Review Report

Comment

Representation ID: 27261

Received: 09/01/2018

Respondent: CCBC

While it is acknowledged that Tir Llwyd is unlikely to demonstrate compliance with TAN15 requirements when considering 75 years of climate change, present day risk to the site is generally acceptable. However, given that the site is at lower risk than
most of the community which it serves there is clear over-riding justification for development of the site to support the community until such time as it may stop being viable to protect the area.

Noted. Recent planning decisions have supported employment development on Tir Llwyd and this will be taken into account as part of the LDP Review.

Comment

Representation ID: 27262

Received: 09/01/2018

Respondent: CCBC

SuDS policy NTE/8 needs to be updated to fully align with Welsh Government SuDS Standards. These standards are likely to become statutory in 2018 with the introduction of SuDS Approval Boards (SAB).
While current policy NTE/8 (if enforced correctly - which is often not the case) matches the standards in most regards the primary requirement for maximising rainwater harvesting is not reflected in NTE/8.

Noted. Officers suggest deleting the policy if otherwise a statutory requirement.

Comment

Representation ID: 27263

Received: 09/01/2018

Respondent: CCBC

There is no indication of the criteria for green, amber, red status.

Noted. The appendix is a summary of the findings of the AMR where full details can be found of the criteria for the indicators.

Comment

Representation ID: 27264

Received: 09/01/2018

Respondent: CCBC

MI/0064 - With increasing guidance and understanding of SuDS over recent years ERF comments have increasingly identified failure to meet policy NTE/8 but without the corresponding enforcement of the policy.
In the period since 2016 we are aware of numerous permissions being granted against advice on NTE/8 and would expect this to be an indicator that will be flagged as red during the next review.

Noted. Policy will be amended.

Comment

Representation ID: 27265

Received: 09/01/2018

Respondent: CCBC

NTE/8 - Since adoption of the LDP there has been new CIRIA SuDS Guidance, Welsh Government SuDS Standard and the upcoming commencement of Schedule 3 of the Flood & Water Management Act. NTE/8 is currently not enforced in order to function effectively and needs amendments to align with current best practice and policy as per our comments.
There is potential to highlight how SuDS can contribute to CFS/11, CFS/13, NTE/3 & NTE/10

Noted. Policy will be amended.