Preferred Strategy

Comment

Representation ID: 28172

Received: 30/09/2019

Respondent: Natural Resources Wales

Table B2.1 European table to update Habitats Directive, the SA Framework is advised to consider:

(i) the management of European Sites;
(ii) Planned provision and management of stepping stone and linear habitats (Article 10);
(iii) Protection of European Species (Article 12);
(iv) Prevention of incidental capture killing (Article 15);
(v) Derogation in respect of European protected species

Noted.

Comment

Representation ID: 28173

Received: 30/09/2019

Respondent: Natural Resources Wales

Table B2.1 National (Wales) Table to be updated to reflect EU Invasive Alien Species Regulations 2014 and Invasive Alien Species (Enforcement and Permitting) Order 2019

Table B2.1 Add reference to the Conservation of Habitats and Species Regulations 2017; Wildlife and Countryside Act 1981

Table B2.1 Local (CCBC & Neighbouring Local Authorities)

We advise that the Biodiversity, Flora and Fauna Conwy Local Biodiversity Action Plan should be updated to reflect the provisions of the Environment (Wales) Act 2016

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

Comment

Representation ID: 28174

Received: 30/09/2019

Respondent: Natural Resources Wales

Section B.3. Review of National Planning Policy Requirements

Table B2.2. Review of PPW - 10th Edition (2018)

We advise additions including Conservation of Habitats and Species Regulations 2017 in respect of Regulation 10 duties in respect of wild birds and EU Invasive Alien Species Regulations and the Invasive Alien Species (Enforcement & Permitting) Order 2019

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

Comment

Representation ID: 28175

Received: 30/09/2019

Respondent: Natural Resources Wales

Table B2.3 Implications of other Welsh National Planning Policies, Advice and Guidance

We advise that updated RLDP policies:

(i) Include clear references to conservation status;
(ii) Include clear references to the consideration of long term issues including but not limited to tenure, resource provision, management and wardening;
(iii) Consider incidental capture killing issues;
(iv) Consider long term surveillance.

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

Comment

Representation ID: 28176

Received: 30/09/2019

Respondent: Natural Resources Wales

Appendix C Table C1.1 - Proposed SA Framework for the LDP review

Under the "proposed SA guide Questions - will the replacement LDP..."

We advise the addition of the word maintain or restore the current conservation status of protected or threatened habitats and species to defined favourable levels at local and county borough spatial scale

And recommend the inclusion of the following point:

Prevention, Eradication or control of invasive non-native species, these actions contribute to measures that help achieve the favourable conservation status for identified habitats and species.

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

Comment

Representation ID: 28177

Received: 30/09/2019

Respondent: Natural Resources Wales

Under the "Proposed Sustainability indicators for candidate site assessments"

We recommend the inclusion of the following points:

Evidence based maintenance or restoration of protected or threatened habitats and species to their favourable conservation status

Evidence based reduction or prevention of incidental injury or killing of protected and threatened species during construction and operational phases of development schemes

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

Comment

Representation ID: 28178

Received: 30/09/2019

Respondent: Natural Resources Wales

Table D2.2 Compatibility Matrix to Assess Replacement LDP vision and objectives

9 Biodiversity - Regarding SO 10 Support for renewables we would highlight issues concerning the prevention of incidental injury or killing of bats by wind turbines. Article 15 of the Habitats Directive concerns the monitoring and prevention of incidental capture or killing of European species

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

Comment

Representation ID: 28179

Received: 30/09/2019

Respondent: Natural Resources Wales

Flood risk is a significant issue for CCBC and the RLDP and there is no strategic objective (SO) below the vision itself to tackle this issue at the strategic planning scale. Ideally the SO objectives should form a smaller set of objectives. The revision or addition of an SO within the RLDP will require the refinement of the wording in the SA objective. There is an absence of local flood risk evidence within the baseline.

Noted: This will be covered in the RLDP.

Comment

Representation ID: 28180

Received: 30/09/2019

Respondent: Natural Resources Wales

It should be clearly noted within the SA framework that Welsh Government are in the process of reviewing and issuing a new TAN 15: Development and Flood Risk and whilst there are no specific timescales. The publication is likely to impact on the development of the RLDP prior to submission to Welsh Government. The iterative SA process should be used to take account of evidence updates and be closely monitored, to update the RLDP.

There is no strategic objective on flood risk within Table 5.1.

Noted.

Comment

Representation ID: 28181

Received: 30/09/2019

Respondent: Natural Resources Wales

Table B2.1 Review of other Relevant Plans, Programmes and Strategies

Review of relevant plans and programmes Table B2.1 on EU, UK legislation and national are correct. However, local legislation has some gaps - please refer to our scoping report comments, together with any changes to the evidence base as this will need updating.

Accepted: Text will be amended.