Preferred Strategy

Comment

Representation ID: 28192

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28193

Received: 30/09/2019

Respondent: 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

Comment

Representation ID: 28194

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28195

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28196

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28197

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28198

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28199

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28200

Received: 30/09/2019

Respondent: 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.

Comment

Representation ID: 28201

Received: 30/09/2019

Respondent: Natural Resources Wales

It is understood that part of the site has suffered from surface water/pluvial flooding in the past. We understand that works to reduce flood risks on this site were carried out in 1990's.

We have no in principle issue with regards to effects on the setting of Snowdonia National Park. However, a well-considered indicative masterplan for the site would be required to ensure the development fits within its landscape and settlement edge context.

The landscape issues for consideration are:
a) Conserving the setting of Snowdonia National Park.
b) Development form and fit
c) Conservation of natural/heritage features of the site

Noted.