Appendix G to the Initial Consultation Report – Addendum to the Initial Consultation Report, July 2023

The Initial Consultation Report was prepared in December 2019 to show how the Council had undertaken its Preferred Strategy Consultation, this being a formal stage in the Local Development Plan Review process. It includes chapters setting out publicity, methods of engagement, main issues identified from the Pre-Deposit consultation, late representations, a policy conversion table (from Preferred Strategy to the first Deposit Plan) and the next steps.

It is set in the context of the original iteration of the LDP 2 Delivery Agreement, which was approved by Welsh Government on the 7^th June 2018. A second iteration of the LDP 2 Delivery Agreement was prepared, to take account of the Covid-19 pandemic, and that was approved by Welsh Government on the 30^th October 2020. A third iteration of the LDP 2 Delivery Agreement has now been agreed by Pembrokeshire County Council Cabinet (24^th April 2023) and Council (11^th May 2023) and Welsh Government endorsement is currently being sought. This third iteration has primarily been prepared to take account of delays caused by the publication by Natural Resources Wales of new guidance on phosphate pollution in non-tidal parts of protected rivers (those with SAC / SSSI designations) in Wales, including the Afon Teifi and Afon Cleddau.

The two later iterations of the Delivery Agreement have updated various details in relation to methods of engagement and the consultees listed, as well as setting out revised timetables for the completion of the remaining stages of the LDP 2 plan preparation process.

This Addendum to the Initial Consultation Report takes account of the later iterations of the LDP 2 Delivery Agreement, but has been prepared primarily to reflect the further, targeted, consultation on the LDP 2 Preferred Strategy which took place in 2022.

Background information on the LDP 2 Preferred Strategy

The pre-Deposit documents were subject to a formal public consultation, which ran between the 17^th December 2018 and the 4^th February 2019 at 4.30pm. The public notice that accompanied the consultation noted that the Local Development Plan sets out a framework for determining planning applications and directing new growth to appropriate locations in Pembrokeshire (excluding Pembrokeshire Coast National Park locations, where the Local Planning Authority is the Pembrokeshire Coast National Park Authority).

The following documents were published at that time:

The Preferred Strategy itself, setting out a draft vision, objectives and the overall growth strategy, as well as key policies, for LDP 2.
A Review Report, setting out which parts of the current LDP (LDP 1) needed to change and why they needed to change.
An Initial Sustainability Appraisal Report, setting out how the Preferred Strategy proposals have been assessed in terms of their potential social and environmental impacts.
A Habitats Regulations Appraisal Screening Report, providing an assessment of whether or not the Preferred Strategy is likely to have impacts on Natura 2000 sites.
A Candidate Sites Register – showing all Candidate Sites proposing land for development and protection and the degree to which any of the proposals submitted is likely to accord with the Preferred Strategy. An opportunity was provided for the public to comment on the Candidate Sites that had been submitted prior to the commencement of consultation on the 17^th December 2018.

At that stage of the Plan process, a further opportunity was also provided for the submission of Candidate Sites for inclusion in the LDP. An additional 55 sites were submitted and an opportunity for the public to comment on these was provided, which ran from the 17^th April 2019 to the 6^th June 2019 at 4.30pm.

Subsequent to that stage of the process, it became known that a small number of individuals on the PCC LDP 1 database were not notified of the opportunity to register their interest for the LDP 2 Plan database. The total number was 62 and of these 38 were found to have registered for inclusion on the LDP 2 Plan database in advance of the error being identified.

As part of the remedy to this, the Council wrote to the affected persons, inviting them to a) register to receive notification on the Replacement LDP (LDP 2) and b) to offer each of them an opportunity to submit land as a Candidate Site. This resulted in three further Candidate Sites being added, as an Addendum to the Candidate Sites Register, during 2021. The public was given an opportunity to comment on the three further Candidate Sites between the 19^th January 2022 and the 16^th March 2022 at 5pm. This was consistent with the approach taken with regard to the Candidate Sites that had been submitted earlier in the plan process. These three further sites will be assessed using the same methodology as all other Candidate Sites in conjunction with the preparation of the second Deposit Plan and the Site Assessment Report will be updated accordingly at the same time that LDP 2, Deposit Plan 2 is published.

A further part of the remedy to the database issue was to give the persons affected by this issue a limited opportunity to comment on the Preferred Strategy and its associated documents. As noted in the Initial Consultation Report, the Preferred Strategy consultation ran between the 17th December 2018 and the 4^th February 2019. This re-opening of the Preferred Strategy consultation was only made available to those affected by the database issue, each of which was separately contacted. Those affected were informed where to view the documents, how to obtain paper copies (if required) and how to submit comments. Those affected were provided with an opportunity to submit comments on the Preferred Strategy and its associated documents between the 19^th January 2022 and the 16^th March 2022 at 5pm. As noted above, this did not provide an opportunity for wider public comment on these documents.

For purposes of clarity, the Preferred Strategy was published alongside a number of other documents and the initial consultation between the 17^th December 2018 and the 4^th February 2019 provided an opportunity for public comment on each of these:

The LDP Review Report – setting out what needs to change in the LDP and why.

The Initial Sustainability Appraisal Report – setting out the social, environmental and economic effects of the preferred options, strategic policies and general policies within the Preferred Strategy, to be read in conjunction with the Sustainability Appraisal Scoping Report and its associated Appendices.

The Habitats Regulations Appraisal Screening Report – which looks at the impact of the policies of the Preferred Strategy on Natura 2000 sites. It is a high level strategic screening of the Strategy.

The Candidate Sites Register

The re-opening of the Preferred Strategy consultation to those affected by the database issue between 19^th January 2022 and 16^th March 2022 at 5pm provided an opportunity for those affected by the database issue to also comment on the associated documents, to accord with the scope of the original consultation.

The Initial Consultation Report included an Appendix setting out the LDP 2 Preferred Strategy consultation responses (those submitted between 17^th December 2018 and 4^th February 2019). The equivalent information in relation to the single response to the further, targeted, Preferred Strategy consultation in 2022 is presented in Appendix A to this Council Report and will form a new Appendix F to the Initial Consultation Report documentation on the PCC website. As no further changes to the Preferred Strategy document are proposed at this stage, the track change version of the Preferred Strategy from March 2019, taking account of responses to the original consultation and presented as Appendix E to the Initial Consultation Report does not need to be modified and represents the version of this document that will be taken forward to the later stages of the Plan preparation process.

One further matter that needs to be addressed relates to the consultation responses received from the public in response to the three consultations on LDP 2 Candidate Sites. To date, these have not been published. However, a further Appendix to the Initial Consultation Report, which will be referenced as Appendix H, will now be prepared, setting out the responses received during each of the three tranches of public consultation. This will be a factual record of what has been received and will not include a formal Council response to points raised. It will be published to the PCC website as soon as is practicable and no later than the publication of LDP 2, Deposit Plan 2.