Carmarthenshire-specific strategies. Carmarthenshire County Council and this National Park Authority are stakeholders in a Regional Strategic Economic study along with Pembrokeshire County Council and Brecon Beacons National Park Authority. The final report was published in October 2019. The study broadly concludes that there is sufficient strategic land available to meet demand across the area. The policy approach across the Pembrokeshire County Council, Carmarthenshire County Council and Pembrokeshire Coast National Park Authority is to protect strategic and smaller employment sites for employment use.
Support the general conformity of approach.

C. Housing Growth
Pembrokeshire Coast National Park Authority has no comment on the anticipated scale of growth proposed.

D. Affordable Housing
The National Park Authority has no comment.
No comment.

Climate Change
The Authorities have a shared understanding of the need to plan for climate change and to mitigate its impacts and to provide for high quality design to ensure that new development is adaptable to climate change.

This National Park Authority supports the approach taken to future-proofing communities in light of predicted sea-level rise and the identification of a Coastal Change Management Area, supported by the South Wales Shoreline Management Plan. Support in principle. Support Policy PSD1 Placemaking and sustainable places, Policy NE5 Coastal Management NE6: Coastal Development; and NE7 Coastal Change Management Area and SP16 Climate change.
Note: See comment across.

Visitor Economy
Both Authorities recognise the importance of the visitor economy to west Wales and aim to support the sector and attract visitors all year round. Both also recognise that some attractions require a countryside setting but that this should be the exception, and the majority of tourism related development being sustainably located. Support SP11 The Visitor Economy, VE1 Visitor Attractions and Facilities; VE2 Holiday Accommodation; VE3 Touring Caravan, camping and Non-Permanent Alternative Camping Accommodation; VE4 Static Caravan and Chalet Sites and Permanent Alternative Camping Accommodation.

Retail
Both Authorities’ strategies focus on the need to maintain / create vibrant and diverse town, district, and local centres. Retail provision in both Authorities is identified through the retail hierarchy with Carmarthenshire’s hierarchy being based on Sub Regional- High Order Town Centres, Mid Order Town Centres and Lower Order Town Centres. Support SP 2 Retail and Town Centres

Renewable Energy
Both plans have regard to the need to generate more electricity from renewable sources. Pembrokeshire Coast National Park Authority has a renewable energy strategy policy seeking the delivery of appropriate renewable energy developments.

Both Authorities implement joint guidance on assessing the cumulative impact of wind turbines

It would be useful to confirm if Carmarthenshire intends to bring forward the Cumulative Impact of Turbine Guidance in the replacement Local Development Plan.

Carmarthenshire includes renewable energy as part of Strategic Policy 16: Climate Change (parts c and d), and both CCH1: Renewable Energy within Pre-Assessed Areas and Local search Areas and CCH”: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. Whilst Pembrokeshire does not have Local Search Areas, these policies are broadly in line with this Authority’s Renewable and Low Carbon Energy policy.
LSA for solar is shown on the Proposals map and it is considered that none of these are likely to have an impact on the Pembrokeshire Coast National Park.
Support SP 15 Climate Change and CCH1 / CCH2

Environment
Both Plans seek to ensure that their Plan areas natural and historic environment and landscape will be protected from inappropriate development and, where possible, enhanced.

The Welsh language which continues to be an important component in the social, cultural and economic life of many communities will be protected and supported by managing development sensitively in areas where it has a significant role in the community. Support SP8 Welsh Language and WL1 Welsh Language and New Developments, SP14
PSD3: Green and Blue Infrastructure Network
Maintaining and Enhancing the Natural Environment. SP 15 Protection and Enhancement of the Built and Historic Environment and BHE2 Landscape Character. SP14 Maintaining and Enhancement of the Built and Historic Environment

Note See across for comment.

Regional Working
Strategic Policy – SP 14: Maintaining and Enhancing the Natural Environment: Reasoned Justification: 11.409 In addition, and reflecting the duties placed upon Local Authorities, the Plan has regard to the National Park designation and the purpose for which it is designated, where it may affect the consideration of planning proposals.
BHE2: Landscape Character Development proposals should relate to the specific landscape and visual characteristics of the local area, ensuring that the overall integrity of landscape character is maintained by: …. b) protecting international and national landscape designations including National Parks and Areas of Outstanding Natural Beauty (AONB) and their settings;

11.456 Carmarthenshire is characterised by diverse and high-quality landscape resources and areas of notable visual value. It also includes or borders a range of landscape designations, including the Brecon Beacons and Pembrokeshire Coast National Parks and Gower AONB.

Appendix 2 Regional and Local Strategic Context:
Regional working: Pembrokeshire Coast National Park Authority’s adopted LDP is broadly compatible with a hierarchical settlement structure and a consistency in the broad planning policy approach with Carmarthenshire. Continuing liaison will ensure a mutual understanding of the respective approaches including through regional arrangements and the scope and progress of the Strategic Development Plan. A proactive approach towards regional and sub-regional working is implicit on policy matters, evidence gathering and strategic considerations.

Minerals
The terrestrial sand and gravel landbank and the apportionment of provision to meet future needs is now considered on a regional basis with the RTS Second Review setting out the contribution that each constituent local authority should make towards meeting the demand for aggregates. There is no requirement for a landbank to be maintained within National Park (PPW 11)

Although Carmarthenshire is now in a separate sub-region to Pembrokeshire, previous combined working arrangements with regard to future apportionments and allocations for sand and gravel as suggested in the RTS1 as recommended to continue in RTS2 with the production of a Statement of Sub-regional Collaboration between Pembrokeshire, Carmarthenshire and Ceredigion to meet the allocation requirement of 3.626 million tonnes.

The Area of Search for Sand and Gravel is located to the west as shown on the Proposals Map, the northern end of which lies approximately 4.3km south east of the Pembrokeshire Coast National Park.
Support the compatibility of approach between the two Plans.
Support SP 18: Mineral Resources.

Waste
Both authorities’ policies on waste management are broadly aligned. Carmarthenshire acknowledges TAN 21 and the need for collaboration between local planning authorities to progress towards an integrated and adequate network for waste management.
Support
Support SP 19: Sustainable Waste Management

Sustainability Appraisal/Strategic Environmental Appraisal

Appendix E: Growth Options
1st Deposit LDP Preferred Growth Option: check shading for ISA3. The appraisal is ‘+/-‘and the shading is that of minor negative effect rather than the yellow of positive and negative effect.

Appendix F: ISA Strategic Policies
SP 2: Retail and Town Centres: ISA Objective 1 has a positive assessment but no commentary.

SP 10: Gypsy and Traveller Provision: ISA Objective 8 is neutral. Could this be a positive since providing sites sustains Gypsy and Traveller culture?

Habitats Regulations Assessment

Comments:

Thank you for considering and incorporating PCNPA’s comments on the Habitat Regulations Assessment Report (2020) as detailed in the appendices to the Habitats Regulations Assessment Addendum report.

4.3 Interim action plan – land available for constructed wetlands.
It is suggested that it would be beneficial to include discussion of the identified lands current use (e.g. to eliminate land of existing or other potential nature conservation value from consideration).
Other discussion points:
The long-term use of wetlands as nutrient sinks is not well understood.
The ability of wetlands to remove nutrients may be influenced by climate change scenarios, e.g. drying out, flood events.

Page 8 (PPP) – while not yet adopted, we note that consultation recently (February 2023) closed on Dŵr Cymru Welsh Water’s draft Water Resources Management Plan 2024
Typos
“3.2.15 ‘screened out screened out’
3.3.2 ‘unlikely to have a significant effects’
4.2.17 ‘there are important’
4.2.20 ‘which can demonstrate not cause the failure’
4.3.1 ‘ready in conjunction’

Thank you for consulting the Welsh Government on the Carmarthenshire County Council Local Development Plan (LDP) 2nd Deposit plan and documents. It is essential the authority is covered by an up-to-date LDP to give certainty to local communities and business.
Without prejudice to the Minster’s powers, the Welsh Government is committed to helping Local Planning Authorities (LPAs) minimise the risk of submitting unsound plans by making comments at the earliest stages of plan preparation. The Welsh Government looks for clear evidence that the plan is in general conformity with Future Wales: The National Development Framework and aligns with Planning Policy Wales (PPW), and that the tests of soundness (as set out in the ‘LDP Manual’) are addressed.
National planning policies are set out in Planning Policy Wales (PPW) Edition 11, which seeks to deliver high quality, sustainable places through a place-making approach. The implementation of the core policy areas in PPW, such as adopting a sustainable spatial strategy, appropriate housing and economic growth levels, infrastructure delivery and place-making, are articulated in more detail in the LDP Manual (Edition 3). We expect the core elements of the Manual, in particular Chapter 5 and the ‘De-risking Checklist(s) to be followed. The development planning system in Wales is evidence led and demonstrating how a plan is shaped by the evidence is a key requirement of the LDP examination.
After considering the key issues and policies in Future Wales, the Welsh Government is of the view that the level and spatial distribution of growth is in general conformity with Future Wales: The National Development Framework. However, the Statement of General Conformity (Annex 1 to this letter) is a ‘caveated response’. Annex 2 of this letter raises fundamental inconsistencies regarding the total housing provision and until these matters have been addressed and their implications understood, it is not possible to give a firm view on matters of general conformity at this time. Annex 2 of this letter also highlights a range of issues that need to be addressed for the plan to align with PPW and DPM. Collectively, our comments highlight a range of issues that need to be addressed for the plan to be considered ‘sound’ as follows:
Annex 1 – General Conformity with Future Wales (Caveated Response)
· Regional Collaboration/Level of growth Further clarity required. Annex 2 – Core matters that need to be addressed (PPW and the DPM)
Our representations are separated into three categories set out by topic area, with further detail in the attached annex.
Category A: Fundamental issues that are considered to present a significant degree of risk for the LPA if not addressed prior to submission stage and may have implications for the plan’s strategy.
None.
Category B: Matters where it appears that the deposit plan has not satisfactorily translated national policy down to the local level and there may be tensions within the plan, namely (not exhaustive):
· Level of Housing Provision
· Delivery and Viability
· Restriction of new homes to Class C3 only
· Gypsy and Traveller Provision
· Best and Most Versatile Land (BMV)
Category C: Whilst not considered to be fundamental to the soundness of the LDP, we consider there to be a lack of certainty or clarity on the following matters:
· Flooding
· Renewable Energy
· Minerals
· Phosphates
I would urge you to seek your own legal advice to ensure you have met all the procedural requirements, including the Sustainability Appraisal (SA), Strategic Environmental Assessment (SEA) and Habitats Regulation Assessment (HRA), as responsibility for these matters rests with your authority. A requirement to undertake a Health Impact Assessment (HIA) arising from the Public Health (Wales) Act 2017, if appropriate, should be carried out to assess the likely effect of the proposed development plan on health, mental well-being and inequality.
It is for your Authority to ensure that the LDP is ‘sound’, and it will be for the Inspector to determine how the examination proceeds if you submit the plan without addressing the concerns we raise. My colleagues and I look forward to meeting you and the team to discuss matters arising from this response.

Amend 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.