LDP2 Preferred Strategy

8.0 Strategic Policies Comment

Introduction

8.1 This chapter sets out a suite of 21 strategic policies that provide the initial policy framework for delivering 'Abertawe 2038' (the LDP2 Vision). These emanate from the Objectives set out in Chapter 4 and will deliver the core components of the Strategy, as set out in Chapter 7. Comment

8.2 LDP2 takes an iterative approach to strategic place-led policy formation, and public consultation and stakeholder engagement will allow for modifications and enhancements to the strategic policy framework as part of the preparation of the Deposit Plan. Comment

Aligning with the National Sustainable Placemaking Outcomes

8.3 The Strategic Policies are grouped under the five overarching National Sustainable Placemaking Outcomes set out in Planning Policy Wales as follows: Comment

• Creating and Sustaining Communities;
• Growing Our Economy in a Sustainable Manner;
• Facilitating Accessible and Healthy Environments;
• Maximising Environmental Protection and Limiting Environmental Impact, and
• Making Best Use of Resources.

8.4 Further information setting out how the Strategic Policies align with the plan objectives and key issues is set out in the supporting background paper ''Compatibility Analysis and Alignment of Key Issues, Vision, Objectives and Strategic Policies, December 2024, (see Appendix A). Comment

Creating and Sustaining Communities

Housing Provision

8.5 Facilitating the delivery of an appropriate number and range of quality new homes that will meet the identified housing requirement for future generations is a fundamental aim of the Plan. Comment

8.6 The above Strategic Policy is founded on up to date evidence regarding the likely scale of future population and employment growth. The housing requirement numbers for the County have been assessed using the Welsh Government Local Authority level Household Projections for Wales as the starting point for establishing the level of population growth to be addressed by the Plan, however the figures have also been supplemented by up to date research^[4] and data that is locally and regionally specific. In particular, this research and data relates to future economic growth scenarios and the associated level of housing required. The identified housing requirement was set following an analysis of various growth options (summarised in Chapter 6) and having regard to the most up to date evidence available. The requirement is based on the economic growth that is likely over the Plan period and that will support the regeneration and economic aspirations of the Council and City Region. The housing requirement is fully aligned with and supports the level of economic growth set out in the policy. Comment

8.7 The housing provision includes a 20% flexibility allowance. This is to allow for instances that may arise where site specific circumstances, unknown at the Plan making stage, delay the delivery of some sites. The allowance will enhance the ability of the Plan to respond to changing circumstances. It has been set to reflect the nature and mix of sites that will be allocated, including the complexity of bringing forward the larger strategic sites, since it is known they can take longer to come forward. Comment

8.8 The sites that will be allocated in the Plan will reflect the Sustainable Settlement Strategy defined in Strategic Policy 2 and provide a mix of sites to meet the housing requirement. In addition to housing land allocations, there will be other sources of housing provision in the Plan. The county has a significant landbank of housing sites with planning consent, while some homes have already been delivered in the first year of the Plan ,410 (2023-24). These sites are collectively known as commitments. A snapshot review of the existing commitments in the county is set out in the Plan's evidence base^[5]. Comment

8.9 It can also be expected that windfall sites will come forward over the Plan period. Research of windfall sites delivered over recent years, which is set out in the evidence base^[6], has been undertaken to identify a realistic forecast for the Plan period. The expected supply from these components is summarised in Table 4 below. Comment

Table 4 Housing Supply components Comment

8.10 On the basis of the current information available only some of the housing provision, approximately just under 5,000 homes, will need to come from land allocations in the Deposit Plan. It should though be noted that the number of homes built since the LDP2 start date, and total commitments, is subject to change and will be monitored during Plan preparation. Any changes will influence the final number of homes required from site allocations in the Deposit Plan. Comment

Economy and Jobs

8.11 The above Strategic Policy will ensure Swansea can effectively meet future supply needs in relation to both office and research and development floorspace, as well as industrial and warehousing land, collectively regarded as B class uses, over the Plan period. Comment

8.12 The Plan considers employment land needs strategically and is founded on a comprehensive review of economic circumstances and investment targets^[7]. The assessment reflects the City Region context, travel to work patterns, and economic/ housing market overlaps. It provides a broad overview of the entire economy, not just uses defined under parts B1-8 of the Town and Country Planning Use Classes Order. Employment forecasts have been undertaken for the County to underpin the Plan's job target and reflect the potential impact of key major interventions, including projects that form part of the Swansea Bay City Deal proposals. Comment

8.13 The preferred growth forecast suggests that a net additional 10,238 jobs will be created in the County over the Plan period primarily driven by proposed future growth in key sectors including: Comment

• Financial, business and professional services
• Information and communications
• Government services
• Accommodation and food service

8.14 Overall, these forecasts suggest a continued sustained movement towards a service-oriented economy, with some potential for growth in higher-value business services, as well as in the public sector. Other factors included in the forecasts are the potential for additional manufacturing employment in the medium term from a key manufacturing project, the Swansea Energy and Transport Hub and related port development. Comment

8.15 The Plan aims to ensure that sufficient land is available to support economic growth i.e. a sufficient employment landbank. The evidence base underpinning the Plan's employment growth strategy identifies the amount of business space that would be required to support the adopted employment growth forecast. Overall, based on 10,238 net new jobs over the Plan period, there is a requirement across the County for 25ha of employment land (Use Class B1-B8 space). This level of provision would support the adopted economic growth forecast and replace all losses of B use land that might occur over the Plan period (following consideration of past trends of site redevelopments and changes from B use). An Employment Land Review has been undertaken (see Appendix A) as part of the evidence base. The review has highlighted that the identified need in terms of land for B Class employment uses is available within existing business parks and/or employment sites, and Strategic Placemaking and Regeneration Areas. Comment

8.16 It should be noted that this level of job growth should not be viewed as a ceiling or maximum level. A higher level of growth could occur if other investment beyond that which it has been possible to quantify comes forward. The Plan reflects this by providing an appropriate level of flexibility in the amount of land identified with the potential for employment use which is justified having regard to: Comment

• The evidence base has identified a range of scenarios in terms of how much employment land for B uses could be required to accommodate the adopted job growth forecast (for example, it has reviewed the differing levels of density of office development that might be provided, and the amount of B use land that could be lost and that should be replaced), and the 25ha proposed will provide for the upper level identified.

• The clear differentiation between the nature of the sites and their relative locations, reflecting the need to provide different options for a range of sectors and investors and to be flexible to changes in market demand with particular regard to the current uncertainty about future national and international economic growth projections.

• The need to ensure developments come forward in a sustainable manner, incorporating a range of uses at the SPRAs, in particular to ensure employment uses are delivered alongside residential development.

• The need to ensure economic growth is not constrained and to recognise that the scale of growth envisaged could be realised more quickly than forecast and/or exceeded.

8.17 Approximately 47% of all forecasted employment growth will need to be accommodated within this identified requirement for B-use land, and it is therefore important to plan for this through strategic allocations. To ensure sufficient sites are available with appropriate infrastructure and servicing, land will be allocated at Mixed Use SPRAs for appropriate employment generating uses. Comment

8.18 The SPRA sites can effectively contribute towards meeting the identified requirement for industrial, warehousing and office premises and land, with the size and characteristics of the sites likely to facilitate delivery of the range of sizes of premises/floorplates as required by the market over the Plan period. Comment

8.19 B use development will also be supported in appropriate locations within the designated hierarchy of Centres defined in Strategic Policy SP 10, within established industrial and business parks and areas, and other appropriate locations within settlement boundaries in line with the settlement strategy. National Planning Policy and Guidance recognises that local employment opportunities within rural settlements are important to sustain and improve communities. In-line with this, rural settlements designated in the Plan may allow for appropriate small scale sustainable enterprises within the settlement boundary, such as restaurants, craft businesses and knowledge intensive business services. Outside of these settlements within the open countryside, the Plan supports the diversification of the rural economy away from a focus on agriculture. This is particularly relevant to the County's rural areas where the Plan supports rural enterprise development. Rural enterprises are land related businesses and include traditional operations relating to agriculture and forestry, as well as other rural businesses that obtain their primary inputs from the site. Examples of these include the processing of agricultural products, land management activities and tourism enterprises. Comment

8.20 Land which is currently, or has most recently been, used for B use class development will be considered part of the existing employment uses land bank. This land will be safeguarded from alternative forms of development unless the site is no longer appropriate for that use (for example in relation to its surrounding land uses), or the site is no longer financially viable. A further important consideration will be to ensure that the loss of B use land will not lead to a deficiency in the provision of good quality premises for that use in the County. Detail on the type of evidence required will be set out in the Deposit Plan policies. Comment

8.21 Other non B-space job growth will be delivered through uses such as retail, as well as new education facilities and a number of sui generis / unique uses. Some jobs will also be accommodated through homeworking. Comment

8.22 A Settlement Assessment (see Appendix A) has been undertaken using a consistent methodology, based upon the principles set out in WG guidance and relevant examples of best practice, to examine the role and function of settlements in the County. Comment

8.23 This assessment has involved a quantitative assessment of components based on the size of places (including number of homes, employment opportunities and development opportunities and demand), provision of everyday services and facilities, and access to public transport. The quantitative assessment has been combined with qualitative information taking in aspects such as urban character and sense of place, environmental capacity, and social and community factors such as the Welsh language. Alongside this assessment, the LHMA and high level viability evidence have also informed the hierarchy. Comment

8.24 The Swansea Settlement Hierarchy provides a framework for directing development to the most sustainable places in the County and will inform land allocations in the Deposit Plan. It also recognises the importance of a 'One Swansea' approach, whereby the needs of distinctive and often contrasting areas are acknowledged and provided for. Comment

8.25 The four tiers identified in the hierarchy recognise that settlements across the County are either considered part of the urban area (Tier 1), or a rural/semi-rural settlement that meets criteria identified in the settlement assessment in respect of settlement size, form, character and function (Tiers 2 and 3). All settlements defined within Tiers 1-3 will have defined settlement boundaries. Tier 4 is described as 'countryside' and encompasses the wide range of places across the County that are not considered to meet the criteria for defining settlement boundaries. Comment

8.26 The process of undertaking settlement boundary reviews will continue to be undertaken to inform the Deposit Plan, which will ultimately confirm precise settlement boundaries on the LDP2 Deposit Plan Proposals Map. This approach will provide clarity as to where development is acceptable, or not. Policies in the Deposit Plan will clearly articulate where and why settlement boundaries have been drawn, and which types of development are acceptable or not within each settlement tier. Comment

8.27 The Deposit Plan will detail the housing supply (completions, units with planning permission, new housing allocations, large windfall sites and small windfall sites) and employment land provision attributed to each tier of the settlement hierarchy so that it is clear how growth will be distributed spatially to achieve the Plan objectives and sustainable development. Comment

Affordable Housing Needs

8.28 Affordable housing for the purposes of the land use planning system is housing where there are secure mechanisms in place to ensure that it is accessible to those who cannot afford market housing, both on first occupation and for subsequent occupiers. Affordable housing is defined by National Planning Policy and must meet the WG development quality standards. The detailed policies of the Deposit Plan will provide further definition, where required, to clarify what the authority would regard as affordable housing and the LPA will engage with affordable housing providers in the plan preparation process. Comment

8.29 The draft Swansea Local Housing Market Assessment (LHMA)^[8], which is pending completion of the WG approval process, estimates that there is an overall additional net affordable housing need of 5,355 affordable homes in total over the 15 year plan period to 2038. The tenure split of the identified need is 82% social rented and 18% intermediate affordable tenure. While there is a need identified for all types of accommodation, the draft LHMA highlights a significant need for single bedroom homes. Comment

8.30 The provision of affordable housing to meet identified needs is a material consideration for the preparation of the Plan. The Deposit Plan will identify a realistic target for the total number of affordable homes that the Plan can deliver through the means identified in the above Strategic Policy criteria, based on the evidence available. However, it is also recognised that the delivery of affordable homes through the planning system is only one of a variety of means to achieving a supply of such housing. Comment

8.31 The Deposit Plan will set financially viable targets and site thresholds to deliver the provision of onsite affordable housing on residential developments. There are significant financial viability implications which must be considered to inform the preparation of the Deposit Plan. The targets will be based on detailed financial viability testing of site scenarios and will reflect variations in viability in different parts of the County. Initial testing undertaken to date^[9] suggests targets of between 10%-50% will be viable in specific parts of the County. The LPA will engage with the relevant parties in continuing to develop this work during the preparation of the Plan. The largescale strategic SPRA opportunities have been subject to initial high level viability reviews and will be informed by detailed site specific viability testing for the Deposit Plan to determine the level of affordable housing that can viably be provided onsite along with other developer requirements. Comment

8.32 It is recognised that during the lifetime of the Plan there will be some exceptional circumstances, such as the unusual characteristics of a site or unique circumstances of the developer, which will require the Council to consider an alternative to the obligation to provide affordable housing on site. In such circumstances, the Council will consider other mechanisms for the developer to still meet the requirement to ensure the delivery of affordable homes. In exceptional circumstances, which will be set out in the Deposit Plan, the LPA will seek financial contributions for off-site provision where it is demonstrated that it is not feasible to deliver affordable homes on site. Comment

8.33 The Deposit Plan will make provision for affordable housing led sites by allocating appropriate land where such sites are viable and deliverable. These sites will include at least 50% affordable housing based on criteria to be set out in the Deposit reflecting local circumstances and the creation of sustainable communities. Comment

8.34 The Deposit Plan will set out the circumstances where provision of affordable housing exception sites will be considered to help meet the needs of local people in perpetuity. A policy framework will be established for the determination of such proposals on sites within or adjoining existing settlements for the provision of 100% affordable housing in perpetuity to meet local needs. Comment

8.35 The Council has an ambitious social housing programme with the aim of delivering affordable homes. The Plan will support the delivery of the Council's 'More Homes' affordable housing program, including through the allocation of appropriate land for residential use. Comment

8.36 The LHMA will be the starting point for evidence in determining the mix of dwelling sizes, types and tenures required to be provided on residential sites alongside other relevant local information such as the latest Council and Registered Social Landlord (RSL) waiting lists and any recently delivered affordable housing units within the area. Comment

Specialist Housing

8.37 This policy relates to housing designed and designated for occupation by older people, or people with disabilities, who have specific housing needs. This type of accommodation is collectively termed 'specialist housing'. The policy relates to sheltered housing, residential care and nursing homes, and extra care housing. Comment

8.38 Specialist housing should be provided at locations where there is a demonstrable need for the amount and type of accommodation proposed. It should be provided to enable people moving into such accommodation to remain in their local area and to create and maintain balanced communities. The development should have safe and convenient access to facilities, services, shops and public transport appropriate to the needs of the occupants. Depending on the needs of the occupants and the location, it may also be necessary to provide appropriate facilities and services on site to prevent isolation and loneliness. The Deposit Plan will contain a development management policy setting out the criteria against which proposals will be determined. Comment

Gypsy and Traveller Needs

8.39 The accommodation requirements over the Plan period for Gypsies, Travellers and Show People are set out in the Council's latest published Gypsy Traveller Accommodation Assessment (GTAA)^[10]. The GTAA identifies the overall and type of need for the Plan period, which is summarised in table 5 below. Comment

Table 5 Summary of the Gypsy and Traveller need identified in the GTAA Comment

8.40 The need for pitches to accommodate the identified Gypsy/Traveller needs will be met through the provision of additional pitches on sites that have relevant planning consents and/or appropriate lawful use for such development at Tygwyn/Pant y Blawdd Road and Millstream Way in Swansea Vale^[11]. The existing Travelling Showpeople site at Railway Terrace, Gorseinon^[12] is lawful and has capacity to accommodate the pitches needed. The GTAA also considers transit provision and identifies that demand for transit provision is not confined to Local Authority boundaries and there is a lack of provision across the Region and wider in Wales. It does not identify a specific requirement to be met within the county. Transit need is by its nature an issue that should be tackled at a regional or wider level to ensure efficient provision is made in the right locations across Wales. It is potentially an issue for any future Strategic Development Plan (SDP). Comment

8.41 The provision outlined above will accommodate all of the need identified in the latest GTAA and there is no unmet need for pitches that requires additional land to be allocated for this use in the Plan. A development management policy for dealing with any new proposals for pitches/sites that might come forward during the Plan period will be included in the Deposit Plan which will assist in dealing with any unforeseen needs through a policy approach. Comment

Houses in Multiple Occupation

8.42 It is likely that there will continue to be a need for new Houses in Multiple Occupation (HMOs) over the lifetime of the Plan to meet both an occupier demand and a societal need, including need arising from the effects of welfare reforms and the increase in student numbers associated with Swansea's expanding universities. It is important however that future HMO provision is managed sustainably in the interests of fostering cohesive communities, including avoiding instances of over-concentration of HMO properties to the detriment of residential amenity and community balance. The Deposit Plan will contain a development management policy based on the latest evidence setting out the concentration tests and detailed criteria that will be applied to proposals. Comment

8.43 Placemaking is defined as a cornerstone of the national planning agenda in Wales and the sustainable development objectives which underpin it. It is at the heart of the Council's strategic approach to planning policy and development management. Placemaking is a holistic 'people centred' approach to the planning, design and management of places and spaces, focusing on positive outcomes. It seeks to create and sustain buildings, uses and places within which people desire to live, work and spend recreational time. Comment

8.44 All new development can help sustain and create great places, and influence how that place will be experienced and enjoyed (i.e. its sense of place) to stand as a legacy for future generations of communities, occupants and visitors. The Council is committed to the Placemaking Charter and recognises Placemaking as a fundamental principle in achieving the LDP2 Vision. Comment

8.45 The six principles of the Placemaking Wales Charter are described by the Design Commission for Wales as: Comment

1. People and Community: The local community are involved in the development of proposals. The needs, aspirations, health and well-being of all people are considered at the outset. Proposals are shaped to help meet these needs, create, integrate, protect and/or enhance a sense of community and promote equality
2. Location: Places grow and develop in a way that uses land efficiently, supports and enhances existing places and is well connected. The location of housing, employment, leisure and other facilities are planned to help reduce the need to travel
3. Movement: Walking, cycling and public transport are prioritised to provide a choice of sustainable transport modes and reduce reliance on private vehicles. Well designed and safe active travel routes connect to the wider active travel and public transport network, and public transport stations and stops are positively integrated
4. Mix of Uses: Places have a range of purposes which provide opportunities for community development, local business growth and access to jobs, service and facilities via walking, cycling or public transport. Development density and a mix of uses and tenures helps to support a diverse community and vibrant public realm
5. Public realm: Streets and public spaces are well defined, welcoming, safe and inclusive with a distinct identity. They are designed to be robust and adaptable with landscape, green infrastructure and sustainable drainage well integrated. They are well connected to existing places and promote opportunities for social interaction and a range of activities for all people
6. Identity: The positive, distinctive qualities of existing places are valued and respected. The unique features and opportunities of a location, including heritage, culture, language, built and natural physical attributes, are identified and responded to

8.46 Fundamental to Placemaking is attaining an understanding of an area's potential in order to create high quality and resilient buildings, spaces and infrastructure that promotes prosperity, health, happiness and well-being. Placemaking considers the context, function and relationships between a development and the wider surroundings. This will be true for major developments creating new places as well as small developments created within a wider existing place. Essentially placemaking seeks to ensure social inclusion, equality of opportunity and access for all. This includes all aspects of development including the physical environment, land uses and movement. The principle of 'access for all' encompasses all elements of society and is applicable to all developments, in all locations. Comment

8.47 Placemaking has generation legacies and is a key element of regeneration, therefore the Council will ensure development throughout Swansea exhibits the highest standards of place-led design. This will be achieved via Development Management and Public Sector Leadership in the Council's own projects. The key method of place dialogue will be via the Design and Access Statement to explain and justify proposals against analysis and placemaking principles. Comment

8.48 Design encompasses matters of layout, scale, form, massing, height, density, colour, fenestration, articulation, climate resilience, sustainability, inclusion of Green Infrastructure, connectivity, materials and specific detailing that will vary considerably between development proposals. Crucially, creating successful places, or achieving positive changes in existing places requires a holistic approach that brings together multiple disciplines. In this context, good design is about much more than addressing the physical appearance of buildings and a focus on details alone will not create a successful place. The mixture of uses within a development, and the way in which buildings relate to one another and surrounding streets, are also key elements of creating safe, vibrant, accessible and attractive streets, spaces and places. In addition, opportunities to future proof buildings in order for them to be adaptive and flexible makes them resilient to future generational needs. In this sense this policy embraces the wider principles of good design for delivering sustainable places, as advocated by the Design Commission for Wales. Comment

8.49 This approach is essential to contribute to the Plan's overall vision to ensure that development at all scales will have the principles of placemaking, climate resilience and biodiversity enhancement as its foundations, helping to create places that encourage healthy living and enhance people's well being. Comment

8.50 The strategic approach to placemaking requires joined up multi-disciplinary collaborative working, with a masterplan being one of the most important component outputs. All those involved in regeneration and development benefit from establishing a shared vision and clear strategy for the physical, economic and social transformation of places and a masterplan will set out how to create and sustain excellent places in this regard. Successful places are underpinned by a guiding vision for the place to be created. This could stem from aspects such as understanding of the site and context, suitable precedents and opportunities for innovation. Comment

8.51 The policy requires the masterplan led approach for residential led developments on allocated sites and windfall sites with a 'trigger threshold' of 1.5ha or greater, or where there is a capacity for 50 homes or more, which will ensure that this approach encompasses the delivery of a wide range of development proposals that come forward within existing communities. This approach lays the framework for a place led approach to new development, making clear that a requirement for positive dialogue and establishing agreement on key principles early on is not just to be reserved for large scale strategic sites. Relatively small sites can be major additions to existing places and the key themes that are addressed by the masterplanning process are just as important to address. A case-by-case approach can be utilised in respect of developments that fall under the threshold by a small amount and/or any impact resulting from cumulative considerations (e.g. phased developments). Comment

8.52 The masterplan led approach is founded upon analysis. This includes understanding the existing site, the context and engaging with the existing community. There is no one size fits all approach to masterplanning because every site, context and community will be different. However, the six principles of the Placemaking Wales Charter should be used to frame analysis, conversations, masterplan strategies and visioning. Reference to precedent examples is also beneficial to communicate the positive aspects of successful places to inform the masterplanning process. Comment

8.53 It is important that the masterplan approach is based upon joined up collaborative working and that siloed working is challenged. The applicant design team should be well integrated working in an iterative and transparent manner with Placemaking leadership. This should form the basis of early and meaningful community engagement, plus pre-application dialogue with the Local Planning Authority and design review by the Design Commission for Wales. Comment

8.54 Often the masterplanning approach will result in an indicative scheme that shows one way a site could be developed, integrated with the context and addressing the requirements of LDP2 policies, supplementary planning guidance and national policy. Where proposals are submitted as outline planning applications, the indicative masterplan should be based on a strategic vision and be clear on the fixed elements and the flexible elements of the proposals. This can be achieved by disaggregating the indicative scheme into a series of parameter plans setting a strategic placemaking framework that addresses (but is not limited to); connections across and beyond sites; land use and density; street hierarchy and movement; green infrastructure, sustainable drainage and open spaces; built form and townscape; character, identity and uplift areas; and phasing. On some sites it may be beneficial to address character aspects via Design Codes. Comment

8.55 The provision of new infrastructure, as well as the safeguarding, improvement and efficient use of existing infrastructure is central to ensuring that all new development proposed within the Plan period contributes to achieving 'Abertawe 2038'. The policy seeks to ensure that all new developments, irrespective of their size, location, or land use, make efficient use of existing infrastructure and, where relevant, make appropriate provision for, or contribute to, new infrastructure. Comment

8.56 The Plan's spatial strategy focuses larger scale development to locations that are well serviced and where the infrastructure, services and facilities considered necessary to deliver and support the development proposal are available or can be readily achieved. In so doing, the Sustainable Settlement Strategy is informed by a robust evidence base, stakeholder engagement (including technical consultees) and an overall recognition of the role and function of the County's communities. Comment

8.57 The LDP2 Sustainable Settlement Strategy exhibits a high level of continuity in strategic approach from that which underpinned the Adopted LDP. This provides continued certainty and alignment for the market, the community and critically for key infrastructure providers both within the Council (e.g. education investment programme) and outside the Council (e.g. Dwr Cymru Welsh Water Asset Management Plan programme). Such place-based integration across partner agencies reaffirms the deliverability and sustainability credentials of the Plan and will assist in ensuring that the required infrastructural capacity is in place. Comment

8.58 With reference to the Climate Adaptation Strategy for Wales (2024), it is considered that Climate change adaptation and resilience should be embedded into the consideration of infrastructural capacity. Reference should be made to Strategic Policy 15 'Climate change and decarbonisation'. Comment

8.59 Sufficient infrastructural capacity means ensuring that the social, economic, cultural and environmental needs of existing and planned places are met. A range of physical, social, green and digital requirements should be considered, having regard to the nature, scale, location and financial viability of the proposed development. Comment

8.60 The delivery of any new or improved infrastructure, or other appropriate measures, must be undertaken in a timely and coordinated manner prior to, or from the commencement of, the relevant phases of development. Comment

8.61 Specific infrastructure requirements will vary in different locations and be dependent upon the scale and nature of proposed development. Infrastructure may be required to facilitate development or can be required to make a development acceptable and sustainable. Comment

8.62 The aspects listed below are not exhaustive but are intended to give a broad indication of the potential scope of measures which may be required. The Deposit LDP can include further topic-based information as appropriate. It is recognised that it may be possible to categorise infrastructural requirements into either "essential" or "required". The below are likely to be considered to be examples of "essential measures", which would make the development acceptable in planning terms, or measures without which the development would not come forward: Comment

Social requirements: Affordable Housing - including the provision of Affordable Housing for Local Needs. Education and Training - including nursery; primary; secondary and sixth form. Public Open Space and Green Infrastructure - including parks, green spaces; children's play; destination play and teen facilities; sports pitches and games areas; open space and recreational facilities including playgrounds; allotments and the Active Travel network.

Environmental requirements: Biodiversity requirements/mitigation (for example compliance with regulations / national site network mitigation). Environmental Protection Management - including a range of protection, management, enhancement and mitigation measures relating to the natural and built environment; flood mitigation defences; drainage measures. Utility Services - including water and waste water infrastructure; gas and electricity.

Economic requirements: Digital infrastructure such as telecommunications and broadband. Physical infrastructure such as transportation and highways - including movement and connectivity measures such as roads; junctions; parking; public transport provision; Active Travel measures.

8.63 The following are examples of measures that could be required to make the development acceptable, many of which would allow for consideration of cultural matters: Comment

• Health – including primary and secondary health care and social care.
• Community Facilities – including libraries; sports centres and indoor recreation facilities; multi-functional community facilities; district and local centre improvements and creation of community hubs; leisure and recreation facilities.
• Welsh language – including immersion initiatives and mitigation measures as required.
• Environmental Management – including recycling and waste management facilities.
• Public Realm – including improvements for Public Art.
• Renewable and Sustainable Energy – including district heating and cooling.

8.64 With regards water supply and treatment, there is confidence that the levels of growth set out within the Preferred Strategy can be accommodated. However, the Deposit Plan may need to set out policy approaches within specific Waste Water Treatment Works (WwTW) catchments, notably Gowerton. Reference will be made to the HRA prepared in support of the Preferred Strategy as appropriate, whilst Strategic Policy 15 'Climate change and Decarbonisation' should be referred to in respect of management of water (including surface water/run-off). Comment

8.65 An Infrastructure Delivery Plan will be prepared alongside the Deposit Plan, which will provide detailed information on the phasing, delivery and estimated costs of the necessary infrastructure requirements identified in the Plan to support development on allocated sites, including Strategic Placemaking and Regeneration Areas (Strategic Policy 8 refers). The Plan will also be underpinned by viability evidence, whilst extensive engagement will take place with a number of stakeholders, including technical consultees and a developer forum. Comment

8.66 The preparation of the Deposit LDP will allow for further elaboration on any site-specific requirements for allocated sites. It will also include a housing trajectory. As part of a proactive approach, the Council will work with proponents of allocated sites in the production of evidence. This can include the production of Statements of Common Ground, SPG / Development Briefs and/or masterplans as appropriate. Comment

8.67 National guidance set out within 'The use of planning conditions for development management (WGC 016/2014)' outlines that the use of planning conditions are used as a first measure to make a development acceptable. However, there are instances where contributions to infrastructure need to be secured through planning obligations. This will be done in accordance with the legislative and policy framework provided in Planning Policy Wales (Edition 12, 2024), Community Infrastructure Levy (CIL) Regulations 2010 (as amended), Welsh Government guidance set out within the 'Community infrastructure levy: the production of a charging schedule (2011)' and Welsh Office Circular 13/97 'Planning Obligations' (or subsequent versions). Further detail of how the levels of contribution for each type of infrastructure will be calculated and requirements negotiated will be set out within the Deposit LDP (and any associated SPG as appropriate). There is no CIL in Swansea, therefore due regard is given to any matters arising in respect of pooling restrictions. Comment

8.68 The preparation of the deposit plan and detailed policy framework will also allow for the Council to provide clarity on any prioritisation in terms of any contributions sought (including through production of SPG as appropriate). Whilst considered on a case by case basis, it is generally considered that the priority for the Authority will be the provision of affordable housing and in most cases its provision will be prioritised above other contributions. There may be specific instances however where another specific contribution will take overall priority. This could be a place and/or site specific policy that ensures that the Plan is in compliance with regulations (for example providing mitigation to offset any matters raised within the HRA in respect of the National Site Network). Comment

8.69 Ensuring that development is viable is an essential part of delivering sustainable development. The Council expects that the costs relating to any measures required to make the development viable and sustainable will be taken into account at an early stage of the development process (including land acquisition) in order that realistic values and costs are achieved as part of the development appraisal. Comment

8.70 Where a developer seeks to question the viability of a scheme to be delivered in accordance with the policy requirements (e.g. claiming abnormal/unforeseen costs), the Council will request an independent development appraisal is undertaken by a suitably qualified and approved third party, which may involve a full assessment if no viability appraisal has been undertaken. The Council will expect the costs of any such appraisal to be met by the developer. In noting that the deliverability and viability of the Plan will be borne out by its extensive evidence base and all requirements transparently set out in the Plan itself, the onus will be on the proponent to demonstrate why any requirements set out within the Plan cannot be met. In this regard, the Council's starting point in any negotiations will be to apply the policies and proposals of the Plan. Comment

8.71 The Council has worked in partnership with other Councils across the region, alongside Town Planning and Development consultants Burrows-Hutchinson Ltd, to establish the Development Viability Model (DVM) assessment tool. The DVM has been created as a comprehensive, user-friendly model that can be used by site promoters and decision makers for the purpose of assessing the financial viability of a development proposal. Comment

8.72 The Welsh language is an important part of the social fabric of communities across the County; however, it does face challenges. In considering the national target of 1 million Welsh speakers by 2050 as set out in the Welsh Government's 'Cymraeg 2050 Strategy' (2017), it is noted that over the ten-year period (2011-2021) there was a reduction of 1.3% of speakers in the County (this reduction was lower than the 5.3% fall recorded in Wales as a whole). In the 2021 Census, around 26,000 people in the County (11.2% of all aged 3 and over) were able to speak Welsh, lower than the equivalent figure for Wales (17.8% or 538,300 people). Comment

8.73 Whilst the Plan seeks to contribute towards efforts to increase the number of speakers County wide, it is important to acknowledge the spatial context / nuances. The distribution of people able to speak Welsh by ward differs). 2021 Census data reveals that the largest percentages of Welsh speakers in the County live in the wards of Pontarddulais (25.9%), Clydach (20.1%) and Pontlliw & Tircoed (19.4%). Comment

8.74 The production of the Deposit Plan can allow for the delineation of an area of linguistic sensitivity on the Proposals Map. This would offer continuity in respect of the approach set out within the Adopted LDP 2010-2025, subject to evidence and rationale. Comment

8.75 The Deposit Plan can also set out any specific policy requirements that can elaborate upon the content of Strategic Policy 7, including any requirement for assessment of applications for linguistic impact – taking into account the provisions of national policy set out in Planning Policy Wales (Edition 12, 2024), Future Wales: The National Plan 2040 (2021) and Technical Advice Note 20 planning and the Welsh language (2017). Another potential area for further review in the Deposit LDP will be consideration of the range of potential measures and/or interventions that can help promote the use of the Welsh language as part of developments, including the use of place names and the desired provision of bi-lingual signage in regards advertisements that are subject to planning control. Comment

8.76 The impact of the Plan (including site allocations) is continually and iteratively assessed. Reference should be made to the Welsh language Impact Assessment, together with the Integrated Impact Assessment, which accompanies this Preferred Strategy. Comment

8.77 There are a number of wider facets of the Plan that can make a positive contribution to the Welsh language. Reference should be made to policies relating to housing, affordable housing and the economy in this regard. There may also be potential in terms of planning obligations, for example working with language immersion initiatives and organisations such as Menter Iaith Abertawe. Comment

8.78 A notable corporate emphasis has been placed upon education (including the Welsh in Education Strategic Plan (WESP) September 2022 – August 2032). The Council has a vision to increase the number of pupils attending Welsh medium schools to between 23% and 27% of year 1 pupils by 2032, compared to 15.4% in 2019/2020. Comment

8.79 The provision of a range of leisure, work, education and living opportunities up to 2038 can help retain younger age cohorts and help deliver the Plan's Vision for 'Abertawe 2038'. The sustainable and integrated housing and employment land growth strategy which underpins the Preferred Strategy can help with the retention of younger age cohorts. This will lead to more balanced, cohesive and sustainable communities and help minimise unsustainable commuting out of the County for work. It is noted in this regard that in the 16-19 age group, the increase in the number of Welsh speakers in the County between the 2011 and 2021 Census was 12.8% - by contrast this figure fell across Wales by 11.1%. A similar increase was seen in the County for the 20-44 age group also. Comment

8.80 The Council can seek the views of key stakeholders such as the Welsh Language Commissioner and Menter Iaith Abertawe so as to inform the Deposit Plan. Due regard is also given to the regional context, noting the eminence of the Welsh language within Future Wales 2040. Comment

8.81 The Welsh language is also considered to be a cultural asset of the County – see Strategic Policy 19 'Historic and Cultural Assets'. Comment

Growing Our Economy in a Sustainable Manner

8.82 The allocation of Strategic Placemaking and Regeneration Areas (SPRA's) in the Deposit LDP will be fundamental to ensuring delivery of the core components that comprise the Placemaking Strategy for Swansea to 2038, including in terms of housing supply. They will deliver well serviced strategic development at connected locations and will have green infrastructure at their heart. As such, the threshold of a minimum of 400 units for residential led SPRAs is considered appropriate, reflecting the requirement for comprehensively planned and viable sites. Comment

8.83 In identifying appropriate locations for SPRA's, due regard must be given to the Sustainable Settlement Strategy of the Plan. This Strategy outlines that the primary focus for development shall be locations within the North; East; West, Central and Greater Northwest Strategic Housing Policy Zones. It is also considered that large scale proposals should be located within or adjacent to the urban area. It is noted in this regard that the Urban area is identified as Tier 1 of the hierarchy - see Strategic Policy 2 'Sustainable Settlement Strategy'. Comment

8.84 The location of SPRAs identified in the policy will ensure a broad continuity in strategic approach in respect of strategic development opportunities that underpinned the Swansea LDP 2010-2025. This provides continued certainty and alignment for the market, the community and for key infrastructure / utility providers both within and outside the Council. Comment

8.85 The SPRAs have been identified with a robust understanding of the role and function of places and the different characteristics and constraints of the SHPZs. Further information is set out in Chapter 5 of this Strategy. The figure below illustrates the relative location of the SPRA opportunities within the context of the SHPZs. Comment

Figure 6 Location of SPRAs by SHPZ Comment

8.86 Certain areas of the County are more appropriate than others to accommodate SPRA's, for example having regard to infrastructural and environmental capacity, levels of population and provision of services/facilities. Alignment is also required with other key place based considerations e.g. regeneration activity and employment areas. Reference is also made to the cross border and regional context, noting Future Wales 2040 and the Swansea Bay and Llanelli National Growth Area. Comment

8.87 The Greater North West; North; West, East and Central SHPZs exhibit credentials that are akin to strategic development focused functions. Conversely, the Gower and Gower Fringe SHPZ do not exhibit credentials that are akin to strategic development focused functions. Such evidence is reflected within Strategic Policy 2 'Sustainable Settlement Strategy'. Comment

8.88 The identification of 13 areas across a range of SHPZs will provide a measure of flexibility and choice. Further information is set out in Appendix C on the planning status of these opportunity sites, and reference should also be made to the Housing Supply Paper in order to consider the assumptions made in respect of the potential numbers of homes that could come forward. Comment

8.89 The SPRA opportunities have been subject to some initial high level viability review and will be further informed by detailed site specific viability testing for the Deposit Plan. This will determine the level of affordable housing that can viably be provided onsite along with other developer requirements and infrastructure required to support their delivery. Comment

8.90 The Greater North West SHPZ encompasses former industrial communities such as Gorseinon and Pontarddulais. This zone features a population of approximately 40,400 over a 98km² area, with a population density of 412 per km². The Welsh Language is evident within this SHPZ. The locations identified in the policy for SPRA opportunities in the Greater North West SHPZ are: Pontarddulais, Garden Village/Gorseinon, Penllergaer and Llangyfelach. Evidence indicates that the housing delivery potential of SPRAs in the Greater North West Zone would be in the region of 3000 units. Comment

8.91 The Central SHPZ is dominated by the Swansea Central Area and City Waterfront site, which encompasses the main commercial and business core of the city. Also in this zone are well-established residential areas such as Sandfields, Brynmill, Mount Pleasant and Uplands. This zone features a population of approximately 54,400 over an 18.9km² area, with a population density of 2,878 per km². The locations identified in the policy for SPRA opportunities in the Central SHPZ are: Swansea Central Area & City Waterfront, Tawe Riverside Corridor & Hafod Morfa Copper Works, SA1 Waterfront and Swansea Port and Docks & Fabian Way Corridor. The Swansea Central Area and City Waterfront has seen a focus on regeneration activity and commercial investment, reflecting the corporate ambitions of Swansea Council and partners in terms of delivering transformative change at this location, including through the Swansea Bay City Deal portfolio. Comment

8.92 Strategic Policy 9 'Swansea Central Area and City Waterfront' sets out the specific aims and requirements for new development within this priority area, which does include the delivery of significant numbers of new homes alongside other mixed commercial uses. Strategic Policy 11 'Port of Swansea and Docks Regeneration' provides a framework to guide development at this major brownfield area, which is a unique asset for Swansea and the wider region in respect of its potential to deliver transformative change in commercial, industrial and renewable energy development. Comment

8.93 The port and docks sit alongside the Swansea 'SA1 Waterfront' area which has its own distinct mixed use character with significant numbers of homes. Development at the Tawe Riverside Corridor & Hafod Morfa Copper Works site is anticipated to deliver mixed use heritage and culture led regeneration including residential development, employment uses (B1), leisure, recreation and community uses, river activation, open spaces and green infrastructure, all contributing towards the preservation and enhancement of the area's unique historic and cultural heritage. This area has complex constraints and opportunities plus a multitude of ownerships. Therefore, a robust masterplan led approach must be displayed by all proposals within this area. This should demonstrate compatibility between developments delivered on a phased basis. Evidence indicates that the housing delivery potential of SPRAs in the Central Zone would be in the region of 600 units. This is a conservative estimate which is expected to represent a minimum level of development for the Central Area, Tawe Riverside and Fabian Way Corridor which may well be exceeded as more detailed assessment of Candidate Sites and emerging regeneration proposals for these areas is undertaken to inform the Deposit Plan. Comment

8.94 The North SHPZ incorporates largely residential urban areas around the fringes of Central Swansea, including Penlan, Mynyddbach, Llangyfelach, and Morriston; and also established business parks at Fforestfach and Waunarlwydd. This zone features a population of approximately 50,100 over a 23.2km² area, with a population density of 2,159 per km² The locations identified in the policy for SPRA opportunities in the North SYPZ are: Llangyfelach, Morriston, Morriston Hospital and Waunarlwydd/ Fforestfach. Evidence indicates that the housing delivery potential of SPRAs in the North Zone would be in the region of 3000 units. Comment

8.95 In relation to Morriston Hospital, the plan will support the expansion of healthcare facilities to the north of the existing hospital within the existing safeguarded area in the current adopted LDP to facilitate emerging health board strategy for the improvement of clinical facilities at the site. The current programme for strategic care improvements identified within the existing safeguarded area at this location includes a new emergency department building with helipad, new thoracic facility, support services, energy centre and University Institute for Life Sciences. Further development proposals within the existing hospital estate include a new ward block and ITU refurbishment. Strategic transport infrastructure improvements to facilitate this strategic scheme of improvements will be supported by LDP2 which will require access route improvements at Mynydd Gelli Wastad road and new transport infrastructure to the north within safeguarded land. The strategic transport improvements to accommodate the uses may necessitate the provision of a new link road from J46 of the M4 to tie in with any upgraded access route infrastructure. The plan will facilitate delivery of this subject to the need being justified as part of a detailed Transport Impact Assessment as part of the emerging project. Comment

8.96 The West SHPZ rapidly expanded in the late Twentieth Century, expanding to its environmental limits from the waterfront through to the Gower National Landscape (AONB). The zone comprises primarily residential settlements, including Sketty and Mumbles. This zone features a population of approximately 40,100 over a 23.9km² area, with a population density of 1,678 per km². The location cited as an opportunity for a SPRAs within Strategic Policy 8 within this SHPZ is: Cefn Coed Hospital, Cockett. Evidence indicates that the housing delivery potential of SPRAs in the West Zone is unlikely to be greater than 200 units. Comment

8.97 The East SHPZ largely comprises the urban area East of the River Tawe and extends as far North as Clydach. It includes employment and mixed-use locations, such as Swansea Enterprise Park, Swansea Vale, Swansea Port and SA1 Swansea Waterfront. This zone features a population of approximately 37,700 over a 60.8km² area, with a population density of 620 per km². The Zone has seen a focus on regeneration activity, including the appropriate re-use of previously developed land. Whilst the Strategic Policy identifies SPRAs within the East SHPZ, the extent of any SPRA allocation within this zone is likely to be marginal in comparison to the other SHPZs highlighted for SPRA development. This is in recognition of the constraints affecting development in the East SHPZ. Nevertheless, the area may still provide opportunities for smaller scale development opportunities, notably the Swansea Vale area. Comment

8.98 The Gower Fringe SHPZ is characterised by small and large villages located in rural and semi-rural landscapes, some near the Western fringe of the urban area. This zone features a population of approximately 9,600 over a 25.9 km² area, with a population density of 371 per km². Comment

8.99 The Gower SHPZ is characterised by small and large villages located in rural and semi-rural landscapes, some near the Western fringe of the urban area. This zone features a population of approximately 6,000 over a 124.4km² area, with a population density of 48 per km². The zone can be considered to play a key role in the County's overall visitor economy offer, whilst the Gower National Landscape (AONB) is a notable consideration. Comment

8.100 The approach set out in Strategic Policy 8 will provide opportunities across the County and as such will not over saturate a specific SHPZ. Further detailed evidence will be formulated (including viability and statements of common ground as appropriate) to support the identification of specific SPRAs as part of the preparation of the deposit LDP, including their delineation on the proposals map. However, the 13 opportunities set out within Strategic Policy 8 provide a robust starting point and strategic steer in this regard. Comment

8.101 The Deposit Plan can include the following information for those SPRAs that are allocated: Comment

• Concept plans and placemaking principles;
• Development requirements - including any necessary supporting infrastructure or off-site measures that may be identified as necessary for the development to come forward, which must be delivered in an appropriate phased manner, and
• Any energy reporting / net zero design requirements.

8.102 For all SPRAs, the proposals must respond to the Concept Plans via a Masterplanning approach as set out in SP5. Comment

8.103 The regeneration of the Swansea Central Area and City Waterfront is a corporate priority of the Council and given its regional and national significance will be a key driver of economic prosperity in the Swansea Bay and Llanelli National Growth Area and across the Swansea Bay City Region. The Council, by working closely with Swansea BID (Business Improvement District) and the private sector, aims to continue the transformational change that is underway in the Swansea Central Area and City Waterfront to make the area a highly attractive place to invest and to shop, study, stay, visit and do business. Comment

8.104 The Swansea Central Area and City Waterfront needs a vibrant mix and right balance of uses which are delivered in a legible way with distinctive highquality buildings and public spaces which celebrate the culture of Swansea and differentiate it from other cities. It has a proud history and sense of identity and is in many ways the public face of the County. Development that enhances its status and profile as a focal destination will be pursued as part of a co-ordinated strategy to ensure the Swansea Central Area and City Waterfront enters a new era of opportunity, continues to benefit from investment and becomes a vibrant centre for work and social interaction for many generations to come. Alongside its commercial function, the Swansea Central Area and City Waterfront will be considered the focus for future civic, education and cultural development projects. Comment

8.105 The corporate commitment to city centre regeneration and increasing footfall, is demonstrated by the £1bn regeneration programme well under way. Completed schemes include Swansea Arena and the coastal park at the heart of the city's new £135m Copr Bay district, together with 71/72 Kingsway. Other completed and future regeneration schemes include: The Biome mixed-use regeneration project, Princess Quarter Grade A Office Accommodation, Castle Gardens and Y Storfa. Future 'Shaping Swansea' sites will offer transformative impact. Comment

8.106 Transforming Towns was launched by the Welsh Government in January 2020 to address the decline in town and city centres and the reduced demand for high street retail. The Council is in the process of preparing a replacement for the current regeneration framework (Swansea Central Area Regeneration Framework) with the emerging City Centre Placemaking Plan. This will provide supporting information to inform development proposals in the Swansea Central Area and City Waterfront. This Strategic Policy reflects the wider place-based focus on the City Centre and provides a spatial framework for the land use planning aspects to deliver upon. Reference should also be made to Strategic Policy 8 'Strategic Placemaking and Regeneration Areas'. Comment

8.107 A sequential search to meeting the evidenced requirement for significant high quality, modern office space should start with the Swansea Central Area and City Waterfront. This location also forms the starting point in regards the location for appropriate proposals for Centre living opportunities, including Purpose Built Student Accommodation (PBSA). Appropriate proposals that unlock the potential for upper floor conversions and deliver wider regeneration, social cohesion, and widen the tenure mix within the Swansea Central Area and City Waterfront will be supported. Further information on the spatial extent of the Swansea Central Area and City Waterfront will be set out in the Deposit Plan and will align with the Placemaking Plan. Comment

8.108 Proposals in the Swansea Central Area and City Waterfront will be expected to contribute towards delivering enhanced multifunctional green infrastructure as part of efforts to address the nature and climate emergencies. The Swansea Central Area: Regenerating our City for Wellbeing and Wildlife Green Infrastructure Strategy, alongside the Initial Green Infrastructure Assessment (see Appendix A) will inform Green Infrastructure Strategies as part of new development schemes. Comment

8.109 There is clear alignment between this Strategic Policy and Strategic Policy 10 'Centres First'. It is noted in this regard that Strategic Policy 10 identifies 'Swansea Central Area Leisure and Retail Core' at the head of the retail and commercial hierarchy of the County, recognising its regional role in South West Wales. Comment

8.110 Appropriate proposals for tourism, culture, recreation and leisure proposals in the Swansea Central Area and City Waterfront which contribute to diversifying and enhancing current provision and which create unique opportunities which attract footfall and investment will be supported. Comment

8.111 Regeneration developments and proposals outside of the Swansea Central Area and City Waterfront will need to be justified. Proponents will need to satisfy the Council that the location is appropriate both in terms of site specific characteristics, together with the role and function of the settlement and the Spatial Strategy of the Plan. Such proposals should be subordinate in terms of impact, scale and function to those located in the Swansea Central Area and City Waterfront and should reflect the sequential emphasis placed on the Swansea Central Area and City Waterfront as the starting point in spatial terms. Proposals must not compromise the primacy of the Central Area as the focus for transformative change. Comment

8.112 Planning Policy Wales (Edition 12, 2024) requires that a hierarchy of retail and commercial centres should be considered as part of the preparation of the Plan. The identification and categorisation of retail and commercial centres should be informed by the functions they fulfil, consideration as to their future roles, and a recognition of opportunities to support Welsh Government retail and commercial centre objectives. Comment

8.113 SP10 sets out a hierarchy of centres that ranges from the small neighbourhood centres proving the most localised provision through to larger neighbourhood centres that inevitably provide the resident and visiting populations with a wider range of services and facilities and a greater choice for users over a wider product range. In noting the provisions of Strategic Policy 9 'Swansea Central Area and City Waterfront', the hierarchy clearly identifies the leisure and retail core of the Central Area as being at the top of the Hierarchy, which reflects the primacy of Swansea City Centre's destination function. Comment

8.114 The Hierarchy will protect and enhance the principal role of the Swansea City Centre Retail and Leisure Core in serving wider catchment areas for comparison shopping (clothing, footwear, electrical etc.) and specialised items to ensure its continued attractiveness as town centre and shopping destinations. In smaller centres, it seeks to ensure that local communities have reasonable access to a satisfactory range of high street facilities and services particularly convenience goods (food and other essential day to day requirement). Comment

8.115 There is clear alignment between this Strategic Policy and Strategic Policy 9 'Swansea Central Area and City Waterfront'. For clarity, it is not appropriate for the whole of the Swansea Central Area and City Waterfront to be designated as the 'Retail Centre' for planning purposes, given it encompasses significant areas of residential and other non-core retail districts. It should be noted in this context that the Swansea Central Area Leisure and Retail Centre' is a 'sub area' of the Swansea Central Area and City Waterfront. The delineation of such areas will be set out within the Deposit LDP. Comment

8.116 Goods and services required on a day-to-day basis are considered as convenience items, with a local dimension, and for which residents may make short journeys frequently. Specialised items are considered as comparison goods and will generally be sought less frequently and for which shoppers are prepared to travel further. Comment

8.117 Large Neighbourhood Centres are identified at Clydach, Gorseinon, Gowerton, Killay, Morriston, Mumbles, Pontarddulais, Sketty, Uplands and Penclawdd. These provide an appropriate range and choice of retail and non retail uses to support the communities they serve. Notwithstanding respecting the primary shopping function of these areas, it is recognised that encouraging a mix of uses in addition to Class A1 can generate footfall and help maintain vibrancy and attractiveness. Comment

8.118 Transforming Towns was launched by the Welsh Government in January 2020 to address the decline in town and city centres and the reduced demand for high street retail. Placemaking plans are being prepared (including for Swansea City Centre and a number of other places including Pontarddulais, Clydach, Morriston and Mumbles). The progress of such plans will be reviewed and responded to as appropriate as part of the preparation of the Deposit LDP. These Plans may inform detailed decisions on retail policy for these retail centres alongside a review of existing boundaries to ensure the plan facilitates the objectives of these emerging placemaking plans. Comment

8.119 A network of Small Neighbourhood Centres exist across Swansea, these are more residential in nature and do not typically have the scale or variety or retail and non-retail uses. They provide valuable facilities to meet the needs of local neighbourhood providing local services such as convenience provision, food and drink and other complementary uses. The existing/Adopted LDP identifies 25 local centres, this may be refined and further areas included as part of ongoing assessment to inform the Deposit Plan. Comment

8.120 SP10 promotes the Plan's defined Centres as the most appropriate and sustainable locations for locating new retail, leisure ,commercial and complementary development. The co-location of facilities and services at such locations will help support their long term health and vitality as convenient and attractive places to shop, live, socialise, access services for health and well-being, and to conduct business. It will also encourage linked trips and a reduction in travel demand. The preparation of the Deposit Plan will allow for the spatial extent of centres to be delineated on a proposals map as required and/or appropriate. Comment

8.121 There may be specific exceptional circumstances where, subject to a specific need being identified, an edge or out of centre retail or leisure proposal may be appropriate. Edge of centre sites should be considered in preference to out of centre locations. The Deposit LDP will allow for the delineation of any specific edge of centre locations. Comment

8.122 Where evidence clearly demonstrates that no sites within centres or at edge of centre locations can be made available for the proposed development, out of centre sites will be considered. In such circumstances, developers should consider available sites and premises within defined Retail Park boundaries, which are the preferred location for out of centre retail developments. The Retail Parks in Swansea are as follows: Cadle (Pontarddulais Road), Cwmdu, Fforestfach, Morfa and Swansea Enterprise Park. The spatial extent of these parks will be reviewed to inform proposed boundaries to be included in the Deposit LDP. Comment

8.123 Retail and leisure proposals should only be considered at out of centre locations outside Retail Parks in exceptional circumstances, and where a specific need is identified. These could include small local convenience shopping facilities in rural and urban areas that can demonstrate a level of alignment with the settlement strategy and wider policy framework of the Plan, whilst also reflecting the role and function of places. Another example could be development that is part of a planned new Centre or is a specific facility proposed to serve a substantial new residential neighbourhood within a Strategic Placemaking and Regeneration Area. Some developments may require a particular type of unit, either with an extensive floor area and/or a bespoke designed premises, that is not normally available within Centres or Retail Parks, in order to accommodate the proposed range of goods to be sold. Comment

8.124 Further information will be set out in the Deposit LDP in respect of the circumstances where a departure from the hierarchy could be justified. However, the strategic direction as set out within the Strategic Policy will not change, in that the defined Centres are considered the most appropriate and sustainable locations for locating retail, commercial, leisure or public service facilities. Exceptions should not result in a material adverse impact to the attractiveness, vitality or viability of any Centre defined in the Retail Hierarchy. Comment

8.125 Monitoring data indicates that variations exist in the vitality and vibrancy of the County's centres, with the % of vacancy rates noted in this regard. In sustaining and enhancing their retail function, the importance of encouraging a diversity of activity and uses is also recognised as part of driving footfall. In 2020, the Welsh Government published 'Building Better Places: The Planning System Delivering Resilient and Brighter Futures'. This reaffirms a commitment to placemaking with a people-focused and placemaking-led recovery from the pandemic. In recognising that traditional retail patterns are changing, the preparation of the deposit plan will allow for the specific Adopted LDP policy framework to be reviewed, notably for the consideration of ground floor 'non A1 use class' proposals within centres. Comment

8.126 Amongst the local missions set out within the Local Economic Delivery Plan are 'Growing and Promoting Swansea's Strengths and Experience Offer', with the strategic aims of 'Creating Connected, Sustainable Places' and 'Strengthening Our Distinctiveness'. With particular reference to the former, a specific objective refers to 'Creating flourishing, accessible district and local centres'. Comment

8.127 Appropriate regeneration opportunities that enhance the vitality and viability of the network of Large & Small Neighbourhood Centres will be supported. Proposals will however need to accord with Strategic Policy 9 'Swansea Central Area and City Waterfront recognising the primacy of the Swansea Central Area and City Waterfront. Proposals should demonstrate a level of alignment with the settlement strategy and wider policy framework of the Plan, whilst also reflecting the role and function of places. Comment

8.128 Associated British Ports (ABP) is the owner and operator of the Port of Swansea which is the most westerly of ABP's South Wales Ports. The operational ports and docks covers an area of some 521 acres and is an important commercial asset and handles around £140 million of trade per year. The port has the capacity to handle large vessels and is equipped to handle a wide range of cargo. The port is an attractive destination for visiting cruises and offers exciting development opportunities. Comment

8.129 The operational port and docks is an important commercial asset, providing jobs and business opportunities that contribute towards economic regeneration and international trade. The future development and viability of the port and docks provides a strategic opportunity for investment and regeneration along the Fabian Way Corridor, which is a regional regeneration priority and surrounds the established port. Comment

8.130 The National Marine Plan (2019), seeks to support the sustainable development of port, harbour and marina infrastructure and safeguard the ports and shipping sector. In 2023 the Celtic Freeport, which includes Port Talbot, was announced by the UK and Welsh Governments as one of two successful bidders in Wales; the Freeport is expected to be formally operational in 2025, with tax site benefits already in place. This is likely to result in increased activity at the Port of Swansea and, in particular, is well placed to take advantage of renewable energy opportunities from the energy sector. Comment

8.131 ABP indicate that over the plan period, the port will continue to be an operational port, accommodating traditional port cargoes as it moves away from supporting carbon-based industry. The Port will also play an increasingly important role in the decarbonization of the wider economy and zero-carbon energy generation, as well as being a home for digital logistics, high-productivity advanced manufacturing and innovation. There is a particular opportunity to increase economic activity associated with Floating Offshore Wind in the Celtic Sea (FLOW). The designation of the Celtic Freeport offers opportunities to create an integrated 'Swansea Bay' offer to FLOW investors, attracting business to Swansea in the FLOW technical supply chain along with Operations & Maintenance (O&M) activity. There may also be possibilities to develop other supporting research and development and innovation space for businesses that need a quayside location. Comment

8.132 Transformative proposals are being led by DST innovations and Batri for the creation of a £6.25 billion renewable energy scheme at the port. Potential components of the scheme include a tidal lagoon, renewable energy transport hub on Fabian Way and oceanic and climate change research centre data centre and high tech battery manufacturing plant, floating solar array and battery farm, alongside other related development. Subject to full assessment through the planning process in the context of local and national planning policy, the project has potential to create over 2,500 permanent jobs and has potential to support the creation of thousands more across Wales and the UK. This could include many hundreds of jobs during its construction phases. Comment

8.133 Proposals for enhancing facilities and operations at the port and docks will be supported where development has suitable regard to issues of amenity, land use compatibility and environmental impact. Whilst considerable Permitted Development (PD) Rights exist for docks related development, where proposals are subject to EIA Regulations, the PD Rights do not apply. Any proposals to alter the water level within the Prince of Wales Docks (no longer in operational port use) will be carefully assessed via the Habitats Regulations as there is a direct hydrological link between Crymlyn Bog SAC and the Kings and Queens Docks and Tennant Canal. Comment

8.134 Proposals must have regard to safeguarding the rail link to the docks and the potential for future enhancement of the rail freight network, together with wharves which are used for the unloading of marine dredged sand and gravel resources in order to encourage the transport of mineral freight carried by rail or waterway rather than by road, wherever this is economically feasible. This is in order to promote the integration and coordination of transport and land use planning, inclusive of the provision of adequate storage and processing facilities for minerals at the docks, having regard to national planning guidance. The route of the former canal route, which could link the Tennant Basin with Prince of Wales Dock and the River Tawe, must also be considered. Comment

8.135 The visitor economy is a key component of the County's wider economy, with the County attracting over 4.7million visitors in 2023, contributing £609 million to the local economy and supporting over 5,000 jobs. Comment

8.136 Noting the provisions of Strategic Policies SP9 'Swansea Central Area and City Waterfront' and SP10 'Centres First' and the primacy of Swansea Central Area and City Waterfront's destination function, appropriate new tourism attractions and accommodation will be supported in the Swansea Central Area and City Waterfront along with significant new leisure and cultural facilities in order to help develop the County as an attractive and sustainable year round tourism destination. Comment

8.137 Outside the urban area, all development must be undertaken in a sustainable manner so that there is no detriment on the natural environment, landscape, seascape or townscape for the enjoyment of future generations. New, or the expansion of existing, tourism attractions, leisure and cultural facilities, and visitor accommodation will be supported where appropriate in terms of type of proposal, location, landscape setting and capacity, infrastructure capacity and other constraints. Within the Gower National Landscape (AONB), development must have regard to the purpose of the designation to conserve and enhance the natural beauty of the area. Comment

8.138 Existing visitor, cultural and tourism assets should be maintained in order to sustain and enhance the visitor economy. Comment

8.139 The Council's Destination Management Plan(DMP) 2023-2026 (produced by the Council and the tourism industry partners) sets the direction for the visitor economy in the County, with four strategic priorities: Driving quality, braking fee of seasonality, encouraging sustainability and working partnerships. Comment

Facilitating Accessible and Healthy Environments

8.140 Healthier places reflect the health and well-being needs of users, both existing and future. The policy aims to support the delivery of the key Well Being Plan Objective to 'Live Well, Age well' with planning decisions contributing towards achieving the best possible health and well-being outcomes. The wider determinants of health are social, economic and environmental factors that influence health, well-being and inequalities.  Comment

8.141 This strategic policy highlights the importance of understanding these determinants and considering health and wellbeing within all development proposals. Detailed consideration will be given via specific policies within the Deposit Plan. Comment

8.142 The planning system and development can contribute positively to health and wellbeing by using Placemaking principles to facilitate more inclusive and accessible places, connecting people to a range of services via high quality walking and cycling routes enabling people to enjoy active and healthy lifestyles. This includes the provision of active travel infrastructure, open spaces, formal and informal outdoor spaces for play and sport provision, green infrastructure, including spaces for growing food; and high-quality housing that meets identified needs. In this context, existing formal and informal outdoor spaces will be safeguarded to ensure their loss will not result in a deficiency. Areas for food growing spaces and agricultural land graded Best Most Valuable (BMV) are key for food security and healthy living as well as lowering the carbon footprint associated with food production. Development will not be permitted that would result in the unjustified loss of BMV agricultural land. Policies SP15 'Climate Change and Decarbonisation' and SP17 'Green Infrastructure' provide further details. Comment

8.143 Development proposals must safeguard public health and well-being, including the potential risks arising from climate change. In achieving this, development proposals must demonstrate that they will not result in an unacceptable impact on people and residential amenity, including from varying forms of pollution. Comment

8.144 Pollution may cause significant risk to human health and well-being, residential amenity, and the natural and historic environment. Development that would result in significantly high levels of air, noise or light pollution must be appropriately located away from residential areas in order to reduce exposure, other sensitive developments and areas of landscape, natural environment and heritage importance. The Plan also seeks to ensure that incompatible development and land uses are not located close to existing sources of potential pollution. Sensitive development (such as hospitals, schools, care homes and housing) will not be permitted in locations resulting in increased exposure of people to pollution unless adequate mitigation is demonstrated, and impacts are minimised. Consideration of surrounding soundscape must be demonstrated, and development will not be permitted which increases exposure to poor or inappropriate soundscapes. Where practical and feasible, all developments should seek to improve soundscape. Comment

8.145 The County has a designated Air Quality Management Area, a number of defined Quiet Areas and Noise Action Planning Areas all of which will be shown on the Deposit Plan Constraints and Issues Map. Comment

8.146 The redevelopment and rehabilitation of derelict and contaminated sites can aid regeneration and help improve the overall character of an area. Developers will be required to demonstrate that any actual or potential contamination can be overcome, thereby ensuring that the land is suitable for the development proposed. The County contains one defined land slip area which will be shown on the Deposit Plan Constraints and Issues Map. Comment

8.147 LDP2 supports the provision of primary and secondary health care facilities, and whilst the Council does not directly deliver healthcare facilities, it does have a key enabling role. The Plan will support the expansion of healthcare facilities to the north of Morriston, within the existing safeguarded area in the current adopted LDP, to facilitate emerging Health Board strategy for the improvement of clinical facilities at the site. Strategic transport infrastructure improvements to facilitate this strategic scheme of improvements will be supported by LDP2 which will require access route improvements at Mynydd Gelli Wastad Road and new transport infrastructure to the north within safeguarded land. The strategic transport improvements to accommodate the uses may necessitate the provision of a new link road from J46 of the M4 to tie in with any upgraded access route infrastructure. The plan will facilitate delivery of this subject to the need being justified as part of a detailed Transport Impact Assessment as part of the emerging project. Comment

8.148 Proposals at Cefn Coed Hospital involve the creation of a new Adult Mental Health Unit along with some redevelopment of surplus land within the site for residential development. Both the Morriston and Cefn Coed proposals form SPRA opportunities identified in Policy SP8 Strategic Planning and Regeneration Areas. Comment

8.149 The Council will consult with the Local Health Board if, as a result of large housing developments (or where there are cumulative effects from a number of smaller developments), there is considered to be a potential need to deliver appropriate new health care facilities or infrastructure. Comment

8.150 Health Impact Assessments consider how the population will be affected by development, assessing both positive and negative health impacts. The policy seeks to ensure that new development does not increase health inequality in an area but promotes healthy communities and reducing health inequalities. HIAs will be encouraged on relevant applications which should be proportionate to the nature and scale of development. Guidance on completing HIAs has been produced by the Welsh Health Impact Assessment Unit. Comment

8.151 Llwbyr Newydd – the Wales Transport Strategy (2021) sets out the vision that will shape the delivery of a national integrated transport system over the next 20 years. There are 3 key headline priorities over the next 5 years identified in the Strategy (and which are also overarching key priorities in the emerging Regional Transport Plan (RTP) for South West Wales), which LDP2 will address through this strategic policy and subsequent detailed policies in the Deposit Plan. These are: Comment

• Bring services to people in order to reduce the need to travel;
• Allow people and goods to move easily from door to door by accessible, and sustainable and efficient transport services and infrastructure;
• Encourage people to make the change to more sustainable transport.

8.152 The Transport Hierarchy for Planning (Planning Policy Wales (Edition 12, 2024) supports the aims of enhancing sustainable travel options and decreasing dependency on car travel by bringing services to people to reduce the need to travel. The Plan will reflect such aims, both at a strategic level (in terms of the scale and distribution of growth) along with a site/application level (in terms of the provision of a policy framework for the consideration of development proposals). In this regard, the clear link and interrelationship between spatial and transport planning is readily acknowledged. Comment

Figure 7 The Sustainable Transport Hierarchy for Planning (Planning Policy Wales Edition 12, 2024) Comment

8.153 The embedding of a Placemaking approach to all new development proposals means that the consideration of transport, movement and connectivity related matters should form an integral component of site-based design and layout considerations. Detailed policies covering such matters will be set out in the Deposit Plan (which may include matters relating to density requirements, parking layout and surveillance considerations and parking standards, visibility splays/safety and technical aspects as appropriate). Comment

8.154 As well as providing site based guidance, the preparation of the Deposit Plan can also allow for any proposed priority schemes (e.g. within the emerging RTP) to be safeguarded and/or shown on the proposals map where there is sufficient certainty in place that they will happen. Comment

8.155 In noting the emphasis on reducing the need to travel (and reducing emissions), the recognition of the accessibility needs of rural communities, as well as urban communities, is an implicit facet of the 'One Swansea' approach that underpins the 'Abertawe 2038' vision. The Plan will contribute towards ensuring that communities have access to a modern, resilient, accessible, inclusive, and integrated sustainable transport network, helping to promote social inclusion. For example, this could involve supporting demand responsive transport which can help with accessibility challenges in rural areas. Comment

8.156 Swansea Central Area has a mainline railway station on the South Wales Main Line, providing direct services to Cardiff, Newport, Bristol, and London Paddington. There are three further railway stations in the County. The stations at Gowerton and Pontarddulais. provide rail services connecting Swansea to West Wales, such as Llanelli, Carmarthen, and Pembrokeshire. Comment

8.157 The Swansea Bay and West Wales Metro (SBWWM) is being developed in partnership by Swansea, Neath Port Talbot, Carmarthenshire and Pembrokeshire local authorities, working alongside Welsh Government and the South West Wales Corporate Joint Committee. The Plan will seek to align and reflect such emerging proposals and will also respond as appropriate to the priorities set out in the RTP and its delivery plan. As set out in chapter 7, this identifies significant new projects to improve the efficiency of the transport network through proposed new stations at various locations across Swansea. Comment

8.158 The bus network in the County is operated by First Cymru and South Wales Transport. The proposed move to bus franchising as part of Welsh Government bus reform proposals is intended to improve the reliability, affordability and flexibility and ease of use of the bus network. The franchising area include South West Wales from 2027 and the plan will need to take account of this as it emerges. Buses link the Swansea Central Area with outlying suburbs, the Gower Peninsula, and neighbouring towns and villages. There are currently two park and ride sites which are located 1.5 miles north and east of the city centre at Landore and Fabian Way. Comment

8.159 Future Wales: The National Plan 2040 (2021) recognises that the South West Wales region is served by ports at Milford Haven, Port Talbot, Swansea and Fishguard and plays an important role supporting the maritime sector and the national economy. It recognises that the ports are important national infrastructure and supporting their future role locally, regionally and nationally is a key consideration. Comment

8.160 In line with the Welsh Government's Active Travel (Wales) Act 2013 and delivered as part of the active travel fund, there has been significant investment in the County's Active Travel routes. The current active travel network in Swansea consists of over 120km of on and off-road cycle and walking routes. There is significant further investment ongoing to increase Active Travel routes in the County and the plan will facilitate these. Comment

Other Key Infrastructure projects

8.161 There are a number of key infrastructure projects supported by committed funding schemes and/or subject to future potential bids that will contribute to the overall objective of improving the quality of the integrated network across Swansea. Specifically, development should, where appropriate, support the delivery of the following alongside any other projects that may be identified in the emerging RTP: Comment

• Public Transport Hubs – Improvements to existing interchange facilities, maximising the opportunities for travel and improving comfort, safety and the installation of real time passenger information to allow for passengers to make informed decisions about their journeys.
• Bus Corridor Infrastructure Assessment and Improvement Package– The study is taking a holistic approach and is looking to implement mobility hubs at strategic locations along the Swansea Valley bus network.
• Swansea Valley Bus Corridor Infrastructure Study – This includes alternative options being considered for additional park and ride in Swansea. Progress is also being made with a potential new South Wales Metro station at Landore.
• The Swansea Valley Sustainable Transport Corridor; - This is a key study aiming to enhance sustainable transport options from Cadle to High St Station, taking in the current junction pinch points, and improving access to the proposed new Cockett Station.
• Swansea Northern City Sustainable Transport Corridor – This encompasses a stretch between High Street along Carmarthen Road to Fforestfach. The scheme is currently at WelTAG Stage 2 and will look to implement sustainable transport modes along the corridor in line with the transport hierarchy.
• Active Travel Network Development opportunities

8.162 The Council has secured £7 million of grant funding from Welsh Government to provide a number of sustainable transport schemes across the City, including: Comment

• The Swansea Bay and West Wales Metro project.
• The installation of real time passenger information along key bus routes.
• The development of passenger transport hubs at Mumbles and Morriston as part of the Swansea Valley Bus Pilot scheme.
• The installation of more electric vehicle charging points plus eight new 'fast' charging points across four sites in the city.

8.163 The RTP Delivery Plan will set the initiatives and schemes that are proposed for delivery in the timeframe 2025 to 2030 and will encompass a fully prioritised list of the interventions in the Region that the CJC and the four local authorities are committed to in order to achieve the RTP objectives and implement Llwybr Newydd – The Wales Transport Strategy (2021). Amongst those schemes that are deemed of relevance to Swansea listed in the draft RTP Delivery Plan are: Comment

• Cockett Station Access: Improved access for all modes to enable interchange at the proposed Cockett Station.

• Fabian Way Corridor Enhancements: A programme of works, predominantly focused on the replacement of Baldwins Bridge, subsequently enabling extension of Langdon Road to Baldwins Crescent and the A483. A new link road would be constructed as part of this scheme. This programme of works could progress alongside and complement the tidal lagoon and other developments along the Fabian Way corridor, or in isolation.

• Morriston Hospital Link Road: Support with delivery of Morriston Hospital (NHS funded) link road.

• Park and Rail Gowerton Station: Implementation of a park and rail facility and multi-modal interchange facilities at Gowerton train station.

• Park and Rail Llansamlet Station: Implementation of a park and rail facility and multi-modal interchange facilities at Llansamlet train station.

• Pontarddulais Station Access: Improved access for all modes to enable interchange at Pontarddulais Station.

• Regional Transport/Land Use Planning Initiative: Policy based framework for the integration of land use planning with transport. This is designed to support the development of the SDP and will include policy and scheme definition in the SDP context.

• Supporting infrastructure for Swansea Bay and South West Wales Metro schemes: Schemes or works providing supporting infrastructure to enable rail enhancements through new stations / services proposed as part of the Swansea Bay and South West Wales Metro.

8.164 The above is not an exhaustive list of all infrastructure schemes and/or key transport measures and the Deposit LDP2 will be formulated on the very latest proposals having regard to the agreed RTP and Delivery Plan. Comment

8.165 There are two canals in the County, the Swansea Canal and the Tennant Canal. These Canals, and any potential links to the River Tawe or the Prince of Wales Dock, will be preserved or enhanced. The canals form an important part of the County's heritage and are significant for biodiversity and landscape reasons, while providing opportunities for regeneration, Active Travel and recreation as part of the wider Green Infrastructure network. Comment

Maximising Environmental Protection and Limiting Environmental Impact

8.166 In acknowledging the Council's declaration of a climate emergency and its 'net zero by 2030' ambitions, together with the wider just transition to net zero by 2050 societal target, a core function of LDP2 is to ensure that all development in the County is sustainable. Particular reference is made in this regard to the Well-being of Future Generations (Wales) Act 2015 and the Climate Adaptation Strategy for Wales (2024). As part of net zero ambitions, the Council's Local Area Energy Plan presents the strategic vision for Swansea's future energy system delineating the essential characteristics it will need to achieve a net zero energy system by 2050. The placemaking strategy will contribute to the key action of facilitating renewable and low carbon energy through the planning process. Comment

8.167 Whilst the Plan cannot tackle these challenges in isolation, it does need to provide a framework for sustainable growth that contributes to addressing the climate emergency by promoting development that mitigates the causes of climate change and which is able to adapt to its likely effects, as well as increasing resilience. Comment

8.168 The Swansea Local Area Energy Plan (LAEP) May 2024 outlines that historic carbon emissions have fallen, mainly due to the decarbonisation of the electricity grid since 2013. However, fossil fuels still make up the majority of energy consumption. The LAEP confirms that road transport and domestic housing are the two most energy intensive and polluting sectors and Strategic Policy 13 acknowledges the contribution that the Plan needs to make in this regard. Comment

8.169 Carbon sinks act as a means of off-setting carbon emissions by natural means. Trees and soils act as substantial reservoirs of carbon, sequestering or trapping atmospheric carbon. Soils accumulate carbon faster under tree cover than other forms of vegetation. This stored carbon will usually be emitted as a greenhouse gas if trees are removed or damaged, or soils removed, covered or disturbed (by compaction or contamination) during the construction process. Areas of the County shown as important for Peat (Peatlands of Wales) are critical carbon sinks that need to be protected. Further strategic opportunities for the sequestration and storage of carbon in different land, vegetation, soils and sediments over time may be identified through the processes set out in the Welsh Local Government Association's Land Use and Carbon Sequestration Guidance and Tool (2023). Comment

8.170 The County's open spaces, trees and soils play a crucial role in mitigating the effects of climate change at the local level. Strategic Policy 15 promotes that, as far as practicable, trees should be retained and protected, and land kept as functioning vegetated soil open to the fall of organic matter, with new trees and shrubs provided by developers wherever possible. Open vegetated soils absorb rainfall and runoff. Where trees and shrubs cannot be surrounded by open soil, hard surfaces should not be used unless there is an overriding need, and areas that are not needed for pedestrian or vehicle use should be retained for soft landscaping. Comment

8.171 A key facet of the 'Placemaking Strategy for Swansea to 2038' is to embed a place led approach in new development that delivers sustainable placemaking and connected growth which aligns locations for new housing, employment, services and facilities to reduce the need to travel. Furthermore, there is emphasis on allocating development in connected locations well served by existing public transport provision. One of the actions set out within the LAEP is to 'Enhance Active Travel and Public Transport to Reduce Reliance on Personal Motorised Vehicles'. Reference is also made to Strategic Policy 14 Sustainable Transport & Active Travel'. Comment

8.172 Adapting to the implications of climate change will require buildings to be designed such that they are able to cope with the likely increased temperature ranges, more frequent and severe flooding and increased extreme weather events. Buildings and related infrastructure should be designed to be robust and flexible not only to climatic change, but also to accommodate a variety of uses over their lifetime rather than being suitable for one sole application. Comment

8.173 Prioritisation should be given to the reuse and/or adaption of existing buildings, with an emphasis on resource efficiency and sustainable construction techniques, including sourcing materials locally. Development should incorporate appropriate climate responsive design solutions including orientation, layout, density and low carbon solutions. Planning Policy Wales (Edition 12, 2024) sets out clear guidance in terms of the requirements for climate responsive developments and sustainable buildings. Reference should be made to the Practice Guidance – Planning for Sustainable Buildings (Welsh Government (2014). Further guidance can be set out within the Deposit Plan. Comment

8.174 The vulnerability of infrastructural assets to climate change is noted within the Climate Adaptation Strategy for Wales (2024). Many modern-day services and their underlying infrastructure rely on digital connectivity to operate effectively including water, electricity and gas infrastructure. Comment

8.175 The key risks to telecommunications are from the impacts on the enabling infrastructure such as subsurface, undersea and overground cables, communications masts, key buildings (e.g. telephone exchanges) and data infrastructure (e.g. data centres). These can be impacted by severe weather (e.g. storms) and both fluvial and coastal flooding. Comment

8.176 There will also be a need to manage risks to wider infrastructure such as roads, railways and utilities, all of which are at risk to the threats of coastal change. High temperatures can impact upon infrastructure, power supplies, productivity and health. Comment

8.177 Social infrastructure is already being impacted, with many of these matters having a wider well-being perspective – for example postponement of recreational activities (e.g. football) due to unplayable facilities. Comment

8.178 Energy infrastructure assets could affect, or be affected by, failures of other assets due to extreme weather such as transport, information and communications technology (ICT) and water infrastructure including reservoirs, pipelines, water treatment plants and sewage treatment plants. There are also risks to buried infrastructure such as gas pipelines, with damage potentially becoming more frequent in future. Reference is made to Strategic Policy 6 'Planning Obligations for Infrastructure and Other Measures'. Comment

8.179 The Welsh Government has set a target for Wales to meet the equivalent of 70% of its annual electricity demand from renewable sources by 2030. Planning Policy Wales outlines that the planning system has an active role to help ensure the delivery of these targets, in terms of new renewable energy generating capacity and the promotion of energy efficiency measures in buildings. Furthermore, in January 2023, the Climate Change Minister published a consultation on 'ambitious but credible' targets for Wales to meet 100% of its electricity needs from renewable sources by 2035. Comment

8.180 The South West Wales Regional Energy Strategy (2022) has been adopted as the framework for the South West Wales Corporate Joint Committee's (SWWCJC) energy programme. It sets out a policy ambition of a 55% reduction in energy emissions across the region by 2035, and amongst the priorities to achieve this are energy efficiency, decarbonising heat and electricity generations. Comment

8.181 The South West Wales Regional Economic Delivery Plan (2021) has been adopted as the regional strategy for the economic wellbeing strand of the SWWCJC. It contains a mission of establishing South West Wales as a UK leader in renewable energy and the development of a net zero economy, taking forward the region's major energy related projects and driving the benefits through the region (via industrial decarbonisation, supply chain opportunities, university-linked innovation, etc.). Also, one of the actions set out within the LAEP is to 'facilitate renewable and low carbon energy schemes via a supportive planning process to increase locally produced decarbonised energy'. Comment

8.182 Amongst the local missions set out within the Local Economic Delivery Plan) are 'Transitioning to a Net Zero Economy', with the strategic aims of 'Decarbonising the Business Base' and 'Decarbonising the Wider Economy'. Energy is also a central theme in the Council's Corporate Plan 2023-2028, focusing on developing low carbon energy and efficient council homes, whilst the Council's Net Zero Delivery Plan includes a breakdown of actions that the Council wants to pursue – including building retrofit and renewable energy schemes. Comment

8.183 Strategic Policy 15 recognises the fact that Future Wales: The National Plan 2040 (2021) outlines that in determining planning applications for renewable and low carbon energy development, decision‑makers must give significant weight to the need to meet Wales's international commitments and our target to generate 70% of consumed electricity by renewable means by 2030 in order to combat the climate emergency. Future Wales also sets out pre-assessed areas for wind energy and district network priority areas. Proposals for large-scale energy development are classed as 'Developments of National Significance' and are determined by the Welsh Ministers. Proposals below the threshold for Developments of National Significance are determined by local planning authorities. Comment

8.184 The County boasts significant potential for renewable and low carbon energy generation, along with new energy infrastructure, which together can help meet carbon reduction requirements and deliver economic benefits. It is noted that, at 10.4m, Swansea Bay has the second highest tidal range in the world. Strategic Policy 11 'Port of Swansea and Docks Regeneration' is enabling of a potentially transformational renewable energy scheme at this location that could harness this unique opportunity. Comment

8.185 Appropriate proposals that will increase the supply of renewable and low carbon energy within the County will be supported. The Deposit LDP will contain more information and specific policies as appropriate in order to elaborate and build upon the positive direction of travel set out in Strategic Policy 15. This can include the setting out of criteria for the consideration of various types of proposals, including wind and solar. Comment

8.186 A Stage 1 Renewable Energy Assessment (REA) has been produced in support of the Preferred Strategy. A detailed REA will be produced to inform the Deposit Plan. Due regard will be given to setting out targets for generating renewable energy within the Deposit Plan, recognising the importance of the Plan contributing to unlocking the renewable energy production potential in the County. Comment

8.187 The REA follows the method set out in the Welsh Government's guidance 'Planning for Renewable and Low Carbon Energy - A Toolkit for Planners, 2015'. The evidence base produced aims to estimate the scale of resource within the Swansea Council geographic boundary that is available for use, providing context for setting local policy and targets. It will also provide direction to the authority on how it can play its part in meeting the National and UK renewable energy targets. Initial work consists of an 'Area wide renewable energy assessment' to inform the preferred strategy, the remainder of the REA study will be completed at a later date to accompany the deposit plan. Comment

8.188 The preparation of the Deposit Plan can also respond to the identification of Swansea as a district heat network priority area, and in accordance with Planning Policy Wales, consideration will be given to requiring applications for major development to be accompanied by an Energy Report. Furthermore, there is an opportunity for strategic sites to identify opportunities to require higher sustainable building standards, including zero carbon. Comment

Figure 8 Future Wales Wind Energy and Heat Networks

8.189 There are communities within the County at risk from flooding and/or coastal erosion. Avoiding unnecessary flood risk from development proposals will be achieved by strictly assessing the flood risk implications from all sources within susceptible areas and preventing development that unacceptably increases risk. A precautionary approach means that development will only be considered in areas at high risk of flooding where the Council is satisfied that the flood risk location is justified and where technical assessments demonstrate that the consequences of flooding can be satisfactorily managed. A South West Wales Stage 1 Strategic Flood Consequence Assessment (SFCA) (2022) has been produced. Ahead of the preparation of the Deposit Plan, the Council will continue to monitor the position in respect of any new Technical Advice Note (TAN) 15 and the Flood Map for Planning being issued by the Welsh Government. Comment

8.190 Whilst Sustainable Drainage Systems (SuDS) is covered by a separate regulatory regime, it is important to embed a strategic recognition of the importance of managing surface water and runoff as part of the development process, including site design. The importance of nature based solutions in this context should be recognised. Development proposals should not increase flood risk elsewhere, and in a changing climate of more intense and prolonged rainfall, suitable attenuation and management of water (recognising capacity of sewer systems and any CSO outfall issues) is key. Comment

8.191 Climate change also requires consideration of water supply and drought. Whilst it is considered that the levels of growth set out within the Preferred Strategy can be accommodated, the promoting of the efficient use of water resources as part of the development process is inherently recognised as a strategic priority. Comment

8.192 Climate change also poses challenges to societal well-being. Landscape and green infrastructure will be a critical issue with trees providing protection both by shading and active cooling, including for habitat retreat. This cooling will be particularly important in urban centres, and where children, older people, and people with mobility impairments gather. Growing spaces and Best and Most Versatile agricultural land are key for food security and healthy living as well as lowering the carbon footprint associated with food production. Comment

8.193 The Council recognises that the implications of biodiversity loss is as serious as climate change and that they are inherently linked, and as such, declared a nature emergency in November 2021. The Section 6 Biodiversity and Resilience of Ecosystems Duty Action Plan (Section 6 Action Plan) 2023-2025 prioritises key actions the Council can take that best impact positively on nature in Swansea. The Swansea Local Nature Recovery Action Plan (LNRAP) (2023) sets out the Council's response to address the decline in nature and the resultant nature emergency and a strategy for achieving nature recovery. The strategy reflects Welsh Government's '30x30' target aiming to ensure at least 30% of Swansea county is protected and effectively managed for nature by 2030. It contains objectives and actions to increase the resilience of the natural environment by restoring degraded habitats and habitat creation and to tackle key pressures on species and habitats, including increasing connectivity of key wildlife corridors. Future development should recognise the importance of the County's natural environment and ensure it is conserved and enhanced for future generations. A net benefit for Biodiversity sought by the Council will be proportionate to the nature and scale of the development. Comment

8.194 The County is ecologically rich, with approx. 21% of the area statutorily designated for nature, increasing to 43% if non statutory designations such as Sites of Importance for Nature Conservation (SINCs) are included. Seven national network sites are partly within Swansea's boundaries – Crymlyn Bog SAC, Carmarthen Bay and Estuaries SAC, Carmarthen Bay Dunes SAC, Bristol Channel Approaches SAC, the Limestone Coast of South West Wales SAC, Carmarthen Bay SPA and Burry Inlet SPA. Only two sites are located entirely within the County (Gower Ash Woods SAC and Gower Commons SAC). Other statutorily protected sites include sites of Special Scientific Interest (SSSIs), National and Local Nature Reserves (NNRs and LNRs). Protected sites tend to have the highest levels of ecosystem resilience. Comment

8.195 The LNRAP recognises the importance of facilitating ecosystem resilience across Swansea to address biodiversity decline. Ecosystem resilience is the capacity of an ecosystem to deal with pressures and demands whilst retaining their ability to deliver ecosystem services and benefits. The greater the diversity and connectivity of an ecosystem, the more it is able to provide ecosystem services and continue to provide them in face of pressures, such as climate change. Development should seek to facilitate this through the design of schemes and through GI Statements. It is also necessary that development proposals consider the importance and features of Sites of Importance for Nature Conservation (SINCs) and local wildlife sites. Development on, or adversely affecting, other non-designated sites or wildlife corridors with biodiversity value will only be permitted where it can be demonstrated that the need for the development outweighs any harm caused by the development and that net biodiversity benefit measures can be provided. Comment

8.196 Climate change is exacerbating the wider existing pressures upon species and ecosystems. Maintaining and enhancing biodiversity promotes the resilience of ecosystems and the ability to adapt to climate change. Resilient ecosystems are defined as diverse, connected, of sufficient extent and in good ecological condition so that they can adapt to change and continue to provide benefits for future generations. Measures to address the climate emergency in policy SP16 therefore include the promotion of ecosystem resilience. Nature networks, areas of high ecological resilience, ecological networks and habitat connectivity corridors will be detailed further in the Deposit Plan. Comment

8.197 Development will not be permitted if judged to have a significant adverse effect on the integrity of any European Designated Sites, either alone or in combination with other plans or projects. European Designated Sites are protected via the Conservation of Habitats and Species Regulations 2017 (as amended) (Habitats Regulations). Such sites include Special Protection Areas (SPAs) and Special Areas of Conservation (SACs), and UN designated Ramsar sites. As a matter of national policy, Ramsar sites are afforded the same policy protection as SPAs and SACs. The County contains a number of such sites which are vulnerable from pollution, including air and water. Only development which demonstrates compliance with the Habitats Regulations will be permitted. Comment

8.198 Green infrastructure describes a multifunctional network of natural and managed spaces that connect nature, people and communities for mutual benefit. It is a network of natural and semi‑natural features, green spaces, rivers and lakes that intersperse and connect places. Component elements of green infrastructure can function at different scales and some components, such as trees and woodland, are often universally present and function at all levels. At the landscape scale green infrastructure can comprise entire ecosystems such as wetlands, waterways, peatlands and mountain ranges or be connected networks of mosaic habitats, including grasslands. At a local scale, it might comprise parks, fields, ponds, natural green spaces, public rights of way, allotments, cemeteries and gardens, or may be designed or managed features such as sustainable drainage systems. At smaller scales, individual urban interventions such as street trees, hedgerows, roadside verges, and green roofs/walls can all contribute to green infrastructure networks. Comment

8.199 Green infrastructure has a potentially important role to play in mitigating the impacts of extreme weather events, particularly extended heat waves. In addition, green infrastructure helps support biodiversity and makes an important contribution to the quality of the environment. Access to beautiful and well-maintained green spaces such as parks and gardens, country parks and wildlife areas, supports both physical and mental health and well-being. By its nature, Green Infrastructure is capable of providing several functions at the same time (multifunctionality) and, as a result, offers multiple benefits for social economic and cultural as well as environmental resilience. Comment

8.200 Important elements of existing green infrastructure will need to be identified, protected and enhanced wherever possible, with existing GI incorporated into the design of proposals where this would deliver good placemaking. The significance and functions of existing GI will need to be assessed taking into account the size, context, character and features of the site. Comment

8.201 The plan will facilitate the creation of recreation facilities including formal and informal open space provision. This will include the creation of new on-site facilities, or the improvement of existing local provision off-site, along with appropriate maintenance contributions. Formal outdoor spaces are areas designed and maintained for structured, organised activities, such as sports and formal recreational use which include playing pitches. Informal outdoor spaces are green areas intended for unstructured, casual use, promoting relaxation and social interaction which include parks and natural & semi natural greenspace. Comment

8.202 An initial Green Infrastructure Assessment (GIA) has been produced to underpin the LDP2 Green Infrastructure Policies and Strategies. This identifies key strategic opportunities where the restoration, maintenance, creation and connection of green features and functions will deliver the most significant benefits. The GIA will inform the concept planning and detailed masterplans for sites that will be allocated in the Deposit LDP. Comment

8.203 The GIA has split the county into six 'Green Infrastructure Target Areas' (GITAs). These are based on geographies where emerging priorities for GI enhancement or concentrations of GI assets are located. This approach, rather than based on other boundaries such as habitats or watersheds, was felt to be more appropriate when identifying areas of multi-functional GI. This is because GI assets include cultural or transportation related features that do not relate or follow environmental boundaries. As such, the GITAs do cross watersheds, ecological designations and topography but that is not intended to mean that the functional connections and links between these GI systems should be ignored. The interim GIA sets out a vision and objectives for each GITA. The priorities align with the South West Wales Area Statement and ecosystem resilience priorities. The six GITAs are: Comment

• Parc Y Mawr
• Gower Linkages
• Swansea Urban Greenspace Network
• Crymlyn Bog and surrounding area
• Tawe Valley
• Gower National Landscape and North/South Gower Links

8.204 Swansea Central Area and City Waterfront lies within the Swansea Urban Greenspace Network GITA which is further supported by the Council's Green Infrastructure Strategy: Swansea Central Area - Regenerating our City for Wellbeing and Wildlife. Comment

8.205 All planning applications are required to submit a Green Infrastructure Statement. The statement should be proportionate to the scale and nature of the development proposed and describe how green infrastructure has been incorporated into the proposal. The green infrastructure statement will be an effective way of demonstrating positive multi‑functional outcomes which are appropriate to the site in question and must be used for demonstrating how the step‑wise approach has been applied and a net benefit for biodiversity achieved. A Biodiversity and Development Supplementary Planning Guidance supports the existing LDP setting out in detail how the stepwise approach is applied in Swansea and provides guidance on the approach for development at all scales. This will be updated as necessary to inform LDP2. Comment

8.206 The GIA should be used by design teams in the preparation of GI Statements. The GIA helps identifies the functions of GI which are a priority in each of the GITAs and development should seek to positively contribute to these objectives where appropriate. Comment

Figure 9 Swansea GI Strategic context

8.207 The County has significant landscape resources and areas of visual quality and is home to a nationally designated landscape. This provides significant environmental, economic, cultural, and social benefits and help to create a sense of place. Comment

8.208 National Planning Guidance requires development plan policies to favour the conservation of the natural beauty of National Landscapes (AONBs), whilst also recognising that regard should be had to the economic and social well-being of such areas. National Landscapes must be afforded the highest status of protection from inappropriate developments. The LDP seeks to protect the Gower National Landscape (AONB) from inappropriate development in order to maintain its unique character, special landscape qualities and local distinctiveness. Comment

8.209 The Gower National Landscape (AONB) provides a range of benefits for the County's residents and the quality of the landscape and seascape is a major draw to visitors. Proposals for development within, or affecting the setting of, the Gower National Landscape (AONB) should have regard to the strategic objectives and policy proposals set out in the Gower AONB Management Plan, 2017 and seek to conserve and enhance the unique character and special qualities of the landscape. A Landscape Visual Impact Assessment may be required for development proposals within the Gower National Landscape (AONB). Comment

8.210 Development proposals should aim to protect or enhance the natural or historic character and landscape of undeveloped coastlines. The Heritage Coast does not directly affect the status of the area in planning terms, however, the features which contributed to its designation will be an important consideration. Comment

8.211 Any areas of local landscape designation will be identified within the Deposit Plan. Comment

8.212 The County's heritage and cultural assets are integral to Swansea's identity and a finite, irreplaceable source of information about our past. Comment

8.213 The evidence of people's interactions and relationships over generations with place is all around us in the buildings, features and town and settlement patterns of our modern townscapes and landscapes. This historical evidence can help us to understand how places have evolved and provide a deeper context to inform the making of better places for current and future generations. Every place has its own history which has shaped its character. This makes each place unique and understanding this is a key element of placemaking. Comment

8.214 The Plan's spatial strategy recognises the importance of community and sense of place by seeking to distribute new development in a manner that recognises and respects the role and function of our settlements. Understanding the role of historic and cultural heritage and how it can be preserved or enhanced will therefore be key to the success of delivering 'Abertawe 2038'. The Welsh language is one such cultural asset, and reference should be made to Strategic Policy 7 'Safeguarding and promoting the Welsh Language' in this regard. Comment

8.215 Strategic Policy 19 seeks to secure the sustainable management, preservation and enhancement of the character, appearance and setting of our heritage and cultural assets, whilst supporting appropriate heritage led regeneration proposals to realise the social and economic potential of these assets. It also emphasises the importance of increasing the climate resilience and accessibility of such assets. Comment

8.216 Those designated assets and sites referred to in the policy include: Comment

• Scheduled ancient monuments and archaeological sensitive areas;
• Listed buildings and their curtilage;
• Conservation areas;
• Registered Historic Parks and Gardens;
• Registered Historic Landscapes; and
• Historic Assets of Special Local Interest.

8.217 It is important to understand the significance of heritage assets in order to assess the acceptability of change. Heritage Impact Assessments (HIA) are required by Technical Advice Note 24 The Historic Environment (2017) for listed building consent and conservation area consent applications. It may also be necessary to adopt the HIA approach for settings of listed buildings, settings of scheduled monuments development in conservation areas, and undesignated heritage assets. Comment

8.218 In recognition of the large extent of important local buildings and places of interest across Swansea that currently do not benefit from statutory protection, work is underway on preparing a list of local historic assets of special local interest that warrant safeguarding. LDP2 will provide a detailed policy framework to help preserve the special qualities that have resulted in their inclusion and bring forward positive restoration where this is required. The Deposit LDP will set out local policy for the conservation and safeguarding of locally important assets so that their special interest can be taken into account when changes are proposed that require planning permission. Comment

8.219 With reference to the Climate Adaptation Strategy for Wales (2024), together with The Historic Environment and Climate Change in Wales Sector Adaptation Plan (2020), it is acknowledged that climate change will have many impacts on our precious heritage and cultural assets. Development proposals should seek to increase the capacity to manage the impacts and to build resilience, whilst avoiding unintended consequences that could harm the value and significance of cultural and historic assets. Reference should be made to Strategic Policy 15 'Climate Change and Decarbonisation'. Comment

8.220 Development proposals should seek to increase the accessibility of our heritage and cultural assets as a resource such that they can be enjoyed and celebrated by all members of society in a sustainable manner. There is considerable potential in terms of education /interpretation and engendering a feeling of well-being and community pride, as well as providing a vehicle for effective public engagement on climate change. Comment

8.221 Heritage and culture-led regeneration schemes are schemes where cultural or heritage regeneration is a primary component or driver of the proposal. The sensitive and sustainable re-use of redundant historic cultural buildings are important elements of the regeneration and revitalisation of a distinctive and vibrant Swansea City Centre. Comment

8.222 The Council's overall strategic approach in respect of viability considerations and negotiations within a historic / cultural asset context (e.g. a conversion / adaptation / re-use scheme) will be to apply the policies and provisions of the Plan. The onus will therefore be on the applicant to demonstrate why a scheme is not viable and the requirements of the Plan cannot be met. As part of a 'one team Swansea' approach to facilitating delivery of appropriate regeneration schemes and enabling development, the Planning Authority will continue to work in close collaboration with relevant Council departments to ensure that identified grant funding is channelled towards appropriate projects that will deliver economic development aspirations alongside safeguarding and enhancing heritage assets. Reference can be made to Strategic Policy 6 'Planning Obligations for Infrastructure and Other Measures. Comment

8.223 A fundamental part of the Plan's 'Abertawe 2038' Vision is the creation of a place which captures the distinctive relationship between the County's urban, rural and coastal areas and capitalises on these in order to secure the economic sustainability of the area. In particular, the County's industrial and waterfront heritage is a vital part of the Council's initiatives to regenerate the City Centre and Urban Waterfront and ensure that the County represents a strong commercial investment opportunity. Swansea is also a network of places which are the focus of regeneration activities at the heart of local communities. Comment

8.224 The historic and cultural environment also provides opportunities for leisure, tourism and recreation development capable of making a major contribution to the local and regional economy which the Plan seeks to support. Comment

8.225 Further information and elaboration on the strategic policy can be provided in the Deposit Plan and associated guidance as appropriate. Comment

Making Best Use of Resources

8.226 A circular economy is one which aims to keep materials, products and components in use for as long as possible. The principles of the circular economy represent a move away from the current linear model of make, use, dispose, towards the reuse, repair and recycle of wastes which arise during development and should underpin all new development. SP4 'Placemaking Principles' and SP15 'Climate Change and Decarbonisation' also provide guidance on this topic. Comment

8.227 Construction sites inevitably require a degree of cut and fill engineering operations. Developers should design proposals to achieve an earthwork balance and will be required to submit a natural material management plan as part of development proposals which seeks to minimise cut and fill or which may provide for remediation of land elsewhere in the area. The Plan should identify all the natural materials on the site prior to the development, these may be existing buildings to be demolished or the natural ground to be disturbed. It should explain how the generation of waste from these materials will be minimised and that the design and layout has fully considered the need to ensure that a cut and fill balance is as close to neutral as possible. Comment

8.228 Prioritising the reuse of existing buildings over demolishing and rebuilding takes account of their embedded carbon and can prevent waste and the use of new materials. However, it is recognised that this is not always efficient, especially where a new building could have significantly greater sustainability credentials. Therefore, Whole Life Carbon Assessments are encouraged as these can justify when it may be more appropriate to replace a building based by evidencing where less carbon may be emitted by replacing a building. Comment

8.229 The Council must develop a sustainable approach to the management of waste, including the support of proposals for waste operations which move the management of waste up the waste hierarchy, and the identification of land appropriate to facilitate an integrated and sustainable network of waste facilities. In principle, B2 use employment sites are considered appropriate locations for building waste management facilities. Comment

Figure 10 The Waste Hierarchy (Planning Policy Wales, Edition 12, 2024)

8.230 The 'Nearest Appropriate Installation' concept and the principle of self‑sufficiency will only be applicable in relation to wastes covered by Article 16 of the revised Waste Framework Directive^[13] and should guide the provision of an integrated and adequate network for the treatment of such wastes. The network should include all necessary supporting facilities such as waste transfer stations and processing facilities. Comment

8.231 Regard will be had to the annual Waste Planning Monitoring Reports (WPMRs) for the South-west Wales region (as identified in TAN 21) which provide information and recommendations on cross border working, particularly in respect of how the region's residual waste is being managed and whether there is sufficient remaining landfill capacity. Comment

8.232 Planning issues which must be taken into account when preparing applications for waste developments are set out within Annex C of Technical Advice Note (TAN) 21 Waste (2014). A Waste Planning Assessment (WPA) should be submitted with all applications for a waste facility classified as a disposal, recovery, or recycling facility. The WPA should be appropriate and proportionate to the nature, size and scale of the development proposed. Further advice is contained within Annex B of TAN 21 Waste. Comment

8.233 The following information will need to be provided in support of developments, as appropriate, to demonstrate how sustainable waste management will be provided for: Comment

• Plans demonstrating an adequate footprint for the internal and external on-site waste, recycling, composting, separation and storage facilities. Communal facilities are unfavourable however these may be appropriate for larger developments should sufficient consideration be afforded to recycling separation and residual waste minimisation/restriction; and
• Details of proposed access routes for 26 tonne recycling and refuse collection vehicles, including adequately sized access pathways and service roads with suitable dropped kerbs and crossovers. These requirements will need to be considered in accordance with the User Hierarchy as featured in Manual for Streets.

8.234 The views of the Council's Waste Management Section will be taken into account on all types of development to ascertain the extent and nature of facilities needed to deal with any potential municipal waste arising associated with the proposed development Comment

8.235 Future Wales identifies the important role played by the South West region's minerals and aggregates in supporting development across Wales and England. SDPs will be required to provide a coordinated framework for minerals extraction, however, the SDP may not be in place ahead of LDP2 adoption. Comment

8.236 Mineral resources can only be worked where they are situated. The County's limestone resources are almost all located within the Gower National Landscape (AONB). The County also has sandstone and land based sand and gravel resources outside of the national landscape. Comment

8.237 National planning requires LPAs to make provision for a minimum land bank of 10 years for crushed rock and 7 years for land-based sand and gravel throughout the full 15 years of a development plan period, and to promote the sustainable management of aggregates. Comment

8.238 The County currently has no landbank of permitted reserves. Where the shortfall cannot be addressed through new allocations or permissions, the continuation of ongoing collaborative working with neighbouring authorities in the same sub-region will be required in order to transfer the required provision to other LPAs. This position will be updated in the Deposit Plan. Comment

8.239 The potential needs of future generations must be considered, and sterilisation of mineral resources will not be permitted unless justified in accordance with national planning guidance. Mineral safeguarding areas will be shown on the Deposit Plan Proposals Map. Comment

8.240 Swansea Docks is used for landing marine sand and gravel and is important route of resource into the County. Future proposals will need to consider the potential impact on its operation in this regard. Comment

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