Remove site from the Plan

1. Introduction

This document is provided in support of our submission that seeks the allocation of land in
our ownership for residential development in the new, Revised Local Development Plan
(Revised LDP).
The detailed appraisal that has been prepared in accordance with our understanding of the
relevant national and local planning policies and guidance seeks to demonstrate that the
subject land meets all of the relevant criteria for inclusion as an allocated site within the new
Revised LDP.

2. Planning Policy and Guidance
The national land use policies for Wales are set out in the Welsh Government publication
Planning Policy Wales, Edition 11 (PPW) that principally requires that planning policies,
proposals and decisions must promote sustainable development and support the well-being
of people within their communities. New development has to be sustainable and improve the
social, economic, environmental and cultural well-being of Wales.
PPW, that is supported by a series of focussed, topic based Technical Advice Notes (TANs)
and other key legislation such as the Planning (Wales) Act 2015, and the Well-being of
Future Generations (Wales) Act 2015, conveys that ‘Local Development Plans should set
out a vision for how places are expected to change in land-use terms to accommodate
development needs over the plan period’; that ‘Everyone engaged with or operating within
the planning system in Wales must embrace the concept of placemaking in both plan making
and development management decisions in order to achieve the creation of sustainable
places and improve the well-being of communities’ and that ‘The planning system should
create sustainable places which are attractive, sociable, accessible, active, secure,
welcoming, healthy and friendly. Development proposals should create the conditions to
bring people together, making them want to live, work and play in areas with a sense of
place and well-being, creating prosperity for all.’

Detailed guidance with regard to the preparation of development plans is provided in the
Development Plans Manual, Edition 3, (DPM) March 2020. The DPM identifies the key
requirements in the consideration of a candidate site. These are set out as the candidate site
must:
 be at a sustainable location;
 be readily available;
 be free from physical constraints such as access, ground condition; biodiversity or
flooding issues
 whether the site has any relevant planning history; and,
 if there are any barriers to the delivery of the site the candidature must include a
detailed summary as to how the barriers shall be overcome.
Locally, the current Carmarthenshire Local Development Plan (LDP), adopted in December
2014, advocates a hierarchical approach to new residential development, namely, Growth
Areas, Service Centres, Local Service Centres and Sustainable Communities.
The principal status of the Growth Area settlements reflects their high population levels and
that these settlements are well served by the necessary facilities, services and public
transport provision extending beyond their localised catchments that are vital to supporting
the principles of sustainability and are capable of accommodating a proportionally high level
of growth.
The LDP identifies three Growth Areas centred on the principal towns of Carmarthen, Llanelli
and Ammanford respectively. The Ammanford/Cross Hands Growth Area, referenced GA3
within the LDP, is described as performing a key role within the area due to its strategic
location on the M4 corridor and at its role at the hub of the Amman and Gwendraeth Valleys.
The Ammanford/Cross Hands Growth Area is the second largest settlement in population
terms within the LDP.
The LDP conveys that the topographical characteristic of GA3, comprising of two centres,
Ammanford and Cross Hands, along with a number of interrelated, smaller settlements of
varying scale and function, has a direct bearing on the suitability for growth with a balanced
decision having to be taken on the ability of any particular settlement to accommodate new
growth, without resulting in harm to the character of the area or community.

LDP polices AH1 – AH3 detail the need for new residential development to contribute
towards affordable housing in the locality. New developments comprising 5 or more
dwellings are required to provide an on-site accommodation, while smaller developments
require a relevant financial contribution towards the provision of affordable housing in the
area.
The Council’s intention to locate new development primarily within the identified growth
areas reflects the national land use planning aim for sustainable development in well
serviced areas to improve the well-being of the local population.
The Second Deposit Revised LDP, while continuing to identify a settlement hierarchy offers
a new spatial strategy, with a strategic approach aimed at locating new development at
locations that are both deliverable and sustainable. The Revised LDP again identifies key
strategic growth areas focused on six key areas or ‘defined clusters’, three of which are
again centred at Carmarthen, Llanelli and Ammanford/Cross Hands.
The continued approach in the Revised LDP again clearly reflects the national theme of
‘place making’ embedded within PPW that new residential development should seek to
sustain and enhance existing communities. This guiding principal shall ensure that the future
growth of communities shall result in built and natural environments where people can
sustainably live, work and spend their leisure time.
Proposed Strategic Policy SP3 aims to secure that key place-making responsibility through
the provision of new homes at sustainable locations through the allocation of sites at
established settlements in a hierarchical framework of Principal Centres, Service Centres,
Sustainable Villages and Rural Villages.
Strategic Policy SP4 further conveys the Plan’s strategic aim of providing new homes in a
sustainable manner through the allocation of sites in established settlements; supporting
windfall residential development on appropriate sites within settlements; and the provision of
appropriate affordable housing opportunities to meet an identified local need.
Proposed policy AHOM1 maintains the Council’s commitment to the provision of affordable
housing as part of any new residential development.

3. Candidate Site

3.1 Location and Description
Our candidate site is located along the western flank of Parklands Road, Penybanc,
Ammanford as shown on the location plan below.
The site is located a short walk (250 metres) from the social, retail, commercial and
recreational facilities of the community located in close proximity to the junction of Parklands
Road with Penybanc Road (A483). The site is also within walking distance of Parcyrhun
Primary School, Amman Valley Comprehensive School, higher education at Coleg Sir Gar,
Ammanford Campus and the local train (Swansea – Shrewsbury) station (1240 metres).
Bus-stops at the A483 junction provide a regular, every 30 minutes, service to Ammanford,
Llandeilo and Swansea. Similarly, bus stops at the junction of Parklands Road with Dyffryn
Road (at the telephone kiosk symbol on the plan), again within convenient walking distance
(410 metres) provide regular services to Ammanford, Carmarthen, Cross Hands and the
communities of the Gwendreath Valley.
Directly opposite the south-eastern corner of the site is a public footpath (51/21) that
provides for a pleasant, woodland walk to Ammanford.
The convenient public transport, walking and cycling connectivity to Ammanford and the
wider area significantly increases the range of services, amenities and facilities readily
available for Penybanc residents.

The candidate site is situated alongside the bungalow, number 26, to the south with the
remainder of the enclosure up to our agricultural field access immediately adjacent to the
house number 54 to the north, with a mix of houses (35 – 39) and bungalows (33) opposite.
The land that is laid to grass slopes gently downward from north to south with the road
frontage and southern boundaries clearly delineated by stock proof fencing.

3.2 Context
Penybanc principally extends in a linear form along both the A483 Penybanc Road and
Parklands Road with an established group of housing directly opposite the candidate site at
Newtown, Newtown Close, Waunfawr and Park Mill Road.
As indicated in red on the Revised LDP extract plan below, our candidate site is bounded to
the south and opposite by the residential development limits as delineated in both the
current LDP and the proposed Revised LDP
The site lies outside of the area within which a financial contribution would be required
towards funding the implementation of specific marsh fritillary butterfly habitat management
initiatives, the boundary of which is indicated by the dashed purple line in the plan above.
With established residential development to the north, south and east, the candidate site
represents a logical location for partly infill, residential development.

3.3 Planning History
During the 1960s and 1970s a substantial acoustic bund associated with the historic
opencast mining of the area existed along the entirety of the candidate site and the
remainder of the adjoining road frontage. That bund resulted in a significant sense of
enclosure along the street scene.
Full planning permission (P6/13142/87) was granted in July 1987 for a bungalow and garage
at a nearby plot along the road frontage land in our ownership. An extract of the approved
block and location plan is provided below.

3.4 Residential Development Proposal
We anticipate that the site would be developed in a linear arrangement of two bungalows or
dormer bungalows, served by a paired private drive, that would positively respond to both
the site and the surroundings. To ensure that the new development is sympathetic to the
character of the existing housing, the alignment and design shall reflect the form of the
existing nearby properties.

The proposed development shall provide for south/south west facing gardens that shall seek
to maximise the potential for solar energy and contribute positively to the well-being of the
future occupants in that the dwellings shall have private outdoor amenity areas that shall be
available for the maximum periods of time throughout the year.
Although unclassified, Parklands Road where it fronts the site has a carriageway width of
7m, with a grassed verge and 1.7 m wide footway along the site frontage. At the opposite
side of the carriageway the footway fronting the existing bungalows is 1.9 m in width.
The alignment of the highway, together with the wide footway along the site frontage, shall
duly facilitate the required visibility splay for each new vehicular access.
We understand that given the very limited scale of the proposal along with the proximity to
existing facilities there shall be no requirement for an area of on-site, formal open
recreational space. To meet the Council’s requirements in terms of affordable housing we
also understand that the Revised LDP requires the relevant financial contribution towards
affordable housing shall have to be provided, that would be secured by planning obligation.
While the schematic layout proposes what is considered to be a sympathetic form and
density of development, we acknowledge that the final number, design and layout shall be
established through the submission of a full planning application.

3.5 Infrastructure
The candidate site is at a location well served by mains water, gas, electricity, public
sewerage and fast fibre broadband to the home.
Having due regard to disposal of surface water, with the adjoining land being in our
ownership there are a number of options available to facilitate the provision of a sustainable
urban drainage system.

3.6 Ecology
As evident in the photographs provided at 3.1 Location and Description above, the candidate
site is actively used and managed for the purposes of agriculture. The site is part of a larger
enclosure of improved grassland, subject to the usual nutrient practices with the road
frontage defined by a timber post and rail fence.
Other than a very small part in the south-eastern corner being designated grade 3b,
‘moderate quality agricultural land’, the majority of the land is grade 5, ‘very poor quality
agricultural land’.
The candidate site does not form part of any local or national nature conservation
designation, with the nearest Sites of Special Scientific Interest (SSSI), being the group of
fields known as Caeau Blaenau Mawr and Caeau Capel Hendre located 2km to the west.
Having due regard to the above, it is considered that the site has a very low biodiversity
value and that the residential development of the site shall have no detrimental impact upon
any SSSI.

3.7 Environmental Considerations
The candidate site is not located within an area where residential development would cause
concern with regard to river phosphate levels or within any of the categorised flood risk
areas detailed in the Development Advice Maps published by National Resources Wales.
The residential development of the land shall therefore not be at any risk of flooding.
Being in agricultural use the greenfield land has no ground contamination issues.

3.8 Historical Assets
There are no listed buildings or scheduled ancient monuments within or adjoining the
candidate site. Similarly, there are no listed buildings within the community of Penybanc or a
designated conservation area within either Penybanc or Ammanford. The residential
development of the candidate site shall therefore not have any detrimental impact on any
historical asset or the setting of any such asset.

4. Viability and Deliverability

4.1 Financial Viability
National planning policy requires that all land use allocations are both financially viable and
deliverable to ensure that plan making and decision making viability strikes a balance
between the aspirations of developers and landowners, in terms of returns against risk, and
the aims of the planning system to secure maximum benefits in the public interest through
the granting of planning permission.
Though a detailed analysis of the financial viability is difficult at this initial stage due to the
absence of such things as a comprehensive site survey and full engineering details, the
following high level appraisals with due regard to both the current LDP and Revised LDP
have been undertaken. The submitted data has been informed by discussion with
established agents and professionals to ensure that the figures accurately reflect the local
market benchmark land and property values at the present time.
The costs are based upon:
 Three bedroom dwelling – 130m2
 New three bedroom dwelling - £280,000
 Construction cost of £1,500 per square metre
 Utility Connections to include water, electric, gas and foul water
 Professional Fees (including Design, Planning, Building Regulations, Estate
Agents, SAB & LABC warranty) at 8% of the construction fee
 Developer’s profit based upon the RICS guideline of 15%

Two Dwellings with the relevant Affordable Housing financial contribution
Costs No of dwellings Cost per dwelling/m2 Total
3 bed dwellings 2 1500 390,000
Affordable Housing - 41.98 10,915
Utility Connections 5000 10,000
Professional Fees - 31,200
Total 442,115
Sales No of dwellings Value Total
3 bed dwellings 2 280,000 560,000
Total 560,000
Developer’s profit 84,000
Residual Land Value 33,885
The in-principle appraisal above demonstrates that the residential development of our
candidate site would be financially viable, while also capable of providing the relevant
contribution towards affordable housing in the community.

4.2 Deliverability
With the proposed residential development being financially viable, there are no ownership
or physical constraints to prevent the delivery of the candidate site.
The site would, on adoption of the Revised LDP, be immediately available for development
with its delivery, including the community affordable housing benefit, anticipated to be
completed in the short term, within the first 5 years following adoption of the Plan.

5. Comment on the Previous Concerns of the Council
Although the Council previously (SR/004/009) considered the whole of the road frontage
candidate site to be acceptable in terms of the location of future growth presented in its
preferred strategy, both the initial and detailed site assessment, sustainability appraisal and
habitat regulation assessment, the site was not recommended to be taken forward at that
time due to two concerns, namely that it was considered that there is more suitable land
available for residential development and that the development of the site would be likely to
result in ribbon development.

5.1 ‘More suitable land available’
It is reasonably assumed that the land referred to is that at Tirychen Farm, Dyffryn Road,
Ammanford, Revised LDP reference PrC3/h4, an allocation rolled over from the previous
development plan, where Outline planning permission (P6/16576/89) in respect of the
residential development of the land was initially granted in April 1990, having expired three
years later.
Full planning permission (P6/305/95) was granted for 141 houses and bungalows in
February 2008 that expired in February 2013.
Outline planning permission (E/21663) was granted in October 2014, renewed by means of
the Variation of Condition consent (E/38686) approved October 2019. It would seem that this
most recent permission that proposed 289 dwellings expired in October 2021 and as such
there is no current planning permission for the development of that land.
Aside from the key question whether there is a valid consent in place, the deliverability of the
site allocated for 250 dwellings in the LDP and 150 dwellings in the Revised LDP is
extremely doubtful.

Each permission that has been granted at the former Tirychen Farm has been subject to
numerous conditions and a planning obligation. The number and requirement of the
conditions such as significant highway improvements including a new bus layby, along with
the financial and physical requirements of the planning obligation (affordable housing,
cemetery car park extension, six-figure highways and education contributions, detailed
woodland management scheme) render the development beyond the realm of local building
contractors while the national, volume housebuilders have not shown any interest in the site
during the 33 years since permission was first granted, instead focussing their attention on
the M4/A48 corridor, more specifically at sites in and around Cross Hands.
An online search reveals that the land at Tirychen is not presently being marketed which
would indicate that the site was merely being land-banked.
The Council has expressed its own concern with regard to the deliverability of the allocation
in the report to Full Council in January 2018 that adopted a traffic light system in respect of
the viability and deliverability of the proposed residential land allocations within the Revised
LDP. The land at Tirychen Farm was categorised as red, ‘no indication of progress towards
delivery’.
In the absence of a valid planning permission, it would seem extremely questionable
whether a new submission at what is a large scale, rural, natural landscape would be
considered acceptable in the context of the current biodiversity objectives.
The potential delivery of the land at Tirychen, that would appear to require a new planning
permission, is markedly uncertain.

5.2 ‘The development of the candidate site would be likely to result in ribbon
development’
In the absence of any specific reasoning why the allocation of our land would be ‘likely’ to
[not ‘shall’] result in ribbon development, we understand that ribbon development is usually
deemed to be unacceptable as such linear development along highways can result in urban
sprawl or an unacceptable intrusion into the countryside; the inefficient use of resources;
hinder access to and/or the development/use of the land to the rear; and/or result in the
coalescence of settlements.

To address each in turn, our proposed site lies within a well-established area of housing with
the most recent residential development within Penybanc being the bungalows at Waunfawr
and the houses at Newtown Close opposite the candidate site. As such, the residential
development of the land shall not result in an urban sprawl or an unacceptable intrusion into
the open countryside and would be more appropriately characterised as partly infilling an
area within the established built fabric of the community.
The site is well served by the necessary services infrastructure and as such shall not
therefore result in the inefficient use of resources.
Residential development of the site shall not hinder or impede in any way the continued
access to the land to the rear that is served by an existing access to the north of the site and
also from the rear of our home to the south.
Being located within an established residential area the site shall not result in the
coalescence of any neighbouring settlements.
The reduction of the candidate site from that submitted in 2014 (SR/004/009) to comprise
only part of the road frontage shall serve to safeguard against any concern the Council may
have with regard to the loss of part of an area of a natural landscape within the local built
environment. Furthermore, the woodland adjacent to 54 Parklands Road to the north, that
fronts Parcwern Care Home and is only 100 metres from the candidate site, is the subject of
a Tree Preservation Order (CCC TPO E20). That TPO shall ensure that a formally secured,
natural interruption to the street scene is permanently maintained.
The extract from the CCC TPO plan below illustrates the proximity of the candidate site to
the woodland TPO E20.

It is also noted that no concerns with regard to any unacceptable loss of a natural landscape
feature, sporadic or ribbon development were deemed relevant in the grant of planning
permission P6/13142/87 referred to above.
Having due regard to our aforesaid reasoning, it is considered that the residential
development of the site shall not result in ribbon development.

6. Conclusion
Our candidate site, that has housing on two sides and nearby on a third, has all of the mains
services including fast fibre broadband readily available. The site therefore represents a
logical form of part infill development at a sustainable location, being only a short walking
distance to the community social, retail, commercial, and recreational facilities and also to
public transport that regularly links Penybanc with the neighbouring hub of Ammanford and
the wider area, further increasing the range of services and facilities available to future
occupants.
The land that has in part previously benefited from the grant of a residential planning
permission is free from any constraint in terms of access, biodiversity, ground condition or
flooding.
In terms of its sustainability credentials, the simple, efficient layout of the development shall
require minimal access construction; prioritise the solar orientation of houses and gardens;
provide for a sustainable urban drainage system with features such as permeable surfaces
where possible, together with a landscaping scheme that would significantly improve and
enhance the existing biodiversity through the planting of indigenous species. The location of
the site encourages sustainable transport use through convenient, close access to the local
bus and train service along with direct access opposite the site to an attractive public
footpath that affords easy walking connectivity to the town of Ammanford, and also to the
established local cycle path network.
With significant doubt around the deliverability of the only, longstanding allocation in the
locality our candidate site would be immediately available, with no uncertainty in terms of its
viability or deliverability. Although very modest in scale, the allocation of our site for
residential development would represent both a sound option to address the likely deficit in
provision and offer a positive contribution to the housing growth strategy of the area.
We respectfully contend that the robust information provided in this appraisal demonstrates
that the designation of the land for residential development would be consistent with the key
objectives of both national and local guidance and policy objectives in that the candidate site
is at a sustainable location, viable, readily available and free from any physical or
environmental constraints