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Introduction

1.1 Further to Carmarthenshire County Council’s ‘Second Deposit Revised Local Development Plan’
consultation, Asbri Planning on behalf of the client, T.H James and M.A. Tomos wish to provide
a statement that supports the principles of Policy HOM3 (Homes in Rural Villages).

1.2 Asbri Planning, on behalf of the client, T.H James and M.A. Tomos previously submitted a
candidate site submission for a plot of land within Broad Oak, Llandeilo as part of the first call
for candidate sites in 2018 (see Appendix A).

1.3 In the First Deposit Revised LDP Written Statement, Policy HOM3 (Homes in Rural Villages)
stated:
“In those settlements identified as rural villages under Policy SP16, proposals for 1 to 4 dwellings
will be permitted for the following:
 minor infill of a small gap between the existing built form; or,
 logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 conversion or the sub-division of large dwellings.
Such proposals will be subject to other detailed planning considerations set out within LDP
policies.
Reference made to the guidance on acceptable plots in the County's rural villages (see below).
Proposals which exceed the 20% cap above the number of existing homes in the settlement, as
at the LDP base date, will not be permitted except where they conform to Policy AHOM1 in
relation to the provision of affordable homes”.

1.4 The Second Deposit Revised LDP Written Statement for the relevant policy noted:
“In those settlements identified as rural villages under Policy SP3, proposals for 1 to 4 dwellings
will be permitted for the following:
 minor infill of a small gap between the existing built form; or,
 logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 conversion or the sub-division of large dwellings.
Such proposals will be subject to other detailed planning considerations set out within LDP
policies.
Reference made to the guidance on acceptable plots in the County's rural villages (see below).
Proposals which exceed the 10% cap above the number of existing homes in the settlement, as
at the LDP base date, will not be permitted except where they conform to Policy AHOM1 in
relation to the provision of affordable homes”.

1.5 The policies are identical, apart from the fact that between the first and second draft written
statement, a decision has been made to halve the cap concerning proposals that exceed the
number of dwellings currently within a settlement.

2. Reasoning behind supporting Policy HOM3

2.1 Housing need within rural areas of Wales has always been an issue. In 2022, 96% of dwellings
within the settlement of Cwm-yr-Eglwys in Pembrokeshire were holiday homes. Within Future
Wales, it notes that in rural areas “Where housing, employment, key services and infrastructure
are not sufficient to accommodate current or future needs, or are not easily accessible, the
resilience and sustainability of an area may be undermined, possibly leading to economic and
social decline”.

2.2 Paragraph 9.3 of the Revised Draft LDP correctly recognises the role that smaller settlements
within Carmarthenshire have in delivering local and sustainable growth. This is further
expanded upon in Paragraph 9.16 which again correctly recognises that by supporting growth
of a proportionate scale in such areas, a positive contribution can be made towards the long
term sustainability and cohesiveness of rural communities and the rural economy. One such
positive impact relates to the promotion of the Welsh Language as recognised in Paragraph 9.18 of the Revised Draft LDP.

2.3 Policies such as HOM3 ought to be included within the next LDP as at present, the lack of
rural housing opportunities is having a detrimental effect on rural communities, companies
and the economy in rural settings which is currently deemed to be an important contributor
to labour shortages within sectors such as tourism and agriculture.

2.4 Having said this, addressing the issue ought to be done in a manner that considers the current
makeup of the rural setting therefore promoting small scale residential developments in a
proportionate manner is considered appropriate. There has previously been examples of an
over dependence on some larger sites which has impacted the resilience of housing land supply,
with these larger sites not delivering the homes and jobs they previously promised. A different
approach is warranted in certain areas of Carmarthenshire, with a large proportion of the County
being rural in nature.

2.5 Allowing a sustainable amount of growth in rural villages by adding a small number of homes
that represent a minor infill or logical extension of the existing built form appears far more
realistic, allowing increased opportunity to focus on aspects such as design which matches the
character of the neighbouring surroundings. In addition to this, the nature of Policy HOM3 will
enable the location of these additional dwellings to enhance and maintain the vitality of rural
communities.

2.6 The policy in question aligns neatly with Policy 4 of Future Wales – Supporting Rural
Communities. This policy sets out that the Welsh Government supports sustainable and
vibrant rural communities. The policy states that “Strategic and Local Development plans must
identify their rural communities, assess their needs and set out policies that support them”. It
also notes the importance of providing affordable and market housing within these
settlements, therefore implementing this policy will contribute to a wider national strategy for
rural settlements.

2.7 The Policy also aligns well with the seven well-being goals of the Well-being of Future
Generations Act, including ‘A Resilient Wales’, ‘A Wales of Cohesive Communities’, and ‘A Ales
of Vibrant Culture and Thriving Welsh Language’.

2.8 Within the current deposit statement there is an increased focus on rural areas. Addressing
this housing matter is one way ensuring the resilience of rural villages, however factors such
as employment and transport ought to also be considered. It is evident that the policy would
not benefit only one settlement, with the policy able to sustainably increase the number of
dwellings within 76 rural villages spread across 6 clusters as noted in Policy SP3 of the Deposit
LDP. Such proportionate growth is apt for these tier 4 settlements as development in the
countryside needs to be of a scale that maintains the essential character of the area, whilst
meeting the housing needs of local individuals.

2.9 The Moving Rural Carmarthenshire Forward Report conducted in 2019 stated that in order to
make rural areas attractive for younger people adequate housing needed to be provided to
ensure that they could remain within their local communities. The report stated that a shift
was required from depending on large housing developments to focusing more on smaller
scale residential developments that would address housing requirements in rural settlements.
A survey produced during the report revealed only 15% of respondents were happy with the
housing provided within their rural area.

2.10 It is imperative that this policy is included to ensure that a sustainable and proportionate
amount of housing growth is allowed in rural areas of Carmarthenshire during the plan
period. The lack of such housing has unfortunately resulted in younger individuals departing
rural areas, looking for housing and work in urban areas which is having a detrimental impact
upon the resilience of rural villages.

2.11 This policy will provide for local individuals, and also individuals who may wish to move back
home to be nearer friends and family. Moreover, promoting small scale residential development
is far likelier to meet identified local needs, as its unlikely there is a demand for a large-scale
residential proposal within the rural villages noted in the LDP. The targets set out in the policy
for rural villages in terms of housing are realistic, and therefore can be achieved over the plan
period, and thus the policy is considered to be sound.

3. Case Study – Broad Oak, Llandeilo

3.1 Broad Oak is a tier 4 rural village that contains circa 27 dwellings at present. Any housing
development to occur there during the plan period would have to accord with Policy HOM3.
The acceptable plots of land to meet the requirements of this policy are noted below:
1) Infill sites within these rural villages will take priority over other locations;
2) Where appropriate, sites adjoining a rural village are also acceptable. Such sites will be
required to adjoin the boundary of one property which forms part of the rural village group.
All proposals which adjoin a group (as opposed to infill sites) will be required to
demonstrate the following:
 there is an existing physical or visual feature which provides a boundary for the
group - reducing pressure for unacceptable ribbon development or rural sprawl;
 where such a feature does not exist, there should be potential for such a feature to
be provided so long as it is in character with the scale and appearance of the group.

3.2 The candidate site submission provided in Appendix A shows that a proposed residential
development would adjoin dwellings that already lie within the village. It is evident that the
proposal for up to 6 semi-detached dwellings or two detached dwellings forms a logical
extension to the settlement of Broad Oak, and would not disrupt its character. This is evidence
that this policy would work in such locations as Broad Oak.

3.3 Broad Oak could gain additional dwellings if the cap figure from the first deposit plan was
adopted. Based on the existing number of dwellings in Broad Oak, a 10% cap would only permit
the construction of two dwellings, whereas a 20% cap would permit five dwellings to be erected
during the plan period up to 2033. Due to the cap being put in place, no rural village will be
flooded with additional dwellings as a result of the replacement LDP, however the first deposit
plan offers an opportunity to provide more homes that would enable more people to reside in
rural areas of Carmarthenshire.

3.4 The same reasoning behind the cap is provided in both written statements, however no
justification is provided over it`s halving for the second plan. For example, the image showing
the addition of two detached dwellings to Broad Oak still shows some land to the west where
another two dwellings could be added. This would not go against the cap provided in the first
deposit plan, whilst still being a logical extension to the village and not impacting the character
of this countryside settlement. Furthermore, Broad Oak is in close proximity to the new Tywi
Valley cycle path whilst implementation of this policy would benefit the wider area, including
the recently opened Dryslwyn Business Park that lies a short distance west of the proposed
location of the dwellings further enhancing the economic capability of this rural area.

3.5 It is considered that Policy HOM3 is a policy that has credibility, as evidenced in the applicant’s
previous candidate site submission example. Having said this, the higher cap provided in the
first deposit plan should be reconsidered as that would allow a proportionate but greater
number of dwellings to be built within rural villages without negatively impacting the
settlement. If this is not possible, consideration should be given to a 15% cap rather than the
proposed 10% cap.

4. Conclusion

4.1 In summary, Policy HOM3 (Homes in Rural Villages) is a key policy that addresses an urgent
matter within rural Carmarthenshire. Rural villages will benefit from additional small scale
housing developments that will take into consideration the existing pattern of the settlement.

4.2 One of the findings from the Living Locally in Rural Wales paper published in 2022 was the need
for “Continuing to focus housing development within established, well connected communities”,
which this policy advocates. This policy addresses housing in rural settlements of
Carmarthenshire in a realistic manner which should contribute towards overcoming the issues
currently faced by rural areas.

4.3 Providing further dwellings will make these rural villages more attractive to people, enticing
people back to these areas and encouraging young families to remain within their communities.
In total, 76 rural villages could benefit from this policy which would have an enormous positive
impact on rural Carmarthenshire.

4.4 This statement is also supported by a 2nd Deposit Revised LDP Representation Form that states
our support for Policy HOM3