ECONOMIC AND COMMUNITY REGENERATION CABINET BOARD 17 MARCH 2011

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ECONOMIC AND COMMUNITY REGENERATION CABINET BOARD


17
TH

MARCH 2011




ENVIRONMENT SERVICES


REPORT OF THE HEAD OF PLANNING


G. WHITE


INDEX OF REPORT ITEMS


PART 1


Doc.Code:
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SECTION A


MATTERS FOR DECISION

Report Item

P
age Nos

Wards Affected


1. Neath Port Talbot Local
Development Plan Consideration
of Amendment of the Delivery
Agreement.



2
-
6


All


2. Neath Port Talbot Local
Development Plan Sustainability
Appraisal, Strategic
Environmental Assessment,
Habitats Reg
ulations and
Related Appraisals Scoping
Document.



7
-
20


All





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ITEM NO. 1

PART 1. SECTION A.


NEATH PORT TALBOT
LOCAL
DEVELOPMENT PLAN
CONSIDERATION OF
AMENDMENT OF THE DELIVERY
AGREEMENT


Purpose of Report.


To consider
the revision of the L
DP Delivery Agreement and agree the
submission to be put to the Welsh Assembly Government for its formal
approval.



Introduction


The authority is required to prepare the LDP in accordance with a Delivery
Agreement, approved by the WAG in 2008, that sets
out the timetable, resources
and consultation arrangements. As the timetable has slipped by more than 4
months, the Authority is required to renegotiate the agreement with WAG. The
slippage is due to a number of factors including the level of public respo
nse and
interest in the Plan and the need to tackle new duties.



The Revision of the Delivery Agreement


The revision of the Delivery Agreement needs to address: the timetable, and to
update the financial provision. The remainder of the agreement remain
s valid.


The Timetable


The key dates in the Agreement relate to the publication of the Pre
-
Deposit Plan,
the placing of the Deposit Plan on formal deposit, and the submission of the
Plan to WAG for Examination In Public. The last date needs only to be
in
dicative.



It is proposed that the
Pre
-
Deposit Plan be published for consultation this
September.
This would require:


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Informal discussion with stakeholders (in accordance with the existing DA), and
then the Authority agreeing the matters for inclusion
in the Pre
-
Deposit Plan,
having considered the findings of the Sustainability Assessment. It would also
be necessary to consider whether a Habitats Regulations Assessment would be
likely to be required.


The
full Deposit Plan would be published for consul
tation in February 2013


The LDP
would be

submitted to WAG for Examination in Public in
November 2013.


The plan would then be adopted in November 2014.

This would represent a
slippage of 18 months compared with the original Delivery Agreement.



Budget Pr
ovision


The budget provision set aside for the Plan preparation will need to be rolled
forward to reflect the slippage in timescale. A large proportion of the funding
will be needed to fund the Examination In Public. Other authorities have
estimated this
to cost in the region of £400,000.



2011/l4: £558,000


This equates to the funding set aside in the original Delivery Agreement net of
expenditure to date.



Consultation on the Proposed Amendments


A public consultation was held concerning the draft De
livery Agreement. The
proposed revisions relate to addressing the timetable and updating other
information. All those people and stakeholders that have indicated an interest in
the plan preparation have been informed that the Delivery Agreement is under
re
view and have been invited to contact the LDP team if they have any queries
or concerns. In addition a newspaper notice to the same effect has been
published. The closing date for comments is the 25
th

March 2011
.
If necessary,
a Special Meeting of this

Ca
binet
Board and Scrutiny Committee will be
arranged to consider any com
m
ents that are received, and whether it is necessary
to make any

amendments to the submission to WAG.

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Recommendation


That the revisions relating to the Delivery Agreement timetable
, and budget
provision set out above be agreed and submitted to WAG for formal approval
subject
to a further meeting of this Board being held to consider any comments
that
may be

received
after the date of this Board
by March 25
th

2011 should they
raise an
ything that would require

amend
ment to

the submission to WAG.



Reasons for Proposed Recommendation


The proposed revisions to the Delivery Agreement balance the need to regain
momentum in the plan preparation against the need to ensure that the plan is
so
undly based on adequate preparation,


Financial Appraisal


The costs can be accommodated within existing budgets.


Consultation Outcome


The report has been the subject of internal consultations and its final form
reflects the outcome of that process
.


Sustainability Appraisal


A central purpose of the LDP is to address and influence sustainability. This is
assessed in the Revised Strategic Environmental Assessment which incorporates
a Sustainability Appraisal.


List of Background Papers.


Legislation a
nd Regulations:


Planning Policy Wales 2010

Local Development Plan Manual

Local Development Plan Regulations

Neath Port Talbot Local Development Plan Delivery Agreement 2008.





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Wards Affected.


All.



Contact Officer


Owain Lewis


Planning Policy M
anager on 6287 (o.lewis@npt.gov.uk)

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ITEM NO. 1

PART 1. SECTION A. COMPLIANCE STATEMENT


NEATH PORT TALBOT
LOCAL
DEVELOPMENT PLAN
CONSIDERATION OF
AMENDMENT OF THE DELIVERY
AGREEMENT


(a)

Implementation of Decision


The decision will be implemented
after the 3 day call in period.


(b)

Sustainability Appraisal:



Community Plan Impacts


Economic Prosperity



..

Significant Impacts

Education & Lifelong Learning


..

Significant Impacts

Better Health and Wellbeing


..

Significant Impacts

Environmental &
Transport


..

Significant Impacts

Crime and Disorder



..

Significant Impacts


Other Impacts

Welsh Language




..

Significant

Impacts

Equalities





..

Significant Impacts

Social Inclusion




..

Significant Impacts


(c)

Consultation


There has been consu
ltation concerning this matter as is explained in the report.





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ITEM NO. 2

PART 1. SECTION A.


NEATH PORT TALBOT LOCAL DEVELOPMENT PLAN
SUSTAINABILITY APPRAISAL, STRATEGIC ENVIRONMENTAL
ASSESSMENT, HABITATS REGULATIONS AND RELATED
APPRAISALS SCOPIN
G DOCUMENT.



Purpose of Report.


To consider

the comments and representations made following the public
consultation on the draft Scoping Document for the Sustainability Appraisal
(SA) of the Local Development Plan. The Scoping Document was published on
1
4
th

June 2010 and the consultation period closed on 27
th

July 2010.


Background.


The preparation of

the Local Development Plan is guided and directed by a
range of Acts, Regulations and WAG guidance. These provisions require that a
Sustainability Apprais
al and Strategic Environmental Assessment must be
undertaken to assess the effects that the plan is likely to have. The appraisals are
broad
-
ranging and include social and economic as well as environmental issues.

There are related requirements to assess o
ther impacts including those on
equalities, health and the Welsh language.


The approach to the preparation of the Sustainability Appraisal was considered
by the ECR Board on the 16
th

February 2010 and this included the creation of
an advisory SA Forum.


The Scoping Document sets out baseline information for Neath Port Talbot on
sustainability and environmental matters and outlines how we propose to
undertake the Sustainability Appraisal and other related assessments. It also
covers Habitats Regulations A
ppraisal (HRA). In accordance with the
regulations, consultation was undertaken with the statutory consultees
(Countryside Council for Wales (CCW), Environment Agency Wales (EAW)
and C
ADW
). In addition,

a notice was placed in the local press, information w
as
posted on the LDP web
-
site and copies made available in libraries and Civic
Centres. Community Councils and LDP stakeholders were also informed of the
consultation.


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The
undertaking of the
SA

is proceeding alongside the LDP and a report setting
out its
findings will be produced and published for formal consultation alongside
the Pre
-
Deposit Plan. The Pre
-
Deposit plan will also be assessed to see whether
it would be likely to create significant adverse effects on any Special Area of
Conservation (SAC) suc
h as Crymlyn Bog. A preliminary note on the likely
need to undertake an assessment under the Habitats Regulations will be
published alongside the Pre
-
Deposit Plan and SA findings.



Comments received


In response to the consultation, detailed comments were

received from all three
statutory consultees. In addition, brief comments were received from three
stakeholders.


The main points raised, and responses to these points, are summarised in the
table attached (Appendix A). In addition to the points set out i
n the table,
general comments were made relating to
minor amendments and updating of
guidance and
references
. As this will be an on
-
going process throughout the plan
preparation period it is not proposed to update the scoping document in this
respect, but
current guidance and legislation will be followed as appropriate in
undertaking the appraisals. Similarly, detailed suggestions have been made
about appropriate indicators and targets: these are being reviewed and refined as
an ongoing process, and specifi
c amendments have not been made to the
scoping document at this stage. CCW also made separate detailed comments on
the information included in the chapter on Habitats Regulations Appraisal.
These comments will be taken into account when undertaking the HRA
, which
will be subject to further detailed consultation with CCW.


The main significant points raised relate to the following matters:




Reference should be made to waste water treatment and foul disposal in
the area
. This point is a
ccept
ed



more informat
ion needed

on this matter
which will be researched and taken into account.



The scoping document states that there should be no losses of carbon
from soil and vegetation, but it is not clear how this can be achieved
. It is
accepted that
no

losses of carbon

is unrealistic, but that the aim should be
to
minimise

losses
.



In relation to the Western Wales River Basin Management Plan, the
appraisal should note the key environmental effects which can be
addressed by the plan.

This point is a
ccepted

and the informa
tion will
be incorporated in the appraisal.

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Clarification is required about the ways the LDP could affect water
quality issues
.

This point is a
ccepted

and the information will be
incorporated in the appraisal.



Additional SACs should be considered from the
perspective of possible
water resources issues
.

This point is noted and will be addressed in the
HRA.



A number of additional indicators and targets are suggested
.

The
indicators and targets will be reviewed and amended.


Action
s proposed


It is proposed th
at the comments made and amendments suggested (as set out in
the appendix and outlined above) should be accepted and taken into account
when undertaking the appraisals. Amendments to the scoping document will be
posted on the website.


Recommendation


That

the comments made on the LDP Sustainability Appraisal Scoping
Document be noted and appropriate amendments
, as detailed above,
be made.



Reasons for Proposed Recommendation.


In order to take account of the responses to the draft

SA
Scoping Report.


Fi
nancial Appraisal


The decisions will incur expenditure in relation to the preparation and
publication of the final document and notification procedures. These costs can
be accommodated within existing budgets.


Consultation Outcome


The report addresses
the responses to the consultation on the SA
S
coping
Report.

and its final form reflects the outcome of that process.


Sustainability Appraisal


This report relates to the Sustainability Appraisal of the emerging Local
Development Plan.

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List of Backgroun
d Papers.


Legislation and Regulations:


EU Directive 2001/42/EC on the assessment of the effects of certain plans and
programmes on the environment (The SEA Directive).

Planning and Compulsory Purchase Act 2004.

The Environmental Assessment of Plans and P
rogrammes (Wales) Regulations
2004.


Planning Guidance:

Planning Policy Wales 2010

Technical Advice Notes (TANs)

Sustainability Appraisal of Unitary Development Plans: A good Practice Guide
(WAG 2002)

A Practical Guide to the SEA Directive (WAG/ODPM 2005)

Local Development Plans Wales (2005)

Local Development Plan Manual (2006)


UDP Documents:

The
Adopted
Plan (200
8
)



Wards Affected

All



Contact Officer


Owain Lewis


Planning Policy Manager on 6287 (o.lewis @npt.gov.uk)

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ITEM NO. 2

PART 1. SECTION A.
COMPLIANCE STATEMENT


NEATH PORT TALBOT LOCAL DEVELOPMENT PLAN
SUSTAINABILITY APPRAISAL, HABITATS REGULATIONS AND
RELATED APPRAISALS SCOPING DOCUMENT.




(a)

Implementation of Decisions


The decisions will be implemented after the 3 day call in period.


(b
)

Sustainability Appraisal:



Community Plan Impacts

Economic Prosperity



..

Significant Impacts

Education & Lifelong Learning


..

Significant Impacts

Better Health and Wellbeing


..

Significant Impacts

Environmental & Transport


..

Significant Impacts

Cr
ime and Disorder



..

Significant Impacts

Other Impacts

Welsh Language




..

Sig
nificant

Impacts

Equalities





..

Significant Impacts

Social Inclusion




..

Significant Impacts



(c)

Consultation


The report has been the subject of an internal consultati
on and it reflects the
outcome of that consultation.











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APPENDIX A



Environment Agency

Topic

Consultee Comment

Response

General comments

Need to update various policy requirements and references

Noted


qhis⁷ill b攠慮ngoing
牥ruir敭敮t⁴桲 ug
hout th攠十⁰ o捥ss

2.1 Climate
Change

BAT (use of Best Available Technologies) is a requirement
for regulated industrial processes (p9)

Noted: No amendment to text.

Relevance of accessibility to environmental performance is
unclear (p10)

Note need to c
larify: Text amended
.



Correction and clarification required with regard to flood
map classifications (p10)

Noted: Text amended

Query need for Fig. 2.1.2


in景牭慴ion is too high vel?

䙩gu牥ris⁣onsid敲ed⁴o⁰ ovid攠use晵l
illust牡tion⸠

卨o牥rin
攠䵡nag敭ent⁐lansW⁳uggest⁡ ending⁲ 晥牥n捥c
to⁓ 倠牥mi敷
pNN)

A捣数琺⁔ext⁡ 敮ded

k敥e⁴o⁡dd⁐ort⁔慬bot⁡nd⁃ m慦慮⁡猠晬ood⁲ sk⁡牥 s
identified⁩n⁴h攠䍆j倠⡰ㄱm

A捣数琺⁔ext⁡ 敮ded

k敥e⁴o⁣onsid敲esu牦慣攠a慴敲⁦looding⁡ ⁡湴楣ip慴ed
敦e
散t映 lim慴攠捨慮g攠epNN)

kotedW⁎o⁡ 敮dment to text.

䍯nsid敲慴ion should⁢攠 iv敮 to⁗䙄⁡ dn
-
going
牥ri敷映 onsents⁲ ⁷慴敲⁥et牡捴ion

kotedW⁎o⁡ 敮dment to text.

io捡cionⰠd敳ign⁡nd spe捩fi捡tion映湥眠dev敬opm敮t
⡩n捬uding⁓ua匠pt挩c捯
uld⁢攠 敮tioned⁡s⁷慹s映
慤d牥rsing⁳om攠捬em慴攠ehang攠issues
 NP)

ko⁡ 敮dm敮t⁲ qui牥r
th攠s散tion
牥rates⁴o⁩denti晹ing p牯bl敭sⰠth攠
solutions⁡牥 an⁌a倠m慴t敲e

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Details of transport links likely to be at increased risk from
flooding needed

Accepted. Further information needed.

Refer to BREEAM/Code for Sustainable Homes in relation
to reducing water demand

Not necessary


捯ve牥r by⁲敦敲敮捥cto
d敳ign⁡nd⁳p散ifi捡tion o映f敶敬opm敮t⸠

ko⁲敦敲 n捥cis慤e⁴ ⁃
2

emissions and their imp
acts

Not relevant here


th攠獥etion⁲敬慴es⁴o
th攠probl敭s⁣慵s敤 by⁣汩m慴攠捨慮g攬e
not⁴h攠捡uses映 lim慴攠ehang攮e䍏
2

emissions are dealt with elsewhere in the
chapter.
They are raised specifically in
the indicators and targets.


TAN 15 states tha
t new development should be directed
away from all of zone C, contrary to what is implied in the
text (p14), which should be amended.

The text is not incorrect: amendment is
not considered to be necessary.

The term ‘hillier areas’ is not defined. This pa
牡g牡ph
should⁢攠慭敮d敤
pNR)

qh攠灡r慧r慰h⁲敦敲e in gen敲el⁴ 牭s⁴
th攠敦晥ets o映flim慴攠捨ang攮eko
am敮dm敮t⁩s⁣ nsid敲敤 n散ess慲a⸠

rpland⁡牥 s⁣ uld b攠慦晥et敤 by⁳ 牦慣攠e慴敲⁦eooding

A捣数琠ce敤 to⁣onsid敲⁳u牦慣攠a慴敲e
晬ooding
獥攠慢
ov攩

2.2 Natural
Resources and
Waste

Reference should be made to PPW which promotes the use
of brownfield sites.

Reference is made to PPW

Sites for waste disposal/recovery/recycling should be
indicated in line with the Regional Waste Plan.

Reference is
made to existing sites: the
identification of new sites is a matter for
the LDP.

Recommend that minerals, wind, waste and contaminated
land are looked at separately, but included as policies
within the deposit plan

Noted: policies are a matter for the L
DP


The LDP should identify actions to address pressures on
the water catchment area.

Noted


愠a慴t敲⁦o爠rh攠ea倮m

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Reference should be made to waste water treatment and
foul disposal in the area.

Accept


mo牥⁩rform慴ion敥d敤.


ko⁩湤i捡tion⁩s
m慤攠潦⁨ow⁴h攠eutho物ty⁩ t敮ds to
慤d牥rs th攠e慩lu牥⁴o m敥e⁗䙄 j散eives⁦潲′MNRⰠo爠
wh慴 steps⁷ill⁢攠瑡k敮⁴o⁩ p牯v攠eh攠und敲standing映
th攠捡cses⸨.OO)

eow⁴ 攠obj散eiv敳 o映瑨攠e䙄⁡牥
慤d牥rsed⁩s⁡ m慴t敲e景爠rth敲⁳t牡tegi敳
慮d⁰l慮sⰠi
ncluding⁴h攠ea倮m䥮⁲ l慴ion
to und敲st慮ding⁴h攠捡cs敳Ⱐadvic攠慮d
info牭慴ion is⁡ aited⁦牯 ⁴ 攠eA
this慴t敲e

䥴⁳hould b攠
highlight敤

that⁦ ilu牥rto敥e⁷慴敲equ慬ity
obj散tivesay⁨慶攠empli捡cions⁦潲⁌a倠慬lo捡tions

䥴⁩s⁣ nsid敲敤 th
at⁴his⁩s⁩ pli捩t⁩n⁴h攠
十⁰牯c敳s⁴hroughout.

t慴敲⁡eailability


a⁲敶楥 映 bst牡rtion⁣潮獥nts⁩s
捵牲rntly⁢敩湧 und敲t慫敮Ⱐwhich⁷ill t慫攠楮eo⁡捣ount
th攠e䙄⸠⁁v慩l慢ility映 慴敲⁲esou牣敳 may⁨慶攠
impli捡tions⁦o爠ra倠慬汯捡tions.

koted


䥴⁩s⁳tat敤 th慴 th敲攠ehould b攠eo loss敳 o映捡牢on⁦牯
soil⁡nd⁶ getationⰠbut it is not⁣l敡爠how this⁣ n⁢攠
慣aiev敤.

A捣数琺⁔ext⁡ 敮ded.

koted⁴hat⁧ood qu慬ity⁳ ils⁡牥 lo捡t敤 pa牴i捵l慲ly⁩ ⁴h攠
䵡牧慭⁡牥愮 qh敳攠慲敡a should b攠灲ot
e捴ed⁦牯
dev敬opm敮t.

kotedW⁡ m慴t敲⁦o爠th攠ea倮m

䥴⁩s⁩ plied that⁲敭敤i慴ion o映fh攠䉐e䉡glan⁡nd
il慮d慲捹⁳楴敳 is 捯mpl整攬ebut⁩t⁩s stilln
-
going⸠
剥捯mm敮d⁡ 敮dm敮t
.

A捣数琺⁔ext⁡ 敮ded.

The term ‘decontamination’ should be replaced b

‘remediation to be fit for purpose’

A捣数琺⁔ext⁡ 敮ded.

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Objective C (p33) should be broadened to encourage
resource efficiency and the use of secondary and recycled
materials.

No change: the objective is to reduce
waste


牥sou牣攠敦晩ci敮捹⁡湤

捹捬ing⁦敥d⁩nto this obj散tiv攮

lbj散eiv攠䌠should b攠瑯 driv攠east攠e慮慧敭敮t⁵p⁴h攠
w慳t攠hi敲慲ehy⁴ ⁧iv攠e牥晥牥nc攠eo⁷慳t攠牥euctionⰠ牥
-
us攬e牥捹捬ingⰠ牥rove特⁡湤⁦楮慬ly⁤ sposal.

qhis⁩s⁩nco牰o牡ted⁩n⁴h攠ebj散tiv攠to
minimis攠e慳t攮

2.
3 Biodiversity
and Geodiversity

It should be indicated that conifer plantations are known to
be ecologically poor and increase the acidity of water in
their catchments.

Accept: Text amended.

Inappropriate development should be identified as a cause
of ha
bitat decline in the table on p43

Accept: Text amended.

Poor air quality should be included as a threat to habitats

Accept: Text amended.

No commitment has been made to create new habitat

No change: this is a matter for the LDP.

Objective A (p44) sh
ould be amended to remove ‘net’ and
replace ‘biodiversity’ with ‘habitats and species’

qh攠eording⁲敦 散es th攠gove牮m敮t
biodiv敲sity⁴慲 et


no⁣hang攮e

2.5 Pollution

In addition to the official monitoring station, a network of
other monitoring statio
ns are located around the Taibach
Margam AQMA

Noted

A trend line should be added to fig 2.5.1 to show the
downward trend of results.

Not accepted


th攠杲慰h⁤oesot show
愠捬a慲at牥nd


䥴⁩sⁱu敲ied⁷heth敲enitrog敮 dioxid攠eonitoring⁨慳
begun
pR8
)

qhis⁩s⁣ v敲敤 in tabl攠

䥤enti晹 m敡eu牥r being tak敮⁷ithin th攠en䵁⁴
慤d牥rs⁡i爠ruality⡰SO)

a整慩lot⁣ nsid敲ed⁴ b攠湥捥ss慲a

s敲e⁦楮攠灡rticul慴敳
偍
2.5
) and Polycyclic Aromatic
Hydrocarbons (PAH) have been recognised as future
polluta
nts of concern in NPT. How will these be taken into
account?

Information not currently available.

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The SA objectives are weak. ‘Acceptable’ levels need to be
d敦ined.

qh攠ebj散eiv敳⁡牥⁩nt敮d敤 to b攠
gen敲elⰠwitho牥⁳灥捩fi挠c敦enition o映
t敲es⁩ ⁴he

indi捡cors⁡ d⁴慲a整s⁴ bl敳⸠

3.1 Health Impact
Assessment

Recommend that the HIA includes the effects of pollutants
on health

Noted.

Appendix B:
Indicators and
Targets



1. Climate Change

Indicator A: Flood risk areas should be defined as area C2

Not accepted: there is flood risk in other
areas that needs to be considered.

Increased risk of surface water flooding should be
identified

Needs to be included in chapter: See
above

Target A: change to ‘…unless shown to be
acceptable

by a
FCA

Accept

Increased use of SuDS should be included as a target

Not accepted
-

Now part of national
legislation

2. Resources and
Waste

Indicator A: 30 dwellings per ha appears high

This is the standard density requirement:
follows UDP/national policy.

Indicato
r B: Amend ‘decontaminated’ to ‘remediated’(see
慢ove⤮

A捣数c

Additional⁩ndic慴ors sugg敳ted

A捣数琬cwithodific慴ion

q慲aet⁂㈠should⁢攠em敮ded⁴o⁲敦l散t⁴h攠e䙄⁴慲 整映
S4B⁷at敲⁢odies good ov敲ell status.

kot⁡捣数ted⸠qhis⁩s th攠e䉍倠t慲ae
t⸠
qh攠eA⁨慳 stated⁴h慴⁴h攠e䙄⁴慲 et⁩s
not⁡ hi敶慢l攮e

3. Biodiversity and
Geodiversity

Query whether targets(A&B) are achievable

It is considered that while they are
challenging, the targets could be
achieved (see comments on use of term
‘net’ abov
攩e

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Additional suggested target: New habitat creation.

Noted

Additional suggested target: maintenance and protection of
wildlife corridors

Not accepted: the creation of corridors is
a matter for the LDP

5. Pollution

Amend objective A to read “achiev
攠湡tion慬Lbu牯p敡n
standards of air quality…”

A捣数琠

7. Health and
Wellbeing

Inclusion of Indicator B welcomed

Noted

Target B1a


should⁩denti晹⁴ 慴 th攠物sk and
捯nsequen捥s映 looding⁣慮 b攠牥du捥d by⁤ 牥rting n敷
dev敬opm敮t⁡ 慹⁦ om⁡牥慳
f flood risk ….

kot⁡捣数ted⸠
tays映牥du捩ng th攠物sk
慲a

m慴t敲
s

fo爠rh攠ea倮


qh攠eumb敲e⁰lanning⁡ppli捡tions⁅At j散t⁴on
晬ood⁲ sk⁧ ounds⁣ould⁢攠愠pot敮ti慬 indi捡cor

kot⁡捣数ted⸠qhis⁷ouldnly⁲敦 散t
th攠numb敲e⁰l慮ning⁡ppli捡t
ions
submitted
not⁴h攠敦晥捴iveness o映fa倠
poli捩敳
.

qh攠eumb敲e⁩nciden捥s⁷h敲攠inte牮al⁦looding⁦ om
s敷敲eg攠e慳 o捣u牲rd⁣ uld b攠愠potential⁩湤楣慴or

koted

q慲aet‱b


en敲gy⁥晦 ci敮t⁴散enologi敳Ⱐ慣aieving 愠
捥牴ain vel映 剅bA䴠景爠慬
l敷 dev敬opm敮ts⁷ould
h敬p⁡ hiev攠ehis⁴慲a整.

koted


愠a慴t敲⁦o爠rh攠eam

Countryside Council for Wales

Topic

Consultee Comment

Response

General Comment

It should be noted that the SEA Regulations do not allow
for significant negative environmenta
l effects to be
‘balanced’ against positive social or economic effects.

koted

2.1 Climate
Change

Additional international policies/legislation references
suggested

Noted

Additional national policies/legislation references
Noted

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suggested

Need for exp
licit mention of the role of planning in
reducing the need to travel (with supporting objectives and
indicators)


牥映南t䥔䍈⁒qm

A捣数琺⁔ext⁡ 敮ded.

Suggest the objective of taking into account ‘likely future
changes from climate change’ should be st
牥rgthened⁴o
include the aim of ‘climate proofing’

kot
慣a数tedW⁣hange潴⁣ nsid敲敤 to
b攠e散essa特.

Objective B should be amended: ‘Achieve government
t慲g整s⁦o爠牥du捩ng g牥敮hous攠g慳⁥ issions
with a
particular focus on reducing emissions from
buildings,
transport, energy generation and industry
(Mitigation)’

kot
慣a数tedW⁣hange潴⁣ nsid敲敤 to
b攠e散essa特.

Objective C should be amended: ‘Make the area’s
慰p牯priat攠捯nt物bution to
renewable

national energy
production (Mitigation)’

kot⁡捣
数tedW th攠十⁳桯畬d⁣ nsid敲e
th攠imp慣as o映fll⁦orms映敮敲ey
p牯duction.

Additional⁩ndic慴ors 慲攠auggest敤

koted

2.2 Natural
Resources and
Waste

Additional policies/legislation references suggested

Noted


The SEA will need to note the key enviro
nmental effects
which relate to the LDP process and to ensure that these
are addressed by the plan

Noted

Clarification is required about the ways the LDP could
affect water quality issues.

Accept: Text amended.

There should be more explicit reference t
o the importance
of bathing water quality, including reference to the EU
bathing waters Directive.

Accept: Text amended.

Further consideration should be given to the role of soils in
flooding and carbon sequestration (cross ref climate
change)

Noted

F
ig 2.2.3 requires a legend for the y axis

Not considered necessary

The section on water availability should be cross
Generally cross referencing has been
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referenced to the climate change section

avoided due to the holistic nature of the
SA

Additional S
ACs should be considered from the
perspective of possible water resources issues.

Noted


will⁢攠 dd牥ssed⁴hrough⁈剁.

Additional⁩ndic慴ors 慲攠auggest敤

koted


2.3 Biodiversity
and Geodiversity

Additional policies/legislation recommended to be added

Noted

An indicator and targets should be identified to encourage
greater connectivity.

Noted

It is recommended that indicators and targets should be
positive and aspirational: examples suggested

Not accepted: it is considered that
indicators/targets a
re worded
appropriately.

2.4 Landscape,
Townscape and
Historic Character

Suggest reference to World Heritage Convention

Not accepted: not directly relevant to
NPT

Additional policies/legislation recommended to be added

Noted

Indicators for landscape s
hould be more proactive and
positive: amended SA objective for landscape is
recommended: ‘To steer landscape
-
sc慬攠d敶elopm敮t⁴hat
is appropriate to Landmap classifications.’

kot⁡捣数ted
-

慮⁌a倠潢j散tive

bxplicit⁲敦敲敮c攠ehould⁢攠 慤攠eo⁴h攠e慣a

that
p牯t散tion映污ndscap攠e牯vides⁰牯t散tion⁦潲 biodiv敲sity
慮d⁧ odiv敲sity.

d敮敲elly⁣牯獳⁲敦敲敮cing⁨慳 b敥n
慶oided⁤u攠eo th攠holisti挠n慴u牥ro映th攠


Additional⁩ndic慴ors 景爠r慮ds捡p攠慲攠sugg敳ted

koted

2.5 Pollution

Additional poli
cies/legislation recommended to be added

Noted

2.7Health and
Wellbeing

Reference to Local Authority’s rights of way improvement
p牯g牡rm政

kot⁡捣数tedW too d整慩l敤


would⁢攠
捯v敲ed⁢ ⁴ 攠eommunity⁃潨esion
indi捡tors⁡nd th攠桥alth⁩ndic慴ors⁂㜠
慮d
䈱M

Appendix A: Goals
compatibility
Amendment to wording suggested in relation to the
assessment of biodiversity and geodiversity objectives
Not accepted that wording should be the
same as elsewhere in the table, but tex
t
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matrix

against economic objectives

amended to clarify.

General comment

Suggest reference to WAG’s emerging Natural
bnvi牯nm敮t⁆牡 敷o牫 慮d⁴h攠牥lated⁅捯syst敭s
doods⁡nd⁓敲vic敳⁡gend愮

koted


Cadw

Topic

Consultee Comment

Response

2.4 Landscape,
townscape and
historic character

R
eference should be made to non
-
designated
archaeological sites and historic buildings of local
importance and the desirability of preserving them.

Accept: Text amended.

Reference should be made to the Historic Environment
Record

Accept: Text amended.

S
uggest possibly adding reference to Wales Spatial Plan

Not accepted: No direct relevance.

Additional information will be available in due course
regarding Scheduled Ancient Monuments at risk

Noted

References to historic
heritage

should be changed to
hi
storic
environment
.

Accepted: Text amended.

Additional targets are suggested

Noted

The Theatres Trust

Topic

Consultee Comment

Response

2.6 Community
Cohesion

Suggest wording of Objective B be amended to: “Protect
慮d⁥ han捥c
th攠捵ltu牥⁡rd⁣ 慲慣t敲

sports and cultural
facilities
,
the natural and cultural assets

of communities
including cultural resources and the Welsh language.”

kot⁡捣数tedW th攠潲iginal⁷ording⁩s
捯nsid敲ed⁴o⁲敬慴攠a捣c牡tely⁴ ⁴h攠
ov敲慬l goal.