Second Deposit LDP
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Second Deposit LDP
11.356
Representation ID: 5746
Received: 25/05/2023
Respondent: Natural Resources Wales
11.356 We welcome the inclusion of this paragraph which address our previous points regarding agricultural developments. We would advise that reference to ‘intensive’ agriculture and livestock units is removed to prevent confusion as the comments are applicable to all agricultural developments.
The content of the Chief Planning Officers letter of 12 June 2018 on intensive agriculture states “LPAs are advised to put in place appropriate policies in Local Development Plans in order to facilitate the sustainable consideration of this type of development.” It should be made clear what the sensitive receptors are within the county and what will require buffering from such developments. Given that Carmarthenshire is a strong agricultural setting we question whether a specific policy is required.
We note you have included a policy on equestrian facilities (RD5) which from an environmental perspective tend to pose less risk when considering the discharges/emissions and wastes arising, cumulative impacts and water quality.
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. Matters to be further considered at Examination.
Object
Second Deposit LDP
11.357
Representation ID: 5747
Received: 25/05/2023
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
11.357 We would advise you remove reference to our guidance GN021 as it is to be replaced shortly.
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 noted. The adopted Plan will, as necessary, make reference to the latest national guidance at the time of adoption.
Support
Second Deposit LDP
Strategic Policy – SP 14: Maintaining and Enhancing the Natural Environment
Representation ID: 5748
Received: 25/05/2023
Respondent: Natural Resources Wales
• Strategic Policy - SP 14: Maintaining and Enhancing the Natural Environment
We welcome the principle of this policy and acknowledge that a HRA has been undertaken to assess the impacts of the Plan on European Protected Sites (including the allocated sites). Our detailed comments on the HRA are provided in Annex 2.
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.
Support welcomed
Support
Second Deposit LDP
11.406
Representation ID: 5749
Received: 25/05/2023
Respondent: Natural Resources Wales
11.406 The WG’s land use maps and previous habitat and species mapping undertaken by the Authority can provide valuable information for the protection and enhancement of connectivity. These should be used to provide some background data to ensure the links in and beyond Carmarthenshire are understood so that it is clear what needs protection and why.
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
Object
Second Deposit LDP
NE3: Corridors, Networks and Features of Distinctiveness
Representation ID: 5750
Received: 25/05/2023
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
The supporting text needs to provide clarity on the definition of exceptional circumstances in this context to ensure the robustness of the plan.
Amend supporting text
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. Policy NE2 provides the clarity requested relating to exceptional circumstances.
Support
Second Deposit LDP
NE4: Development within the Caeau Mynydd Mawr SPG Area
Representation ID: 5751
Received: 25/05/2023
Respondent: Natural Resources Wales
We support the inclusion of this policy and the supporting SPG. We welcome the commitment to prioritise contributions regarding the Caeau Mynydd Mawr SPG area, for the sites subject to the requirements of Policy NE4.
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.
Support welcomed.
Support
Second Deposit LDP
11.429
Representation ID: 5752
Received: 25/05/2023
Respondent: Natural Resources Wales
11.429 We welcome the change in wording in line with our previous response.
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.
Support welcomed
Object
Second Deposit LDP
NE7: Coastal Change Management Area
Representation ID: 5753
Received: 25/05/2023
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
NE7: Coastal Change Management Area
1. New Residential Development
The policy states ‘Proposals for any residential use within the CCMA will not be supported.’ For robustness we advise the policy wording ‘will not be supported’ is changed to ‘not be permitted’ in line with the policy wording of the subsequent points.
Amend Policy wording
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.
Changes to the policy will be discussed at examination.
Object
Second Deposit LDP
11.440
Representation ID: 5754
Received: 25/05/2023
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
11.440 For clarity, the supporting text requires strengthening in line with the policy to:
New residential development will not supported / not be permitted in the Coastal Change Management Area.
Amend supporting text
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. Consideration will be given to the wording at examination
Support
Second Deposit LDP
11.458
Representation ID: 5755
Received: 25/05/2023
Respondent: Natural Resources Wales
Paragraph 11.458 - Our existing guidance on the use of LANDMAP is on our website here.
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.
Noted.
