Second Deposit LDP

Reinstate Special Landscape Areas as set out in the current LDP.

Carmarthenshire Residents’ Action Group: Representations to the public consultation of the Second Deposit Revised Carmarthenshire Local Development Plan 2018-2033 and the Integrated Sustainability Assessment
We, Carmarthenshire Residents’ Action Group, are responding to the public consultation on the Carmarthenshire Local Development Plan 2018-2033 (Second Deposit) (‘Revised LDP’) to raise concerns with regard to the plan making process in relation to landscape(s) within the LDP’s geographical area. We request several changes to the plan on the basis that we consider the plan not to be sound and request the opportunity to make representations during the examination process.1
This letter contains a series of comments and objections in relation to landscape policies, and approach to policy making with regard to landscapes, within Carmarthenshire’s Revised LDP drafting process, including the Integrated Sustainability Appraisal (‘ISA’).
This letter also consolidates a series of comments made via the online comments portal on the proposed Revised LDP. It refers Carmarthenshire’s Forward Planning Department and, in due course, the appointed Examination Planning Inspector, to Carmarthenshire Residents Action Group’s petition to maintain the Special Landscape Areas within the 2018-2033 LDP. This petition has raised 438 signatures, details of which are contained within Appendix 1 of this letter.
A strong objection is raised, backed by significant local support, to the removal of Carmarthenshire’s locally designated Special Landscape Areas within the Revised LDP. Objections are also raised with regard to the replacement landscape related policies in the second Deposit Revised LDP with materially weakened policies compared to the existing 2006-2021 LDP (‘Current LDP’). The letter also raises concerns with regard to the assessment carried out in the ISA as it pertains to the Sustainability Objective on Landscape.
Our representations are set out as follows:
1. Objection to the removal of Special Landscape Areas from the Revised LDP;
2. Inadequate Evidence Base;
3. Revised LDP Policies;
4. Specific suggested amendments to Revised LDP Policies;
5. Adequacy of the assessment Integrated Sustainability Appraisal as it concerns Landscape; and,
6. Conclusion
1 It is noted that Welsh Government Local development plan examinations: procedure guidance (28 November 2022) states in paragraph 1.7 that ‘Those who have sought changes to the submitted plan or plan revisions and have indicated that they would like to speak must be invited to the hearings.’

1. Objection to the removal of the Special Landscape Areas from the Revised LDP
‘The use of non-statutory designations such as Special Landscape Areas to protect areas of landscape value has long been a policy tool within the UK planning system. They have been seen by local planning authorities as a means of protecting sensitive landscapes and in developing an understanding and awareness of those features and characteristics that give a locality its sense of place.’2
Carmarthenshire’s 18 Special Landscape Areas (‘SLAs’) listed under Policy EQ6 in the Current LDP have not been carried forward into the Revised LDP.
We recognise that SLAs are a local non-statutory designation, however these areas are an acknowledged designation which carries weight within the Current LDP as a standalone policy. SLAs are also acknowledged and given weight within neighbouring Local Planning Authority (‘LPA’) LDPs.3 The weight given to the SLA designations is recognised across Appeal decisions by the Planning Inspectorate and in Planning Inspectorate recommendations with regard to Development Consent Order applications.4
We object to the Second Deposit LDP on the basis of the removal of the SLAs and request that SLAs are reintroduced into the Revised LDP, either as a standalone policy or that provision is made within the new Policy BHE2: Landscape Character.
This could be achieved by an amendment to Policy BHE2: Landscape Character to add wording as follows:
Proposals must take account of Carmarthenshire’s locally designated Special Landscape Areas (as set out in Appendix X (Appendix 4 of the Current LDP) and shown on the Policies Map). Development proposals will only be permitted where there is no significant adverse impact, including cumulative impact, on the character and quality of the landscape. Development proposals should aim to protect and enhance the features for which the SLA has been designated.
Where appropriate, a Landscape Impact Assessment will be required to assess and justify the impact of the development on Landscape Character and/or the designated area.
In exceptional circumstances, where development is necessary and could result in a significant landscape impact, appropriate mitigation and enhancement measures should be provided, including the undergrounding of associated infrastructure where possible.
Our suggested wording is similar to the City of Swansea LDP which was successfully adopted following Examination in February 2019.5 Appendix 4 of the Current LDP would remain relevant to the Revised LDP and could be brought across, with edits as necessary to increase the robustness of the assessment of the area’s character. SLAs could be added back into the Policies Map, with minor boundary edits as necessary.
2 Bridgend County Borough Council, Designation of Special Landscape Areas, March 2010
3 City of Swansea LDP (adopted February 2019), Ceredigion LDP (adopted 2013)
4 Including, but not solely, APP/M6825/A/12/2189697, APP/M6825/X/13/515763 & APP/M6825/X/13/515764; and Brechfa Forest Connection DCO application ref EN020016;
5 https://www.swansea.gov.uk/article/9914/Swansea-Local-Development-Plan-2010-2025-LDP

Reasons for retention
The retention of the SLAs in the Revised LDP is well supported, with 438 people resident within the county signing Carmarthenshire Residents’ Action Group’s petition.
We argue that the retention of the SLAs is important to fulfil to objectives of the LDP and question if the SLAs are removed if the plan meets its Sustainability Objectives on Landscape set against the baseline criteria. We do not consider that a robust, proportionate and credible case has been set out by the LPA for the removal of this landscape designation. We consider that the removal of the SLAs significantly weakens the Revised LDP’s SO9 regarding sense of place and impacts Carmarthenshire’s planning framework in terms of delivering on sustainable development on the basis of the Well-being of Future Generations Act.
By designating SLAs it is easier for communities, visitors and tourists to engage with the highest value landscapes of Carmarthenshire. The SLA designations are reflective of the local value communities place on these landscapes in a manner not captured in the replacement Policy BHE2: Landscape Character. This revised policy places too much reliance on LANDMAP assessment. Whilst LANDMAP is an excellent tool for those engaged with the planning process, it is harder to engage with than the specifically designated SLAs which have clear and geographical boundaries capturing the outstanding and high quality landscapes of Carmarthenshire. The removal of the SLAs, and their removal from the Polices Map, invariably makes it makes it harder for specific communities and the wider public to engage with the LDP and weakens community representations as part of the planning consultation processes for individual development applications.
We consider that the SLAs improve the delivery of the Revised LDP objectives. Natural Resources Wales (‘NRW’) states that ‘there may be more than one role for an identified SLA: To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place / bro; To influence positive landscape planning. […]; To raise understanding and appreciation of the importance of local landscapes by communities, visitor and the wider public.’ The SLAs currently provide these roles and retaining them in the Revised LDP would better meet the LDP and ISA Objectives.
The developmental pressures on the landscape have not weakened in the time between the Current LDP adoption and the Revised LDP drafting. The Current LDP Appendix 4 assessment of SLAs specifically states in relation to the Tywi Valley, that ‘Inappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation.’ We do not see that these reasons for designation have weakened. However, if the LPA consider otherwise, then the evidence of this decision making process should be published.
Planning Policy Wales 11 (‘PPW11’) paragraphs 6.3.12 and 6.3.13 relate to the characteristics of local landscapes. These paragraphs highlight the ability for LPAs to designate SLAs. Paragraph 6.3.13 states that ‘Planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.’ Given that pressures on the landscape have not weakened and that the existing SLAs have proven weight in the planning determination process, we consider that the removal of the SLAs in the Revised LDP runs contrary to this part of PPW11.

Compatibility with Policy and Guidance
In addition to the point with regard to PPW 11 above, our view is that the SLAs are wholly compatible with the Revised LDP, the proposed Policy BHE2: Landscape Character and can be seamlessly incorporated into this policy, or alternatively, the existing policy could be retained in the Revised LDP.
NRW LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, endorses a dual approach to landscape management, in line with our suggested edits to the Revised LDP Policy BHE2: Landscape Character. On page 3 of the document, it is stated that ‘in this dual approach, all landscapes will be underpinned equally by LANDMAP […] but in addition to this, landscapes of high local importance will be specifically identified as a SLA with additional guidance being produced for these key landscapes’.
We recognise that there is potential tension between the SLA designation of Llanllwni Mountain SLA and the Cothi Valley SLA, and that these areas are also within the Pre-Assessed Area for Wind Energy in Future Wales 2040 the National Development Plan (‘NDP’). We argue that the SLA designation of these areas is not in conflict with the NDP, including Policies 17 and 18. However, we recognise that this is an area of the Revised LDP which may benefit from further exploration at Examination and we would appreciate an invitation to make representations on this issue.

2. Inadequate Evidence Base
The Issues, Vision and Options paper makes it clear that this 2018-2033 LDP is a review of the previous LDP and not a new local plan (para 1.3, page 2, Issues, Vision and Options Topic Paper, February 2023). There is a general expectation in plan making that evidence is front-loaded. As the Revised LDP revises the Current LDP, it is reasonable to expect that the entire removal of locally designated SLA from the plan should be carried out on a sound, evidence backed, basis. Statements by the LPA during the plan making process did not indicate that SLAs would be removed from the plan at Review or Preferred Strategy stages. The weakening of the landscape policies and the removal of SLAs was not revealed until the publication of the First Deposit LDP in early 2020. Prior to the publication of the First Deposit LDP, the LPA indicated that further evidence would be published if the policy were to be changed.
The 2006-2021 LDP Review Report 2018 did not raise concerns about the effectiveness of the SLA Policy, giving it a green colour coding indicating the policy target was being achieved or exceeded. The report stated in paragraph 9.141 that ‘The Plan identifies Special Landscape Areas (SLAs) within Policy EQ6. These were identified following a formal assessment of the landscape qualities of the County and are a non-statutory designation. It is noted that the policy places an emphasis on enhancement and improvement. There may be opportunities to supplement and/or review the supporting evidence for this policy and explore those wider linkages (e.g. the renewable energy policies and those design related policies).’
Further, Appendix 1 of the Review Report reviewing specific policies states that in relation to Policy EQ6 SLAs that ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy.’ This wording is a standard response to policies which were expected to be kept in the Revised LDP close to their current form. It is difficult to ascertain how the
removal of the SLAs does not constitute a fundamental change, to a degree where evidence justifying this change would reasonably be expected to be published.
Following on from the review, the Preferred Strategy was published in 2019. The Preferred Strategy gave no indication of the intention to remove the SLAs from the Deposit Plan and gave significant indication that landscape policies would remain strong within the Revised LDP. Issue 8 of the LDP issues is ‘Rich landscape or townscape qualities’; the Vision states that ‘rich cultural and environmental qualities are valued and respected’; paragraph 10.19 states that ‘the LDP will promote the principles of sustainability by: Protecting and enhancing biodiversity, townscapes and landscapes’; ‘A New Strategy – Key Components’ paragraph 10.20 states that ‘the key components of the strategy are as follows:’ one of which is to ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes’.6
Given these statements, it would not be unreasonable to expect that the SLA policy would remain in the Revised LDP, particularly given specific reference to the protection of high value landscapes. The means of recognising and protecting the areas of outstanding and high value landscapes in the LPA’s geographical area is specifically the Current LDP’s SLA policy.
Furthermore, in response to a representation made on the Preferred Strategy, the LPA stated ‘The consideration of whether any Special Landscape Areas will be identified in the Revised LDP, along with any resultant evidential facets, will be a matter for the deposit LDP.’ [our emphasis].
In our view, it is reasonable to consider that prior to the First Deposit Plan publication that the full SLA policy, or a slightly revised version of it, would remain in place in the new LDP; or that evidence would be published alongside the Deposit Plan to justify removal of the SLA policy given the LPAs statements in the Plan Review and the response to the Preferred Strategy public consultation. Therefore, given the above timeline indicates a very late decision to remove the SLAs from the Revised LDP, we question whether the decision has been carried out with robust, proportionate and credible evidence.
What evidence has been used?
At the date of this letter, the LPA have not provided information within the Plan Evidence Base, as accessed online, for the decision to remove the SLAs from the LDP; nor the evidence that the new landscape Policy BHE2: Landscape Character sufficiently delivers on the aims of the New Strategy which includes the key component to protect and enhance high-value landscapes.
Assessments which have been published by the LPA in relation to Landscape Character are due to expire when the new LDP is adopted. These comprise existing assessments of the SLA areas in Appendix 4 of the Current LDP; there is a reference to NRW’s 48 broad scale, not locally specific, National Landscape Character Areas (NLCA), and the SLAs within the Placemaking and Design SPG (adopted 2016); and consideration of landscapes in the Carmarthenshire Wind Turbine Development Landscape Sensitivity and Capacity Study, prepared by Anthony Jellard Associates.
The SLAs are removed from the Revised LDP. The Placemaking and Design SPG is not slated to be carried forward with the new Revised LDP7. The current status of the Anthony Jellard study is unclear,
6 These parts of the Preferred Strategy are carried into the Second Deposit LDP, February 2023, and are found across Chapters 5-9.
7 See Appendix 3, Second Deposit LDP 2018-2033
it is referenced within the current Wind and Solar SPG; however this SPG is not intended to be carried forward as part of the Revised LDP. The removal of these assessments is likely to leave a gap with regard to the protection and enhancement of landscapes when the new Revised LDP is adopted.
Given the anticipated expiry of these assessments, it is not credible that they can form part of an evidence base for the creation of the Revised LDP policies. No evidence has been provided that any other assessments have been carried out in forming the LPAs landscape character policy or that NRW’s LANDMAP has been utilised to inform revised policy preparation. The Revised LDP states that a Landscape Character Assessment SPG is proposed to be adopted by Summer 2025, but as no draft has been published this does not form part of the evidence base. The target Revised LDP adoption date is Autumn 2024 and with the SPG proposed for Summer 2025, this leaves a significant gap around landscape policy guidance in the interim, even if the Landscape Character SPG is published on time.
The LPAs Cabinet Member for Planning has responded to a question on the evidence base by discussing assessment of development proposals utilising information contained within NRWs LANDMAP. However, this is an existing means of assessment in the Current LDP and will be retained as a means of assessing change to landscape in the Revised LDP, as such it does not make a difference to the baseline. Notably, the question asked to the Cabinet Member for Planning was with regard to the evidence around the formation of new Policy BHE2 and the removal of the SLAs, to which she did not furnish an answer. 8
Finally, the lack of published evidence relevant to the landscape policies of the Revised LDP appears to be in conflict with paragraph 6.3.21 of PPW 11, which states ‘Planning authorities should draw upon LANDMAP in the preparation of landscape plans and assessments needed to inform development plans, SPGs and the development management process. LANDMAP assessments should be published.’ [our emphasis]
In our view, the evidence base for the Revised LDP in terms of Landscape Policy is not sufficiently substantiated and we request that this is interrogated by the Inspector appointed for the Examination.

3. Revised LDP Policies
We argue that the Revised LDP policies are substantively weaker with regard to landscape protection and enhancement than the Current LDP Policies. Comparison of similar policies in relation to placemaking, sustainability, high quality design, landscapes and features of importance, landscape character and renewable energy, between the Current LDP and the Revised LDP, show fewer mentions of the need to ‘preserve or enhance’, that development ‘must’ meet certain criteria, that development ‘will only be permitted’ if specific criteria are met, and the clear setting out of designated Special Landscape Areas with the expectation that development should enhance or improve these areas.
This is in contrast to the Revised LDP which uses wording such as ‘should relate to’, maintaining ‘overall integrity’, ‘development shall demonstrate’, that ‘development must acknowledge’ and ‘demonstrate a clear understanding’. Whilst it is acknowledged that this can be a more positive way of forming LDP policies and there are good reasons for this approach, it would be erroneous to suggest
8https://democracy.carmarthenshire.gov.wales/ieListDocuments.aspx?CId=131&MId=6351&Ver=4 [accessed 14 April 2023]
that these changes do not make the Policies easier for development to be consented and weaker in some instances. In our view, this is notably the case with regard to landscape protections and most significantly the removal of a whole policy layer designating Special Landscape Areas. With regard to landscape there is a question if the Policies as currently drafted are sufficiently robust to deliver on the Issues, Vision and Objectives of the plan, as well as key components of the Strategy.
We appreciate that Policies SP12: Placemaking and Sustainable Places and BHE2: Landscape Character, do contain some landscape protections. However, with the removal of the designated SLAs the Revised LDP remains materially weaker with regard to the protection of Carmarthenshire’s highest quality landscapes (outstanding and high value). This is especially the case prior to the publication of the promised Landscape Character SPG, and without publication of this SPG in draft form before examination it is difficult to fully consider the likely strength of these policies.

4. Specific suggested amendments to Revised LDP Policies
In addition to the objection to the removal of the SLA policy and suggestions for its reintroduction, we have the following additional comments on the Revised LDP.

Object. Strategic Policy – SP12: Placemaking and Sustainable Places
Policy point f) ‘Exhibit and demonstrate a clear understanding of the existing local landscape context, natural and built heritage, local character and sense of place.’
Proposed change to ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’
This change would deliver the key components of the New Strategy more convincingly in relation to this Policy, one of which is ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes.’ It would also deliver Strategic Objective 9 (SO9) more convincingly. SO9 aims ‘To protect and enhance the diverse character, distinctiveness, safety and vibrancy of the County’s communities by promoting a place making approach and a sense of place.’ Currently the specific phrase ‘protect and enhance’ only features in Strategic Policy SP14: Maintaining and Enhancing the Natural Environment which is only one component of the County’s diverse character. Variations of protect and enhance feature elsewhere in the written statement and there is benefit in bringing SP12 more into line with these.

Object. PSD1: Effective Design Solution: Sustainability and Placemaking. Policy point d) states ‘Quality landscapes design solutions’, this appears to be a typo where ‘landscape’ fits better. In our view, for policy point d) to work effectively, either reference to a published Landscape Character SPG, or reference to NRW LANDMAP (especially the Visual and Sensory assessment layer) should be made within this Policy or in the accompanying notes. This would benefit from explicitly stating that it applies to all development, including infrastructure, Renewable and Low Carbon developments, as well as buildings, transport, excavation sites, and smaller scale landscape proposals in the private and public realm.

Object. BHE2: Landscape Character. The use of ‘overall’ in the policy substantively weakens its protection of the landscape character. We request that this word is removed. It is unclear in the current presentation of the policy if the onus is on the applicant to identify the landscape character of the ‘local area’ through their own assessment, or if NRWs LANDMAP data is to be used, or if the
LPAs own Landscape Character SPG is to be used. This should be more explicitly set out and clarified. If the expectation is that the Landscape Character SPG is the baseline then it would be beneficial for this to be published in advance of the Revised LDPs adoption, preferably at the time of Examination. Reference to the Landscape Character Assessment should also be made in the Policy text.
It is also unclear where the key landscape views and vistas mentioned in point e. are set out, in order for them to be protected in the policy. If these are due to be identified in the Landscape Character SPG then, again, this would benefit publication prior to plan Examination.
We also request that reference to SLAs are added into this policy, as set out in section 1 of this letter.

Object. Policy CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and presumption of consent for renewable development proposals by communities, as well as those already set out for large scale wind farms. We suggest that the following are added to the policy:
d. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
e. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
f. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
g. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Policy CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and explicit presumption of consent for renewable development proposals from communities. We suggest that the following are added to the policy:
b. [add]… , including SLAs;
g. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
h. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
j. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
k. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Table 9 Resource Summary for Renewable Electricity. The Onshore Wind Target to deliver 588.5 MW of additional installed capacity by 2033 is in our view unrealistic given there has not been a call for sites for wind power. By our calculations, extrapolating from the evidence base document, AECOM Renewable and Low Carbon Energy Assessment Section 4.3, delivery of this target may require 75% of the area unconstrained by features such as buildings, roads and rivers in the Pre-Assessed Area in north Carmarthenshire to be developed for onshore wind.9 Given the mix of landowners and small scale farms across this area, delivery of the target may be challenging without large scale land purchases, which would not be feasible or desirable for smaller scale community wind developers. This policy is likely to result in more large scale multi-national corporation wind farm developments across Carmarthenshire. This is notwithstanding the scale of significant adverse impacts, including cumulative impacts, on the landscape a target like this will create.

Object. Policy CCH6: Renewable and Low Carbon Energy in New Developments. This policy could be more ambitious helping to deliver Net Zero targets by requiring all new housing or commercial development to fit solar panels to roofs, unless it is demonstrated by the applicant that to do so would not be viable, or if by doing so would conflict with other policies in the Revised LDP (such as built heritage, townscape or landscape policies).
Object. Policy CCH7: Climate Change – Forest, Woodland and Tree Planting. Specific reference should be made in the policy text to native trees and that planting schemes much be appropriate to the cultural and ecological character of the locality. This is referenced in paragraph 11.534, however due to the large ecological and landscape impacts that can arise from non-native tree planting, in our view the wording should be directly within the policy text.
The AECOM assessment estimates that the Pre-Assessed Area in Carmarthenshire, identified in Future Wales 2040, covers an area of 687 km2. The report assumes a maximum of 5 2MW turbines per 1km2 of land. Applications for new onshore wind at scale is more likely to be focused within the Pre-Assessed Areas due to the favourable planning framework for these locations. The Revised LDP target for installed capacity is an additional 588.5 MW, which using AECOM’s calculations would need to cover a land area of 58.85 Km2, or, 14,542 acres, equivalent to 8.5% of the Pre-Assessed Area. Taking into account the expected delivery of the remaining capacity in the former TAN 8 SSA, there is the expectation that 54.83 km2 will be delivered on a total possible unconstrained area of 73.1km2, or 75% of the unconstrained land in the Pre-Assessed Area. For the purposes of the AECOM study the constrains are National Parks, Natura 2000 sites, Buildings, Roads, Rivers, the TAN8 SSA and Topple Distance buffers applied to buildings, roads and rivers. Calculations taken from data within page 29 and 30 of the AECOM Renewable and Low Carbon Energy Assessment published in the LDP Evidence Base.

5. Adequacy of the Integrated Sustainability Appraisal assessment as it concerns Landscape
We are raising substantive concerns with regard to the robustness of the assessment carried out in the Integrated Sustainability Appraisal (‘ISA’).
The Sustainability Appraisal Scoping Report (published July 2018) set out the parameters of the Sustainability Appraisal, identifying Sustainability Issues and Opportunities, Sustainability Assessment Objectives and Decision Making Influences. This identified Landscape as number 9 of a total of 15 equal issues. Issue 9 is set out as follows: ‘There are several sites designated as of landscape or townscape value within the county. These features need to be protected, and where possible enhanced.’ In the Decision Making Influences, the question, ‘Will the LDP have a positive or negative impact on designated landscapes?’ is posed.
Linking these two quotes is the specific mention of ‘designated landscapes’, not statutory designated, nor ‘Designated’ noun. Special Landscape Areas are considered designated landscapes in this definition. This is the case in comparable LPAs in Wales, PPW11 para 6.3.12 refers to ‘the designation of Special Landscape Areas’ and the Current LDP Policy EQ6 states that ‘Special Landscape Areas are designated…’. Thus, references to designated landscapes in the Sustainability Appraisal, must take into account local as well as statutory designations, including SLAs. The question ‘will the LDP have a positive or negative impact on designated landscapes?’ and that the Revised LDP removes some of these designated landscapes, is an important consideration for the assessments in the Sustainability Appraisal.
Sustainable development is defined in the Well-being of Future Generations (Wales) Act 2015 as the ‘process of improving the economic, social, environmental, and cultural wellbeing of Wales by taking action.’ A change to the development plan which removes some designated landscapes should be considered carefully and assessed robustly on the terms that those designations have been removed, to demonstrate that the change is not an impairment to sustainable development.
Turning to the latest version of the ISA, published February 2023. The prediction of the effects of the plan involves identifying changes to the environmental baseline. The baseline for sustainability objective ISA9 – Landscape is set out in ISA Appendix B (pp.61-67) with the other baseline assessments. This baseline constitutes an introductory paragraph explaining that the Brecon Beacons National Park sits outside the LDP boundaries, along with a copy of the Current LDP Appendix 4 Special Landscape Areas assessment in full, then proceeds to state the ‘Predicted effect without implementation of the LDP’.
In our view, this assessment of predicted effects has been carried out incorrectly. The predicted effects mention protected habitat and species and biodiversity, which are assessed under ISA2 Biodiversity, and fails to comment adequately on changes to landscape as a characteristic in and of itself. Crucially, this assessment fails to note that the locally designated landscapes, SLAs, will continue to be in effect once the Plan period expires. This is, in our opinion, a substantive omission especially given that the baseline text is comprised of Special Landscape Area descriptions and assessing areas noted as being ‘worthy of the protection that the designation of SLAs provides.’
Section 4 of the ISA sets out a summary of the environmental baseline and predicted effects, noting that the future baseline for landscape is declining. This summary has a stronger summarisation of the likely effect on landscape than that set out in the ISA Appendix and states clearly that ‘landscape
protection measures should be strengthened’. As this assessment is provided on the basis that the Current LDP continues to remain in place, the need to have measures strengthening landscape protection must be considered to be in addition to those already in place, including the designated SLAs.
As the ISA needs to take into account the effect of the Revised LDP being adopted, against the baseline of the Current LDP remaining, some assessment of the removal of the local designated SLAs would be expected in the ISA. However, Special Landscape Areas are not mentioned in the main text of the ISA, nor the ISA Appendices, outside of the Baseline and list of Abbreviations. Failure to take account of the loss of this designation from the LDP is, in our view, a major error and questions the credibility of the appraisal of predicted effects on ISA9 – Landscape, throughout the ISA document and brings into question the soundness of the Plan.
There are also other concerning errors and omissions. One example is the review of SP16: Climate Change and associated specific policies CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas and CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas, in Appendix F and G. The appraisal considers the effects on landscape to be ‘neutral’ and with ‘positive and negative effects’. This is not credible given the scale of change proposed to the landscape on the basis of the targets for new wind power generation by 2033, and this target set in the context of the removal of the SLAs from the LDP. A negative effect should be identified. Whether the negative effect should be acceptable on balance is a test that is separate to this specific part of the ISA. The ISA should credibly take into account the high magnitude of the changes, the Plan’s intention to remove the SLA designated landscapes, and the effect characteristics including the scale of cumulative effects, their special extent and their probability; all of which is high impact and likely.
Another example is the review of SP14: Maintaining and Enhancing of the Natural Environment, where the Appraisal comments against ISA9 state that ‘This policy directly refers to the protection and enhancement of Carmarthenshire’s landscape’ (ISA Appendix F, p.46). This policy does not do as the Appraisal states. The protection and enhancement is directed at the natural environment more generally, it is not a policy linked back to ISA9 in its monitoring objectives, and points more generally to a confusion throughout the Revised LDP between the character of landscape as a visual and integral whole vs smaller scale aspects which make up the natural environment, which are nonetheless important, but fundamentally different.

6. Conclusion
The removal of the SLA designations from the LDP cannot but be an adverse change. The failure to take account of this substantive change and substantiate why this is not a significant weakening of the LDP from its current form is of great concern.
We encourage Carmarthenshire’s Forward Planning Department to set this right before the LDP is examined and re-introduce the SLA designations into the Plan to address the issues raised in this letter, re-providing a substantive part of the means to protect and enhance our outstanding and high valued landscapes for future generations.
We re-iterate our request to make representations on the LDP examination on the subject of landscape, with regard to relevant policies.
We appreciate your, and the appointed Planning Inspector’s, consideration of this letter.

Proposed change to Policy point f) - ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’

Carmarthenshire Residents’ Action Group: Representations to the public consultation of the Second Deposit Revised Carmarthenshire Local Development Plan 2018-2033 and the Integrated Sustainability Assessment
We, Carmarthenshire Residents’ Action Group, are responding to the public consultation on the Carmarthenshire Local Development Plan 2018-2033 (Second Deposit) (‘Revised LDP’) to raise concerns with regard to the plan making process in relation to landscape(s) within the LDP’s geographical area. We request several changes to the plan on the basis that we consider the plan not to be sound and request the opportunity to make representations during the examination process.1
This letter contains a series of comments and objections in relation to landscape policies, and approach to policy making with regard to landscapes, within Carmarthenshire’s Revised LDP drafting process, including the Integrated Sustainability Appraisal (‘ISA’).
This letter also consolidates a series of comments made via the online comments portal on the proposed Revised LDP. It refers Carmarthenshire’s Forward Planning Department and, in due course, the appointed Examination Planning Inspector, to Carmarthenshire Residents Action Group’s petition to maintain the Special Landscape Areas within the 2018-2033 LDP. This petition has raised 438 signatures, details of which are contained within Appendix 1 of this letter.
A strong objection is raised, backed by significant local support, to the removal of Carmarthenshire’s locally designated Special Landscape Areas within the Revised LDP. Objections are also raised with regard to the replacement landscape related policies in the second Deposit Revised LDP with materially weakened policies compared to the existing 2006-2021 LDP (‘Current LDP’). The letter also raises concerns with regard to the assessment carried out in the ISA as it pertains to the Sustainability Objective on Landscape.
Our representations are set out as follows:
1. Objection to the removal of Special Landscape Areas from the Revised LDP;
2. Inadequate Evidence Base;
3. Revised LDP Policies;
4. Specific suggested amendments to Revised LDP Policies;
5. Adequacy of the assessment Integrated Sustainability Appraisal as it concerns Landscape; and,
6. Conclusion
1 It is noted that Welsh Government Local development plan examinations: procedure guidance (28 November 2022) states in paragraph 1.7 that ‘Those who have sought changes to the submitted plan or plan revisions and have indicated that they would like to speak must be invited to the hearings.’

1. Objection to the removal of the Special Landscape Areas from the Revised LDP
‘The use of non-statutory designations such as Special Landscape Areas to protect areas of landscape value has long been a policy tool within the UK planning system. They have been seen by local planning authorities as a means of protecting sensitive landscapes and in developing an understanding and awareness of those features and characteristics that give a locality its sense of place.’2
Carmarthenshire’s 18 Special Landscape Areas (‘SLAs’) listed under Policy EQ6 in the Current LDP have not been carried forward into the Revised LDP.
We recognise that SLAs are a local non-statutory designation, however these areas are an acknowledged designation which carries weight within the Current LDP as a standalone policy. SLAs are also acknowledged and given weight within neighbouring Local Planning Authority (‘LPA’) LDPs.3 The weight given to the SLA designations is recognised across Appeal decisions by the Planning Inspectorate and in Planning Inspectorate recommendations with regard to Development Consent Order applications.4
We object to the Second Deposit LDP on the basis of the removal of the SLAs and request that SLAs are reintroduced into the Revised LDP, either as a standalone policy or that provision is made within the new Policy BHE2: Landscape Character.
This could be achieved by an amendment to Policy BHE2: Landscape Character to add wording as follows:
Proposals must take account of Carmarthenshire’s locally designated Special Landscape Areas (as set out in Appendix X (Appendix 4 of the Current LDP) and shown on the Policies Map). Development proposals will only be permitted where there is no significant adverse impact, including cumulative impact, on the character and quality of the landscape. Development proposals should aim to protect and enhance the features for which the SLA has been designated.
Where appropriate, a Landscape Impact Assessment will be required to assess and justify the impact of the development on Landscape Character and/or the designated area.
In exceptional circumstances, where development is necessary and could result in a significant landscape impact, appropriate mitigation and enhancement measures should be provided, including the undergrounding of associated infrastructure where possible.
Our suggested wording is similar to the City of Swansea LDP which was successfully adopted following Examination in February 2019.5 Appendix 4 of the Current LDP would remain relevant to the Revised LDP and could be brought across, with edits as necessary to increase the robustness of the assessment of the area’s character. SLAs could be added back into the Policies Map, with minor boundary edits as necessary.
2 Bridgend County Borough Council, Designation of Special Landscape Areas, March 2010
3 City of Swansea LDP (adopted February 2019), Ceredigion LDP (adopted 2013)
4 Including, but not solely, APP/M6825/A/12/2189697, APP/M6825/X/13/515763 & APP/M6825/X/13/515764; and Brechfa Forest Connection DCO application ref EN020016;
5 https://www.swansea.gov.uk/article/9914/Swansea-Local-Development-Plan-2010-2025-LDP

Reasons for retention
The retention of the SLAs in the Revised LDP is well supported, with 438 people resident within the county signing Carmarthenshire Residents’ Action Group’s petition.
We argue that the retention of the SLAs is important to fulfil to objectives of the LDP and question if the SLAs are removed if the plan meets its Sustainability Objectives on Landscape set against the baseline criteria. We do not consider that a robust, proportionate and credible case has been set out by the LPA for the removal of this landscape designation. We consider that the removal of the SLAs significantly weakens the Revised LDP’s SO9 regarding sense of place and impacts Carmarthenshire’s planning framework in terms of delivering on sustainable development on the basis of the Well-being of Future Generations Act.
By designating SLAs it is easier for communities, visitors and tourists to engage with the highest value landscapes of Carmarthenshire. The SLA designations are reflective of the local value communities place on these landscapes in a manner not captured in the replacement Policy BHE2: Landscape Character. This revised policy places too much reliance on LANDMAP assessment. Whilst LANDMAP is an excellent tool for those engaged with the planning process, it is harder to engage with than the specifically designated SLAs which have clear and geographical boundaries capturing the outstanding and high quality landscapes of Carmarthenshire. The removal of the SLAs, and their removal from the Polices Map, invariably makes it makes it harder for specific communities and the wider public to engage with the LDP and weakens community representations as part of the planning consultation processes for individual development applications.
We consider that the SLAs improve the delivery of the Revised LDP objectives. Natural Resources Wales (‘NRW’) states that ‘there may be more than one role for an identified SLA: To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place / bro; To influence positive landscape planning. […]; To raise understanding and appreciation of the importance of local landscapes by communities, visitor and the wider public.’ The SLAs currently provide these roles and retaining them in the Revised LDP would better meet the LDP and ISA Objectives.
The developmental pressures on the landscape have not weakened in the time between the Current LDP adoption and the Revised LDP drafting. The Current LDP Appendix 4 assessment of SLAs specifically states in relation to the Tywi Valley, that ‘Inappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation.’ We do not see that these reasons for designation have weakened. However, if the LPA consider otherwise, then the evidence of this decision making process should be published.
Planning Policy Wales 11 (‘PPW11’) paragraphs 6.3.12 and 6.3.13 relate to the characteristics of local landscapes. These paragraphs highlight the ability for LPAs to designate SLAs. Paragraph 6.3.13 states that ‘Planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.’ Given that pressures on the landscape have not weakened and that the existing SLAs have proven weight in the planning determination process, we consider that the removal of the SLAs in the Revised LDP runs contrary to this part of PPW11.

Compatibility with Policy and Guidance
In addition to the point with regard to PPW 11 above, our view is that the SLAs are wholly compatible with the Revised LDP, the proposed Policy BHE2: Landscape Character and can be seamlessly incorporated into this policy, or alternatively, the existing policy could be retained in the Revised LDP.
NRW LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, endorses a dual approach to landscape management, in line with our suggested edits to the Revised LDP Policy BHE2: Landscape Character. On page 3 of the document, it is stated that ‘in this dual approach, all landscapes will be underpinned equally by LANDMAP […] but in addition to this, landscapes of high local importance will be specifically identified as a SLA with additional guidance being produced for these key landscapes’.
We recognise that there is potential tension between the SLA designation of Llanllwni Mountain SLA and the Cothi Valley SLA, and that these areas are also within the Pre-Assessed Area for Wind Energy in Future Wales 2040 the National Development Plan (‘NDP’). We argue that the SLA designation of these areas is not in conflict with the NDP, including Policies 17 and 18. However, we recognise that this is an area of the Revised LDP which may benefit from further exploration at Examination and we would appreciate an invitation to make representations on this issue.

2. Inadequate Evidence Base
The Issues, Vision and Options paper makes it clear that this 2018-2033 LDP is a review of the previous LDP and not a new local plan (para 1.3, page 2, Issues, Vision and Options Topic Paper, February 2023). There is a general expectation in plan making that evidence is front-loaded. As the Revised LDP revises the Current LDP, it is reasonable to expect that the entire removal of locally designated SLA from the plan should be carried out on a sound, evidence backed, basis. Statements by the LPA during the plan making process did not indicate that SLAs would be removed from the plan at Review or Preferred Strategy stages. The weakening of the landscape policies and the removal of SLAs was not revealed until the publication of the First Deposit LDP in early 2020. Prior to the publication of the First Deposit LDP, the LPA indicated that further evidence would be published if the policy were to be changed.
The 2006-2021 LDP Review Report 2018 did not raise concerns about the effectiveness of the SLA Policy, giving it a green colour coding indicating the policy target was being achieved or exceeded. The report stated in paragraph 9.141 that ‘The Plan identifies Special Landscape Areas (SLAs) within Policy EQ6. These were identified following a formal assessment of the landscape qualities of the County and are a non-statutory designation. It is noted that the policy places an emphasis on enhancement and improvement. There may be opportunities to supplement and/or review the supporting evidence for this policy and explore those wider linkages (e.g. the renewable energy policies and those design related policies).’
Further, Appendix 1 of the Review Report reviewing specific policies states that in relation to Policy EQ6 SLAs that ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy.’ This wording is a standard response to policies which were expected to be kept in the Revised LDP close to their current form. It is difficult to ascertain how the
removal of the SLAs does not constitute a fundamental change, to a degree where evidence justifying this change would reasonably be expected to be published.
Following on from the review, the Preferred Strategy was published in 2019. The Preferred Strategy gave no indication of the intention to remove the SLAs from the Deposit Plan and gave significant indication that landscape policies would remain strong within the Revised LDP. Issue 8 of the LDP issues is ‘Rich landscape or townscape qualities’; the Vision states that ‘rich cultural and environmental qualities are valued and respected’; paragraph 10.19 states that ‘the LDP will promote the principles of sustainability by: Protecting and enhancing biodiversity, townscapes and landscapes’; ‘A New Strategy – Key Components’ paragraph 10.20 states that ‘the key components of the strategy are as follows:’ one of which is to ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes’.6
Given these statements, it would not be unreasonable to expect that the SLA policy would remain in the Revised LDP, particularly given specific reference to the protection of high value landscapes. The means of recognising and protecting the areas of outstanding and high value landscapes in the LPA’s geographical area is specifically the Current LDP’s SLA policy.
Furthermore, in response to a representation made on the Preferred Strategy, the LPA stated ‘The consideration of whether any Special Landscape Areas will be identified in the Revised LDP, along with any resultant evidential facets, will be a matter for the deposit LDP.’ [our emphasis].
In our view, it is reasonable to consider that prior to the First Deposit Plan publication that the full SLA policy, or a slightly revised version of it, would remain in place in the new LDP; or that evidence would be published alongside the Deposit Plan to justify removal of the SLA policy given the LPAs statements in the Plan Review and the response to the Preferred Strategy public consultation. Therefore, given the above timeline indicates a very late decision to remove the SLAs from the Revised LDP, we question whether the decision has been carried out with robust, proportionate and credible evidence.
What evidence has been used?
At the date of this letter, the LPA have not provided information within the Plan Evidence Base, as accessed online, for the decision to remove the SLAs from the LDP; nor the evidence that the new landscape Policy BHE2: Landscape Character sufficiently delivers on the aims of the New Strategy which includes the key component to protect and enhance high-value landscapes.
Assessments which have been published by the LPA in relation to Landscape Character are due to expire when the new LDP is adopted. These comprise existing assessments of the SLA areas in Appendix 4 of the Current LDP; there is a reference to NRW’s 48 broad scale, not locally specific, National Landscape Character Areas (NLCA), and the SLAs within the Placemaking and Design SPG (adopted 2016); and consideration of landscapes in the Carmarthenshire Wind Turbine Development Landscape Sensitivity and Capacity Study, prepared by Anthony Jellard Associates.
The SLAs are removed from the Revised LDP. The Placemaking and Design SPG is not slated to be carried forward with the new Revised LDP7. The current status of the Anthony Jellard study is unclear,
6 These parts of the Preferred Strategy are carried into the Second Deposit LDP, February 2023, and are found across Chapters 5-9.
7 See Appendix 3, Second Deposit LDP 2018-2033
it is referenced within the current Wind and Solar SPG; however this SPG is not intended to be carried forward as part of the Revised LDP. The removal of these assessments is likely to leave a gap with regard to the protection and enhancement of landscapes when the new Revised LDP is adopted.
Given the anticipated expiry of these assessments, it is not credible that they can form part of an evidence base for the creation of the Revised LDP policies. No evidence has been provided that any other assessments have been carried out in forming the LPAs landscape character policy or that NRW’s LANDMAP has been utilised to inform revised policy preparation. The Revised LDP states that a Landscape Character Assessment SPG is proposed to be adopted by Summer 2025, but as no draft has been published this does not form part of the evidence base. The target Revised LDP adoption date is Autumn 2024 and with the SPG proposed for Summer 2025, this leaves a significant gap around landscape policy guidance in the interim, even if the Landscape Character SPG is published on time.
The LPAs Cabinet Member for Planning has responded to a question on the evidence base by discussing assessment of development proposals utilising information contained within NRWs LANDMAP. However, this is an existing means of assessment in the Current LDP and will be retained as a means of assessing change to landscape in the Revised LDP, as such it does not make a difference to the baseline. Notably, the question asked to the Cabinet Member for Planning was with regard to the evidence around the formation of new Policy BHE2 and the removal of the SLAs, to which she did not furnish an answer. 8
Finally, the lack of published evidence relevant to the landscape policies of the Revised LDP appears to be in conflict with paragraph 6.3.21 of PPW 11, which states ‘Planning authorities should draw upon LANDMAP in the preparation of landscape plans and assessments needed to inform development plans, SPGs and the development management process. LANDMAP assessments should be published.’ [our emphasis]
In our view, the evidence base for the Revised LDP in terms of Landscape Policy is not sufficiently substantiated and we request that this is interrogated by the Inspector appointed for the Examination.

3. Revised LDP Policies
We argue that the Revised LDP policies are substantively weaker with regard to landscape protection and enhancement than the Current LDP Policies. Comparison of similar policies in relation to placemaking, sustainability, high quality design, landscapes and features of importance, landscape character and renewable energy, between the Current LDP and the Revised LDP, show fewer mentions of the need to ‘preserve or enhance’, that development ‘must’ meet certain criteria, that development ‘will only be permitted’ if specific criteria are met, and the clear setting out of designated Special Landscape Areas with the expectation that development should enhance or improve these areas.
This is in contrast to the Revised LDP which uses wording such as ‘should relate to’, maintaining ‘overall integrity’, ‘development shall demonstrate’, that ‘development must acknowledge’ and ‘demonstrate a clear understanding’. Whilst it is acknowledged that this can be a more positive way of forming LDP policies and there are good reasons for this approach, it would be erroneous to suggest
8https://democracy.carmarthenshire.gov.wales/ieListDocuments.aspx?CId=131&MId=6351&Ver=4 [accessed 14 April 2023]
that these changes do not make the Policies easier for development to be consented and weaker in some instances. In our view, this is notably the case with regard to landscape protections and most significantly the removal of a whole policy layer designating Special Landscape Areas. With regard to landscape there is a question if the Policies as currently drafted are sufficiently robust to deliver on the Issues, Vision and Objectives of the plan, as well as key components of the Strategy.
We appreciate that Policies SP12: Placemaking and Sustainable Places and BHE2: Landscape Character, do contain some landscape protections. However, with the removal of the designated SLAs the Revised LDP remains materially weaker with regard to the protection of Carmarthenshire’s highest quality landscapes (outstanding and high value). This is especially the case prior to the publication of the promised Landscape Character SPG, and without publication of this SPG in draft form before examination it is difficult to fully consider the likely strength of these policies.

4. Specific suggested amendments to Revised LDP Policies
In addition to the objection to the removal of the SLA policy and suggestions for its reintroduction, we have the following additional comments on the Revised LDP.

Object. Strategic Policy – SP12: Placemaking and Sustainable Places
Policy point f) ‘Exhibit and demonstrate a clear understanding of the existing local landscape context, natural and built heritage, local character and sense of place.’
Proposed change to ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’
This change would deliver the key components of the New Strategy more convincingly in relation to this Policy, one of which is ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes.’ It would also deliver Strategic Objective 9 (SO9) more convincingly. SO9 aims ‘To protect and enhance the diverse character, distinctiveness, safety and vibrancy of the County’s communities by promoting a place making approach and a sense of place.’ Currently the specific phrase ‘protect and enhance’ only features in Strategic Policy SP14: Maintaining and Enhancing the Natural Environment which is only one component of the County’s diverse character. Variations of protect and enhance feature elsewhere in the written statement and there is benefit in bringing SP12 more into line with these.

Object. PSD1: Effective Design Solution: Sustainability and Placemaking. Policy point d) states ‘Quality landscapes design solutions’, this appears to be a typo where ‘landscape’ fits better. In our view, for policy point d) to work effectively, either reference to a published Landscape Character SPG, or reference to NRW LANDMAP (especially the Visual and Sensory assessment layer) should be made within this Policy or in the accompanying notes. This would benefit from explicitly stating that it applies to all development, including infrastructure, Renewable and Low Carbon developments, as well as buildings, transport, excavation sites, and smaller scale landscape proposals in the private and public realm.

Object. BHE2: Landscape Character. The use of ‘overall’ in the policy substantively weakens its protection of the landscape character. We request that this word is removed. It is unclear in the current presentation of the policy if the onus is on the applicant to identify the landscape character of the ‘local area’ through their own assessment, or if NRWs LANDMAP data is to be used, or if the
LPAs own Landscape Character SPG is to be used. This should be more explicitly set out and clarified. If the expectation is that the Landscape Character SPG is the baseline then it would be beneficial for this to be published in advance of the Revised LDPs adoption, preferably at the time of Examination. Reference to the Landscape Character Assessment should also be made in the Policy text.
It is also unclear where the key landscape views and vistas mentioned in point e. are set out, in order for them to be protected in the policy. If these are due to be identified in the Landscape Character SPG then, again, this would benefit publication prior to plan Examination.
We also request that reference to SLAs are added into this policy, as set out in section 1 of this letter.

Object. Policy CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and presumption of consent for renewable development proposals by communities, as well as those already set out for large scale wind farms. We suggest that the following are added to the policy:
d. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
e. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
f. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
g. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Policy CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and explicit presumption of consent for renewable development proposals from communities. We suggest that the following are added to the policy:
b. [add]… , including SLAs;
g. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
h. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
j. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
k. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Table 9 Resource Summary for Renewable Electricity. The Onshore Wind Target to deliver 588.5 MW of additional installed capacity by 2033 is in our view unrealistic given there has not been a call for sites for wind power. By our calculations, extrapolating from the evidence base document, AECOM Renewable and Low Carbon Energy Assessment Section 4.3, delivery of this target may require 75% of the area unconstrained by features such as buildings, roads and rivers in the Pre-Assessed Area in north Carmarthenshire to be developed for onshore wind.9 Given the mix of landowners and small scale farms across this area, delivery of the target may be challenging without large scale land purchases, which would not be feasible or desirable for smaller scale community wind developers. This policy is likely to result in more large scale multi-national corporation wind farm developments across Carmarthenshire. This is notwithstanding the scale of significant adverse impacts, including cumulative impacts, on the landscape a target like this will create.

Object. Policy CCH6: Renewable and Low Carbon Energy in New Developments. This policy could be more ambitious helping to deliver Net Zero targets by requiring all new housing or commercial development to fit solar panels to roofs, unless it is demonstrated by the applicant that to do so would not be viable, or if by doing so would conflict with other policies in the Revised LDP (such as built heritage, townscape or landscape policies).
Object. Policy CCH7: Climate Change – Forest, Woodland and Tree Planting. Specific reference should be made in the policy text to native trees and that planting schemes much be appropriate to the cultural and ecological character of the locality. This is referenced in paragraph 11.534, however due to the large ecological and landscape impacts that can arise from non-native tree planting, in our view the wording should be directly within the policy text.
The AECOM assessment estimates that the Pre-Assessed Area in Carmarthenshire, identified in Future Wales 2040, covers an area of 687 km2. The report assumes a maximum of 5 2MW turbines per 1km2 of land. Applications for new onshore wind at scale is more likely to be focused within the Pre-Assessed Areas due to the favourable planning framework for these locations. The Revised LDP target for installed capacity is an additional 588.5 MW, which using AECOM’s calculations would need to cover a land area of 58.85 Km2, or, 14,542 acres, equivalent to 8.5% of the Pre-Assessed Area. Taking into account the expected delivery of the remaining capacity in the former TAN 8 SSA, there is the expectation that 54.83 km2 will be delivered on a total possible unconstrained area of 73.1km2, or 75% of the unconstrained land in the Pre-Assessed Area. For the purposes of the AECOM study the constrains are National Parks, Natura 2000 sites, Buildings, Roads, Rivers, the TAN8 SSA and Topple Distance buffers applied to buildings, roads and rivers. Calculations taken from data within page 29 and 30 of the AECOM Renewable and Low Carbon Energy Assessment published in the LDP Evidence Base.

5. Adequacy of the Integrated Sustainability Appraisal assessment as it concerns Landscape
We are raising substantive concerns with regard to the robustness of the assessment carried out in the Integrated Sustainability Appraisal (‘ISA’).
The Sustainability Appraisal Scoping Report (published July 2018) set out the parameters of the Sustainability Appraisal, identifying Sustainability Issues and Opportunities, Sustainability Assessment Objectives and Decision Making Influences. This identified Landscape as number 9 of a total of 15 equal issues. Issue 9 is set out as follows: ‘There are several sites designated as of landscape or townscape value within the county. These features need to be protected, and where possible enhanced.’ In the Decision Making Influences, the question, ‘Will the LDP have a positive or negative impact on designated landscapes?’ is posed.
Linking these two quotes is the specific mention of ‘designated landscapes’, not statutory designated, nor ‘Designated’ noun. Special Landscape Areas are considered designated landscapes in this definition. This is the case in comparable LPAs in Wales, PPW11 para 6.3.12 refers to ‘the designation of Special Landscape Areas’ and the Current LDP Policy EQ6 states that ‘Special Landscape Areas are designated…’. Thus, references to designated landscapes in the Sustainability Appraisal, must take into account local as well as statutory designations, including SLAs. The question ‘will the LDP have a positive or negative impact on designated landscapes?’ and that the Revised LDP removes some of these designated landscapes, is an important consideration for the assessments in the Sustainability Appraisal.
Sustainable development is defined in the Well-being of Future Generations (Wales) Act 2015 as the ‘process of improving the economic, social, environmental, and cultural wellbeing of Wales by taking action.’ A change to the development plan which removes some designated landscapes should be considered carefully and assessed robustly on the terms that those designations have been removed, to demonstrate that the change is not an impairment to sustainable development.
Turning to the latest version of the ISA, published February 2023. The prediction of the effects of the plan involves identifying changes to the environmental baseline. The baseline for sustainability objective ISA9 – Landscape is set out in ISA Appendix B (pp.61-67) with the other baseline assessments. This baseline constitutes an introductory paragraph explaining that the Brecon Beacons National Park sits outside the LDP boundaries, along with a copy of the Current LDP Appendix 4 Special Landscape Areas assessment in full, then proceeds to state the ‘Predicted effect without implementation of the LDP’.
In our view, this assessment of predicted effects has been carried out incorrectly. The predicted effects mention protected habitat and species and biodiversity, which are assessed under ISA2 Biodiversity, and fails to comment adequately on changes to landscape as a characteristic in and of itself. Crucially, this assessment fails to note that the locally designated landscapes, SLAs, will continue to be in effect once the Plan period expires. This is, in our opinion, a substantive omission especially given that the baseline text is comprised of Special Landscape Area descriptions and assessing areas noted as being ‘worthy of the protection that the designation of SLAs provides.’
Section 4 of the ISA sets out a summary of the environmental baseline and predicted effects, noting that the future baseline for landscape is declining. This summary has a stronger summarisation of the likely effect on landscape than that set out in the ISA Appendix and states clearly that ‘landscape
protection measures should be strengthened’. As this assessment is provided on the basis that the Current LDP continues to remain in place, the need to have measures strengthening landscape protection must be considered to be in addition to those already in place, including the designated SLAs.
As the ISA needs to take into account the effect of the Revised LDP being adopted, against the baseline of the Current LDP remaining, some assessment of the removal of the local designated SLAs would be expected in the ISA. However, Special Landscape Areas are not mentioned in the main text of the ISA, nor the ISA Appendices, outside of the Baseline and list of Abbreviations. Failure to take account of the loss of this designation from the LDP is, in our view, a major error and questions the credibility of the appraisal of predicted effects on ISA9 – Landscape, throughout the ISA document and brings into question the soundness of the Plan.
There are also other concerning errors and omissions. One example is the review of SP16: Climate Change and associated specific policies CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas and CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas, in Appendix F and G. The appraisal considers the effects on landscape to be ‘neutral’ and with ‘positive and negative effects’. This is not credible given the scale of change proposed to the landscape on the basis of the targets for new wind power generation by 2033, and this target set in the context of the removal of the SLAs from the LDP. A negative effect should be identified. Whether the negative effect should be acceptable on balance is a test that is separate to this specific part of the ISA. The ISA should credibly take into account the high magnitude of the changes, the Plan’s intention to remove the SLA designated landscapes, and the effect characteristics including the scale of cumulative effects, their special extent and their probability; all of which is high impact and likely.
Another example is the review of SP14: Maintaining and Enhancing of the Natural Environment, where the Appraisal comments against ISA9 state that ‘This policy directly refers to the protection and enhancement of Carmarthenshire’s landscape’ (ISA Appendix F, p.46). This policy does not do as the Appraisal states. The protection and enhancement is directed at the natural environment more generally, it is not a policy linked back to ISA9 in its monitoring objectives, and points more generally to a confusion throughout the Revised LDP between the character of landscape as a visual and integral whole vs smaller scale aspects which make up the natural environment, which are nonetheless important, but fundamentally different.

6. Conclusion
The removal of the SLA designations from the LDP cannot but be an adverse change. The failure to take account of this substantive change and substantiate why this is not a significant weakening of the LDP from its current form is of great concern.
We encourage Carmarthenshire’s Forward Planning Department to set this right before the LDP is examined and re-introduce the SLA designations into the Plan to address the issues raised in this letter, re-providing a substantive part of the means to protect and enhance our outstanding and high valued landscapes for future generations.
We re-iterate our request to make representations on the LDP examination on the subject of landscape, with regard to relevant policies.
We appreciate your, and the appointed Planning Inspector’s, consideration of this letter.

For policy point d) to work effectively, either reference to a published Landscape Character SPG, or reference to NRW LANDMAP (especially the Visual and Sensory assessment layer) should be made within this Policy or in the accompanying notes.

Carmarthenshire Residents’ Action Group: Representations to the public consultation of the Second Deposit Revised Carmarthenshire Local Development Plan 2018-2033 and the Integrated Sustainability Assessment
We, Carmarthenshire Residents’ Action Group, are responding to the public consultation on the Carmarthenshire Local Development Plan 2018-2033 (Second Deposit) (‘Revised LDP’) to raise concerns with regard to the plan making process in relation to landscape(s) within the LDP’s geographical area. We request several changes to the plan on the basis that we consider the plan not to be sound and request the opportunity to make representations during the examination process.1
This letter contains a series of comments and objections in relation to landscape policies, and approach to policy making with regard to landscapes, within Carmarthenshire’s Revised LDP drafting process, including the Integrated Sustainability Appraisal (‘ISA’).
This letter also consolidates a series of comments made via the online comments portal on the proposed Revised LDP. It refers Carmarthenshire’s Forward Planning Department and, in due course, the appointed Examination Planning Inspector, to Carmarthenshire Residents Action Group’s petition to maintain the Special Landscape Areas within the 2018-2033 LDP. This petition has raised 438 signatures, details of which are contained within Appendix 1 of this letter.
A strong objection is raised, backed by significant local support, to the removal of Carmarthenshire’s locally designated Special Landscape Areas within the Revised LDP. Objections are also raised with regard to the replacement landscape related policies in the second Deposit Revised LDP with materially weakened policies compared to the existing 2006-2021 LDP (‘Current LDP’). The letter also raises concerns with regard to the assessment carried out in the ISA as it pertains to the Sustainability Objective on Landscape.
Our representations are set out as follows:
1. Objection to the removal of Special Landscape Areas from the Revised LDP;
2. Inadequate Evidence Base;
3. Revised LDP Policies;
4. Specific suggested amendments to Revised LDP Policies;
5. Adequacy of the assessment Integrated Sustainability Appraisal as it concerns Landscape; and,
6. Conclusion
1 It is noted that Welsh Government Local development plan examinations: procedure guidance (28 November 2022) states in paragraph 1.7 that ‘Those who have sought changes to the submitted plan or plan revisions and have indicated that they would like to speak must be invited to the hearings.’

1. Objection to the removal of the Special Landscape Areas from the Revised LDP
‘The use of non-statutory designations such as Special Landscape Areas to protect areas of landscape value has long been a policy tool within the UK planning system. They have been seen by local planning authorities as a means of protecting sensitive landscapes and in developing an understanding and awareness of those features and characteristics that give a locality its sense of place.’2
Carmarthenshire’s 18 Special Landscape Areas (‘SLAs’) listed under Policy EQ6 in the Current LDP have not been carried forward into the Revised LDP.
We recognise that SLAs are a local non-statutory designation, however these areas are an acknowledged designation which carries weight within the Current LDP as a standalone policy. SLAs are also acknowledged and given weight within neighbouring Local Planning Authority (‘LPA’) LDPs.3 The weight given to the SLA designations is recognised across Appeal decisions by the Planning Inspectorate and in Planning Inspectorate recommendations with regard to Development Consent Order applications.4
We object to the Second Deposit LDP on the basis of the removal of the SLAs and request that SLAs are reintroduced into the Revised LDP, either as a standalone policy or that provision is made within the new Policy BHE2: Landscape Character.
This could be achieved by an amendment to Policy BHE2: Landscape Character to add wording as follows:
Proposals must take account of Carmarthenshire’s locally designated Special Landscape Areas (as set out in Appendix X (Appendix 4 of the Current LDP) and shown on the Policies Map). Development proposals will only be permitted where there is no significant adverse impact, including cumulative impact, on the character and quality of the landscape. Development proposals should aim to protect and enhance the features for which the SLA has been designated.
Where appropriate, a Landscape Impact Assessment will be required to assess and justify the impact of the development on Landscape Character and/or the designated area.
In exceptional circumstances, where development is necessary and could result in a significant landscape impact, appropriate mitigation and enhancement measures should be provided, including the undergrounding of associated infrastructure where possible.
Our suggested wording is similar to the City of Swansea LDP which was successfully adopted following Examination in February 2019.5 Appendix 4 of the Current LDP would remain relevant to the Revised LDP and could be brought across, with edits as necessary to increase the robustness of the assessment of the area’s character. SLAs could be added back into the Policies Map, with minor boundary edits as necessary.
2 Bridgend County Borough Council, Designation of Special Landscape Areas, March 2010
3 City of Swansea LDP (adopted February 2019), Ceredigion LDP (adopted 2013)
4 Including, but not solely, APP/M6825/A/12/2189697, APP/M6825/X/13/515763 & APP/M6825/X/13/515764; and Brechfa Forest Connection DCO application ref EN020016;
5 https://www.swansea.gov.uk/article/9914/Swansea-Local-Development-Plan-2010-2025-LDP

Reasons for retention
The retention of the SLAs in the Revised LDP is well supported, with 438 people resident within the county signing Carmarthenshire Residents’ Action Group’s petition.
We argue that the retention of the SLAs is important to fulfil to objectives of the LDP and question if the SLAs are removed if the plan meets its Sustainability Objectives on Landscape set against the baseline criteria. We do not consider that a robust, proportionate and credible case has been set out by the LPA for the removal of this landscape designation. We consider that the removal of the SLAs significantly weakens the Revised LDP’s SO9 regarding sense of place and impacts Carmarthenshire’s planning framework in terms of delivering on sustainable development on the basis of the Well-being of Future Generations Act.
By designating SLAs it is easier for communities, visitors and tourists to engage with the highest value landscapes of Carmarthenshire. The SLA designations are reflective of the local value communities place on these landscapes in a manner not captured in the replacement Policy BHE2: Landscape Character. This revised policy places too much reliance on LANDMAP assessment. Whilst LANDMAP is an excellent tool for those engaged with the planning process, it is harder to engage with than the specifically designated SLAs which have clear and geographical boundaries capturing the outstanding and high quality landscapes of Carmarthenshire. The removal of the SLAs, and their removal from the Polices Map, invariably makes it makes it harder for specific communities and the wider public to engage with the LDP and weakens community representations as part of the planning consultation processes for individual development applications.
We consider that the SLAs improve the delivery of the Revised LDP objectives. Natural Resources Wales (‘NRW’) states that ‘there may be more than one role for an identified SLA: To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place / bro; To influence positive landscape planning. […]; To raise understanding and appreciation of the importance of local landscapes by communities, visitor and the wider public.’ The SLAs currently provide these roles and retaining them in the Revised LDP would better meet the LDP and ISA Objectives.
The developmental pressures on the landscape have not weakened in the time between the Current LDP adoption and the Revised LDP drafting. The Current LDP Appendix 4 assessment of SLAs specifically states in relation to the Tywi Valley, that ‘Inappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation.’ We do not see that these reasons for designation have weakened. However, if the LPA consider otherwise, then the evidence of this decision making process should be published.
Planning Policy Wales 11 (‘PPW11’) paragraphs 6.3.12 and 6.3.13 relate to the characteristics of local landscapes. These paragraphs highlight the ability for LPAs to designate SLAs. Paragraph 6.3.13 states that ‘Planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.’ Given that pressures on the landscape have not weakened and that the existing SLAs have proven weight in the planning determination process, we consider that the removal of the SLAs in the Revised LDP runs contrary to this part of PPW11.

Compatibility with Policy and Guidance
In addition to the point with regard to PPW 11 above, our view is that the SLAs are wholly compatible with the Revised LDP, the proposed Policy BHE2: Landscape Character and can be seamlessly incorporated into this policy, or alternatively, the existing policy could be retained in the Revised LDP.
NRW LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, endorses a dual approach to landscape management, in line with our suggested edits to the Revised LDP Policy BHE2: Landscape Character. On page 3 of the document, it is stated that ‘in this dual approach, all landscapes will be underpinned equally by LANDMAP […] but in addition to this, landscapes of high local importance will be specifically identified as a SLA with additional guidance being produced for these key landscapes’.
We recognise that there is potential tension between the SLA designation of Llanllwni Mountain SLA and the Cothi Valley SLA, and that these areas are also within the Pre-Assessed Area for Wind Energy in Future Wales 2040 the National Development Plan (‘NDP’). We argue that the SLA designation of these areas is not in conflict with the NDP, including Policies 17 and 18. However, we recognise that this is an area of the Revised LDP which may benefit from further exploration at Examination and we would appreciate an invitation to make representations on this issue.

2. Inadequate Evidence Base
The Issues, Vision and Options paper makes it clear that this 2018-2033 LDP is a review of the previous LDP and not a new local plan (para 1.3, page 2, Issues, Vision and Options Topic Paper, February 2023). There is a general expectation in plan making that evidence is front-loaded. As the Revised LDP revises the Current LDP, it is reasonable to expect that the entire removal of locally designated SLA from the plan should be carried out on a sound, evidence backed, basis. Statements by the LPA during the plan making process did not indicate that SLAs would be removed from the plan at Review or Preferred Strategy stages. The weakening of the landscape policies and the removal of SLAs was not revealed until the publication of the First Deposit LDP in early 2020. Prior to the publication of the First Deposit LDP, the LPA indicated that further evidence would be published if the policy were to be changed.
The 2006-2021 LDP Review Report 2018 did not raise concerns about the effectiveness of the SLA Policy, giving it a green colour coding indicating the policy target was being achieved or exceeded. The report stated in paragraph 9.141 that ‘The Plan identifies Special Landscape Areas (SLAs) within Policy EQ6. These were identified following a formal assessment of the landscape qualities of the County and are a non-statutory designation. It is noted that the policy places an emphasis on enhancement and improvement. There may be opportunities to supplement and/or review the supporting evidence for this policy and explore those wider linkages (e.g. the renewable energy policies and those design related policies).’
Further, Appendix 1 of the Review Report reviewing specific policies states that in relation to Policy EQ6 SLAs that ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy.’ This wording is a standard response to policies which were expected to be kept in the Revised LDP close to their current form. It is difficult to ascertain how the
removal of the SLAs does not constitute a fundamental change, to a degree where evidence justifying this change would reasonably be expected to be published.
Following on from the review, the Preferred Strategy was published in 2019. The Preferred Strategy gave no indication of the intention to remove the SLAs from the Deposit Plan and gave significant indication that landscape policies would remain strong within the Revised LDP. Issue 8 of the LDP issues is ‘Rich landscape or townscape qualities’; the Vision states that ‘rich cultural and environmental qualities are valued and respected’; paragraph 10.19 states that ‘the LDP will promote the principles of sustainability by: Protecting and enhancing biodiversity, townscapes and landscapes’; ‘A New Strategy – Key Components’ paragraph 10.20 states that ‘the key components of the strategy are as follows:’ one of which is to ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes’.6
Given these statements, it would not be unreasonable to expect that the SLA policy would remain in the Revised LDP, particularly given specific reference to the protection of high value landscapes. The means of recognising and protecting the areas of outstanding and high value landscapes in the LPA’s geographical area is specifically the Current LDP’s SLA policy.
Furthermore, in response to a representation made on the Preferred Strategy, the LPA stated ‘The consideration of whether any Special Landscape Areas will be identified in the Revised LDP, along with any resultant evidential facets, will be a matter for the deposit LDP.’ [our emphasis].
In our view, it is reasonable to consider that prior to the First Deposit Plan publication that the full SLA policy, or a slightly revised version of it, would remain in place in the new LDP; or that evidence would be published alongside the Deposit Plan to justify removal of the SLA policy given the LPAs statements in the Plan Review and the response to the Preferred Strategy public consultation. Therefore, given the above timeline indicates a very late decision to remove the SLAs from the Revised LDP, we question whether the decision has been carried out with robust, proportionate and credible evidence.
What evidence has been used?
At the date of this letter, the LPA have not provided information within the Plan Evidence Base, as accessed online, for the decision to remove the SLAs from the LDP; nor the evidence that the new landscape Policy BHE2: Landscape Character sufficiently delivers on the aims of the New Strategy which includes the key component to protect and enhance high-value landscapes.
Assessments which have been published by the LPA in relation to Landscape Character are due to expire when the new LDP is adopted. These comprise existing assessments of the SLA areas in Appendix 4 of the Current LDP; there is a reference to NRW’s 48 broad scale, not locally specific, National Landscape Character Areas (NLCA), and the SLAs within the Placemaking and Design SPG (adopted 2016); and consideration of landscapes in the Carmarthenshire Wind Turbine Development Landscape Sensitivity and Capacity Study, prepared by Anthony Jellard Associates.
The SLAs are removed from the Revised LDP. The Placemaking and Design SPG is not slated to be carried forward with the new Revised LDP7. The current status of the Anthony Jellard study is unclear,
6 These parts of the Preferred Strategy are carried into the Second Deposit LDP, February 2023, and are found across Chapters 5-9.
7 See Appendix 3, Second Deposit LDP 2018-2033
it is referenced within the current Wind and Solar SPG; however this SPG is not intended to be carried forward as part of the Revised LDP. The removal of these assessments is likely to leave a gap with regard to the protection and enhancement of landscapes when the new Revised LDP is adopted.
Given the anticipated expiry of these assessments, it is not credible that they can form part of an evidence base for the creation of the Revised LDP policies. No evidence has been provided that any other assessments have been carried out in forming the LPAs landscape character policy or that NRW’s LANDMAP has been utilised to inform revised policy preparation. The Revised LDP states that a Landscape Character Assessment SPG is proposed to be adopted by Summer 2025, but as no draft has been published this does not form part of the evidence base. The target Revised LDP adoption date is Autumn 2024 and with the SPG proposed for Summer 2025, this leaves a significant gap around landscape policy guidance in the interim, even if the Landscape Character SPG is published on time.
The LPAs Cabinet Member for Planning has responded to a question on the evidence base by discussing assessment of development proposals utilising information contained within NRWs LANDMAP. However, this is an existing means of assessment in the Current LDP and will be retained as a means of assessing change to landscape in the Revised LDP, as such it does not make a difference to the baseline. Notably, the question asked to the Cabinet Member for Planning was with regard to the evidence around the formation of new Policy BHE2 and the removal of the SLAs, to which she did not furnish an answer. 8
Finally, the lack of published evidence relevant to the landscape policies of the Revised LDP appears to be in conflict with paragraph 6.3.21 of PPW 11, which states ‘Planning authorities should draw upon LANDMAP in the preparation of landscape plans and assessments needed to inform development plans, SPGs and the development management process. LANDMAP assessments should be published.’ [our emphasis]
In our view, the evidence base for the Revised LDP in terms of Landscape Policy is not sufficiently substantiated and we request that this is interrogated by the Inspector appointed for the Examination.

3. Revised LDP Policies
We argue that the Revised LDP policies are substantively weaker with regard to landscape protection and enhancement than the Current LDP Policies. Comparison of similar policies in relation to placemaking, sustainability, high quality design, landscapes and features of importance, landscape character and renewable energy, between the Current LDP and the Revised LDP, show fewer mentions of the need to ‘preserve or enhance’, that development ‘must’ meet certain criteria, that development ‘will only be permitted’ if specific criteria are met, and the clear setting out of designated Special Landscape Areas with the expectation that development should enhance or improve these areas.
This is in contrast to the Revised LDP which uses wording such as ‘should relate to’, maintaining ‘overall integrity’, ‘development shall demonstrate’, that ‘development must acknowledge’ and ‘demonstrate a clear understanding’. Whilst it is acknowledged that this can be a more positive way of forming LDP policies and there are good reasons for this approach, it would be erroneous to suggest
8https://democracy.carmarthenshire.gov.wales/ieListDocuments.aspx?CId=131&MId=6351&Ver=4 [accessed 14 April 2023]
that these changes do not make the Policies easier for development to be consented and weaker in some instances. In our view, this is notably the case with regard to landscape protections and most significantly the removal of a whole policy layer designating Special Landscape Areas. With regard to landscape there is a question if the Policies as currently drafted are sufficiently robust to deliver on the Issues, Vision and Objectives of the plan, as well as key components of the Strategy.
We appreciate that Policies SP12: Placemaking and Sustainable Places and BHE2: Landscape Character, do contain some landscape protections. However, with the removal of the designated SLAs the Revised LDP remains materially weaker with regard to the protection of Carmarthenshire’s highest quality landscapes (outstanding and high value). This is especially the case prior to the publication of the promised Landscape Character SPG, and without publication of this SPG in draft form before examination it is difficult to fully consider the likely strength of these policies.

4. Specific suggested amendments to Revised LDP Policies
In addition to the objection to the removal of the SLA policy and suggestions for its reintroduction, we have the following additional comments on the Revised LDP.

Object. Strategic Policy – SP12: Placemaking and Sustainable Places
Policy point f) ‘Exhibit and demonstrate a clear understanding of the existing local landscape context, natural and built heritage, local character and sense of place.’
Proposed change to ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’
This change would deliver the key components of the New Strategy more convincingly in relation to this Policy, one of which is ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes.’ It would also deliver Strategic Objective 9 (SO9) more convincingly. SO9 aims ‘To protect and enhance the diverse character, distinctiveness, safety and vibrancy of the County’s communities by promoting a place making approach and a sense of place.’ Currently the specific phrase ‘protect and enhance’ only features in Strategic Policy SP14: Maintaining and Enhancing the Natural Environment which is only one component of the County’s diverse character. Variations of protect and enhance feature elsewhere in the written statement and there is benefit in bringing SP12 more into line with these.

Object. PSD1: Effective Design Solution: Sustainability and Placemaking. Policy point d) states ‘Quality landscapes design solutions’, this appears to be a typo where ‘landscape’ fits better. In our view, for policy point d) to work effectively, either reference to a published Landscape Character SPG, or reference to NRW LANDMAP (especially the Visual and Sensory assessment layer) should be made within this Policy or in the accompanying notes. This would benefit from explicitly stating that it applies to all development, including infrastructure, Renewable and Low Carbon developments, as well as buildings, transport, excavation sites, and smaller scale landscape proposals in the private and public realm.

Object. BHE2: Landscape Character. The use of ‘overall’ in the policy substantively weakens its protection of the landscape character. We request that this word is removed. It is unclear in the current presentation of the policy if the onus is on the applicant to identify the landscape character of the ‘local area’ through their own assessment, or if NRWs LANDMAP data is to be used, or if the
LPAs own Landscape Character SPG is to be used. This should be more explicitly set out and clarified. If the expectation is that the Landscape Character SPG is the baseline then it would be beneficial for this to be published in advance of the Revised LDPs adoption, preferably at the time of Examination. Reference to the Landscape Character Assessment should also be made in the Policy text.
It is also unclear where the key landscape views and vistas mentioned in point e. are set out, in order for them to be protected in the policy. If these are due to be identified in the Landscape Character SPG then, again, this would benefit publication prior to plan Examination.
We also request that reference to SLAs are added into this policy, as set out in section 1 of this letter.

Object. Policy CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and presumption of consent for renewable development proposals by communities, as well as those already set out for large scale wind farms. We suggest that the following are added to the policy:
d. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
e. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
f. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
g. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Policy CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and explicit presumption of consent for renewable development proposals from communities. We suggest that the following are added to the policy:
b. [add]… , including SLAs;
g. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
h. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
j. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
k. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Table 9 Resource Summary for Renewable Electricity. The Onshore Wind Target to deliver 588.5 MW of additional installed capacity by 2033 is in our view unrealistic given there has not been a call for sites for wind power. By our calculations, extrapolating from the evidence base document, AECOM Renewable and Low Carbon Energy Assessment Section 4.3, delivery of this target may require 75% of the area unconstrained by features such as buildings, roads and rivers in the Pre-Assessed Area in north Carmarthenshire to be developed for onshore wind.9 Given the mix of landowners and small scale farms across this area, delivery of the target may be challenging without large scale land purchases, which would not be feasible or desirable for smaller scale community wind developers. This policy is likely to result in more large scale multi-national corporation wind farm developments across Carmarthenshire. This is notwithstanding the scale of significant adverse impacts, including cumulative impacts, on the landscape a target like this will create.

Object. Policy CCH6: Renewable and Low Carbon Energy in New Developments. This policy could be more ambitious helping to deliver Net Zero targets by requiring all new housing or commercial development to fit solar panels to roofs, unless it is demonstrated by the applicant that to do so would not be viable, or if by doing so would conflict with other policies in the Revised LDP (such as built heritage, townscape or landscape policies).
Object. Policy CCH7: Climate Change – Forest, Woodland and Tree Planting. Specific reference should be made in the policy text to native trees and that planting schemes much be appropriate to the cultural and ecological character of the locality. This is referenced in paragraph 11.534, however due to the large ecological and landscape impacts that can arise from non-native tree planting, in our view the wording should be directly within the policy text.
The AECOM assessment estimates that the Pre-Assessed Area in Carmarthenshire, identified in Future Wales 2040, covers an area of 687 km2. The report assumes a maximum of 5 2MW turbines per 1km2 of land. Applications for new onshore wind at scale is more likely to be focused within the Pre-Assessed Areas due to the favourable planning framework for these locations. The Revised LDP target for installed capacity is an additional 588.5 MW, which using AECOM’s calculations would need to cover a land area of 58.85 Km2, or, 14,542 acres, equivalent to 8.5% of the Pre-Assessed Area. Taking into account the expected delivery of the remaining capacity in the former TAN 8 SSA, there is the expectation that 54.83 km2 will be delivered on a total possible unconstrained area of 73.1km2, or 75% of the unconstrained land in the Pre-Assessed Area. For the purposes of the AECOM study the constrains are National Parks, Natura 2000 sites, Buildings, Roads, Rivers, the TAN8 SSA and Topple Distance buffers applied to buildings, roads and rivers. Calculations taken from data within page 29 and 30 of the AECOM Renewable and Low Carbon Energy Assessment published in the LDP Evidence Base.

5. Adequacy of the Integrated Sustainability Appraisal assessment as it concerns Landscape
We are raising substantive concerns with regard to the robustness of the assessment carried out in the Integrated Sustainability Appraisal (‘ISA’).
The Sustainability Appraisal Scoping Report (published July 2018) set out the parameters of the Sustainability Appraisal, identifying Sustainability Issues and Opportunities, Sustainability Assessment Objectives and Decision Making Influences. This identified Landscape as number 9 of a total of 15 equal issues. Issue 9 is set out as follows: ‘There are several sites designated as of landscape or townscape value within the county. These features need to be protected, and where possible enhanced.’ In the Decision Making Influences, the question, ‘Will the LDP have a positive or negative impact on designated landscapes?’ is posed.
Linking these two quotes is the specific mention of ‘designated landscapes’, not statutory designated, nor ‘Designated’ noun. Special Landscape Areas are considered designated landscapes in this definition. This is the case in comparable LPAs in Wales, PPW11 para 6.3.12 refers to ‘the designation of Special Landscape Areas’ and the Current LDP Policy EQ6 states that ‘Special Landscape Areas are designated…’. Thus, references to designated landscapes in the Sustainability Appraisal, must take into account local as well as statutory designations, including SLAs. The question ‘will the LDP have a positive or negative impact on designated landscapes?’ and that the Revised LDP removes some of these designated landscapes, is an important consideration for the assessments in the Sustainability Appraisal.
Sustainable development is defined in the Well-being of Future Generations (Wales) Act 2015 as the ‘process of improving the economic, social, environmental, and cultural wellbeing of Wales by taking action.’ A change to the development plan which removes some designated landscapes should be considered carefully and assessed robustly on the terms that those designations have been removed, to demonstrate that the change is not an impairment to sustainable development.
Turning to the latest version of the ISA, published February 2023. The prediction of the effects of the plan involves identifying changes to the environmental baseline. The baseline for sustainability objective ISA9 – Landscape is set out in ISA Appendix B (pp.61-67) with the other baseline assessments. This baseline constitutes an introductory paragraph explaining that the Brecon Beacons National Park sits outside the LDP boundaries, along with a copy of the Current LDP Appendix 4 Special Landscape Areas assessment in full, then proceeds to state the ‘Predicted effect without implementation of the LDP’.
In our view, this assessment of predicted effects has been carried out incorrectly. The predicted effects mention protected habitat and species and biodiversity, which are assessed under ISA2 Biodiversity, and fails to comment adequately on changes to landscape as a characteristic in and of itself. Crucially, this assessment fails to note that the locally designated landscapes, SLAs, will continue to be in effect once the Plan period expires. This is, in our opinion, a substantive omission especially given that the baseline text is comprised of Special Landscape Area descriptions and assessing areas noted as being ‘worthy of the protection that the designation of SLAs provides.’
Section 4 of the ISA sets out a summary of the environmental baseline and predicted effects, noting that the future baseline for landscape is declining. This summary has a stronger summarisation of the likely effect on landscape than that set out in the ISA Appendix and states clearly that ‘landscape
protection measures should be strengthened’. As this assessment is provided on the basis that the Current LDP continues to remain in place, the need to have measures strengthening landscape protection must be considered to be in addition to those already in place, including the designated SLAs.
As the ISA needs to take into account the effect of the Revised LDP being adopted, against the baseline of the Current LDP remaining, some assessment of the removal of the local designated SLAs would be expected in the ISA. However, Special Landscape Areas are not mentioned in the main text of the ISA, nor the ISA Appendices, outside of the Baseline and list of Abbreviations. Failure to take account of the loss of this designation from the LDP is, in our view, a major error and questions the credibility of the appraisal of predicted effects on ISA9 – Landscape, throughout the ISA document and brings into question the soundness of the Plan.
There are also other concerning errors and omissions. One example is the review of SP16: Climate Change and associated specific policies CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas and CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas, in Appendix F and G. The appraisal considers the effects on landscape to be ‘neutral’ and with ‘positive and negative effects’. This is not credible given the scale of change proposed to the landscape on the basis of the targets for new wind power generation by 2033, and this target set in the context of the removal of the SLAs from the LDP. A negative effect should be identified. Whether the negative effect should be acceptable on balance is a test that is separate to this specific part of the ISA. The ISA should credibly take into account the high magnitude of the changes, the Plan’s intention to remove the SLA designated landscapes, and the effect characteristics including the scale of cumulative effects, their special extent and their probability; all of which is high impact and likely.
Another example is the review of SP14: Maintaining and Enhancing of the Natural Environment, where the Appraisal comments against ISA9 state that ‘This policy directly refers to the protection and enhancement of Carmarthenshire’s landscape’ (ISA Appendix F, p.46). This policy does not do as the Appraisal states. The protection and enhancement is directed at the natural environment more generally, it is not a policy linked back to ISA9 in its monitoring objectives, and points more generally to a confusion throughout the Revised LDP between the character of landscape as a visual and integral whole vs smaller scale aspects which make up the natural environment, which are nonetheless important, but fundamentally different.

6. Conclusion
The removal of the SLA designations from the LDP cannot but be an adverse change. The failure to take account of this substantive change and substantiate why this is not a significant weakening of the LDP from its current form is of great concern.
We encourage Carmarthenshire’s Forward Planning Department to set this right before the LDP is examined and re-introduce the SLA designations into the Plan to address the issues raised in this letter, re-providing a substantive part of the means to protect and enhance our outstanding and high valued landscapes for future generations.
We re-iterate our request to make representations on the LDP examination on the subject of landscape, with regard to relevant policies.
We appreciate your, and the appointed Planning Inspector’s, consideration of this letter.

The following changes are suggested to the policy:
d. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
e. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
f. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
g. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Carmarthenshire Residents’ Action Group: Representations to the public consultation of the Second Deposit Revised Carmarthenshire Local Development Plan 2018-2033 and the Integrated Sustainability Assessment
We, Carmarthenshire Residents’ Action Group, are responding to the public consultation on the Carmarthenshire Local Development Plan 2018-2033 (Second Deposit) (‘Revised LDP’) to raise concerns with regard to the plan making process in relation to landscape(s) within the LDP’s geographical area. We request several changes to the plan on the basis that we consider the plan not to be sound and request the opportunity to make representations during the examination process.1
This letter contains a series of comments and objections in relation to landscape policies, and approach to policy making with regard to landscapes, within Carmarthenshire’s Revised LDP drafting process, including the Integrated Sustainability Appraisal (‘ISA’).
This letter also consolidates a series of comments made via the online comments portal on the proposed Revised LDP. It refers Carmarthenshire’s Forward Planning Department and, in due course, the appointed Examination Planning Inspector, to Carmarthenshire Residents Action Group’s petition to maintain the Special Landscape Areas within the 2018-2033 LDP. This petition has raised 438 signatures, details of which are contained within Appendix 1 of this letter.
A strong objection is raised, backed by significant local support, to the removal of Carmarthenshire’s locally designated Special Landscape Areas within the Revised LDP. Objections are also raised with regard to the replacement landscape related policies in the second Deposit Revised LDP with materially weakened policies compared to the existing 2006-2021 LDP (‘Current LDP’). The letter also raises concerns with regard to the assessment carried out in the ISA as it pertains to the Sustainability Objective on Landscape.
Our representations are set out as follows:
1. Objection to the removal of Special Landscape Areas from the Revised LDP;
2. Inadequate Evidence Base;
3. Revised LDP Policies;
4. Specific suggested amendments to Revised LDP Policies;
5. Adequacy of the assessment Integrated Sustainability Appraisal as it concerns Landscape; and,
6. Conclusion
1 It is noted that Welsh Government Local development plan examinations: procedure guidance (28 November 2022) states in paragraph 1.7 that ‘Those who have sought changes to the submitted plan or plan revisions and have indicated that they would like to speak must be invited to the hearings.’

1. Objection to the removal of the Special Landscape Areas from the Revised LDP
‘The use of non-statutory designations such as Special Landscape Areas to protect areas of landscape value has long been a policy tool within the UK planning system. They have been seen by local planning authorities as a means of protecting sensitive landscapes and in developing an understanding and awareness of those features and characteristics that give a locality its sense of place.’2
Carmarthenshire’s 18 Special Landscape Areas (‘SLAs’) listed under Policy EQ6 in the Current LDP have not been carried forward into the Revised LDP.
We recognise that SLAs are a local non-statutory designation, however these areas are an acknowledged designation which carries weight within the Current LDP as a standalone policy. SLAs are also acknowledged and given weight within neighbouring Local Planning Authority (‘LPA’) LDPs.3 The weight given to the SLA designations is recognised across Appeal decisions by the Planning Inspectorate and in Planning Inspectorate recommendations with regard to Development Consent Order applications.4
We object to the Second Deposit LDP on the basis of the removal of the SLAs and request that SLAs are reintroduced into the Revised LDP, either as a standalone policy or that provision is made within the new Policy BHE2: Landscape Character.
This could be achieved by an amendment to Policy BHE2: Landscape Character to add wording as follows:
Proposals must take account of Carmarthenshire’s locally designated Special Landscape Areas (as set out in Appendix X (Appendix 4 of the Current LDP) and shown on the Policies Map). Development proposals will only be permitted where there is no significant adverse impact, including cumulative impact, on the character and quality of the landscape. Development proposals should aim to protect and enhance the features for which the SLA has been designated.
Where appropriate, a Landscape Impact Assessment will be required to assess and justify the impact of the development on Landscape Character and/or the designated area.
In exceptional circumstances, where development is necessary and could result in a significant landscape impact, appropriate mitigation and enhancement measures should be provided, including the undergrounding of associated infrastructure where possible.
Our suggested wording is similar to the City of Swansea LDP which was successfully adopted following Examination in February 2019.5 Appendix 4 of the Current LDP would remain relevant to the Revised LDP and could be brought across, with edits as necessary to increase the robustness of the assessment of the area’s character. SLAs could be added back into the Policies Map, with minor boundary edits as necessary.
2 Bridgend County Borough Council, Designation of Special Landscape Areas, March 2010
3 City of Swansea LDP (adopted February 2019), Ceredigion LDP (adopted 2013)
4 Including, but not solely, APP/M6825/A/12/2189697, APP/M6825/X/13/515763 & APP/M6825/X/13/515764; and Brechfa Forest Connection DCO application ref EN020016;
5 https://www.swansea.gov.uk/article/9914/Swansea-Local-Development-Plan-2010-2025-LDP

Reasons for retention
The retention of the SLAs in the Revised LDP is well supported, with 438 people resident within the county signing Carmarthenshire Residents’ Action Group’s petition.
We argue that the retention of the SLAs is important to fulfil to objectives of the LDP and question if the SLAs are removed if the plan meets its Sustainability Objectives on Landscape set against the baseline criteria. We do not consider that a robust, proportionate and credible case has been set out by the LPA for the removal of this landscape designation. We consider that the removal of the SLAs significantly weakens the Revised LDP’s SO9 regarding sense of place and impacts Carmarthenshire’s planning framework in terms of delivering on sustainable development on the basis of the Well-being of Future Generations Act.
By designating SLAs it is easier for communities, visitors and tourists to engage with the highest value landscapes of Carmarthenshire. The SLA designations are reflective of the local value communities place on these landscapes in a manner not captured in the replacement Policy BHE2: Landscape Character. This revised policy places too much reliance on LANDMAP assessment. Whilst LANDMAP is an excellent tool for those engaged with the planning process, it is harder to engage with than the specifically designated SLAs which have clear and geographical boundaries capturing the outstanding and high quality landscapes of Carmarthenshire. The removal of the SLAs, and their removal from the Polices Map, invariably makes it makes it harder for specific communities and the wider public to engage with the LDP and weakens community representations as part of the planning consultation processes for individual development applications.
We consider that the SLAs improve the delivery of the Revised LDP objectives. Natural Resources Wales (‘NRW’) states that ‘there may be more than one role for an identified SLA: To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place / bro; To influence positive landscape planning. […]; To raise understanding and appreciation of the importance of local landscapes by communities, visitor and the wider public.’ The SLAs currently provide these roles and retaining them in the Revised LDP would better meet the LDP and ISA Objectives.
The developmental pressures on the landscape have not weakened in the time between the Current LDP adoption and the Revised LDP drafting. The Current LDP Appendix 4 assessment of SLAs specifically states in relation to the Tywi Valley, that ‘Inappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation.’ We do not see that these reasons for designation have weakened. However, if the LPA consider otherwise, then the evidence of this decision making process should be published.
Planning Policy Wales 11 (‘PPW11’) paragraphs 6.3.12 and 6.3.13 relate to the characteristics of local landscapes. These paragraphs highlight the ability for LPAs to designate SLAs. Paragraph 6.3.13 states that ‘Planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.’ Given that pressures on the landscape have not weakened and that the existing SLAs have proven weight in the planning determination process, we consider that the removal of the SLAs in the Revised LDP runs contrary to this part of PPW11.

Compatibility with Policy and Guidance
In addition to the point with regard to PPW 11 above, our view is that the SLAs are wholly compatible with the Revised LDP, the proposed Policy BHE2: Landscape Character and can be seamlessly incorporated into this policy, or alternatively, the existing policy could be retained in the Revised LDP.
NRW LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, endorses a dual approach to landscape management, in line with our suggested edits to the Revised LDP Policy BHE2: Landscape Character. On page 3 of the document, it is stated that ‘in this dual approach, all landscapes will be underpinned equally by LANDMAP […] but in addition to this, landscapes of high local importance will be specifically identified as a SLA with additional guidance being produced for these key landscapes’.
We recognise that there is potential tension between the SLA designation of Llanllwni Mountain SLA and the Cothi Valley SLA, and that these areas are also within the Pre-Assessed Area for Wind Energy in Future Wales 2040 the National Development Plan (‘NDP’). We argue that the SLA designation of these areas is not in conflict with the NDP, including Policies 17 and 18. However, we recognise that this is an area of the Revised LDP which may benefit from further exploration at Examination and we would appreciate an invitation to make representations on this issue.

2. Inadequate Evidence Base
The Issues, Vision and Options paper makes it clear that this 2018-2033 LDP is a review of the previous LDP and not a new local plan (para 1.3, page 2, Issues, Vision and Options Topic Paper, February 2023). There is a general expectation in plan making that evidence is front-loaded. As the Revised LDP revises the Current LDP, it is reasonable to expect that the entire removal of locally designated SLA from the plan should be carried out on a sound, evidence backed, basis. Statements by the LPA during the plan making process did not indicate that SLAs would be removed from the plan at Review or Preferred Strategy stages. The weakening of the landscape policies and the removal of SLAs was not revealed until the publication of the First Deposit LDP in early 2020. Prior to the publication of the First Deposit LDP, the LPA indicated that further evidence would be published if the policy were to be changed.
The 2006-2021 LDP Review Report 2018 did not raise concerns about the effectiveness of the SLA Policy, giving it a green colour coding indicating the policy target was being achieved or exceeded. The report stated in paragraph 9.141 that ‘The Plan identifies Special Landscape Areas (SLAs) within Policy EQ6. These were identified following a formal assessment of the landscape qualities of the County and are a non-statutory designation. It is noted that the policy places an emphasis on enhancement and improvement. There may be opportunities to supplement and/or review the supporting evidence for this policy and explore those wider linkages (e.g. the renewable energy policies and those design related policies).’
Further, Appendix 1 of the Review Report reviewing specific policies states that in relation to Policy EQ6 SLAs that ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy.’ This wording is a standard response to policies which were expected to be kept in the Revised LDP close to their current form. It is difficult to ascertain how the
removal of the SLAs does not constitute a fundamental change, to a degree where evidence justifying this change would reasonably be expected to be published.
Following on from the review, the Preferred Strategy was published in 2019. The Preferred Strategy gave no indication of the intention to remove the SLAs from the Deposit Plan and gave significant indication that landscape policies would remain strong within the Revised LDP. Issue 8 of the LDP issues is ‘Rich landscape or townscape qualities’; the Vision states that ‘rich cultural and environmental qualities are valued and respected’; paragraph 10.19 states that ‘the LDP will promote the principles of sustainability by: Protecting and enhancing biodiversity, townscapes and landscapes’; ‘A New Strategy – Key Components’ paragraph 10.20 states that ‘the key components of the strategy are as follows:’ one of which is to ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes’.6
Given these statements, it would not be unreasonable to expect that the SLA policy would remain in the Revised LDP, particularly given specific reference to the protection of high value landscapes. The means of recognising and protecting the areas of outstanding and high value landscapes in the LPA’s geographical area is specifically the Current LDP’s SLA policy.
Furthermore, in response to a representation made on the Preferred Strategy, the LPA stated ‘The consideration of whether any Special Landscape Areas will be identified in the Revised LDP, along with any resultant evidential facets, will be a matter for the deposit LDP.’ [our emphasis].
In our view, it is reasonable to consider that prior to the First Deposit Plan publication that the full SLA policy, or a slightly revised version of it, would remain in place in the new LDP; or that evidence would be published alongside the Deposit Plan to justify removal of the SLA policy given the LPAs statements in the Plan Review and the response to the Preferred Strategy public consultation. Therefore, given the above timeline indicates a very late decision to remove the SLAs from the Revised LDP, we question whether the decision has been carried out with robust, proportionate and credible evidence.
What evidence has been used?
At the date of this letter, the LPA have not provided information within the Plan Evidence Base, as accessed online, for the decision to remove the SLAs from the LDP; nor the evidence that the new landscape Policy BHE2: Landscape Character sufficiently delivers on the aims of the New Strategy which includes the key component to protect and enhance high-value landscapes.
Assessments which have been published by the LPA in relation to Landscape Character are due to expire when the new LDP is adopted. These comprise existing assessments of the SLA areas in Appendix 4 of the Current LDP; there is a reference to NRW’s 48 broad scale, not locally specific, National Landscape Character Areas (NLCA), and the SLAs within the Placemaking and Design SPG (adopted 2016); and consideration of landscapes in the Carmarthenshire Wind Turbine Development Landscape Sensitivity and Capacity Study, prepared by Anthony Jellard Associates.
The SLAs are removed from the Revised LDP. The Placemaking and Design SPG is not slated to be carried forward with the new Revised LDP7. The current status of the Anthony Jellard study is unclear,
6 These parts of the Preferred Strategy are carried into the Second Deposit LDP, February 2023, and are found across Chapters 5-9.
7 See Appendix 3, Second Deposit LDP 2018-2033
it is referenced within the current Wind and Solar SPG; however this SPG is not intended to be carried forward as part of the Revised LDP. The removal of these assessments is likely to leave a gap with regard to the protection and enhancement of landscapes when the new Revised LDP is adopted.
Given the anticipated expiry of these assessments, it is not credible that they can form part of an evidence base for the creation of the Revised LDP policies. No evidence has been provided that any other assessments have been carried out in forming the LPAs landscape character policy or that NRW’s LANDMAP has been utilised to inform revised policy preparation. The Revised LDP states that a Landscape Character Assessment SPG is proposed to be adopted by Summer 2025, but as no draft has been published this does not form part of the evidence base. The target Revised LDP adoption date is Autumn 2024 and with the SPG proposed for Summer 2025, this leaves a significant gap around landscape policy guidance in the interim, even if the Landscape Character SPG is published on time.
The LPAs Cabinet Member for Planning has responded to a question on the evidence base by discussing assessment of development proposals utilising information contained within NRWs LANDMAP. However, this is an existing means of assessment in the Current LDP and will be retained as a means of assessing change to landscape in the Revised LDP, as such it does not make a difference to the baseline. Notably, the question asked to the Cabinet Member for Planning was with regard to the evidence around the formation of new Policy BHE2 and the removal of the SLAs, to which she did not furnish an answer. 8
Finally, the lack of published evidence relevant to the landscape policies of the Revised LDP appears to be in conflict with paragraph 6.3.21 of PPW 11, which states ‘Planning authorities should draw upon LANDMAP in the preparation of landscape plans and assessments needed to inform development plans, SPGs and the development management process. LANDMAP assessments should be published.’ [our emphasis]
In our view, the evidence base for the Revised LDP in terms of Landscape Policy is not sufficiently substantiated and we request that this is interrogated by the Inspector appointed for the Examination.

3. Revised LDP Policies
We argue that the Revised LDP policies are substantively weaker with regard to landscape protection and enhancement than the Current LDP Policies. Comparison of similar policies in relation to placemaking, sustainability, high quality design, landscapes and features of importance, landscape character and renewable energy, between the Current LDP and the Revised LDP, show fewer mentions of the need to ‘preserve or enhance’, that development ‘must’ meet certain criteria, that development ‘will only be permitted’ if specific criteria are met, and the clear setting out of designated Special Landscape Areas with the expectation that development should enhance or improve these areas.
This is in contrast to the Revised LDP which uses wording such as ‘should relate to’, maintaining ‘overall integrity’, ‘development shall demonstrate’, that ‘development must acknowledge’ and ‘demonstrate a clear understanding’. Whilst it is acknowledged that this can be a more positive way of forming LDP policies and there are good reasons for this approach, it would be erroneous to suggest
8https://democracy.carmarthenshire.gov.wales/ieListDocuments.aspx?CId=131&MId=6351&Ver=4 [accessed 14 April 2023]
that these changes do not make the Policies easier for development to be consented and weaker in some instances. In our view, this is notably the case with regard to landscape protections and most significantly the removal of a whole policy layer designating Special Landscape Areas. With regard to landscape there is a question if the Policies as currently drafted are sufficiently robust to deliver on the Issues, Vision and Objectives of the plan, as well as key components of the Strategy.
We appreciate that Policies SP12: Placemaking and Sustainable Places and BHE2: Landscape Character, do contain some landscape protections. However, with the removal of the designated SLAs the Revised LDP remains materially weaker with regard to the protection of Carmarthenshire’s highest quality landscapes (outstanding and high value). This is especially the case prior to the publication of the promised Landscape Character SPG, and without publication of this SPG in draft form before examination it is difficult to fully consider the likely strength of these policies.

4. Specific suggested amendments to Revised LDP Policies
In addition to the objection to the removal of the SLA policy and suggestions for its reintroduction, we have the following additional comments on the Revised LDP.

Object. Strategic Policy – SP12: Placemaking and Sustainable Places
Policy point f) ‘Exhibit and demonstrate a clear understanding of the existing local landscape context, natural and built heritage, local character and sense of place.’
Proposed change to ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’
This change would deliver the key components of the New Strategy more convincingly in relation to this Policy, one of which is ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes.’ It would also deliver Strategic Objective 9 (SO9) more convincingly. SO9 aims ‘To protect and enhance the diverse character, distinctiveness, safety and vibrancy of the County’s communities by promoting a place making approach and a sense of place.’ Currently the specific phrase ‘protect and enhance’ only features in Strategic Policy SP14: Maintaining and Enhancing the Natural Environment which is only one component of the County’s diverse character. Variations of protect and enhance feature elsewhere in the written statement and there is benefit in bringing SP12 more into line with these.

Object. PSD1: Effective Design Solution: Sustainability and Placemaking. Policy point d) states ‘Quality landscapes design solutions’, this appears to be a typo where ‘landscape’ fits better. In our view, for policy point d) to work effectively, either reference to a published Landscape Character SPG, or reference to NRW LANDMAP (especially the Visual and Sensory assessment layer) should be made within this Policy or in the accompanying notes. This would benefit from explicitly stating that it applies to all development, including infrastructure, Renewable and Low Carbon developments, as well as buildings, transport, excavation sites, and smaller scale landscape proposals in the private and public realm.

Object. BHE2: Landscape Character. The use of ‘overall’ in the policy substantively weakens its protection of the landscape character. We request that this word is removed. It is unclear in the current presentation of the policy if the onus is on the applicant to identify the landscape character of the ‘local area’ through their own assessment, or if NRWs LANDMAP data is to be used, or if the
LPAs own Landscape Character SPG is to be used. This should be more explicitly set out and clarified. If the expectation is that the Landscape Character SPG is the baseline then it would be beneficial for this to be published in advance of the Revised LDPs adoption, preferably at the time of Examination. Reference to the Landscape Character Assessment should also be made in the Policy text.
It is also unclear where the key landscape views and vistas mentioned in point e. are set out, in order for them to be protected in the policy. If these are due to be identified in the Landscape Character SPG then, again, this would benefit publication prior to plan Examination.
We also request that reference to SLAs are added into this policy, as set out in section 1 of this letter.

Object. Policy CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and presumption of consent for renewable development proposals by communities, as well as those already set out for large scale wind farms. We suggest that the following are added to the policy:
d. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
e. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
f. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
g. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Policy CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and explicit presumption of consent for renewable development proposals from communities. We suggest that the following are added to the policy:
b. [add]… , including SLAs;
g. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
h. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
j. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
k. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Table 9 Resource Summary for Renewable Electricity. The Onshore Wind Target to deliver 588.5 MW of additional installed capacity by 2033 is in our view unrealistic given there has not been a call for sites for wind power. By our calculations, extrapolating from the evidence base document, AECOM Renewable and Low Carbon Energy Assessment Section 4.3, delivery of this target may require 75% of the area unconstrained by features such as buildings, roads and rivers in the Pre-Assessed Area in north Carmarthenshire to be developed for onshore wind.9 Given the mix of landowners and small scale farms across this area, delivery of the target may be challenging without large scale land purchases, which would not be feasible or desirable for smaller scale community wind developers. This policy is likely to result in more large scale multi-national corporation wind farm developments across Carmarthenshire. This is notwithstanding the scale of significant adverse impacts, including cumulative impacts, on the landscape a target like this will create.

Object. Policy CCH6: Renewable and Low Carbon Energy in New Developments. This policy could be more ambitious helping to deliver Net Zero targets by requiring all new housing or commercial development to fit solar panels to roofs, unless it is demonstrated by the applicant that to do so would not be viable, or if by doing so would conflict with other policies in the Revised LDP (such as built heritage, townscape or landscape policies).
Object. Policy CCH7: Climate Change – Forest, Woodland and Tree Planting. Specific reference should be made in the policy text to native trees and that planting schemes much be appropriate to the cultural and ecological character of the locality. This is referenced in paragraph 11.534, however due to the large ecological and landscape impacts that can arise from non-native tree planting, in our view the wording should be directly within the policy text.
The AECOM assessment estimates that the Pre-Assessed Area in Carmarthenshire, identified in Future Wales 2040, covers an area of 687 km2. The report assumes a maximum of 5 2MW turbines per 1km2 of land. Applications for new onshore wind at scale is more likely to be focused within the Pre-Assessed Areas due to the favourable planning framework for these locations. The Revised LDP target for installed capacity is an additional 588.5 MW, which using AECOM’s calculations would need to cover a land area of 58.85 Km2, or, 14,542 acres, equivalent to 8.5% of the Pre-Assessed Area. Taking into account the expected delivery of the remaining capacity in the former TAN 8 SSA, there is the expectation that 54.83 km2 will be delivered on a total possible unconstrained area of 73.1km2, or 75% of the unconstrained land in the Pre-Assessed Area. For the purposes of the AECOM study the constrains are National Parks, Natura 2000 sites, Buildings, Roads, Rivers, the TAN8 SSA and Topple Distance buffers applied to buildings, roads and rivers. Calculations taken from data within page 29 and 30 of the AECOM Renewable and Low Carbon Energy Assessment published in the LDP Evidence Base.

5. Adequacy of the Integrated Sustainability Appraisal assessment as it concerns Landscape
We are raising substantive concerns with regard to the robustness of the assessment carried out in the Integrated Sustainability Appraisal (‘ISA’).
The Sustainability Appraisal Scoping Report (published July 2018) set out the parameters of the Sustainability Appraisal, identifying Sustainability Issues and Opportunities, Sustainability Assessment Objectives and Decision Making Influences. This identified Landscape as number 9 of a total of 15 equal issues. Issue 9 is set out as follows: ‘There are several sites designated as of landscape or townscape value within the county. These features need to be protected, and where possible enhanced.’ In the Decision Making Influences, the question, ‘Will the LDP have a positive or negative impact on designated landscapes?’ is posed.
Linking these two quotes is the specific mention of ‘designated landscapes’, not statutory designated, nor ‘Designated’ noun. Special Landscape Areas are considered designated landscapes in this definition. This is the case in comparable LPAs in Wales, PPW11 para 6.3.12 refers to ‘the designation of Special Landscape Areas’ and the Current LDP Policy EQ6 states that ‘Special Landscape Areas are designated…’. Thus, references to designated landscapes in the Sustainability Appraisal, must take into account local as well as statutory designations, including SLAs. The question ‘will the LDP have a positive or negative impact on designated landscapes?’ and that the Revised LDP removes some of these designated landscapes, is an important consideration for the assessments in the Sustainability Appraisal.
Sustainable development is defined in the Well-being of Future Generations (Wales) Act 2015 as the ‘process of improving the economic, social, environmental, and cultural wellbeing of Wales by taking action.’ A change to the development plan which removes some designated landscapes should be considered carefully and assessed robustly on the terms that those designations have been removed, to demonstrate that the change is not an impairment to sustainable development.
Turning to the latest version of the ISA, published February 2023. The prediction of the effects of the plan involves identifying changes to the environmental baseline. The baseline for sustainability objective ISA9 – Landscape is set out in ISA Appendix B (pp.61-67) with the other baseline assessments. This baseline constitutes an introductory paragraph explaining that the Brecon Beacons National Park sits outside the LDP boundaries, along with a copy of the Current LDP Appendix 4 Special Landscape Areas assessment in full, then proceeds to state the ‘Predicted effect without implementation of the LDP’.
In our view, this assessment of predicted effects has been carried out incorrectly. The predicted effects mention protected habitat and species and biodiversity, which are assessed under ISA2 Biodiversity, and fails to comment adequately on changes to landscape as a characteristic in and of itself. Crucially, this assessment fails to note that the locally designated landscapes, SLAs, will continue to be in effect once the Plan period expires. This is, in our opinion, a substantive omission especially given that the baseline text is comprised of Special Landscape Area descriptions and assessing areas noted as being ‘worthy of the protection that the designation of SLAs provides.’
Section 4 of the ISA sets out a summary of the environmental baseline and predicted effects, noting that the future baseline for landscape is declining. This summary has a stronger summarisation of the likely effect on landscape than that set out in the ISA Appendix and states clearly that ‘landscape
protection measures should be strengthened’. As this assessment is provided on the basis that the Current LDP continues to remain in place, the need to have measures strengthening landscape protection must be considered to be in addition to those already in place, including the designated SLAs.
As the ISA needs to take into account the effect of the Revised LDP being adopted, against the baseline of the Current LDP remaining, some assessment of the removal of the local designated SLAs would be expected in the ISA. However, Special Landscape Areas are not mentioned in the main text of the ISA, nor the ISA Appendices, outside of the Baseline and list of Abbreviations. Failure to take account of the loss of this designation from the LDP is, in our view, a major error and questions the credibility of the appraisal of predicted effects on ISA9 – Landscape, throughout the ISA document and brings into question the soundness of the Plan.
There are also other concerning errors and omissions. One example is the review of SP16: Climate Change and associated specific policies CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas and CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas, in Appendix F and G. The appraisal considers the effects on landscape to be ‘neutral’ and with ‘positive and negative effects’. This is not credible given the scale of change proposed to the landscape on the basis of the targets for new wind power generation by 2033, and this target set in the context of the removal of the SLAs from the LDP. A negative effect should be identified. Whether the negative effect should be acceptable on balance is a test that is separate to this specific part of the ISA. The ISA should credibly take into account the high magnitude of the changes, the Plan’s intention to remove the SLA designated landscapes, and the effect characteristics including the scale of cumulative effects, their special extent and their probability; all of which is high impact and likely.
Another example is the review of SP14: Maintaining and Enhancing of the Natural Environment, where the Appraisal comments against ISA9 state that ‘This policy directly refers to the protection and enhancement of Carmarthenshire’s landscape’ (ISA Appendix F, p.46). This policy does not do as the Appraisal states. The protection and enhancement is directed at the natural environment more generally, it is not a policy linked back to ISA9 in its monitoring objectives, and points more generally to a confusion throughout the Revised LDP between the character of landscape as a visual and integral whole vs smaller scale aspects which make up the natural environment, which are nonetheless important, but fundamentally different.

6. Conclusion
The removal of the SLA designations from the LDP cannot but be an adverse change. The failure to take account of this substantive change and substantiate why this is not a significant weakening of the LDP from its current form is of great concern.
We encourage Carmarthenshire’s Forward Planning Department to set this right before the LDP is examined and re-introduce the SLA designations into the Plan to address the issues raised in this letter, re-providing a substantive part of the means to protect and enhance our outstanding and high valued landscapes for future generations.
We re-iterate our request to make representations on the LDP examination on the subject of landscape, with regard to relevant policies.
We appreciate your, and the appointed Planning Inspector’s, consideration of this letter.

The following changes are suggested to the policy:
b. [add]… , including SLAs;
g. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
h. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
j. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
k. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Carmarthenshire Residents’ Action Group: Representations to the public consultation of the Second Deposit Revised Carmarthenshire Local Development Plan 2018-2033 and the Integrated Sustainability Assessment
We, Carmarthenshire Residents’ Action Group, are responding to the public consultation on the Carmarthenshire Local Development Plan 2018-2033 (Second Deposit) (‘Revised LDP’) to raise concerns with regard to the plan making process in relation to landscape(s) within the LDP’s geographical area. We request several changes to the plan on the basis that we consider the plan not to be sound and request the opportunity to make representations during the examination process.1
This letter contains a series of comments and objections in relation to landscape policies, and approach to policy making with regard to landscapes, within Carmarthenshire’s Revised LDP drafting process, including the Integrated Sustainability Appraisal (‘ISA’).
This letter also consolidates a series of comments made via the online comments portal on the proposed Revised LDP. It refers Carmarthenshire’s Forward Planning Department and, in due course, the appointed Examination Planning Inspector, to Carmarthenshire Residents Action Group’s petition to maintain the Special Landscape Areas within the 2018-2033 LDP. This petition has raised 438 signatures, details of which are contained within Appendix 1 of this letter.
A strong objection is raised, backed by significant local support, to the removal of Carmarthenshire’s locally designated Special Landscape Areas within the Revised LDP. Objections are also raised with regard to the replacement landscape related policies in the second Deposit Revised LDP with materially weakened policies compared to the existing 2006-2021 LDP (‘Current LDP’). The letter also raises concerns with regard to the assessment carried out in the ISA as it pertains to the Sustainability Objective on Landscape.
Our representations are set out as follows:
1. Objection to the removal of Special Landscape Areas from the Revised LDP;
2. Inadequate Evidence Base;
3. Revised LDP Policies;
4. Specific suggested amendments to Revised LDP Policies;
5. Adequacy of the assessment Integrated Sustainability Appraisal as it concerns Landscape; and,
6. Conclusion
1 It is noted that Welsh Government Local development plan examinations: procedure guidance (28 November 2022) states in paragraph 1.7 that ‘Those who have sought changes to the submitted plan or plan revisions and have indicated that they would like to speak must be invited to the hearings.’

1. Objection to the removal of the Special Landscape Areas from the Revised LDP
‘The use of non-statutory designations such as Special Landscape Areas to protect areas of landscape value has long been a policy tool within the UK planning system. They have been seen by local planning authorities as a means of protecting sensitive landscapes and in developing an understanding and awareness of those features and characteristics that give a locality its sense of place.’2
Carmarthenshire’s 18 Special Landscape Areas (‘SLAs’) listed under Policy EQ6 in the Current LDP have not been carried forward into the Revised LDP.
We recognise that SLAs are a local non-statutory designation, however these areas are an acknowledged designation which carries weight within the Current LDP as a standalone policy. SLAs are also acknowledged and given weight within neighbouring Local Planning Authority (‘LPA’) LDPs.3 The weight given to the SLA designations is recognised across Appeal decisions by the Planning Inspectorate and in Planning Inspectorate recommendations with regard to Development Consent Order applications.4
We object to the Second Deposit LDP on the basis of the removal of the SLAs and request that SLAs are reintroduced into the Revised LDP, either as a standalone policy or that provision is made within the new Policy BHE2: Landscape Character.
This could be achieved by an amendment to Policy BHE2: Landscape Character to add wording as follows:
Proposals must take account of Carmarthenshire’s locally designated Special Landscape Areas (as set out in Appendix X (Appendix 4 of the Current LDP) and shown on the Policies Map). Development proposals will only be permitted where there is no significant adverse impact, including cumulative impact, on the character and quality of the landscape. Development proposals should aim to protect and enhance the features for which the SLA has been designated.
Where appropriate, a Landscape Impact Assessment will be required to assess and justify the impact of the development on Landscape Character and/or the designated area.
In exceptional circumstances, where development is necessary and could result in a significant landscape impact, appropriate mitigation and enhancement measures should be provided, including the undergrounding of associated infrastructure where possible.
Our suggested wording is similar to the City of Swansea LDP which was successfully adopted following Examination in February 2019.5 Appendix 4 of the Current LDP would remain relevant to the Revised LDP and could be brought across, with edits as necessary to increase the robustness of the assessment of the area’s character. SLAs could be added back into the Policies Map, with minor boundary edits as necessary.
2 Bridgend County Borough Council, Designation of Special Landscape Areas, March 2010
3 City of Swansea LDP (adopted February 2019), Ceredigion LDP (adopted 2013)
4 Including, but not solely, APP/M6825/A/12/2189697, APP/M6825/X/13/515763 & APP/M6825/X/13/515764; and Brechfa Forest Connection DCO application ref EN020016;
5 https://www.swansea.gov.uk/article/9914/Swansea-Local-Development-Plan-2010-2025-LDP

Reasons for retention
The retention of the SLAs in the Revised LDP is well supported, with 438 people resident within the county signing Carmarthenshire Residents’ Action Group’s petition.
We argue that the retention of the SLAs is important to fulfil to objectives of the LDP and question if the SLAs are removed if the plan meets its Sustainability Objectives on Landscape set against the baseline criteria. We do not consider that a robust, proportionate and credible case has been set out by the LPA for the removal of this landscape designation. We consider that the removal of the SLAs significantly weakens the Revised LDP’s SO9 regarding sense of place and impacts Carmarthenshire’s planning framework in terms of delivering on sustainable development on the basis of the Well-being of Future Generations Act.
By designating SLAs it is easier for communities, visitors and tourists to engage with the highest value landscapes of Carmarthenshire. The SLA designations are reflective of the local value communities place on these landscapes in a manner not captured in the replacement Policy BHE2: Landscape Character. This revised policy places too much reliance on LANDMAP assessment. Whilst LANDMAP is an excellent tool for those engaged with the planning process, it is harder to engage with than the specifically designated SLAs which have clear and geographical boundaries capturing the outstanding and high quality landscapes of Carmarthenshire. The removal of the SLAs, and their removal from the Polices Map, invariably makes it makes it harder for specific communities and the wider public to engage with the LDP and weakens community representations as part of the planning consultation processes for individual development applications.
We consider that the SLAs improve the delivery of the Revised LDP objectives. Natural Resources Wales (‘NRW’) states that ‘there may be more than one role for an identified SLA: To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place / bro; To influence positive landscape planning. […]; To raise understanding and appreciation of the importance of local landscapes by communities, visitor and the wider public.’ The SLAs currently provide these roles and retaining them in the Revised LDP would better meet the LDP and ISA Objectives.
The developmental pressures on the landscape have not weakened in the time between the Current LDP adoption and the Revised LDP drafting. The Current LDP Appendix 4 assessment of SLAs specifically states in relation to the Tywi Valley, that ‘Inappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation.’ We do not see that these reasons for designation have weakened. However, if the LPA consider otherwise, then the evidence of this decision making process should be published.
Planning Policy Wales 11 (‘PPW11’) paragraphs 6.3.12 and 6.3.13 relate to the characteristics of local landscapes. These paragraphs highlight the ability for LPAs to designate SLAs. Paragraph 6.3.13 states that ‘Planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.’ Given that pressures on the landscape have not weakened and that the existing SLAs have proven weight in the planning determination process, we consider that the removal of the SLAs in the Revised LDP runs contrary to this part of PPW11.

Compatibility with Policy and Guidance
In addition to the point with regard to PPW 11 above, our view is that the SLAs are wholly compatible with the Revised LDP, the proposed Policy BHE2: Landscape Character and can be seamlessly incorporated into this policy, or alternatively, the existing policy could be retained in the Revised LDP.
NRW LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, endorses a dual approach to landscape management, in line with our suggested edits to the Revised LDP Policy BHE2: Landscape Character. On page 3 of the document, it is stated that ‘in this dual approach, all landscapes will be underpinned equally by LANDMAP […] but in addition to this, landscapes of high local importance will be specifically identified as a SLA with additional guidance being produced for these key landscapes’.
We recognise that there is potential tension between the SLA designation of Llanllwni Mountain SLA and the Cothi Valley SLA, and that these areas are also within the Pre-Assessed Area for Wind Energy in Future Wales 2040 the National Development Plan (‘NDP’). We argue that the SLA designation of these areas is not in conflict with the NDP, including Policies 17 and 18. However, we recognise that this is an area of the Revised LDP which may benefit from further exploration at Examination and we would appreciate an invitation to make representations on this issue.

2. Inadequate Evidence Base
The Issues, Vision and Options paper makes it clear that this 2018-2033 LDP is a review of the previous LDP and not a new local plan (para 1.3, page 2, Issues, Vision and Options Topic Paper, February 2023). There is a general expectation in plan making that evidence is front-loaded. As the Revised LDP revises the Current LDP, it is reasonable to expect that the entire removal of locally designated SLA from the plan should be carried out on a sound, evidence backed, basis. Statements by the LPA during the plan making process did not indicate that SLAs would be removed from the plan at Review or Preferred Strategy stages. The weakening of the landscape policies and the removal of SLAs was not revealed until the publication of the First Deposit LDP in early 2020. Prior to the publication of the First Deposit LDP, the LPA indicated that further evidence would be published if the policy were to be changed.
The 2006-2021 LDP Review Report 2018 did not raise concerns about the effectiveness of the SLA Policy, giving it a green colour coding indicating the policy target was being achieved or exceeded. The report stated in paragraph 9.141 that ‘The Plan identifies Special Landscape Areas (SLAs) within Policy EQ6. These were identified following a formal assessment of the landscape qualities of the County and are a non-statutory designation. It is noted that the policy places an emphasis on enhancement and improvement. There may be opportunities to supplement and/or review the supporting evidence for this policy and explore those wider linkages (e.g. the renewable energy policies and those design related policies).’
Further, Appendix 1 of the Review Report reviewing specific policies states that in relation to Policy EQ6 SLAs that ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy.’ This wording is a standard response to policies which were expected to be kept in the Revised LDP close to their current form. It is difficult to ascertain how the
removal of the SLAs does not constitute a fundamental change, to a degree where evidence justifying this change would reasonably be expected to be published.
Following on from the review, the Preferred Strategy was published in 2019. The Preferred Strategy gave no indication of the intention to remove the SLAs from the Deposit Plan and gave significant indication that landscape policies would remain strong within the Revised LDP. Issue 8 of the LDP issues is ‘Rich landscape or townscape qualities’; the Vision states that ‘rich cultural and environmental qualities are valued and respected’; paragraph 10.19 states that ‘the LDP will promote the principles of sustainability by: Protecting and enhancing biodiversity, townscapes and landscapes’; ‘A New Strategy – Key Components’ paragraph 10.20 states that ‘the key components of the strategy are as follows:’ one of which is to ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes’.6
Given these statements, it would not be unreasonable to expect that the SLA policy would remain in the Revised LDP, particularly given specific reference to the protection of high value landscapes. The means of recognising and protecting the areas of outstanding and high value landscapes in the LPA’s geographical area is specifically the Current LDP’s SLA policy.
Furthermore, in response to a representation made on the Preferred Strategy, the LPA stated ‘The consideration of whether any Special Landscape Areas will be identified in the Revised LDP, along with any resultant evidential facets, will be a matter for the deposit LDP.’ [our emphasis].
In our view, it is reasonable to consider that prior to the First Deposit Plan publication that the full SLA policy, or a slightly revised version of it, would remain in place in the new LDP; or that evidence would be published alongside the Deposit Plan to justify removal of the SLA policy given the LPAs statements in the Plan Review and the response to the Preferred Strategy public consultation. Therefore, given the above timeline indicates a very late decision to remove the SLAs from the Revised LDP, we question whether the decision has been carried out with robust, proportionate and credible evidence.
What evidence has been used?
At the date of this letter, the LPA have not provided information within the Plan Evidence Base, as accessed online, for the decision to remove the SLAs from the LDP; nor the evidence that the new landscape Policy BHE2: Landscape Character sufficiently delivers on the aims of the New Strategy which includes the key component to protect and enhance high-value landscapes.
Assessments which have been published by the LPA in relation to Landscape Character are due to expire when the new LDP is adopted. These comprise existing assessments of the SLA areas in Appendix 4 of the Current LDP; there is a reference to NRW’s 48 broad scale, not locally specific, National Landscape Character Areas (NLCA), and the SLAs within the Placemaking and Design SPG (adopted 2016); and consideration of landscapes in the Carmarthenshire Wind Turbine Development Landscape Sensitivity and Capacity Study, prepared by Anthony Jellard Associates.
The SLAs are removed from the Revised LDP. The Placemaking and Design SPG is not slated to be carried forward with the new Revised LDP7. The current status of the Anthony Jellard study is unclear,
6 These parts of the Preferred Strategy are carried into the Second Deposit LDP, February 2023, and are found across Chapters 5-9.
7 See Appendix 3, Second Deposit LDP 2018-2033
it is referenced within the current Wind and Solar SPG; however this SPG is not intended to be carried forward as part of the Revised LDP. The removal of these assessments is likely to leave a gap with regard to the protection and enhancement of landscapes when the new Revised LDP is adopted.
Given the anticipated expiry of these assessments, it is not credible that they can form part of an evidence base for the creation of the Revised LDP policies. No evidence has been provided that any other assessments have been carried out in forming the LPAs landscape character policy or that NRW’s LANDMAP has been utilised to inform revised policy preparation. The Revised LDP states that a Landscape Character Assessment SPG is proposed to be adopted by Summer 2025, but as no draft has been published this does not form part of the evidence base. The target Revised LDP adoption date is Autumn 2024 and with the SPG proposed for Summer 2025, this leaves a significant gap around landscape policy guidance in the interim, even if the Landscape Character SPG is published on time.
The LPAs Cabinet Member for Planning has responded to a question on the evidence base by discussing assessment of development proposals utilising information contained within NRWs LANDMAP. However, this is an existing means of assessment in the Current LDP and will be retained as a means of assessing change to landscape in the Revised LDP, as such it does not make a difference to the baseline. Notably, the question asked to the Cabinet Member for Planning was with regard to the evidence around the formation of new Policy BHE2 and the removal of the SLAs, to which she did not furnish an answer. 8
Finally, the lack of published evidence relevant to the landscape policies of the Revised LDP appears to be in conflict with paragraph 6.3.21 of PPW 11, which states ‘Planning authorities should draw upon LANDMAP in the preparation of landscape plans and assessments needed to inform development plans, SPGs and the development management process. LANDMAP assessments should be published.’ [our emphasis]
In our view, the evidence base for the Revised LDP in terms of Landscape Policy is not sufficiently substantiated and we request that this is interrogated by the Inspector appointed for the Examination.

3. Revised LDP Policies
We argue that the Revised LDP policies are substantively weaker with regard to landscape protection and enhancement than the Current LDP Policies. Comparison of similar policies in relation to placemaking, sustainability, high quality design, landscapes and features of importance, landscape character and renewable energy, between the Current LDP and the Revised LDP, show fewer mentions of the need to ‘preserve or enhance’, that development ‘must’ meet certain criteria, that development ‘will only be permitted’ if specific criteria are met, and the clear setting out of designated Special Landscape Areas with the expectation that development should enhance or improve these areas.
This is in contrast to the Revised LDP which uses wording such as ‘should relate to’, maintaining ‘overall integrity’, ‘development shall demonstrate’, that ‘development must acknowledge’ and ‘demonstrate a clear understanding’. Whilst it is acknowledged that this can be a more positive way of forming LDP policies and there are good reasons for this approach, it would be erroneous to suggest
8https://democracy.carmarthenshire.gov.wales/ieListDocuments.aspx?CId=131&MId=6351&Ver=4 [accessed 14 April 2023]
that these changes do not make the Policies easier for development to be consented and weaker in some instances. In our view, this is notably the case with regard to landscape protections and most significantly the removal of a whole policy layer designating Special Landscape Areas. With regard to landscape there is a question if the Policies as currently drafted are sufficiently robust to deliver on the Issues, Vision and Objectives of the plan, as well as key components of the Strategy.
We appreciate that Policies SP12: Placemaking and Sustainable Places and BHE2: Landscape Character, do contain some landscape protections. However, with the removal of the designated SLAs the Revised LDP remains materially weaker with regard to the protection of Carmarthenshire’s highest quality landscapes (outstanding and high value). This is especially the case prior to the publication of the promised Landscape Character SPG, and without publication of this SPG in draft form before examination it is difficult to fully consider the likely strength of these policies.

4. Specific suggested amendments to Revised LDP Policies
In addition to the objection to the removal of the SLA policy and suggestions for its reintroduction, we have the following additional comments on the Revised LDP.

Object. Strategic Policy – SP12: Placemaking and Sustainable Places
Policy point f) ‘Exhibit and demonstrate a clear understanding of the existing local landscape context, natural and built heritage, local character and sense of place.’
Proposed change to ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’
This change would deliver the key components of the New Strategy more convincingly in relation to this Policy, one of which is ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes.’ It would also deliver Strategic Objective 9 (SO9) more convincingly. SO9 aims ‘To protect and enhance the diverse character, distinctiveness, safety and vibrancy of the County’s communities by promoting a place making approach and a sense of place.’ Currently the specific phrase ‘protect and enhance’ only features in Strategic Policy SP14: Maintaining and Enhancing the Natural Environment which is only one component of the County’s diverse character. Variations of protect and enhance feature elsewhere in the written statement and there is benefit in bringing SP12 more into line with these.

Object. PSD1: Effective Design Solution: Sustainability and Placemaking. Policy point d) states ‘Quality landscapes design solutions’, this appears to be a typo where ‘landscape’ fits better. In our view, for policy point d) to work effectively, either reference to a published Landscape Character SPG, or reference to NRW LANDMAP (especially the Visual and Sensory assessment layer) should be made within this Policy or in the accompanying notes. This would benefit from explicitly stating that it applies to all development, including infrastructure, Renewable and Low Carbon developments, as well as buildings, transport, excavation sites, and smaller scale landscape proposals in the private and public realm.

Object. BHE2: Landscape Character. The use of ‘overall’ in the policy substantively weakens its protection of the landscape character. We request that this word is removed. It is unclear in the current presentation of the policy if the onus is on the applicant to identify the landscape character of the ‘local area’ through their own assessment, or if NRWs LANDMAP data is to be used, or if the
LPAs own Landscape Character SPG is to be used. This should be more explicitly set out and clarified. If the expectation is that the Landscape Character SPG is the baseline then it would be beneficial for this to be published in advance of the Revised LDPs adoption, preferably at the time of Examination. Reference to the Landscape Character Assessment should also be made in the Policy text.
It is also unclear where the key landscape views and vistas mentioned in point e. are set out, in order for them to be protected in the policy. If these are due to be identified in the Landscape Character SPG then, again, this would benefit publication prior to plan Examination.
We also request that reference to SLAs are added into this policy, as set out in section 1 of this letter.

Object. Policy CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and presumption of consent for renewable development proposals by communities, as well as those already set out for large scale wind farms. We suggest that the following are added to the policy:
d. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
e. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
f. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
g. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Policy CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and explicit presumption of consent for renewable development proposals from communities. We suggest that the following are added to the policy:
b. [add]… , including SLAs;
g. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
h. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
j. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
k. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Table 9 Resource Summary for Renewable Electricity. The Onshore Wind Target to deliver 588.5 MW of additional installed capacity by 2033 is in our view unrealistic given there has not been a call for sites for wind power. By our calculations, extrapolating from the evidence base document, AECOM Renewable and Low Carbon Energy Assessment Section 4.3, delivery of this target may require 75% of the area unconstrained by features such as buildings, roads and rivers in the Pre-Assessed Area in north Carmarthenshire to be developed for onshore wind.9 Given the mix of landowners and small scale farms across this area, delivery of the target may be challenging without large scale land purchases, which would not be feasible or desirable for smaller scale community wind developers. This policy is likely to result in more large scale multi-national corporation wind farm developments across Carmarthenshire. This is notwithstanding the scale of significant adverse impacts, including cumulative impacts, on the landscape a target like this will create.

Object. Policy CCH6: Renewable and Low Carbon Energy in New Developments. This policy could be more ambitious helping to deliver Net Zero targets by requiring all new housing or commercial development to fit solar panels to roofs, unless it is demonstrated by the applicant that to do so would not be viable, or if by doing so would conflict with other policies in the Revised LDP (such as built heritage, townscape or landscape policies).
Object. Policy CCH7: Climate Change – Forest, Woodland and Tree Planting. Specific reference should be made in the policy text to native trees and that planting schemes much be appropriate to the cultural and ecological character of the locality. This is referenced in paragraph 11.534, however due to the large ecological and landscape impacts that can arise from non-native tree planting, in our view the wording should be directly within the policy text.
The AECOM assessment estimates that the Pre-Assessed Area in Carmarthenshire, identified in Future Wales 2040, covers an area of 687 km2. The report assumes a maximum of 5 2MW turbines per 1km2 of land. Applications for new onshore wind at scale is more likely to be focused within the Pre-Assessed Areas due to the favourable planning framework for these locations. The Revised LDP target for installed capacity is an additional 588.5 MW, which using AECOM’s calculations would need to cover a land area of 58.85 Km2, or, 14,542 acres, equivalent to 8.5% of the Pre-Assessed Area. Taking into account the expected delivery of the remaining capacity in the former TAN 8 SSA, there is the expectation that 54.83 km2 will be delivered on a total possible unconstrained area of 73.1km2, or 75% of the unconstrained land in the Pre-Assessed Area. For the purposes of the AECOM study the constrains are National Parks, Natura 2000 sites, Buildings, Roads, Rivers, the TAN8 SSA and Topple Distance buffers applied to buildings, roads and rivers. Calculations taken from data within page 29 and 30 of the AECOM Renewable and Low Carbon Energy Assessment published in the LDP Evidence Base.

5. Adequacy of the Integrated Sustainability Appraisal assessment as it concerns Landscape
We are raising substantive concerns with regard to the robustness of the assessment carried out in the Integrated Sustainability Appraisal (‘ISA’).
The Sustainability Appraisal Scoping Report (published July 2018) set out the parameters of the Sustainability Appraisal, identifying Sustainability Issues and Opportunities, Sustainability Assessment Objectives and Decision Making Influences. This identified Landscape as number 9 of a total of 15 equal issues. Issue 9 is set out as follows: ‘There are several sites designated as of landscape or townscape value within the county. These features need to be protected, and where possible enhanced.’ In the Decision Making Influences, the question, ‘Will the LDP have a positive or negative impact on designated landscapes?’ is posed.
Linking these two quotes is the specific mention of ‘designated landscapes’, not statutory designated, nor ‘Designated’ noun. Special Landscape Areas are considered designated landscapes in this definition. This is the case in comparable LPAs in Wales, PPW11 para 6.3.12 refers to ‘the designation of Special Landscape Areas’ and the Current LDP Policy EQ6 states that ‘Special Landscape Areas are designated…’. Thus, references to designated landscapes in the Sustainability Appraisal, must take into account local as well as statutory designations, including SLAs. The question ‘will the LDP have a positive or negative impact on designated landscapes?’ and that the Revised LDP removes some of these designated landscapes, is an important consideration for the assessments in the Sustainability Appraisal.
Sustainable development is defined in the Well-being of Future Generations (Wales) Act 2015 as the ‘process of improving the economic, social, environmental, and cultural wellbeing of Wales by taking action.’ A change to the development plan which removes some designated landscapes should be considered carefully and assessed robustly on the terms that those designations have been removed, to demonstrate that the change is not an impairment to sustainable development.
Turning to the latest version of the ISA, published February 2023. The prediction of the effects of the plan involves identifying changes to the environmental baseline. The baseline for sustainability objective ISA9 – Landscape is set out in ISA Appendix B (pp.61-67) with the other baseline assessments. This baseline constitutes an introductory paragraph explaining that the Brecon Beacons National Park sits outside the LDP boundaries, along with a copy of the Current LDP Appendix 4 Special Landscape Areas assessment in full, then proceeds to state the ‘Predicted effect without implementation of the LDP’.
In our view, this assessment of predicted effects has been carried out incorrectly. The predicted effects mention protected habitat and species and biodiversity, which are assessed under ISA2 Biodiversity, and fails to comment adequately on changes to landscape as a characteristic in and of itself. Crucially, this assessment fails to note that the locally designated landscapes, SLAs, will continue to be in effect once the Plan period expires. This is, in our opinion, a substantive omission especially given that the baseline text is comprised of Special Landscape Area descriptions and assessing areas noted as being ‘worthy of the protection that the designation of SLAs provides.’
Section 4 of the ISA sets out a summary of the environmental baseline and predicted effects, noting that the future baseline for landscape is declining. This summary has a stronger summarisation of the likely effect on landscape than that set out in the ISA Appendix and states clearly that ‘landscape
protection measures should be strengthened’. As this assessment is provided on the basis that the Current LDP continues to remain in place, the need to have measures strengthening landscape protection must be considered to be in addition to those already in place, including the designated SLAs.
As the ISA needs to take into account the effect of the Revised LDP being adopted, against the baseline of the Current LDP remaining, some assessment of the removal of the local designated SLAs would be expected in the ISA. However, Special Landscape Areas are not mentioned in the main text of the ISA, nor the ISA Appendices, outside of the Baseline and list of Abbreviations. Failure to take account of the loss of this designation from the LDP is, in our view, a major error and questions the credibility of the appraisal of predicted effects on ISA9 – Landscape, throughout the ISA document and brings into question the soundness of the Plan.
There are also other concerning errors and omissions. One example is the review of SP16: Climate Change and associated specific policies CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas and CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas, in Appendix F and G. The appraisal considers the effects on landscape to be ‘neutral’ and with ‘positive and negative effects’. This is not credible given the scale of change proposed to the landscape on the basis of the targets for new wind power generation by 2033, and this target set in the context of the removal of the SLAs from the LDP. A negative effect should be identified. Whether the negative effect should be acceptable on balance is a test that is separate to this specific part of the ISA. The ISA should credibly take into account the high magnitude of the changes, the Plan’s intention to remove the SLA designated landscapes, and the effect characteristics including the scale of cumulative effects, their special extent and their probability; all of which is high impact and likely.
Another example is the review of SP14: Maintaining and Enhancing of the Natural Environment, where the Appraisal comments against ISA9 state that ‘This policy directly refers to the protection and enhancement of Carmarthenshire’s landscape’ (ISA Appendix F, p.46). This policy does not do as the Appraisal states. The protection and enhancement is directed at the natural environment more generally, it is not a policy linked back to ISA9 in its monitoring objectives, and points more generally to a confusion throughout the Revised LDP between the character of landscape as a visual and integral whole vs smaller scale aspects which make up the natural environment, which are nonetheless important, but fundamentally different.

6. Conclusion
The removal of the SLA designations from the LDP cannot but be an adverse change. The failure to take account of this substantive change and substantiate why this is not a significant weakening of the LDP from its current form is of great concern.
We encourage Carmarthenshire’s Forward Planning Department to set this right before the LDP is examined and re-introduce the SLA designations into the Plan to address the issues raised in this letter, re-providing a substantive part of the means to protect and enhance our outstanding and high valued landscapes for future generations.
We re-iterate our request to make representations on the LDP examination on the subject of landscape, with regard to relevant policies.
We appreciate your, and the appointed Planning Inspector’s, consideration of this letter.

See suggestion in summary above.

Carmarthenshire Residents’ Action Group: Representations to the public consultation of the Second Deposit Revised Carmarthenshire Local Development Plan 2018-2033 and the Integrated Sustainability Assessment
We, Carmarthenshire Residents’ Action Group, are responding to the public consultation on the Carmarthenshire Local Development Plan 2018-2033 (Second Deposit) (‘Revised LDP’) to raise concerns with regard to the plan making process in relation to landscape(s) within the LDP’s geographical area. We request several changes to the plan on the basis that we consider the plan not to be sound and request the opportunity to make representations during the examination process.1
This letter contains a series of comments and objections in relation to landscape policies, and approach to policy making with regard to landscapes, within Carmarthenshire’s Revised LDP drafting process, including the Integrated Sustainability Appraisal (‘ISA’).
This letter also consolidates a series of comments made via the online comments portal on the proposed Revised LDP. It refers Carmarthenshire’s Forward Planning Department and, in due course, the appointed Examination Planning Inspector, to Carmarthenshire Residents Action Group’s petition to maintain the Special Landscape Areas within the 2018-2033 LDP. This petition has raised 438 signatures, details of which are contained within Appendix 1 of this letter.
A strong objection is raised, backed by significant local support, to the removal of Carmarthenshire’s locally designated Special Landscape Areas within the Revised LDP. Objections are also raised with regard to the replacement landscape related policies in the second Deposit Revised LDP with materially weakened policies compared to the existing 2006-2021 LDP (‘Current LDP’). The letter also raises concerns with regard to the assessment carried out in the ISA as it pertains to the Sustainability Objective on Landscape.
Our representations are set out as follows:
1. Objection to the removal of Special Landscape Areas from the Revised LDP;
2. Inadequate Evidence Base;
3. Revised LDP Policies;
4. Specific suggested amendments to Revised LDP Policies;
5. Adequacy of the assessment Integrated Sustainability Appraisal as it concerns Landscape; and,
6. Conclusion
1 It is noted that Welsh Government Local development plan examinations: procedure guidance (28 November 2022) states in paragraph 1.7 that ‘Those who have sought changes to the submitted plan or plan revisions and have indicated that they would like to speak must be invited to the hearings.’

1. Objection to the removal of the Special Landscape Areas from the Revised LDP
‘The use of non-statutory designations such as Special Landscape Areas to protect areas of landscape value has long been a policy tool within the UK planning system. They have been seen by local planning authorities as a means of protecting sensitive landscapes and in developing an understanding and awareness of those features and characteristics that give a locality its sense of place.’2
Carmarthenshire’s 18 Special Landscape Areas (‘SLAs’) listed under Policy EQ6 in the Current LDP have not been carried forward into the Revised LDP.
We recognise that SLAs are a local non-statutory designation, however these areas are an acknowledged designation which carries weight within the Current LDP as a standalone policy. SLAs are also acknowledged and given weight within neighbouring Local Planning Authority (‘LPA’) LDPs.3 The weight given to the SLA designations is recognised across Appeal decisions by the Planning Inspectorate and in Planning Inspectorate recommendations with regard to Development Consent Order applications.4
We object to the Second Deposit LDP on the basis of the removal of the SLAs and request that SLAs are reintroduced into the Revised LDP, either as a standalone policy or that provision is made within the new Policy BHE2: Landscape Character.
This could be achieved by an amendment to Policy BHE2: Landscape Character to add wording as follows:
Proposals must take account of Carmarthenshire’s locally designated Special Landscape Areas (as set out in Appendix X (Appendix 4 of the Current LDP) and shown on the Policies Map). Development proposals will only be permitted where there is no significant adverse impact, including cumulative impact, on the character and quality of the landscape. Development proposals should aim to protect and enhance the features for which the SLA has been designated.
Where appropriate, a Landscape Impact Assessment will be required to assess and justify the impact of the development on Landscape Character and/or the designated area.
In exceptional circumstances, where development is necessary and could result in a significant landscape impact, appropriate mitigation and enhancement measures should be provided, including the undergrounding of associated infrastructure where possible.
Our suggested wording is similar to the City of Swansea LDP which was successfully adopted following Examination in February 2019.5 Appendix 4 of the Current LDP would remain relevant to the Revised LDP and could be brought across, with edits as necessary to increase the robustness of the assessment of the area’s character. SLAs could be added back into the Policies Map, with minor boundary edits as necessary.
2 Bridgend County Borough Council, Designation of Special Landscape Areas, March 2010
3 City of Swansea LDP (adopted February 2019), Ceredigion LDP (adopted 2013)
4 Including, but not solely, APP/M6825/A/12/2189697, APP/M6825/X/13/515763 & APP/M6825/X/13/515764; and Brechfa Forest Connection DCO application ref EN020016;
5 https://www.swansea.gov.uk/article/9914/Swansea-Local-Development-Plan-2010-2025-LDP

Reasons for retention
The retention of the SLAs in the Revised LDP is well supported, with 438 people resident within the county signing Carmarthenshire Residents’ Action Group’s petition.
We argue that the retention of the SLAs is important to fulfil to objectives of the LDP and question if the SLAs are removed if the plan meets its Sustainability Objectives on Landscape set against the baseline criteria. We do not consider that a robust, proportionate and credible case has been set out by the LPA for the removal of this landscape designation. We consider that the removal of the SLAs significantly weakens the Revised LDP’s SO9 regarding sense of place and impacts Carmarthenshire’s planning framework in terms of delivering on sustainable development on the basis of the Well-being of Future Generations Act.
By designating SLAs it is easier for communities, visitors and tourists to engage with the highest value landscapes of Carmarthenshire. The SLA designations are reflective of the local value communities place on these landscapes in a manner not captured in the replacement Policy BHE2: Landscape Character. This revised policy places too much reliance on LANDMAP assessment. Whilst LANDMAP is an excellent tool for those engaged with the planning process, it is harder to engage with than the specifically designated SLAs which have clear and geographical boundaries capturing the outstanding and high quality landscapes of Carmarthenshire. The removal of the SLAs, and their removal from the Polices Map, invariably makes it makes it harder for specific communities and the wider public to engage with the LDP and weakens community representations as part of the planning consultation processes for individual development applications.
We consider that the SLAs improve the delivery of the Revised LDP objectives. Natural Resources Wales (‘NRW’) states that ‘there may be more than one role for an identified SLA: To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place / bro; To influence positive landscape planning. […]; To raise understanding and appreciation of the importance of local landscapes by communities, visitor and the wider public.’ The SLAs currently provide these roles and retaining them in the Revised LDP would better meet the LDP and ISA Objectives.
The developmental pressures on the landscape have not weakened in the time between the Current LDP adoption and the Revised LDP drafting. The Current LDP Appendix 4 assessment of SLAs specifically states in relation to the Tywi Valley, that ‘Inappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation.’ We do not see that these reasons for designation have weakened. However, if the LPA consider otherwise, then the evidence of this decision making process should be published.
Planning Policy Wales 11 (‘PPW11’) paragraphs 6.3.12 and 6.3.13 relate to the characteristics of local landscapes. These paragraphs highlight the ability for LPAs to designate SLAs. Paragraph 6.3.13 states that ‘Planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.’ Given that pressures on the landscape have not weakened and that the existing SLAs have proven weight in the planning determination process, we consider that the removal of the SLAs in the Revised LDP runs contrary to this part of PPW11.

Compatibility with Policy and Guidance
In addition to the point with regard to PPW 11 above, our view is that the SLAs are wholly compatible with the Revised LDP, the proposed Policy BHE2: Landscape Character and can be seamlessly incorporated into this policy, or alternatively, the existing policy could be retained in the Revised LDP.
NRW LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, endorses a dual approach to landscape management, in line with our suggested edits to the Revised LDP Policy BHE2: Landscape Character. On page 3 of the document, it is stated that ‘in this dual approach, all landscapes will be underpinned equally by LANDMAP […] but in addition to this, landscapes of high local importance will be specifically identified as a SLA with additional guidance being produced for these key landscapes’.
We recognise that there is potential tension between the SLA designation of Llanllwni Mountain SLA and the Cothi Valley SLA, and that these areas are also within the Pre-Assessed Area for Wind Energy in Future Wales 2040 the National Development Plan (‘NDP’). We argue that the SLA designation of these areas is not in conflict with the NDP, including Policies 17 and 18. However, we recognise that this is an area of the Revised LDP which may benefit from further exploration at Examination and we would appreciate an invitation to make representations on this issue.

2. Inadequate Evidence Base
The Issues, Vision and Options paper makes it clear that this 2018-2033 LDP is a review of the previous LDP and not a new local plan (para 1.3, page 2, Issues, Vision and Options Topic Paper, February 2023). There is a general expectation in plan making that evidence is front-loaded. As the Revised LDP revises the Current LDP, it is reasonable to expect that the entire removal of locally designated SLA from the plan should be carried out on a sound, evidence backed, basis. Statements by the LPA during the plan making process did not indicate that SLAs would be removed from the plan at Review or Preferred Strategy stages. The weakening of the landscape policies and the removal of SLAs was not revealed until the publication of the First Deposit LDP in early 2020. Prior to the publication of the First Deposit LDP, the LPA indicated that further evidence would be published if the policy were to be changed.
The 2006-2021 LDP Review Report 2018 did not raise concerns about the effectiveness of the SLA Policy, giving it a green colour coding indicating the policy target was being achieved or exceeded. The report stated in paragraph 9.141 that ‘The Plan identifies Special Landscape Areas (SLAs) within Policy EQ6. These were identified following a formal assessment of the landscape qualities of the County and are a non-statutory designation. It is noted that the policy places an emphasis on enhancement and improvement. There may be opportunities to supplement and/or review the supporting evidence for this policy and explore those wider linkages (e.g. the renewable energy policies and those design related policies).’
Further, Appendix 1 of the Review Report reviewing specific policies states that in relation to Policy EQ6 SLAs that ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy.’ This wording is a standard response to policies which were expected to be kept in the Revised LDP close to their current form. It is difficult to ascertain how the
removal of the SLAs does not constitute a fundamental change, to a degree where evidence justifying this change would reasonably be expected to be published.
Following on from the review, the Preferred Strategy was published in 2019. The Preferred Strategy gave no indication of the intention to remove the SLAs from the Deposit Plan and gave significant indication that landscape policies would remain strong within the Revised LDP. Issue 8 of the LDP issues is ‘Rich landscape or townscape qualities’; the Vision states that ‘rich cultural and environmental qualities are valued and respected’; paragraph 10.19 states that ‘the LDP will promote the principles of sustainability by: Protecting and enhancing biodiversity, townscapes and landscapes’; ‘A New Strategy – Key Components’ paragraph 10.20 states that ‘the key components of the strategy are as follows:’ one of which is to ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes’.6
Given these statements, it would not be unreasonable to expect that the SLA policy would remain in the Revised LDP, particularly given specific reference to the protection of high value landscapes. The means of recognising and protecting the areas of outstanding and high value landscapes in the LPA’s geographical area is specifically the Current LDP’s SLA policy.
Furthermore, in response to a representation made on the Preferred Strategy, the LPA stated ‘The consideration of whether any Special Landscape Areas will be identified in the Revised LDP, along with any resultant evidential facets, will be a matter for the deposit LDP.’ [our emphasis].
In our view, it is reasonable to consider that prior to the First Deposit Plan publication that the full SLA policy, or a slightly revised version of it, would remain in place in the new LDP; or that evidence would be published alongside the Deposit Plan to justify removal of the SLA policy given the LPAs statements in the Plan Review and the response to the Preferred Strategy public consultation. Therefore, given the above timeline indicates a very late decision to remove the SLAs from the Revised LDP, we question whether the decision has been carried out with robust, proportionate and credible evidence.
What evidence has been used?
At the date of this letter, the LPA have not provided information within the Plan Evidence Base, as accessed online, for the decision to remove the SLAs from the LDP; nor the evidence that the new landscape Policy BHE2: Landscape Character sufficiently delivers on the aims of the New Strategy which includes the key component to protect and enhance high-value landscapes.
Assessments which have been published by the LPA in relation to Landscape Character are due to expire when the new LDP is adopted. These comprise existing assessments of the SLA areas in Appendix 4 of the Current LDP; there is a reference to NRW’s 48 broad scale, not locally specific, National Landscape Character Areas (NLCA), and the SLAs within the Placemaking and Design SPG (adopted 2016); and consideration of landscapes in the Carmarthenshire Wind Turbine Development Landscape Sensitivity and Capacity Study, prepared by Anthony Jellard Associates.
The SLAs are removed from the Revised LDP. The Placemaking and Design SPG is not slated to be carried forward with the new Revised LDP7. The current status of the Anthony Jellard study is unclear,
6 These parts of the Preferred Strategy are carried into the Second Deposit LDP, February 2023, and are found across Chapters 5-9.
7 See Appendix 3, Second Deposit LDP 2018-2033
it is referenced within the current Wind and Solar SPG; however this SPG is not intended to be carried forward as part of the Revised LDP. The removal of these assessments is likely to leave a gap with regard to the protection and enhancement of landscapes when the new Revised LDP is adopted.
Given the anticipated expiry of these assessments, it is not credible that they can form part of an evidence base for the creation of the Revised LDP policies. No evidence has been provided that any other assessments have been carried out in forming the LPAs landscape character policy or that NRW’s LANDMAP has been utilised to inform revised policy preparation. The Revised LDP states that a Landscape Character Assessment SPG is proposed to be adopted by Summer 2025, but as no draft has been published this does not form part of the evidence base. The target Revised LDP adoption date is Autumn 2024 and with the SPG proposed for Summer 2025, this leaves a significant gap around landscape policy guidance in the interim, even if the Landscape Character SPG is published on time.
The LPAs Cabinet Member for Planning has responded to a question on the evidence base by discussing assessment of development proposals utilising information contained within NRWs LANDMAP. However, this is an existing means of assessment in the Current LDP and will be retained as a means of assessing change to landscape in the Revised LDP, as such it does not make a difference to the baseline. Notably, the question asked to the Cabinet Member for Planning was with regard to the evidence around the formation of new Policy BHE2 and the removal of the SLAs, to which she did not furnish an answer. 8
Finally, the lack of published evidence relevant to the landscape policies of the Revised LDP appears to be in conflict with paragraph 6.3.21 of PPW 11, which states ‘Planning authorities should draw upon LANDMAP in the preparation of landscape plans and assessments needed to inform development plans, SPGs and the development management process. LANDMAP assessments should be published.’ [our emphasis]
In our view, the evidence base for the Revised LDP in terms of Landscape Policy is not sufficiently substantiated and we request that this is interrogated by the Inspector appointed for the Examination.

3. Revised LDP Policies
We argue that the Revised LDP policies are substantively weaker with regard to landscape protection and enhancement than the Current LDP Policies. Comparison of similar policies in relation to placemaking, sustainability, high quality design, landscapes and features of importance, landscape character and renewable energy, between the Current LDP and the Revised LDP, show fewer mentions of the need to ‘preserve or enhance’, that development ‘must’ meet certain criteria, that development ‘will only be permitted’ if specific criteria are met, and the clear setting out of designated Special Landscape Areas with the expectation that development should enhance or improve these areas.
This is in contrast to the Revised LDP which uses wording such as ‘should relate to’, maintaining ‘overall integrity’, ‘development shall demonstrate’, that ‘development must acknowledge’ and ‘demonstrate a clear understanding’. Whilst it is acknowledged that this can be a more positive way of forming LDP policies and there are good reasons for this approach, it would be erroneous to suggest
8https://democracy.carmarthenshire.gov.wales/ieListDocuments.aspx?CId=131&MId=6351&Ver=4 [accessed 14 April 2023]
that these changes do not make the Policies easier for development to be consented and weaker in some instances. In our view, this is notably the case with regard to landscape protections and most significantly the removal of a whole policy layer designating Special Landscape Areas. With regard to landscape there is a question if the Policies as currently drafted are sufficiently robust to deliver on the Issues, Vision and Objectives of the plan, as well as key components of the Strategy.
We appreciate that Policies SP12: Placemaking and Sustainable Places and BHE2: Landscape Character, do contain some landscape protections. However, with the removal of the designated SLAs the Revised LDP remains materially weaker with regard to the protection of Carmarthenshire’s highest quality landscapes (outstanding and high value). This is especially the case prior to the publication of the promised Landscape Character SPG, and without publication of this SPG in draft form before examination it is difficult to fully consider the likely strength of these policies.

4. Specific suggested amendments to Revised LDP Policies
In addition to the objection to the removal of the SLA policy and suggestions for its reintroduction, we have the following additional comments on the Revised LDP.

Object. Strategic Policy – SP12: Placemaking and Sustainable Places
Policy point f) ‘Exhibit and demonstrate a clear understanding of the existing local landscape context, natural and built heritage, local character and sense of place.’
Proposed change to ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’
This change would deliver the key components of the New Strategy more convincingly in relation to this Policy, one of which is ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes.’ It would also deliver Strategic Objective 9 (SO9) more convincingly. SO9 aims ‘To protect and enhance the diverse character, distinctiveness, safety and vibrancy of the County’s communities by promoting a place making approach and a sense of place.’ Currently the specific phrase ‘protect and enhance’ only features in Strategic Policy SP14: Maintaining and Enhancing the Natural Environment which is only one component of the County’s diverse character. Variations of protect and enhance feature elsewhere in the written statement and there is benefit in bringing SP12 more into line with these.

Object. PSD1: Effective Design Solution: Sustainability and Placemaking. Policy point d) states ‘Quality landscapes design solutions’, this appears to be a typo where ‘landscape’ fits better. In our view, for policy point d) to work effectively, either reference to a published Landscape Character SPG, or reference to NRW LANDMAP (especially the Visual and Sensory assessment layer) should be made within this Policy or in the accompanying notes. This would benefit from explicitly stating that it applies to all development, including infrastructure, Renewable and Low Carbon developments, as well as buildings, transport, excavation sites, and smaller scale landscape proposals in the private and public realm.

Object. BHE2: Landscape Character. The use of ‘overall’ in the policy substantively weakens its protection of the landscape character. We request that this word is removed. It is unclear in the current presentation of the policy if the onus is on the applicant to identify the landscape character of the ‘local area’ through their own assessment, or if NRWs LANDMAP data is to be used, or if the
LPAs own Landscape Character SPG is to be used. This should be more explicitly set out and clarified. If the expectation is that the Landscape Character SPG is the baseline then it would be beneficial for this to be published in advance of the Revised LDPs adoption, preferably at the time of Examination. Reference to the Landscape Character Assessment should also be made in the Policy text.
It is also unclear where the key landscape views and vistas mentioned in point e. are set out, in order for them to be protected in the policy. If these are due to be identified in the Landscape Character SPG then, again, this would benefit publication prior to plan Examination.
We also request that reference to SLAs are added into this policy, as set out in section 1 of this letter.

Object. Policy CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and presumption of consent for renewable development proposals by communities, as well as those already set out for large scale wind farms. We suggest that the following are added to the policy:
d. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
e. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
f. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
g. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Policy CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and explicit presumption of consent for renewable development proposals from communities. We suggest that the following are added to the policy:
b. [add]… , including SLAs;
g. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
h. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
j. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
k. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Table 9 Resource Summary for Renewable Electricity. The Onshore Wind Target to deliver 588.5 MW of additional installed capacity by 2033 is in our view unrealistic given there has not been a call for sites for wind power. By our calculations, extrapolating from the evidence base document, AECOM Renewable and Low Carbon Energy Assessment Section 4.3, delivery of this target may require 75% of the area unconstrained by features such as buildings, roads and rivers in the Pre-Assessed Area in north Carmarthenshire to be developed for onshore wind.9 Given the mix of landowners and small scale farms across this area, delivery of the target may be challenging without large scale land purchases, which would not be feasible or desirable for smaller scale community wind developers. This policy is likely to result in more large scale multi-national corporation wind farm developments across Carmarthenshire. This is notwithstanding the scale of significant adverse impacts, including cumulative impacts, on the landscape a target like this will create.

Object. Policy CCH6: Renewable and Low Carbon Energy in New Developments. This policy could be more ambitious helping to deliver Net Zero targets by requiring all new housing or commercial development to fit solar panels to roofs, unless it is demonstrated by the applicant that to do so would not be viable, or if by doing so would conflict with other policies in the Revised LDP (such as built heritage, townscape or landscape policies).
Object. Policy CCH7: Climate Change – Forest, Woodland and Tree Planting. Specific reference should be made in the policy text to native trees and that planting schemes much be appropriate to the cultural and ecological character of the locality. This is referenced in paragraph 11.534, however due to the large ecological and landscape impacts that can arise from non-native tree planting, in our view the wording should be directly within the policy text.
The AECOM assessment estimates that the Pre-Assessed Area in Carmarthenshire, identified in Future Wales 2040, covers an area of 687 km2. The report assumes a maximum of 5 2MW turbines per 1km2 of land. Applications for new onshore wind at scale is more likely to be focused within the Pre-Assessed Areas due to the favourable planning framework for these locations. The Revised LDP target for installed capacity is an additional 588.5 MW, which using AECOM’s calculations would need to cover a land area of 58.85 Km2, or, 14,542 acres, equivalent to 8.5% of the Pre-Assessed Area. Taking into account the expected delivery of the remaining capacity in the former TAN 8 SSA, there is the expectation that 54.83 km2 will be delivered on a total possible unconstrained area of 73.1km2, or 75% of the unconstrained land in the Pre-Assessed Area. For the purposes of the AECOM study the constrains are National Parks, Natura 2000 sites, Buildings, Roads, Rivers, the TAN8 SSA and Topple Distance buffers applied to buildings, roads and rivers. Calculations taken from data within page 29 and 30 of the AECOM Renewable and Low Carbon Energy Assessment published in the LDP Evidence Base.

5. Adequacy of the Integrated Sustainability Appraisal assessment as it concerns Landscape
We are raising substantive concerns with regard to the robustness of the assessment carried out in the Integrated Sustainability Appraisal (‘ISA’).
The Sustainability Appraisal Scoping Report (published July 2018) set out the parameters of the Sustainability Appraisal, identifying Sustainability Issues and Opportunities, Sustainability Assessment Objectives and Decision Making Influences. This identified Landscape as number 9 of a total of 15 equal issues. Issue 9 is set out as follows: ‘There are several sites designated as of landscape or townscape value within the county. These features need to be protected, and where possible enhanced.’ In the Decision Making Influences, the question, ‘Will the LDP have a positive or negative impact on designated landscapes?’ is posed.
Linking these two quotes is the specific mention of ‘designated landscapes’, not statutory designated, nor ‘Designated’ noun. Special Landscape Areas are considered designated landscapes in this definition. This is the case in comparable LPAs in Wales, PPW11 para 6.3.12 refers to ‘the designation of Special Landscape Areas’ and the Current LDP Policy EQ6 states that ‘Special Landscape Areas are designated…’. Thus, references to designated landscapes in the Sustainability Appraisal, must take into account local as well as statutory designations, including SLAs. The question ‘will the LDP have a positive or negative impact on designated landscapes?’ and that the Revised LDP removes some of these designated landscapes, is an important consideration for the assessments in the Sustainability Appraisal.
Sustainable development is defined in the Well-being of Future Generations (Wales) Act 2015 as the ‘process of improving the economic, social, environmental, and cultural wellbeing of Wales by taking action.’ A change to the development plan which removes some designated landscapes should be considered carefully and assessed robustly on the terms that those designations have been removed, to demonstrate that the change is not an impairment to sustainable development.
Turning to the latest version of the ISA, published February 2023. The prediction of the effects of the plan involves identifying changes to the environmental baseline. The baseline for sustainability objective ISA9 – Landscape is set out in ISA Appendix B (pp.61-67) with the other baseline assessments. This baseline constitutes an introductory paragraph explaining that the Brecon Beacons National Park sits outside the LDP boundaries, along with a copy of the Current LDP Appendix 4 Special Landscape Areas assessment in full, then proceeds to state the ‘Predicted effect without implementation of the LDP’.
In our view, this assessment of predicted effects has been carried out incorrectly. The predicted effects mention protected habitat and species and biodiversity, which are assessed under ISA2 Biodiversity, and fails to comment adequately on changes to landscape as a characteristic in and of itself. Crucially, this assessment fails to note that the locally designated landscapes, SLAs, will continue to be in effect once the Plan period expires. This is, in our opinion, a substantive omission especially given that the baseline text is comprised of Special Landscape Area descriptions and assessing areas noted as being ‘worthy of the protection that the designation of SLAs provides.’
Section 4 of the ISA sets out a summary of the environmental baseline and predicted effects, noting that the future baseline for landscape is declining. This summary has a stronger summarisation of the likely effect on landscape than that set out in the ISA Appendix and states clearly that ‘landscape
protection measures should be strengthened’. As this assessment is provided on the basis that the Current LDP continues to remain in place, the need to have measures strengthening landscape protection must be considered to be in addition to those already in place, including the designated SLAs.
As the ISA needs to take into account the effect of the Revised LDP being adopted, against the baseline of the Current LDP remaining, some assessment of the removal of the local designated SLAs would be expected in the ISA. However, Special Landscape Areas are not mentioned in the main text of the ISA, nor the ISA Appendices, outside of the Baseline and list of Abbreviations. Failure to take account of the loss of this designation from the LDP is, in our view, a major error and questions the credibility of the appraisal of predicted effects on ISA9 – Landscape, throughout the ISA document and brings into question the soundness of the Plan.
There are also other concerning errors and omissions. One example is the review of SP16: Climate Change and associated specific policies CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas and CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas, in Appendix F and G. The appraisal considers the effects on landscape to be ‘neutral’ and with ‘positive and negative effects’. This is not credible given the scale of change proposed to the landscape on the basis of the targets for new wind power generation by 2033, and this target set in the context of the removal of the SLAs from the LDP. A negative effect should be identified. Whether the negative effect should be acceptable on balance is a test that is separate to this specific part of the ISA. The ISA should credibly take into account the high magnitude of the changes, the Plan’s intention to remove the SLA designated landscapes, and the effect characteristics including the scale of cumulative effects, their special extent and their probability; all of which is high impact and likely.
Another example is the review of SP14: Maintaining and Enhancing of the Natural Environment, where the Appraisal comments against ISA9 state that ‘This policy directly refers to the protection and enhancement of Carmarthenshire’s landscape’ (ISA Appendix F, p.46). This policy does not do as the Appraisal states. The protection and enhancement is directed at the natural environment more generally, it is not a policy linked back to ISA9 in its monitoring objectives, and points more generally to a confusion throughout the Revised LDP between the character of landscape as a visual and integral whole vs smaller scale aspects which make up the natural environment, which are nonetheless important, but fundamentally different.

6. Conclusion
The removal of the SLA designations from the LDP cannot but be an adverse change. The failure to take account of this substantive change and substantiate why this is not a significant weakening of the LDP from its current form is of great concern.
We encourage Carmarthenshire’s Forward Planning Department to set this right before the LDP is examined and re-introduce the SLA designations into the Plan to address the issues raised in this letter, re-providing a substantive part of the means to protect and enhance our outstanding and high valued landscapes for future generations.
We re-iterate our request to make representations on the LDP examination on the subject of landscape, with regard to relevant policies.
We appreciate your, and the appointed Planning Inspector’s, consideration of this letter.

Specific reference should be made in the policy text to native trees and that planting schemes might be appropriate to the cultural and ecological character of the locality.

Carmarthenshire Residents’ Action Group: Representations to the public consultation of the Second Deposit Revised Carmarthenshire Local Development Plan 2018-2033 and the Integrated Sustainability Assessment
We, Carmarthenshire Residents’ Action Group, are responding to the public consultation on the Carmarthenshire Local Development Plan 2018-2033 (Second Deposit) (‘Revised LDP’) to raise concerns with regard to the plan making process in relation to landscape(s) within the LDP’s geographical area. We request several changes to the plan on the basis that we consider the plan not to be sound and request the opportunity to make representations during the examination process.1
This letter contains a series of comments and objections in relation to landscape policies, and approach to policy making with regard to landscapes, within Carmarthenshire’s Revised LDP drafting process, including the Integrated Sustainability Appraisal (‘ISA’).
This letter also consolidates a series of comments made via the online comments portal on the proposed Revised LDP. It refers Carmarthenshire’s Forward Planning Department and, in due course, the appointed Examination Planning Inspector, to Carmarthenshire Residents Action Group’s petition to maintain the Special Landscape Areas within the 2018-2033 LDP. This petition has raised 438 signatures, details of which are contained within Appendix 1 of this letter.
A strong objection is raised, backed by significant local support, to the removal of Carmarthenshire’s locally designated Special Landscape Areas within the Revised LDP. Objections are also raised with regard to the replacement landscape related policies in the second Deposit Revised LDP with materially weakened policies compared to the existing 2006-2021 LDP (‘Current LDP’). The letter also raises concerns with regard to the assessment carried out in the ISA as it pertains to the Sustainability Objective on Landscape.
Our representations are set out as follows:
1. Objection to the removal of Special Landscape Areas from the Revised LDP;
2. Inadequate Evidence Base;
3. Revised LDP Policies;
4. Specific suggested amendments to Revised LDP Policies;
5. Adequacy of the assessment Integrated Sustainability Appraisal as it concerns Landscape; and,
6. Conclusion
1 It is noted that Welsh Government Local development plan examinations: procedure guidance (28 November 2022) states in paragraph 1.7 that ‘Those who have sought changes to the submitted plan or plan revisions and have indicated that they would like to speak must be invited to the hearings.’

1. Objection to the removal of the Special Landscape Areas from the Revised LDP
‘The use of non-statutory designations such as Special Landscape Areas to protect areas of landscape value has long been a policy tool within the UK planning system. They have been seen by local planning authorities as a means of protecting sensitive landscapes and in developing an understanding and awareness of those features and characteristics that give a locality its sense of place.’2
Carmarthenshire’s 18 Special Landscape Areas (‘SLAs’) listed under Policy EQ6 in the Current LDP have not been carried forward into the Revised LDP.
We recognise that SLAs are a local non-statutory designation, however these areas are an acknowledged designation which carries weight within the Current LDP as a standalone policy. SLAs are also acknowledged and given weight within neighbouring Local Planning Authority (‘LPA’) LDPs.3 The weight given to the SLA designations is recognised across Appeal decisions by the Planning Inspectorate and in Planning Inspectorate recommendations with regard to Development Consent Order applications.4
We object to the Second Deposit LDP on the basis of the removal of the SLAs and request that SLAs are reintroduced into the Revised LDP, either as a standalone policy or that provision is made within the new Policy BHE2: Landscape Character.
This could be achieved by an amendment to Policy BHE2: Landscape Character to add wording as follows:
Proposals must take account of Carmarthenshire’s locally designated Special Landscape Areas (as set out in Appendix X (Appendix 4 of the Current LDP) and shown on the Policies Map). Development proposals will only be permitted where there is no significant adverse impact, including cumulative impact, on the character and quality of the landscape. Development proposals should aim to protect and enhance the features for which the SLA has been designated.
Where appropriate, a Landscape Impact Assessment will be required to assess and justify the impact of the development on Landscape Character and/or the designated area.
In exceptional circumstances, where development is necessary and could result in a significant landscape impact, appropriate mitigation and enhancement measures should be provided, including the undergrounding of associated infrastructure where possible.
Our suggested wording is similar to the City of Swansea LDP which was successfully adopted following Examination in February 2019.5 Appendix 4 of the Current LDP would remain relevant to the Revised LDP and could be brought across, with edits as necessary to increase the robustness of the assessment of the area’s character. SLAs could be added back into the Policies Map, with minor boundary edits as necessary.
2 Bridgend County Borough Council, Designation of Special Landscape Areas, March 2010
3 City of Swansea LDP (adopted February 2019), Ceredigion LDP (adopted 2013)
4 Including, but not solely, APP/M6825/A/12/2189697, APP/M6825/X/13/515763 & APP/M6825/X/13/515764; and Brechfa Forest Connection DCO application ref EN020016;
5 https://www.swansea.gov.uk/article/9914/Swansea-Local-Development-Plan-2010-2025-LDP

Reasons for retention
The retention of the SLAs in the Revised LDP is well supported, with 438 people resident within the county signing Carmarthenshire Residents’ Action Group’s petition.
We argue that the retention of the SLAs is important to fulfil to objectives of the LDP and question if the SLAs are removed if the plan meets its Sustainability Objectives on Landscape set against the baseline criteria. We do not consider that a robust, proportionate and credible case has been set out by the LPA for the removal of this landscape designation. We consider that the removal of the SLAs significantly weakens the Revised LDP’s SO9 regarding sense of place and impacts Carmarthenshire’s planning framework in terms of delivering on sustainable development on the basis of the Well-being of Future Generations Act.
By designating SLAs it is easier for communities, visitors and tourists to engage with the highest value landscapes of Carmarthenshire. The SLA designations are reflective of the local value communities place on these landscapes in a manner not captured in the replacement Policy BHE2: Landscape Character. This revised policy places too much reliance on LANDMAP assessment. Whilst LANDMAP is an excellent tool for those engaged with the planning process, it is harder to engage with than the specifically designated SLAs which have clear and geographical boundaries capturing the outstanding and high quality landscapes of Carmarthenshire. The removal of the SLAs, and their removal from the Polices Map, invariably makes it makes it harder for specific communities and the wider public to engage with the LDP and weakens community representations as part of the planning consultation processes for individual development applications.
We consider that the SLAs improve the delivery of the Revised LDP objectives. Natural Resources Wales (‘NRW’) states that ‘there may be more than one role for an identified SLA: To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place / bro; To influence positive landscape planning. […]; To raise understanding and appreciation of the importance of local landscapes by communities, visitor and the wider public.’ The SLAs currently provide these roles and retaining them in the Revised LDP would better meet the LDP and ISA Objectives.
The developmental pressures on the landscape have not weakened in the time between the Current LDP adoption and the Revised LDP drafting. The Current LDP Appendix 4 assessment of SLAs specifically states in relation to the Tywi Valley, that ‘Inappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation.’ We do not see that these reasons for designation have weakened. However, if the LPA consider otherwise, then the evidence of this decision making process should be published.
Planning Policy Wales 11 (‘PPW11’) paragraphs 6.3.12 and 6.3.13 relate to the characteristics of local landscapes. These paragraphs highlight the ability for LPAs to designate SLAs. Paragraph 6.3.13 states that ‘Planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.’ Given that pressures on the landscape have not weakened and that the existing SLAs have proven weight in the planning determination process, we consider that the removal of the SLAs in the Revised LDP runs contrary to this part of PPW11.

Compatibility with Policy and Guidance
In addition to the point with regard to PPW 11 above, our view is that the SLAs are wholly compatible with the Revised LDP, the proposed Policy BHE2: Landscape Character and can be seamlessly incorporated into this policy, or alternatively, the existing policy could be retained in the Revised LDP.
NRW LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, endorses a dual approach to landscape management, in line with our suggested edits to the Revised LDP Policy BHE2: Landscape Character. On page 3 of the document, it is stated that ‘in this dual approach, all landscapes will be underpinned equally by LANDMAP […] but in addition to this, landscapes of high local importance will be specifically identified as a SLA with additional guidance being produced for these key landscapes’.
We recognise that there is potential tension between the SLA designation of Llanllwni Mountain SLA and the Cothi Valley SLA, and that these areas are also within the Pre-Assessed Area for Wind Energy in Future Wales 2040 the National Development Plan (‘NDP’). We argue that the SLA designation of these areas is not in conflict with the NDP, including Policies 17 and 18. However, we recognise that this is an area of the Revised LDP which may benefit from further exploration at Examination and we would appreciate an invitation to make representations on this issue.

2. Inadequate Evidence Base
The Issues, Vision and Options paper makes it clear that this 2018-2033 LDP is a review of the previous LDP and not a new local plan (para 1.3, page 2, Issues, Vision and Options Topic Paper, February 2023). There is a general expectation in plan making that evidence is front-loaded. As the Revised LDP revises the Current LDP, it is reasonable to expect that the entire removal of locally designated SLA from the plan should be carried out on a sound, evidence backed, basis. Statements by the LPA during the plan making process did not indicate that SLAs would be removed from the plan at Review or Preferred Strategy stages. The weakening of the landscape policies and the removal of SLAs was not revealed until the publication of the First Deposit LDP in early 2020. Prior to the publication of the First Deposit LDP, the LPA indicated that further evidence would be published if the policy were to be changed.
The 2006-2021 LDP Review Report 2018 did not raise concerns about the effectiveness of the SLA Policy, giving it a green colour coding indicating the policy target was being achieved or exceeded. The report stated in paragraph 9.141 that ‘The Plan identifies Special Landscape Areas (SLAs) within Policy EQ6. These were identified following a formal assessment of the landscape qualities of the County and are a non-statutory designation. It is noted that the policy places an emphasis on enhancement and improvement. There may be opportunities to supplement and/or review the supporting evidence for this policy and explore those wider linkages (e.g. the renewable energy policies and those design related policies).’
Further, Appendix 1 of the Review Report reviewing specific policies states that in relation to Policy EQ6 SLAs that ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy.’ This wording is a standard response to policies which were expected to be kept in the Revised LDP close to their current form. It is difficult to ascertain how the
removal of the SLAs does not constitute a fundamental change, to a degree where evidence justifying this change would reasonably be expected to be published.
Following on from the review, the Preferred Strategy was published in 2019. The Preferred Strategy gave no indication of the intention to remove the SLAs from the Deposit Plan and gave significant indication that landscape policies would remain strong within the Revised LDP. Issue 8 of the LDP issues is ‘Rich landscape or townscape qualities’; the Vision states that ‘rich cultural and environmental qualities are valued and respected’; paragraph 10.19 states that ‘the LDP will promote the principles of sustainability by: Protecting and enhancing biodiversity, townscapes and landscapes’; ‘A New Strategy – Key Components’ paragraph 10.20 states that ‘the key components of the strategy are as follows:’ one of which is to ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes’.6
Given these statements, it would not be unreasonable to expect that the SLA policy would remain in the Revised LDP, particularly given specific reference to the protection of high value landscapes. The means of recognising and protecting the areas of outstanding and high value landscapes in the LPA’s geographical area is specifically the Current LDP’s SLA policy.
Furthermore, in response to a representation made on the Preferred Strategy, the LPA stated ‘The consideration of whether any Special Landscape Areas will be identified in the Revised LDP, along with any resultant evidential facets, will be a matter for the deposit LDP.’ [our emphasis].
In our view, it is reasonable to consider that prior to the First Deposit Plan publication that the full SLA policy, or a slightly revised version of it, would remain in place in the new LDP; or that evidence would be published alongside the Deposit Plan to justify removal of the SLA policy given the LPAs statements in the Plan Review and the response to the Preferred Strategy public consultation. Therefore, given the above timeline indicates a very late decision to remove the SLAs from the Revised LDP, we question whether the decision has been carried out with robust, proportionate and credible evidence.
What evidence has been used?
At the date of this letter, the LPA have not provided information within the Plan Evidence Base, as accessed online, for the decision to remove the SLAs from the LDP; nor the evidence that the new landscape Policy BHE2: Landscape Character sufficiently delivers on the aims of the New Strategy which includes the key component to protect and enhance high-value landscapes.
Assessments which have been published by the LPA in relation to Landscape Character are due to expire when the new LDP is adopted. These comprise existing assessments of the SLA areas in Appendix 4 of the Current LDP; there is a reference to NRW’s 48 broad scale, not locally specific, National Landscape Character Areas (NLCA), and the SLAs within the Placemaking and Design SPG (adopted 2016); and consideration of landscapes in the Carmarthenshire Wind Turbine Development Landscape Sensitivity and Capacity Study, prepared by Anthony Jellard Associates.
The SLAs are removed from the Revised LDP. The Placemaking and Design SPG is not slated to be carried forward with the new Revised LDP7. The current status of the Anthony Jellard study is unclear,
6 These parts of the Preferred Strategy are carried into the Second Deposit LDP, February 2023, and are found across Chapters 5-9.
7 See Appendix 3, Second Deposit LDP 2018-2033
it is referenced within the current Wind and Solar SPG; however this SPG is not intended to be carried forward as part of the Revised LDP. The removal of these assessments is likely to leave a gap with regard to the protection and enhancement of landscapes when the new Revised LDP is adopted.
Given the anticipated expiry of these assessments, it is not credible that they can form part of an evidence base for the creation of the Revised LDP policies. No evidence has been provided that any other assessments have been carried out in forming the LPAs landscape character policy or that NRW’s LANDMAP has been utilised to inform revised policy preparation. The Revised LDP states that a Landscape Character Assessment SPG is proposed to be adopted by Summer 2025, but as no draft has been published this does not form part of the evidence base. The target Revised LDP adoption date is Autumn 2024 and with the SPG proposed for Summer 2025, this leaves a significant gap around landscape policy guidance in the interim, even if the Landscape Character SPG is published on time.
The LPAs Cabinet Member for Planning has responded to a question on the evidence base by discussing assessment of development proposals utilising information contained within NRWs LANDMAP. However, this is an existing means of assessment in the Current LDP and will be retained as a means of assessing change to landscape in the Revised LDP, as such it does not make a difference to the baseline. Notably, the question asked to the Cabinet Member for Planning was with regard to the evidence around the formation of new Policy BHE2 and the removal of the SLAs, to which she did not furnish an answer. 8
Finally, the lack of published evidence relevant to the landscape policies of the Revised LDP appears to be in conflict with paragraph 6.3.21 of PPW 11, which states ‘Planning authorities should draw upon LANDMAP in the preparation of landscape plans and assessments needed to inform development plans, SPGs and the development management process. LANDMAP assessments should be published.’ [our emphasis]
In our view, the evidence base for the Revised LDP in terms of Landscape Policy is not sufficiently substantiated and we request that this is interrogated by the Inspector appointed for the Examination.

3. Revised LDP Policies
We argue that the Revised LDP policies are substantively weaker with regard to landscape protection and enhancement than the Current LDP Policies. Comparison of similar policies in relation to placemaking, sustainability, high quality design, landscapes and features of importance, landscape character and renewable energy, between the Current LDP and the Revised LDP, show fewer mentions of the need to ‘preserve or enhance’, that development ‘must’ meet certain criteria, that development ‘will only be permitted’ if specific criteria are met, and the clear setting out of designated Special Landscape Areas with the expectation that development should enhance or improve these areas.
This is in contrast to the Revised LDP which uses wording such as ‘should relate to’, maintaining ‘overall integrity’, ‘development shall demonstrate’, that ‘development must acknowledge’ and ‘demonstrate a clear understanding’. Whilst it is acknowledged that this can be a more positive way of forming LDP policies and there are good reasons for this approach, it would be erroneous to suggest
8https://democracy.carmarthenshire.gov.wales/ieListDocuments.aspx?CId=131&MId=6351&Ver=4 [accessed 14 April 2023]
that these changes do not make the Policies easier for development to be consented and weaker in some instances. In our view, this is notably the case with regard to landscape protections and most significantly the removal of a whole policy layer designating Special Landscape Areas. With regard to landscape there is a question if the Policies as currently drafted are sufficiently robust to deliver on the Issues, Vision and Objectives of the plan, as well as key components of the Strategy.
We appreciate that Policies SP12: Placemaking and Sustainable Places and BHE2: Landscape Character, do contain some landscape protections. However, with the removal of the designated SLAs the Revised LDP remains materially weaker with regard to the protection of Carmarthenshire’s highest quality landscapes (outstanding and high value). This is especially the case prior to the publication of the promised Landscape Character SPG, and without publication of this SPG in draft form before examination it is difficult to fully consider the likely strength of these policies.

4. Specific suggested amendments to Revised LDP Policies
In addition to the objection to the removal of the SLA policy and suggestions for its reintroduction, we have the following additional comments on the Revised LDP.

Object. Strategic Policy – SP12: Placemaking and Sustainable Places
Policy point f) ‘Exhibit and demonstrate a clear understanding of the existing local landscape context, natural and built heritage, local character and sense of place.’
Proposed change to ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’
This change would deliver the key components of the New Strategy more convincingly in relation to this Policy, one of which is ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes.’ It would also deliver Strategic Objective 9 (SO9) more convincingly. SO9 aims ‘To protect and enhance the diverse character, distinctiveness, safety and vibrancy of the County’s communities by promoting a place making approach and a sense of place.’ Currently the specific phrase ‘protect and enhance’ only features in Strategic Policy SP14: Maintaining and Enhancing the Natural Environment which is only one component of the County’s diverse character. Variations of protect and enhance feature elsewhere in the written statement and there is benefit in bringing SP12 more into line with these.

Object. PSD1: Effective Design Solution: Sustainability and Placemaking. Policy point d) states ‘Quality landscapes design solutions’, this appears to be a typo where ‘landscape’ fits better. In our view, for policy point d) to work effectively, either reference to a published Landscape Character SPG, or reference to NRW LANDMAP (especially the Visual and Sensory assessment layer) should be made within this Policy or in the accompanying notes. This would benefit from explicitly stating that it applies to all development, including infrastructure, Renewable and Low Carbon developments, as well as buildings, transport, excavation sites, and smaller scale landscape proposals in the private and public realm.

Object. BHE2: Landscape Character. The use of ‘overall’ in the policy substantively weakens its protection of the landscape character. We request that this word is removed. It is unclear in the current presentation of the policy if the onus is on the applicant to identify the landscape character of the ‘local area’ through their own assessment, or if NRWs LANDMAP data is to be used, or if the
LPAs own Landscape Character SPG is to be used. This should be more explicitly set out and clarified. If the expectation is that the Landscape Character SPG is the baseline then it would be beneficial for this to be published in advance of the Revised LDPs adoption, preferably at the time of Examination. Reference to the Landscape Character Assessment should also be made in the Policy text.
It is also unclear where the key landscape views and vistas mentioned in point e. are set out, in order for them to be protected in the policy. If these are due to be identified in the Landscape Character SPG then, again, this would benefit publication prior to plan Examination.
We also request that reference to SLAs are added into this policy, as set out in section 1 of this letter.

Object. Policy CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and presumption of consent for renewable development proposals by communities, as well as those already set out for large scale wind farms. We suggest that the following are added to the policy:
d. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
e. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
f. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
g. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Policy CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and explicit presumption of consent for renewable development proposals from communities. We suggest that the following are added to the policy:
b. [add]… , including SLAs;
g. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
h. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
j. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
k. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Table 9 Resource Summary for Renewable Electricity. The Onshore Wind Target to deliver 588.5 MW of additional installed capacity by 2033 is in our view unrealistic given there has not been a call for sites for wind power. By our calculations, extrapolating from the evidence base document, AECOM Renewable and Low Carbon Energy Assessment Section 4.3, delivery of this target may require 75% of the area unconstrained by features such as buildings, roads and rivers in the Pre-Assessed Area in north Carmarthenshire to be developed for onshore wind.9 Given the mix of landowners and small scale farms across this area, delivery of the target may be challenging without large scale land purchases, which would not be feasible or desirable for smaller scale community wind developers. This policy is likely to result in more large scale multi-national corporation wind farm developments across Carmarthenshire. This is notwithstanding the scale of significant adverse impacts, including cumulative impacts, on the landscape a target like this will create.

Object. Policy CCH6: Renewable and Low Carbon Energy in New Developments. This policy could be more ambitious helping to deliver Net Zero targets by requiring all new housing or commercial development to fit solar panels to roofs, unless it is demonstrated by the applicant that to do so would not be viable, or if by doing so would conflict with other policies in the Revised LDP (such as built heritage, townscape or landscape policies).
Object. Policy CCH7: Climate Change – Forest, Woodland and Tree Planting. Specific reference should be made in the policy text to native trees and that planting schemes much be appropriate to the cultural and ecological character of the locality. This is referenced in paragraph 11.534, however due to the large ecological and landscape impacts that can arise from non-native tree planting, in our view the wording should be directly within the policy text.
The AECOM assessment estimates that the Pre-Assessed Area in Carmarthenshire, identified in Future Wales 2040, covers an area of 687 km2. The report assumes a maximum of 5 2MW turbines per 1km2 of land. Applications for new onshore wind at scale is more likely to be focused within the Pre-Assessed Areas due to the favourable planning framework for these locations. The Revised LDP target for installed capacity is an additional 588.5 MW, which using AECOM’s calculations would need to cover a land area of 58.85 Km2, or, 14,542 acres, equivalent to 8.5% of the Pre-Assessed Area. Taking into account the expected delivery of the remaining capacity in the former TAN 8 SSA, there is the expectation that 54.83 km2 will be delivered on a total possible unconstrained area of 73.1km2, or 75% of the unconstrained land in the Pre-Assessed Area. For the purposes of the AECOM study the constrains are National Parks, Natura 2000 sites, Buildings, Roads, Rivers, the TAN8 SSA and Topple Distance buffers applied to buildings, roads and rivers. Calculations taken from data within page 29 and 30 of the AECOM Renewable and Low Carbon Energy Assessment published in the LDP Evidence Base.

5. Adequacy of the Integrated Sustainability Appraisal assessment as it concerns Landscape
We are raising substantive concerns with regard to the robustness of the assessment carried out in the Integrated Sustainability Appraisal (‘ISA’).
The Sustainability Appraisal Scoping Report (published July 2018) set out the parameters of the Sustainability Appraisal, identifying Sustainability Issues and Opportunities, Sustainability Assessment Objectives and Decision Making Influences. This identified Landscape as number 9 of a total of 15 equal issues. Issue 9 is set out as follows: ‘There are several sites designated as of landscape or townscape value within the county. These features need to be protected, and where possible enhanced.’ In the Decision Making Influences, the question, ‘Will the LDP have a positive or negative impact on designated landscapes?’ is posed.
Linking these two quotes is the specific mention of ‘designated landscapes’, not statutory designated, nor ‘Designated’ noun. Special Landscape Areas are considered designated landscapes in this definition. This is the case in comparable LPAs in Wales, PPW11 para 6.3.12 refers to ‘the designation of Special Landscape Areas’ and the Current LDP Policy EQ6 states that ‘Special Landscape Areas are designated…’. Thus, references to designated landscapes in the Sustainability Appraisal, must take into account local as well as statutory designations, including SLAs. The question ‘will the LDP have a positive or negative impact on designated landscapes?’ and that the Revised LDP removes some of these designated landscapes, is an important consideration for the assessments in the Sustainability Appraisal.
Sustainable development is defined in the Well-being of Future Generations (Wales) Act 2015 as the ‘process of improving the economic, social, environmental, and cultural wellbeing of Wales by taking action.’ A change to the development plan which removes some designated landscapes should be considered carefully and assessed robustly on the terms that those designations have been removed, to demonstrate that the change is not an impairment to sustainable development.
Turning to the latest version of the ISA, published February 2023. The prediction of the effects of the plan involves identifying changes to the environmental baseline. The baseline for sustainability objective ISA9 – Landscape is set out in ISA Appendix B (pp.61-67) with the other baseline assessments. This baseline constitutes an introductory paragraph explaining that the Brecon Beacons National Park sits outside the LDP boundaries, along with a copy of the Current LDP Appendix 4 Special Landscape Areas assessment in full, then proceeds to state the ‘Predicted effect without implementation of the LDP’.
In our view, this assessment of predicted effects has been carried out incorrectly. The predicted effects mention protected habitat and species and biodiversity, which are assessed under ISA2 Biodiversity, and fails to comment adequately on changes to landscape as a characteristic in and of itself. Crucially, this assessment fails to note that the locally designated landscapes, SLAs, will continue to be in effect once the Plan period expires. This is, in our opinion, a substantive omission especially given that the baseline text is comprised of Special Landscape Area descriptions and assessing areas noted as being ‘worthy of the protection that the designation of SLAs provides.’
Section 4 of the ISA sets out a summary of the environmental baseline and predicted effects, noting that the future baseline for landscape is declining. This summary has a stronger summarisation of the likely effect on landscape than that set out in the ISA Appendix and states clearly that ‘landscape
protection measures should be strengthened’. As this assessment is provided on the basis that the Current LDP continues to remain in place, the need to have measures strengthening landscape protection must be considered to be in addition to those already in place, including the designated SLAs.
As the ISA needs to take into account the effect of the Revised LDP being adopted, against the baseline of the Current LDP remaining, some assessment of the removal of the local designated SLAs would be expected in the ISA. However, Special Landscape Areas are not mentioned in the main text of the ISA, nor the ISA Appendices, outside of the Baseline and list of Abbreviations. Failure to take account of the loss of this designation from the LDP is, in our view, a major error and questions the credibility of the appraisal of predicted effects on ISA9 – Landscape, throughout the ISA document and brings into question the soundness of the Plan.
There are also other concerning errors and omissions. One example is the review of SP16: Climate Change and associated specific policies CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas and CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas, in Appendix F and G. The appraisal considers the effects on landscape to be ‘neutral’ and with ‘positive and negative effects’. This is not credible given the scale of change proposed to the landscape on the basis of the targets for new wind power generation by 2033, and this target set in the context of the removal of the SLAs from the LDP. A negative effect should be identified. Whether the negative effect should be acceptable on balance is a test that is separate to this specific part of the ISA. The ISA should credibly take into account the high magnitude of the changes, the Plan’s intention to remove the SLA designated landscapes, and the effect characteristics including the scale of cumulative effects, their special extent and their probability; all of which is high impact and likely.
Another example is the review of SP14: Maintaining and Enhancing of the Natural Environment, where the Appraisal comments against ISA9 state that ‘This policy directly refers to the protection and enhancement of Carmarthenshire’s landscape’ (ISA Appendix F, p.46). This policy does not do as the Appraisal states. The protection and enhancement is directed at the natural environment more generally, it is not a policy linked back to ISA9 in its monitoring objectives, and points more generally to a confusion throughout the Revised LDP between the character of landscape as a visual and integral whole vs smaller scale aspects which make up the natural environment, which are nonetheless important, but fundamentally different.

6. Conclusion
The removal of the SLA designations from the LDP cannot but be an adverse change. The failure to take account of this substantive change and substantiate why this is not a significant weakening of the LDP from its current form is of great concern.
We encourage Carmarthenshire’s Forward Planning Department to set this right before the LDP is examined and re-introduce the SLA designations into the Plan to address the issues raised in this letter, re-providing a substantive part of the means to protect and enhance our outstanding and high valued landscapes for future generations.
We re-iterate our request to make representations on the LDP examination on the subject of landscape, with regard to relevant policies.
We appreciate your, and the appointed Planning Inspector’s, consideration of this letter.