Second Deposit LDP
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Second Deposit LDP
PrC2/h10
Representation ID: 5726
Received: 25/05/2023
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
Site appears to provide important ecological connectivity features. Loss of ecosystem connectivity would be at odds with the fundamental aims of maintaining and enhancing biodiversity and your Authority’s duty under Section 6, Part 1 of the Environment (Wales) Act 2016. The Well-Being of Future Generations (Wales) Act and the Environment (Wales) Act provide a duty to maintain
and enhance the resilience of ecosystems.
- PrC2/h10 The Dell, Furnace, Llanelli
Following discussions on this allocation it was confirmed that the surrounding woodland will be retained to maintain a green corridor providing connectivity with the main woodland and the Dell. The mitigation required may reduce the amount of land available for development and the site would need to be allocated on this principle to ensure the soundness of the plan.
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.
Further evidential work will be required for examination, with the matter to be considered at examination
Object
Second Deposit LDP
SeC7/h3
Representation ID: 5727
Received: 25/05/2023
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
Comments on housing allocation SeC7/h3 in Llangennech. The sites appears to provide important ecological connectivity features. Loss of ecosystem connectivity would be at odds with the fundamental aims of maintaining and enhancing biodiversity and your Authority’s duty under Section 6, Part 1 of the Environment (Wales) Act 2016.
However, it is concluded that:
'Following our discussions on this allocation we are satisfied there is a way forward. The mitigation required may reduce the amount of land available for development and the site would need to be allocated on this principle to ensure the soundness of the plan.'
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.
Noted. Any further details relating to ecological connectivity and biodiversity will be considered at the planning application stage.
Further evidential work will be undertaken prior to the examination in to the revised LDP.
Object
Second Deposit LDP
PrC3/h4
Representation ID: 5728
Received: 25/05/2023
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
The site appear to provide important ecological connectivity features. Loss of ecosystem connectivity would be at odds with the fundamental aims of maintaining and enhancing biodiversity and your Authority’s duty under Section 6, Part 1 of the Environment (Wales) Act 2016. The Well-Being of Future Generations (Wales) Act and the Environment (Wales) Act provide a duty to maintain and enhance the resilience of ecosystems.
- PrC3/h4 Tirychen Farm
The site has secured outline permission and there are several ecological requirements attached. The final design of the site will have to be guided by the ecological sensitivities of the site.
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.
Support
Second Deposit LDP
HOM1: Housing Allocations
Representation ID: 5729
Received: 25/05/2023
Respondent: Natural Resources Wales
Natural Resources Wales have provided detailed comments on land allocated for residential development under Policy HOM1. Advice is provided for development and flood risk and the SFCA, ecology, land contamination and sensitive groundwaters, foul drainage.
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.
Comments on sites are noted.
Object
Second Deposit LDP
PrC3/E2
Representation ID: 5730
Received: 25/05/2023
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
EME3: Employment Proposals on Allocated Sites
The allocation appears to border/provide important ecological connectivity features. These features would need to be protected from development. Loss of ecosystem connectivity would be at odds with the fundamental aims of maintaining and enhancing biodiversity and Section 6, Part 1 of the Environment (Wales) Act 2016. The Well-Being of Future Generations (Wales) Act and the Environment (Wales) Act recognise that we have a duty to maintain and enhance the resilience of our ecosystems for our own continued existence and for future generations. This duty is reflected in many policies including Planning Policy Wales.
Our detailed comments on the allocated employment sites can be found in Annex 2 and 3 however, any mitigation required may reduce the amount of land available for development and the site would need to be allocated on this principle to ensure the soundness of the plan.
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.
Comments noted. Matter to be further considered at Examination.
Object
Second Deposit LDP
PrC3/E2(i)
Representation ID: 5731
Received: 25/05/2023
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
EME3: Employment Proposals on Allocated Sites
The allocation appears to border/provide important ecological connectivity features. These features would need to be protected from development. Loss of ecosystem connectivity would be at odds with the fundamental aims of maintaining and enhancing biodiversity and Section 6, Part 1 of the Environment (Wales) Act 2016. The Well-Being of Future Generations (Wales) Act and the Environment (Wales) Act recognise that we have a duty to maintain and enhance the resilience of our ecosystems for our own continued existence and for future generations. This duty is reflected in many policies including Planning Policy Wales.
Our detailed comments on the allocated employment sites can be found in Annex 2 and 3 however, any mitigation required may reduce the amount of land available for development and the site would need to be allocated on this principle to ensure the soundness of the plan.
Change to the 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.
Comments noted. Matter to be further considered at Examination.
Object
Second Deposit LDP
PrC3/E2(ii)
Representation ID: 5732
Received: 25/05/2023
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
EME3: Employment Proposals on Allocated Sites
The allocation appears to border/provide important ecological connectivity features. These features would need to be protected from development. Loss of ecosystem connectivity would be at odds with the fundamental aims of maintaining and enhancing biodiversity and Section 6, Part 1 of the Environment (Wales) Act 2016. The Well-Being of Future Generations (Wales) Act and the Environment (Wales) Act recognise that we have a duty to maintain and enhance the resilience of our ecosystems for our own continued existence and for future generations. This duty is reflected in many policies including Planning Policy Wales.
Our detailed comments on the allocated employment sites can be found in Annex 2 and 3 however, any mitigation required may reduce the amount of land available for development and the site would need to be allocated on this principle to ensure the soundness of the plan.
Change to the 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.
Comments noted. Matter to be further considered at Examination.
Object
Second Deposit LDP
PrC3/E2(iii)
Representation ID: 5733
Received: 25/05/2023
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
EME3: Employment Proposals on Allocated Sites
The allocation appears to border/provide important ecological connectivity features. These features would need to be protected from development. Loss of ecosystem connectivity would be at odds with the fundamental aims of maintaining and enhancing biodiversity and Section 6, Part 1 of the Environment (Wales) Act 2016. The Well-Being of Future Generations (Wales) Act and the Environment (Wales) Act recognise that we have a duty to maintain and enhance the resilience of our ecosystems for our own continued existence and for future generations. This duty is reflected in many policies including Planning Policy Wales.
Our detailed comments on the allocated employment sites can be found in Annex 2 and 3 however, any mitigation required may reduce the amount of land available for development and the site would need to be allocated on this principle to ensure the soundness of the plan.
Change to the 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.
Comments noted. Matter to be further considered at Examination.
Support
Second Deposit LDP
INF4: Llanelli Wastewater Treatment Works Catchment Surface Water Removal
Representation ID: 5734
Received: 25/05/2023
Respondent: Natural Resources Wales
INF4: Llanelli Waste Water Treatment Surface Water Disposal
We support the inclusion of this policy and the supporting Burry Inlet SPG. As you know there has been a long-established partnership approach to dealing with concerns on the risk of deterioration of water quality on the Carmarthen Bay and Estuaries European Marine Site.
Paragraph 11.203 states that Dwr Cymru Welsh Water (DCWW) have confirmed that there is sufficient capacity within Llanelli Waste Water Treatment Works to deliver the Plan’s identified growth without breaching their permit requirements.
We acknowledge that in addition to the implementation of the requirements of the Memorandum of Understanding on new developments, several improvement schemes have also been undertaken within the catchment since it was introduced.
We are satisfied that if DCWW have confirmed the above in writing, the Policy, with its requirements for surface water removal by the major developments, should ensure that the identified growth will cause no detriment to water quality from the generation of foul flows.
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.
Support welcomed
Support
Second Deposit LDP
11.208
Representation ID: 5735
Received: 25/05/2023
Respondent: Natural Resources Wales
11.208 Subject to the above we are satisfied that the policy and Burry Inlet SPG supersede the requirements of the Memorandum of Understanding.
No change to 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 welcomed
