Allocate the alternative site for housing within the settlement of Llandybie.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr A Pritchard to prepare and
submit an Alternative Allocation Report for the allocation of land adjoining Parc
Gelliwastad, Llandybie for the purposes of residential development in the forthcoming
replacement Carmarthenshire Local Development Plan (LDP). Submissions for the
Site were made at the Candidate Site Stage (LPA ref. No. SR/082/005), but the
Council determined to exclude the Site for the following reasons:
“There is sufficient and more suitable land available for development within the village
to accommodate its housing need which is considered to be better located in terms of
its relationship and proximity to the existing urban form and the services and facilities
within the settlement.”
1.2 This report has therefore been prepared in response to the above and provides
further information, highlighting the suitability of the Site for allocation for housing
development. It also relates to a slightly larger parcel of land to that promoted at the
Candidate Site stage, as contrary to the Council’s view above, it has been identified
that the Cluster the settlement of Llandybie forms part of is facing an under provision
of new housing during the Plan period, due to a number of undeliverable sites being
promoted by the Council.
1.3 This report has therefore been prepared in line with the Authority’s published site
assessment and selection documents. The contents of this report therefore address
each point raised within these documents as well as ensuring that it complies with
regards to the guidance and requirements of Planning Policy Wales (Edition 11)
when it comes to the preparation of development plans and the allocation of land for
residential purposes as part of them.
1.4 The contents of this report therefore provide a comprehensive case for the allocation
of the land for residential development purposes, and it should also be read in
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conjunction with the accompanying information, as well as a sustainability
assessment undertaken in-line with the Council’s requirements.
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2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to land measuring approximately 4.6 acres in area in
total, edged red on the plan and the photograph below.
Plan A
Photograph 1
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2.1.2 As can be seen from the aerial photograph above and the accompanying information,
the Alternative Site consists of a single parcel of semi-improved grassland, with its
boundaries being strongly defined by a mix of mature hedge lines and stock proof
fencing. In terms of topography, the Site is generally level to a slight downwards
gradient in an east to west direction.
2.1.3 Access to the site is currently gained via an existing estate road positioned along part
of its eastern boundary (Photograph 2).
Photograph 2
2.1.4 As can be seen, the road has been constructed to adoptable standards and in turn
then leads onto the public highway to the south east (Kings Road).
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site presently lies at
the western edge of the defined Development Limits of the settlement of Llandybie.
However, as the extract of the Proposals Map below illustrates, the Site (outlined in
red) adjoins and is well related to the current built form of the urban area directly to
the east.
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Plan B
2.1.6 As can be seen, the Alternative Site is therefore well related to the existing defined
Development Limits for Llandybie and the settlement’s built form as a whole when
existing residential development directly to its south and east is taken into
consideration. Its position and proposed use therefore represent a natural and logical
location for the settlement’s expansion, as well as an example of natural rounding-off
of the existing built form.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Candidate Site adjoins the existing settlement and form of
Llandybie. As a result, the Site is within walking distance of a number of its
community facilities and local services, including the following:
 Primary School
 Village Hall
 Several Retail Units (A1 and A3)
 Several Public Houses (A3)
 Several Places of Worship
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2.2.2 From an accessibility perspective, Llandybie has a station on the Heart of Wales line,
is located on a main transport artery in the form of the A483, as well as having very
well served bus stops. The bus services serving the settlement are numbers 103,
276, 284 and x13, which provide regular access to the following larger settlements,
as well as the intervening villages:
 Ammanford
 Llandeilo
 Swansea
2.2.3 The strong sustainable position of Llandybie should therefore be given full
consideration when considering potential future growth options.
2.2.4 Llandybie forms part of the wider Principal Centre of Cluster 3 as defined by the 2nd
Deposit LDP, where the Council expects much of the planned growth in the County to
take place. However, two of the proposed housing allocations (PRC3/h19 and
PrC3/h37) have already been constructed or will be near completion by the time the
Replacement LDP will be adopted. This is worrying considering the sustainable
credentials of Llandybie as a settlement and so further deliverable allocations for the
settlement should be considered.
2.2.5 The above is particularly important as having undertaken a comprehensive review of
the proposed allocations put forward by the 2nd Deposit LDP for the Principal Centre
in question, it has been identified that a number have significant questions over their
ability to be delivered within the Plan period, including the following:
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Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8
Table 1
2.2.6 As a result of the above, separate objections have been made in relation to the above
allocations and it is therefore important that alternative more deliverable sites should
be identified, to ensure the Plan can be regarded as being ‘sound’.
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3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, an
indicative layout drawing was prepared as part of the original Candidate Site Stage
submissions. It should be emphasised that the accompanying layout is for illustrative
purposes and that other design solutions for the site could also be reached.
Notwithstanding this, the accompanying layout drawing has taken account of all the
potential assets and constraints of the Site, as well as current Authority design
guidance, and demonstrates that it is capable of delivering 21 units in a deliverable
and sustainable manner. The following information therefore expands on this
principle.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Candidate Site be allocated in the forthcoming replacement
LDP for the purposes of 21 residential units. As detailed above, the accompanying
illustrative layout (reproduced below) demonstrates that the site is capable of
accommodating this number in a deliverable and sustainable manner.
Plan C
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3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 21 units – having therefore taken into
consideration this potential mix. The form of development for the Alternative Site is
also capable of respecting and retaining its current means of enclosure and natural
boundary features both at the edge and within the Site.
3.1.3 With regards then to access, it is proposed that the Alternative Site would be served
by the existing estate road running along part of its eastern boundary. This would
then extend into the Site, off which several private shared driveways would branch.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Alternative Site for residential units would be served by
mains water, public sewer and electricity, connections to which we understand lie
within or in close proximity to the Site.
3.2.2 With regards then to surface water, it is considered that as a result of on-site
features, there would be a number of options available to any development of the site
in terms of its disposal, ensuring its development adheres to current regulatory
requirements.
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4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Site does not contain any protected flora or fauna, or signs of their presence.
Notwithstanding this, any potential biodiversity assets the Site may include have been
given full consideration with regards to exploring its potential for residential
development. This has included the proposed retention and management of existing
site boundary features.
4.1.2 The Alternative Site has been assessed against data held on the “Magic Map”
website which details statutory and non-statutory National and Local sites of
ecological importance. Plan D below provides an extract of those records applied to
the Llandybie locality, with the red star denoting the position of the Alternative Site.
Plan D
4.1.3 As can be seen from the above, the Alternative Site does not form part of and neither
is it near any national or local designations. Although a number are within 2-4km of
the site, due to the intervening distance and topography, the development of the
Alternative Site will not have any detrimental impact on these features.
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4.2 HISTORICAL ASSETS
4.2.1 Below is an extract from the ‘Archwilio’ website that represents a resource for the
Historic Environment Records of Wales, with the Alternative Site indicated by a red
star.
Plan E
4.2.2 Whilst the Llandybie’s core includes a number of Listed Buildings, as can be seen,
neither the Alternative Site nor immediately adjoining element of the settlement
includes any Scheduled Ancient Monuments, Listed Buildings or Conservation
Area’s. As a result, the development of the Site would not have any detrimental
impact on the setting or interest of any nearby historical asset.
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 The Candidate Site is not categorised as being at risk of flooding in terms of the
Development Advice Maps or those produced by Natural Resources Wales, as
illustrated by the plans below (Alternative Site indicated by the red star).
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Plan F
(Development Advice Maps)
Plan G
(Flood Maps for Planning)
4.3.2 In terms of ground conditions, due to its greenfield nature, the Candidate Site has no
ground contamination related constraints.
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5.0 VIABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that
allocations within it are both viable and deliverable. To not make efforts to explore
both these aspects is to then risk that the Plan may be unsound and so in turn fail to
meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s
preparation due to the absence of, for example, such things as full engineering
details, it is possible to undertake such appraisals at a strategic or in-principle level.
The following therefore represents such a process and is fit-for-purpose in providing
confidence with regards to both the viability and deliverability of the Alternative Site at
this stage, but it should be noted, that more detailed analysis at a planning
application stage may result in some variance.
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 21 units
on the Alternative Site in question, based on a typical house type mix. It is based very
much on its greenfield status and uses figures and costings previously accepted by
the local authority through its determination of planning applications and other works.
The following appraisal is therefore based on the assumptions set out below in order
to provide a residual value for the scheme, prior to ascertaining an indicative land
value.
Costs
 Dwelling construction costs are based on £1,150 per metre
 Adoptable road construction cost based on £1200 per metre
 Connections for all utilities include water, foul water and electric
 Developer’s Profit based on RICS guidelines (18%)
 Professional Fees include planning application fee, associated professional
fees, estate agency fees (1%) and LABC Warranty fee.
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Sales
 Sale Prices based on LPAs Affordable Housing SPG, market research and
ACG figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the
proposed 21 units, with 3 units being made available on an affordable basis (based
on 3 three bed units).
Costs
Cost Per
Unit/Metre
No.
Units/Metres Total
4 Bed (150 sqm) 172500 5 862500
3 Bed (110 sq m) 126500 16 2024000
Utility Connections 5000 21 105000
Road and Access 1200 80 96000
Professional Fees - 112951
Sprinklers 3500 21 73500
Parks and Education Cont. 5000 21 100000
Total 3373951
Sales
3 Bed (110 sqm) (Aff.) 76380 3 229140
4 Bed (150 sqm) 310000 5 1550000
3 Bed (110 sq m) 270000 13 3510000
5289140
Total 5289140
Developers Profit Total 952045.2
Residual Land Value 963143.8
Table 2
5.1.3 Although the above figures have not been able to take into account any future
changes to construction costs as a result of other external factors (e.g. changes to
Building Regulations), it is considered that in-principle, the development of the site
would be financially viable.
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5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is
financially and physically viable, with no environmental, geo-physical or technical
constraints prohibiting immediate development. Furthermore, there are no ownership
or third-party interests preventing the site’s delivery.
5.2.2 In terms of a delivery timescale, it is envisaged that the site could be capable of being
completed within 2 years from the adoption of the Replacement Local Development
Plan.
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6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.0.1 In the preparation of any development plan, consideration must be given to national
policy and guidance. At present, this takes the form of Planning Policy Wales (PPW)
(Edition 11) and a series of Technical Advice Notes (TAN) that deal with a range of
topic areas.
6.1 HOUSING SUPPLY
6.1.1 With regards to the provision of housing, Paragraph 4.2.2 of PPW gives the following
requirements the planning system must fulfil:
 Identify a supply of land to support the delivery of the housing requirement to
meet the differing needs of communities across all tenures;
 Enable the provision of a range of well designed, energy efficient, good quality
market and affordable housing that will contribute to the creations of sustainable
places; and
 Focus on the delivery of the identified housing requirement and the related land
supply
6.1.2 In addition to the above, Paragraph 4.2.10 of PPW states “the supply of land to meet
the housing requirement proposed in a development plan must be deliverable”. As
detailed previously, it is considered that the LPA has to date failed to accomplish this
requirement under the provisions of the current LDP and will continue to do so under
the provisions of the proposed allocations of the 2nd Deposit LDP.
6.1.3 In order therefore to re-dress this deficiency in provision, and provide a more robust
approach to housing provision through a mixed site-scale approach, there is an
urgent need to identify alternative deliverable housing allocations in the replacement
Plan. Based on the accompanying information, it is clear that the Alternative Site
represents one such example.
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7.0 CONCLUSION
7.1 Although currently undeveloped, the Alternative Site forms a logical extension to an
existing settlement, being well related to it and being positioned at a location within
the wider landscape to not form a prominent or logical part of the surrounding open
countryside.
7.2 In addition to the above, the site lies within close proximity and walking distance of
the existing community services and local facilities of the adjoining settlement. From
a wider sense, the Site will also benefit from well served excellent public transport
links to the adjoining larger conurbation of Ammanford and indeed Cross Hands and
Carmarthen, together with other locations within and adjoining the County, further
increasing the facilities and services available to future residents of the Site via
sustainable transport means.
7.3 In tandem to the above, the development of the Site will in turn ensure a viable and
so deliverable source of future housing for the area it forms part of, which has seen a
dangerous level of under supply prior to and since the adoption of the current LDP.
The development of the Site will help to redress this imbalance and it is strongly
suggested that the Authority closely scrutinises those sites currently allocated in the
LDP in terms of their suitability and deliverability if it is to continue to allocate them.
National planning policy however would suggest that in view of the uncertainty in
relation to their delivery, such sites should not form part of the replacement LDP.
7.4 With the Alternative Site having no access, ground condition, flood risk, hydrological,
ecological, archaeological or land ownership related constraints, its delivery if
allocated is assured. Combined therefore with its locational characteristics, the Site in
question represents a sustainable candidate for future housing development.
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7.5 In view of the above and information provided in this Statement, it is respectfully
requested that the Alternative Site in question be designated for residential
development.