Strategic Policy – SP 19: Sustainable Waste Management

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’

The MOD requests that the plan highlights that the MOD must be consulted on any mineral extraction, waste or landfill scheme which occupies a statutory range safeguarding zone.

Dear Sir/Madam,

I write to confirm the statutory safeguarding position of the Ministry of Defence (MOD) in relation to the 2nd Deposit Revised Carmarthenshire Local Development Plan (LDP) 2018 – 2033. The 2nd Deposit Revised LDP sets out the land use policies and proposals including the allocation and use of land through to 2033.

The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the MOD as a statutory consultee in the UK planning system to ensure designated zones around key operational defence sites such as aerodromes, explosives storage sites, air weapon ranges, and technical sites are not adversely affected by development outside the MOD estate. For clarity, this response relates to MOD Safeguarding concerns only and should be read in conjunction with any other submissions that might be provided by other parts of the MOD.

Future Wales, the National Plan 2040 makes clear that military sites and assets in Wales are important to the UK strategic defence systems and emphasises that these sites and assets should be protected from the impacts of development. MOD may be involved in the planning system both as a statutory and non-statutory consultee. Statutory consultation occurs as a result of the provisions of the Town and Country Planning (Safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002 (DfT/ODPM Circular 01/2003) and the location data and criteria set out on safeguarding
maps issued by Department for Levelling Up, Housing and Communities (DLUHC) in accordance with the provisions of that Direction.

The area covered by any 2nd Deposit Revised Carmarthenshire Local Development Plan (LDP) 2018 – 2033 will both contain and be washed over by statutory safeguarding zones that are designated to preserve the operation and capability of defence assets and sites including RAF Pembrey Sands, MOD Pendine, and the Mid Wales Tactical Training Area
Copies of these plans, in both GIS shapefile and .pdf format, can be provided on request through the email address above.
On reviewing the potential allocation sites, the following site references fall within statutory safeguarding zones designated to protect the operational capabilities of defence sites and assets:

Housing Allocations
SAFEGUARDING ZONE(S) AFFECTED
Kidwelly
RAF Pembrey Sands (Range safeguarding zone)
Pembrey
RAF Pembrey Sands (Range safeguarding zone)
Trimsaran Ffos Las
RAF Pembrey Sands (Range safeguarding zone)
Llangadog
RAF Pembrey Sands (Range safeguarding zone)

To provide an illustration of the various issues that might be fundamental to MOD assessment carried out in response to statutory consultation, a brief summary of each of the safeguarding zone types is provided below. Depending on the statutory safeguarding zone within which a site allocation or proposed development falls, different considerations will apply.

• Air Weapon Range Safeguarding Zones serve to regulate developments that could introduce or support populations of large and, or, flocking birds hazardous to aircraft. This can include landscaping schemes associated with large developments as well as the creation of new waterbodies, wetlands and Sustainable Drainage Systems (SUDS). The incorporation of open water, both permanent and temporary, wetlands ponds and ditches provide a range of habitats for wildlife, including potentially increasing the creation of attractant environments for large and flocking bird species hazardous to aviation. In addition, these zones serve to monitor the development of new micro-light/leisure flying sites in the vicinity of air weapon ranges.

• Technical safeguarding zones serve to ensure that air traffic management, primarily radar, navigation, and communications systems are safeguarded to limit the impact of development on their capability and operation. The height, massing and materials used to finish a development may all be factors in assessing the impact of a given scheme. Developments that incorporate renewable energy systems may be of particular concern given their potential to provide large expanses of metal at height, for example in the case of a wind turbine or a solar PV system mounted on a roof

• Statutory safeguarding zones are designated around Military explosives storage sites, to ensure that development and land uses will be compatible with MOD capability. Within these zones, where applicable, requirements relating to the siting, design, and construction of buildings, or changes to land use may apply. In principle, the MOD does not object to land in the outer explosives safeguarding zone being developed for residential, commercial, and industrial land use purposes. Any buildings within this zone must be ‘non-vulnerable’ to blast effects, that is of robust construction, so should an explosive event occur, the structure would not collapse or sustain damage that could cause critical injury to the occupants. Of particular concern within this zone are tall buildings (in excess of 3 storeys), light weight construction and large areas of glazing. The MOD will object to development proposals which support people living, working and congregating within the inner explosives safeguarding zone.

• A significant portion of the 2nd Deposit Revised Carmarthenshire LDP 2018 – 2033 area is within a part of the UK Military Low Flying System, designated as Training Area 7T (Mid-Wales). Within the Tactical Training Area (TTA), fixed wing aircraft may operate as low as 100 feet or 30.5 metres Above Ground Level (AGL) to conduct low level flight training. The introduction of development within the TTA has the potential to introduce a physical obstruction to low flying aircraft operating in the area. As such the MOD would wish to be consulted on any development within the TTA which has a height of/or exceeding 15.2M AGL.

Mineral extraction has the potential to have a significant impact on defence capability and operations, through all stages of the extraction, restoration, and aftercare process. These types of developments have the potential to provide attractive environments to certain large and/or flocking bird species hazardous to aviation safety and therefore may be subject to design requirements or for management plans to be applied. Development types that might require the application of planning condition(s) and/or the use of Planning Obligations to secure legal frameworks for the way development is carried out or managed can include mineral extraction schemes, waste development schemes or proposals associated with waste facilities including any restoration of sites. The MOD requests that the plan highlights that the MOD must be consulted on any mineral extraction, waste or landfill scheme which occupies a statutory range safeguarding zone.

The MOD welcomes the provisions of policies CCC1 and CCH2 regarding renewable energy, which makes clear that renewable and low carbon projects will not be acceptable where they would have an unacceptable impact on the operations of defence facilities and operations (including aviation and radar) or the Mid Wales Low Flying Tactical Training Area (TTA-7T).
In addition, and where development falls outside designated safeguarding zones, the MOD may also have an interest, particularly where the development is of a type likely to have an impact on operational capability by virtue of scale, height, or physical properties. The MOD should be consulted, through DIO Safeguarding, where development exceeds a height of 50m above ground level to ensure that the potential for these structures to form a physical obstacle to low flying aircraft can be addressed through appropriate lighting and charting. In addition, the MOD requests to be consulted on any proposals, regardless of height, which fall outside of an MOD safeguarding zone but are in the vicinity of military training estate or property.

The MOD Safeguarding team note that the council will prepare Supplementary Planning Guidance for the Pembrey Peninsula and would ask that we are consulted during the preparation of any SPG.
I trust this clearly explains our position on this update. Please do not hesitate to contact me should you wish to consider these points further.