2.5

Sylw

ID sylw: 28187

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Background Paper 04: SA/SEA of Preferred Strategy Non-Technical Summary

European Protected Species

2.1 Key Sustainability Issues SEA topics

Biodiversity, Flora & Fauna

NRW advise the addition of the word 'restore' into the first sentence: "The need to conserve, restore, protect and enhance biodiversity including important species and sites designated for reasons of biodiversity conservation or ecological importance". ....

Noted. Text will be amended to clarify the approach in the RLDP.

Sylw

ID sylw: 28188

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

SA Objective 5 - Housing

Land use change needs to consider biodiversity and mechanisms should be considered that facilitate the long-term management of biodiversity with an emphasis on protecting and enhancement. Management may be required to facilitate the maintenance; creation, restoration or enhancement of habitat and their associated or component species.

Noted. Text will be amended to clarify the approach in the RLDP.

Sylw

ID sylw: 28189

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

SA Objective 9 - Biodiversity

4.4.27 Bullet point 3 should read "Conserve, protect, 'restore' and enhance site designated as national and local levels for reasons of ecological importance or biodiversity conservation.

Bullet point 5 should read "Protect and enhance the green infrastructure network, 'including stepping stone and linear habitats in the long term'."

Noted. Text will be amended to clarify the approach in the RLDP.

Sylw

ID sylw: 28190

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Flood Risk

Appendix D - Strategic objectives within the RLDP have not been reviewed as there is no strategic objective for the RLDP identified on flood risk. This needs to be revised and included.

Noted. Text will be amended to clarify the approach in the RLDP.

Sylw

ID sylw: 28191

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Appendix E- Growth Options suggests there is lots of uncertainty and this assessment needs to be revisited once the above points have been addressed.

Noted.

Sylw

ID sylw: 28192

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Policies SP23, SP24, SP25, SP26 have been identified for flood risk, but it is unclear what details are included and they do not reflect the RLDP vision and the final SA objective.

Noted. Text will be amended to clarify.

Sylw

ID sylw: 28193

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Background Paper 34: Strategic Flood Risk Assessment

This document is referenced in the PS evidence document but is unavailable on the RLDP website. However, NRW have previously made comment on this background paper and our response can be found under ref: CAS-74411-S6S9.

Noted

Sylw

ID sylw: 28194

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Background Paper 35 Flood Risk and Development Opportunities (July 2019)

The report concludes with 10 bullet points which would seem reasonable and in line with the content of the report and the minimum requirements as indicated in TAN15. We would however advise that although ground raising may be a form of flood mitigation, impacts elsewhere will need to be considered and where site allocations are in close proximity/same flood cells, then the cumulative impacts may provide further detriment than raising of individual sites; this would need further modelling/assessment.

Noted.

Sylw

ID sylw: 28195

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Background Paper 35 Flood Risk and Development Opportunities (July 2019)

The Background Paper only refers to one site (Gwellyn Avenue). Raising sites above the design flood event may be an acceptable form of mitigation (if no increases in flood risk (depths and extent) are shown elsewhere), however as part of this RLDP process the cumulative effects must be shown for site raising for other site allocations along this frontage/flood cell.

Noted. Text will be amended to clarify the approach.

Sylw

ID sylw: 28196

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Background Paper 37 Minerals

The paper covers all the essential elements preventing pollution and protecting groundwater resources and quality and land contamination.

Noted.

Sylw

ID sylw: 28197

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Topic Paper 6 Natural Environment

Section 6 - Updated Evidence base

Green Wedge Assessment should cross reference with Article 10 of Habitats Directive/Regulation 41 of Conservation of Habitats and Species Regulations 2017.

Noted.

Sylw

ID sylw: 28198

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Topic Paper 6 Natural Environment

Policy NTE/3 - Biodiversity

Again, "New development should aim to maintain, 'restore' conserve and where possible, enhance biodiversity through"

Whenever European Protected Species are present statements to include Current Conservation Status (CCS) and Favourable Conservation Status (FCS) of the species will should be required.

Again, no reference is made to invasive non-native species or biosecurity.

Noted. Text will be amended to clarify the approach.

Sylw

ID sylw: 28199

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Topic Paper 9: Renewable Energy

Reference is made to climate change impacts on flood risk in this paper. Welsh Government advise that CL-03-16 - Climate change allowances for Planning purposes should be used. The guidance also contains details of when to use High++ allowances for peak river flow and mean sea level e.g. where developments that significantly change existing settlement patterns/developments that are very sensitive to flood risk are proposed.

Accepted. Text will be amended to clarify the approach.

Sylw

ID sylw: 28200

Derbyniwyd: 30/09/2019

Ymatebydd: Natural Resources Wales

Topic Paper 9: Renewable Energy

We note that within this paper reference is made to the Joint Flood Risk Protocol. The protocol was produced to address development proposals in the Coastal East area of the county which is subject to flood risk and has been in existence for a number of years. We note that CCBC propose to revise this document as part of the RLDP. The RLDP should consider the possible changes to TAN15 following consultation later this year, which is likely to change the current protocol.

Noted. CCBC will work with NRW on any change to the protocol.