Preferred Strategy

Comment

Representation ID: 28152

Received: 30/09/2019

Respondent: Natural Resources Wales

The preferred strategy makes no mention to Invasive Non-native Species (INNS) and Biosecurity for Invasive non-native species.

The PS does not mention or appear to consider Favourable Conservation Status and the other derogation criteria listed under the provisions of Article 16 of the Habitats Directive along with Birds Directive wider countryside actions listed under the provisions of Article 3 and 4(4) of the Birds Directive/ Regulation 10 of the Conservation of Habitats and Species Regulations 2017.

Noted. Text will be amended to clarify

Comment

Representation ID: 28153

Received: 30/09/2019

Respondent: Natural Resources Wales

We fully support the priority in the policy when considering the cumulative effects of incremental development.

As you are aware, TAN15 is due to be revised by Welsh Government. In advance of this, Welsh Government have now published for consultation The Draft National Strategy for Flood and Coastal Erosion Risk Management in Wales, which is available via this link.

Noted. Text will be amended to clarify

Comment

Representation ID: 28154

Received: 30/09/2019

Respondent: Natural Resources Wales

We note that para 2.50 refers to defence improvements and a hold the line (HTL) policy. The HTL would refer to the shoreline management plan policy option of maintaining the existing coastal defences (rather than improvements). We have not been party to any discussions regarding such improvement works, although we appreciate this may be at an early stage. We would advise that TAN15: Development and Flood Risk states ".... government resources for flood and coastal defence are directed at reducing risks for existing development and are not available to provide defences in anticipation of future development...".

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

Comment

Representation ID: 28155

Received: 30/09/2019

Respondent: Natural Resources Wales

5.3.7 states that "...Development should not normally be proposed in coastal locations unless it needs to be on the coast....". We would remind you that TAN15 specifies (in para 5.3 of the TAN) exceptions to this.

Accepted. Text will be amended to clarify

Comment

Representation ID: 28156

Received: 30/09/2019

Respondent: Natural Resources Wales

The relevant sections of the preferred strategy cover all the essential aspects for preventing pollution and protecting groundwater resources and quality and land contamination.

Noted.

Comment

Representation ID: 28157

Received: 30/09/2019

Respondent: Natural Resources Wales

We note and welcome the reference to the Welsh National Marine Plan (WNMP) but would recommend that CCBC refer to the final version of the plan, when published, in order to satisfy that the final policies have been referred to rather than those that were consulted on in 2018.

Noted. Text will be amended to clarify

Comment

Representation ID: 28158

Received: 30/09/2019

Respondent: Natural Resources Wales

Whilst a tidal lagoon has the potential to offer significant amounts of low carbon energy, there is currently insufficient evidence to be confident that a very large scale tidal lagoon can be developed without a significant impact to the environment. Whilst legal protections for the environment provide mechanisms for projects that have large scale impacts to proceed on a public interest basis, it will be very difficult to meet the tests of such derogations in the absence of a clearer sectoral policy framework for tidal lagoon developments.

Noted. Text will be amended to clarify

Comment

Representation ID: 28159

Received: 30/09/2019

Respondent: Natural Resources Wales

In addition to highlighting the community benefits and ownership needs of any onshore works associated with offshore development (section 6.7.32), the RLDP should also consider the implications of the onward transmission of electricity from offshore renewable energy development. This will be especially important if the proposals for new large scale offshore wind development by The Crown Estate, which are at a very early stage, are taken forward.

Noted. Text will be amended to clarify

Comment

Representation ID: 28160

Received: 30/09/2019

Respondent: Natural Resources Wales

We welcome the fact that the Sustainable Management of Natural Resources (SMNR) has been explicitly addressed in the RLDP in several places. It also appears that the PS as a whole addresses many of the principles of SMNR without explicitly highlighting them.

Please note that the North West Area Statement is due to be completed by 31 March 2020.

Noted.

Comment

Representation ID: 28161

Received: 30/09/2019

Respondent: Natural Resources Wales

The PS states that 'the Council will put in place a framework to ensure that the Sustainable Management of Natural Resources (SMNR) Principles, Natural Resource Policy, 'State of Natural Resources Report' and 'Area Statements' are positively contributed to.' This would benefit from some further clarification on how this will be achieved and utilised /used.

Noted.