Preferred Strategy

Comment

Representation ID: 28182

Received: 30/09/2019

Respondent: Natural Resources Wales

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

Table B2.3: the summary of TAN 15 is not correct. Please note that TAN 15 directs development away from Zone C and is based on Development Advice Maps (DAM). There is no reference to strategic approach required by RLDP, justification and acceptability tests, these need to be re-written and summarised succinctly to support the SA objective/framework.

Accepted: Text will be amended.

Comment

Representation ID: 28183

Received: 30/09/2019

Respondent: Natural Resources Wales

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

Appendix C, C1.1: SA10 is required to be re-worded and more reflective of the revised objective and consequently the SA questions and indicators are not currently sufficient.

Noted.

Comment

Representation ID: 28184

Received: 30/09/2019

Respondent: Natural Resources Wales

Table A3.1 Review of Relevant Environmental Aspects, Issues and Problems

Mineral extraction: in addition to referencing the potential to affect hydraulic pathways and landscape, consideration should also be given to the risk of potential land contamination and associated water quality.

The North Wales Coalfield comprises the Flintshire Coalfield in the north and the Denbighshire Coalfield in the south. It extends from the Pont of Ayr through Wrexham to Oswestry, and there is also a small area on Anglesey. However, it does not fall into Conwy.

Accept in Part - Rephrase the Statement
Table A3.1 forms part of Background Paper 04: SA/SEA Scoping Report August 2018, which is contained in the Generic Evidence Base which informs the preparation of the Preferred Strategy. On checking the BGS published National Resource Map of Wales for North East Wales, no part of the Carboniferous Coal Field occurs within Conwy. Within the National Park area the resources are predominantly igneous and metamorphic slates and elsewhere there is a patchwork of Peat, Sandstone, Alluvial, Glaciofluvial and Glacigenic sand and gravels. Recommend replacing the entire Baseline Key Characteristics entry for Natural Resources in Table A3.1 (8) with the following:
"A dominant feature of Conwy CBC is the Silurian mudstone and slates which form the foothills and uplands of the Denbigh Moors in the east, the major valley system of the River Conwy and its tributaries in the central area, and the Silurian Mudstones and igneous rocks of the mountainous areas within Snowdonia to the west. A band of Carboniferous Limestone defines the higher ground along the coastal strip from Abergele to the Great Orme. A number of different mineral resources are illustrated on the National Resource Map for North East Wales, including Sand and Gravel and Hard Rock suitable for aggregates, and metalliferous and slate mining. Although mining activity in Conwy has ceased, many disused mines still exist and may affect hydraulic pathways below and on the surface, and may present sources of contamination which can adversely affect land and water quality. Furthermore, some disused mines may have a detrimental effect on the landscape and visual amenity."

Comment

Representation ID: 28185

Received: 30/09/2019

Respondent: Natural Resources Wales

Table A3.1 Soil and Land: PPW 10 Section 3.5 refers to previously developed (brownfield) land and de-risking it in development, which should be referenced in addition to chapters 5 and 6.

Noted.

Comment

Representation ID: 28186

Received: 30/09/2019

Respondent: Natural Resources Wales

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

Under National UK please note that these documents will soon be superseded.

Water: refers to Groundwater Protection Policy and Practice (GP3), HM Government (2003) - the latest edition is 2018 and is now known as The Environment Agency's approach to groundwater protection.

Under National (Wales) Soil and Land: Consider also referring to Development of Land Affected by Contamination, A Guide for Developers, 2017 published jointly between the WLGA and NRW.

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

Comment

Representation ID: 28187

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28188

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28189

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28190

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28191

Received: 30/09/2019

Respondent: 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.