Second Deposit LDP
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Second Deposit LDP
11.459
Representation ID: 5756
Received: 25/05/2023
Respondent ID: 3253
Respondent: Natural Resources Wales
We note the policy will be supported by a Landscape Character Assessment and Supplementary Planning Guidance (SPG) and acknowledge your intent to remove the the existing “Special Landscape Areas”. We would welcome the opportunity to input to the SPG.
Noted.
Support
Second Deposit LDP
Strategic Policy – SP 16: Climate Change
Representation ID: 5757
Received: 25/05/2023
Respondent ID: 3253
Respondent: Natural Resources Wales
We welcome that the LDP seeks to put a policy framework in place which tackles the causes and effects of climate change within the communities through the adoption of sustainable principles and development. Mitigating and adapting to Climate Change is a central theme in the South West Wales Area Statement.
Support welcomed
Object
Second Deposit LDP
11.471
Representation ID: 5758
Received: 25/05/2023
Respondent ID: 3253
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
11.471 This supporting paragraph is unclear. It states that ‘Proposals affected by flood risk will be required to submit a Flood consequences Assessment as part of any planning application’. It needs to be clear that due to their vulnerability and the nature of the flood risk that certain proposals are unacceptable, and others would be subject to the justification test. Such proposals will only require an assessment if they pass the justification test. This paragraph should be amended to reflect National Policy.
Changes to the policy will be discussed at examination.
Support
Second Deposit LDP
11.486
Representation ID: 5759
Received: 25/05/2023
Respondent ID: 3253
Respondent: Natural Resources Wales
11.486 Three solar photovoltaic Local Search Areas have been identified within the county. These will still be required to minimise landscape and visual impacts, even if the principle of development is acceptable in these areas.
Comments noted and support welcomed.
Object
Second Deposit LDP
CCH4: Water Quality and Protection of Water Resources
Representation ID: 5760
Received: 25/05/2023
Respondent ID: 3253
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
We note paragraph 4.2.10 of the HRA Addendum Report advises that policy CCH4:
Water Quality and Protection of Water Resources is ‘…further revised to be inclusive of all pathways (e.g., wastewater and diffuse run-off)’. However, no change has been made to the policy and there is no explanation given for this. To ensure that the policy meets the tests of soundness we advise further clarity is provided on this point.
Changes to the policy will be discussed at examination.
Object
Second Deposit LDP
11.514
Representation ID: 5761
Received: 25/05/2023
Respondent ID: 3253
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
11.514 The explanatory text states: To facilitate delivery of development which may be affected by this policy, the Council have prepared 'the 'Afon Tywi and Afon Teifi Phosphorus Reduction Strategy'. The document sets out the strategic approach for delivering phosphorus reductions in these catchments while also facilitating LDP growth and demonstrating that mitigation can be delivered in practice. The document sets out a range of measures, which have been agreed in consultation with NRW.
The 'Afon Tywi and Afon Teifi Phosphorus Reduction Strategy' are living documents that will develop during the lifetime of the LDP, in consultation with NRW.
We are aware from discussions with Officers at the Council that the Afon Tywi and Afon Teifi Phosphorus Reduction Strategy has not yet been prepared. In its absence, an Interim Action Plan, dated March 2023, has been prepared for the Council by Arcadis. The document is presented as ‘…a “living document”, i.e., a document that will be updated regularly as uncertainties are removed and understanding is improved’.
Further comments on the Interim Action Plan and HRA Addendum Report are provided within Annex 2.
Comments noted. The Council has undertaken further work relating to excess nutrient levels within riverine SACs.
Built on the basis of the IAP, the ensuing Action Plan (previously referred to as the "Afon Tywi and Afon Teifi Phosphorus Reduction Strategy ") sets out technical calculations that underpin the quantum of mitigation required and contains detail pertaining to feasibility studies that have substantially progressed the maturity of the identified solutions.
Object
Second Deposit LDP
11.525
Representation ID: 5762
Received: 25/05/2023
Respondent ID: 3253
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
11.525 To ensure the soundness of the plan, in consideration of Test 2 (Is the plan appropriate?) reference needs to be made to the FMfP as it represents better and more up-to-date information on areas at flood risk.
Changes to the policy will be discussed at examination.
Object
Second Deposit LDP
CCH7: Climate Change – Forest, Woodland, and Tree Planting
Representation ID: 5763
Received: 25/05/2023
Respondent ID: 3253
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
We support this policy and the recognition given to the importance of the contribution trees, forest and woodland provide to our ecosystems. Whilst potentially covered under ‘effects upon the environment’, flood risk management would be a key consideration in this policy. Therefore, for clarity we advise the wording of the policy be amended as follows:
Proposals should consider potential adverse effects upon the environment, flood risk management, cultural heritage, communities, and landscape, and, where appropriate, follow the mitigation hierarchy. It is equally important that tree planting occurs on appropriate sites. Carmarthenshire is recognised for the importance of its marshy grassland habitat. This is not always considered in proposals and should be highlighted upfront. Marshy grassland is important for biodiversity and connectivity. In Carmarthenshire this provides important potential habitat for the protected Marsh Fritillary butterfly which has a stronghold and a nationally important population in the county.
Changes to the policy will be discussed at examination.
Object
Second Deposit LDP
11.532
Representation ID: 5764
Received: 25/05/2023
Respondent ID: 3253
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
To ensure the robustness of the plan we suggest the following inclusions to this supporting paragraph:
The planting of trees, woodlands and forests can, in some locations, assist in tackling issues around flood risk, providing a soft engineering solution which can be undertaken in isolation or in conjunction with hard infrastructure (man-made structures). Proposals will be expected to demonstrate how they will contribute to flood risk alleviation and not result in adverse flood risk consequences.
Changes to the policy will be discussed at examination.
Object
Second Deposit LDP
Strategic Policy SP 18: Mineral Resources
Representation ID: 5776
Received: 25/05/2023
Respondent ID: 3253
Respondent: Natural Resources Wales
Legally compliant? Not specified
Sound? Not specified
Mineral resource is available in quarries within the Cernydd Carmel SAC. We understand that these are either considered dormant or inactive. However, although classed as inactive and dormant, they have extant planning permissions and could become operational again. We note their capacity can be used in the regional landbank figures set out in the Regional Technical Statement (RTS 1st Review 2014).
Any resumption of quarrying within the Cernydd Carmel SAC must comply with all the relevant legislation, including the Conservation of Habitats and Species Regulations 2017 (as amended). Before commencement, the applicant would have to demonstrate that the operations would have no significant effect on either the biological or geological feature of this European designated site.
There are other quarries in the county which having been left undeveloped and have some rare biodiversity. Some of these are undesignated and perhaps such areas should be considered for designation as Sites of Importance for Nature Conservation (SINCs).
Noted. Any resumption of quarrying within the Cernydd Carmel SAC would be a Development Management matter and would be addressed as part of the conditions of the extant permission.
