Appendix 5: SA/SEA Scoping Report – Representations Received



Calon Cymru Network – Patricia Dodd Racher

General Comments

A great deal to approve of in this scoping study, especially the determination to accord with the Well-Being of Future Generations (Wales) Act 2015.


In addition, explicit reference to the Environment (Wales) Act 2016 would be helpful, so that the LDP can be assessed against the minimum emissions reductions specified in the Act.

Accepted. Explicit reference to be added.

Natural Resources Wales – Sharon Luke

General Comments

Having reviewed your Draft Scoping Report dated July 2018 we are satisfied with your scope for the SA report. As indicated in the scoping report, you have noted that the SA is an iterative and on-going process. We agree and would add that the SA/SEA should be a live document. This is particularly important when you consider that environmental baseline data is evolving, and other plans and programmes are emerging as a result of new legislation. The SA/SEA should therefore be kept under review throughout the LDP preparation.

Noted – SA/SEA will be reviewed and updated in line with developing baseline data and emerging policy, plans and programmes.

The scope and methodologies proposed for the SA seem reasonable. The scope has identified the likely environmental characteristics effected by the LDP and recognises the existing environmental problems within the LDP area.


The SA objectives noted in Chapter 6 (SA/SEA framework) and Table 3 of Chapter 5 should provide a robust assessment of environmental impacts from the LDP strategic options.


We advise that the SA indicators and targets (table 4) seem usable although would recommend the following points are considered.

SA Objective 2 Biodiversity

·         Objective to promote resilience of ecosystems to encompass avoiding the damage or fragmentation of designated sites, habitats and protected species and to encourage connectivity.





Accepted. Objective reworded to included reference to connectivity and resilience:

2-1 To promote resilience of ecosystems by avoiding the damage or fragmentation of designated sites, habitats and protected species and to encourage connectivity.

SA Objective 3 Air Quality

·         Consider the use of improve alongside reduce in objectives 3-1 and 3-2.

·         Include cumulative impacts.

Accepted. Objectives reworded to read:

3-1 To maintain and improve the levels of the UK National Air Quality pollutants


3-2 To improve levels of ground level ozone

SA Objective 5 Water

·         We advise that Objective 5-5 should also include reducing the impact of flood risk.

·         The decision-making influences could include – Will the LDP reduce/increase the risk of bathing waters reaching Blue Flag status?

Accepted. Objective reworded to read:

5-5 To make space for water, and minimise and reduce flood risk



SA Objective 7 Soil

·         The LDP should not increase contamination we would advise this is removed. 

Accepted. Objective reworded to read:

7-1 To promote the regeneration of contaminated land.

SA Objective 9 Landscape

·         Cumulative impacts should be included.

·         Geological heritage should be included. 

·         Areas within Carmarthenshire are in view of the Gower Area of Outstanding Natural Beauty.

Accepted. Wording of Objective issues and opportunities changed to include reference to cumulative effects, geological heritage and potential trans-boundary impacts with Gower Area of Outstanding Natural Beauty.

Appendix A: Review of relevant plans, policies and programmes

We would advise that the following are also included.

·         Urban Waste Water Treatment Directive 91/271/EEC.

·         The Groundwater Directive 2006/118/EC.

·         The Bathing Waters Directive 2006/7/EC.

·         The Water Resources (Control of Pollution) (Silage, Slurry and Agriculture Fuel Oil) (Wales) [‘SSAFO’] Regulations 2010.

·         Memorandum of understanding for protection of Carmarthen Bay and Estuaries European Marine Site.

·         Under PPW Technical Advice Note (TAN) 15 we advise you include Chief Planning Officers (CPOs) letter 23/8/16 CL-03-16 Climate change allowances for planning purposes.

·         Under PPW Technical Advice Note 5 we advise you include CPOs letter 1 March 2018 European Protected Species Licensing – notice of revised procedure.

Accepted. Will add to Appendix A.

Appendix B: Baseline Information

The baseline information to be collected appears to be thorough.  Please note that NRW have duties under the Environment Act (Wales) 2016 and the Well-being of Future Generations (Wales) Act 2015 which will result in the preparation of further evidence. This evidence should be used in the SA/SEA, if timeframes allow.

Noted. Further baseline information as a result of NRW’s duties will be included as and when available.

Chapter 2

The River Cleddau Special Area of Conservation should be included under European sites.

The River Cleddau was included in the table of European Sites under paragraph 2.4.

Chapter 3

Air Quality consideration should be given to cumulative impacts/effects.

Accepted. Baseline information will be updated to consider cumulative impacts.

Chapter 5

In section 5.5 consideration to the proliferation of intensive poultry and pig should be included alongside dairy.




Accepted. Baseline information will be updated to consider poultry and pig farming.

Section 5.6 refers to a map identifying the bathing waters which is not included.

Accepted. Map to be included.

Flood risk – Welsh Government are currently reviewing TAN 15 which should be completed with your timescales. For Section 5.13 Welsh Government have also stated that climate change is to be considered which is not currently mapped

Noted. Baseline will be updated with any new publication of TAN 15.


Other matters to consider

Drainage infrastructure

Memorandum of Understanding requirements for protection of the Carmarthen Bay and Estuaries European Marine Site.

Accepted. Section on drainage infrastructure will be included as part of the baseline information.

Prevention of the proliferation of private foul drainage systems by ensuring appropriate infrastructure in areas identified for growth for the protection of water (and soil) quality.

Opportunities sustainable drainage systems can bring to ecosystems. 

Renewable Energy

The Brechfa Forest Strategic Search Area (SSA) G and Pontardawe SSA E.

Accepted. Section on renewable energy will be included as part of the baseline information.

Incorporating a Sustainable management of natural resources (SMNR) approach.  SMNR is defined in the Environment Act as “using natural resources in a way and at a rate that maintains and enhances the resilience of ecosystems and the benefits they provide. In doing so, meeting the needs of present generations of people without compromising the ability of future generations to meet their needs, and contributing to the achievement of the well-being goals in the Well-being of Future Generations Act.

Noted. Will consider ways to incorporate this into the Deposit SA.