Matters Arising Changes 2026

Object

Representation ID: 6036

Received: 26/06/2026

Respondent ID: 2315

Respondent: Natural Resources Wales

Sound? Yes

In the second new paragraph proposed in the section titled ‘Marine’, the following words should be deleted: ‘Nutrient Neutrality Area for Nitrogen associated with’.

The Council agrees the suggested deletion would improve clarity.

Object

Representation ID: 6037

Received: 26/06/2026

Respondent ID: 2315

Respondent: Natural Resources Wales

Sound? Yes

The third, fourth and fifth paragraphs proposed in the section titled ‘Marine’ should be redrafted. In parts, they are difficult to read and lack clarity.

Disagree. The content of the paragraphs are sufficiently clear and the respondent has failed to provide alternate wording and clarity.

Object

Representation ID: 6038

Received: 26/06/2026

Respondent ID: 2315

Respondent: Natural Resources Wales

Sound? Yes

With regards to the fifth paragraph and the reference to surface water removal (which links to Policy INF4) we suggest this is reworded to advise that

‘…developers may wish to consider also the removal of surface water as a mitigation measure…’

While surface water removal from a combined sewer may reduce the frequency and duration of sewer overflow, further work is required to determine the nutrient reduction benefits of such measures and therefore is may be premature to include the text as currently drafted.

The Council agrees with the proposed wording in that it offers additional clarity and meaning

Object

Representation ID: 6042

Received: 26/06/2026

Respondent ID: 2315

Respondent: Natural Resources Wales

Sound? Yes

The sixth paragraph should be amended as follows:

'The geographical extent of the catchment draining to the Burry Inlet Inner and Milford Haven Inner can be identified using the latest NRW layer as contained on DataMapWales.'

The Council agrees with the proposed change in the interest of accuracy.

Object

Representation ID: 6045

Received: 26/06/2026

Respondent ID: 2315

Respondent: Natural Resources Wales

Sound? Yes

The seventh (and final) paragraph in that section should be amended and simplified as follows:

'The Council has produced (and is continually developing) a library of resources to assist developers when considering proposals that drain into a marine or riverine SAC. These open access resources are regularly updated and can be accessed via the CCC website. The Welsh Government’s All Wales Nutrient Budget calculator, and Mitigation Guidance (published June 2023) are available for developers remain the only catchment specific tools available in Wales.

Agree in part.

The Council agrees with the amendment proposed by the respondent. However, in light of the publication of the DIN handbook the paragraph as proposed by the respondent will need to be amended to reflect the availability of this resource to developers and other interested parties.

Object

Representation ID: 6048

Received: 26/06/2026

Respondent ID: 2315

Respondent: Natural Resources Wales

Sound? Yes

We have one further comment with regards to MAC 036 and the proposed amendments to Policy INF4. Again, this comment relates to further edits to the proposed text for reasons of clarity / accuracy.

In regard to the new paragraphs added after paragraph 11.205, we suggest that the third sentence is amended as follows:

‘It is acknowledged that the removal of surface water may offer wider benefits including making a contribution towards achieving nutrient neutrality where required’.

The Council agrees with the changes suggested by the respondent in the interest of clarity and meaning.

In the interest of consistency the Council's proposes to insert the word 'and minor' after the words 'major' within the first sentence of the new paragraph after paragraph 11.205.

Object

Representation ID: 6049

Received: 26/06/2026

Respondent ID: 2315

Respondent: Natural Resources Wales

Sound? Yes

For consistency and clarity, we advise the spelling of phosphorus is corrected throughout the rLDP (i.e. all references should be to phosphorus, not phosphorous or phosphates).

Noted. This will be undertaken as part of the Minor Editorial Changes.

Object

Representation ID: 6050

Received: 26/06/2026

Respondent ID: 2315

Respondent: Natural Resources Wales

Sound? Yes

NE3: Corridors, Networks and Features of Distinctiveness.

We have considered otters as a feature of the Carmarthen Bay and Estuaries SAC and are aware that you are currently developing a Llanelli Otter Mitigation Strategy, which will provide guidance regarding the provision and maintenance of suitable commuting corridors for otters moving upstream from their coastal habitat areas.
We request that reference to this document is included in the supporting text, after paragraph 11.420 of the reasoned justification.

Noted. The Council notes that an Otter Strategy is being prepared as part of the delivery of planning proposals and live planning applications within South Llanelli. Whilst it is noted that this would provide important information in relation the otter population within the area its inclusion within the policy would be wholly exceptional in that no other strategies or plans are referenced within that policy framework.

Object

Representation ID: 6051

Received: 26/06/2026

Respondent ID: 2315

Respondent: Natural Resources Wales

Sound? Yes

We note that reference to river shingle shoal habitat has been removed from the M12 section in Appendix 4. We recommend that this reference is reinstated, particularly as this section of river may be affected by future river shoal removal works.

Agreed in part. Reference to river shoal will provide more clarity in differentiating that it is being worked in a watercourse rather than being worked dry. However, since a river shoal is a geomorphological landform rather than a type of mineral, the wording will be placed in brackets after 'Sand and Gravel'.

Object

Representation ID: 6052

Received: 26/06/2026

Respondent ID: 2315

Respondent: Natural Resources Wales

Sound? Yes

Strategic Policy – SP 12: Placemaking and Sustainable Places.
We welcome the incorporation of flood resilient design to new construction in a flood zone. However, it should be stressed that new construction in a flood zone should only happen if it can be compliant with TAN15 and that resilient design should not be used as a reason, or as mitigation, for inappropriate development in flood zones.

We advise expanding point i. to include incorporating resilient design into redevelopment / alteration of existing development and not just confined to new development.

The Council agrees with the amendment proposed by the respondent in order to maximise flood resilience