Include the alternative site as a housing allocation in the Revised LDP.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr M Jay to prepare and submit
an Alternative Allocation Report for the allocation of land adjoining Plasnewydd,
Foelgastell for the purposes of residential development in the forthcoming
replacement Carmarthenshire Local Development Plan (LDP).
1.2 This report has 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.
1.3 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
conjunction with the accompanying information and indicative drawing package, as
well as a sustainability assessment undertaken in-line with the Authority’s
requirements.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to a parcel of land measuring approximately 1.8 acres in
area in total, edged red on the plan and the photograph below.
Plan A
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
Photograph 1
2.1.2 Following recent land management, the site currently has a clear appearance, as
illustrated by the photographs below:
Photograph 2 Photograph 3
2.1.3 As can be seen from the above photographs, the site is generally level. In addition, all
it’s boundaries are clearly and well defined, the majority of which are mature tree
lines or hedgerows. The exception is the north-western boundary (Photograph 2),
which is more domestic in appearance, being shared with existing residential
development beyond.
2.1.4 Access to the site is currently gained via an existing field entrance in the site’s south
western boundary, leading directly onto the adjoining public highway (Heol y Foel).
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
The frontage of the site shared with the adjoining highway is particularly straight,
providing excellent visibility in both directions, as illustrated below.
Photograph 4 Photograph 5
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site presently lies at
the southern edge of the defined Development Limits of the settlement of Foelgastell.
However, as the extract of the Proposals Map below illustrates, the Site (outlined in
red) adjoins the current built form of the urban area directly to the north west, with its
remaining boundaries presenting a very strong and defensible boundary to the much
more open landscape to the east and north east of the site.
Plan B
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
2.1.6 As can be seen, the Alternative Site is therefore well related to the existing defined
Development Limits for Foelgastell and the settlement’s built form as a whole when
existing residential development directly to its north west and indeed that to its south
east, is taken into consideration. Its position and proposed use therefore represent a
natural and logical location for the settlement’s expansion.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Alternative Site adjoins the existing built form of the settlement
of Foelgastell. Foelgastell is a linear style development in form, with the bulk of it
being located along Heol y Foel. In more recent times, development has then
occurred ‘in-depth’ off Heol y Foel, with examples being found at Parc y Gelli and
Parc Newydd.
2.2.2 In terms of community facilities and local services, the settlement of Foelgastell
includes a public house, play area, place of worship, as well as a regularly served bus
stop. However, the site (indicated by the red star on Plan C) is in close proximity to
the larger wider conurbation of Cross Hands and its outlying settlements to the south
east (see Plan C below).
Plan C
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
2.2.3 The strong sustainable position of the Alternative Site should therefore be given full
consideration when considering potential future growth options.
2.2.4 In terms of planned growth for Foelgastell, the 2nd Deposit LDP currently contains no
proposed housing allocations for the Plan period. This in itself is surprising,
considering the sustainable qualities of the settlement.
2.2.5 Notwithstanding the above, the proposed Alternative Site lies in close proximity and is
well related to one of the 3 identified Principal Centres within the 2nd Deposit LDP
Within these areas, the majority of the County’s growth (particularly with regards to
housing) is expected to be accommodated within the Plan period. However, 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:
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’.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell

3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, this
Statement is accompanied by an indicative layout for a potential residential scheme
that could be developed on the site. 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 6 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 6 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 D
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 6 units – having therefore taken into
consideration this potential mix. The form of development for the Alternative Site is
also capable of following the current development form of existing properties
positioned along Heol y Foel.
3.1.3 With regards then to access, it is proposed that the Alternative Site would be served
either by a single point of access serving a shared access drive, or via individual
private drives as illustrated in Plan D. In both situations, as can be seen in the
Photographs at Section 2, the required level of visibility is achievable in both
directions.
3.1.4 The Alternative Site proposal can retain and enhance existing boundary treatments
as recommended in the accompanying Ecological Appraisal, as well as
accommodating further biodiversity enhancements within a detailed scheme for the
site.
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.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 Accompanying this submission is an Ecological Appraisal for the site. As indicated,
the Site does not contain any protected flora or fauna, or signs of their presence.
However, and in line with the Appraisal’s recommendations, 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 E below provides an extract of those records applied to
the Foelgastell locality, with the red star denoting the position of the Alternative Site.
Plan E
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.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
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 F
4.2.2 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).
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
Plan G
(Development Advice Maps)
Plan H
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature, the Candidate Site has no ground contamination related
constraints.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
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 6 units
on the Alternative Site in question. 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 £1,300 per metre given that
bespoke four bed detached houses (169 sq.m.), with a medium grade of
internal finishing.
 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%)
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
 Professional Fees include planning application fee, associated professional
fees, estate agency fees (1%) and LABC Warranty fee.
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 6 units, based on an affordable housing level being a financial contribution
of £40.42 per square metre of internal floorspace.
Costs
Cost Per
Unit/Metre
No.
Units/Metres Total
4 Bed semi(169 sqm) 219700 6 1318200
Utility Connections 5000 6 30000
Professional Fees - 42600
Sprinklers 3500 6 21000
Affordable Hsng. Cont. 42000
Parks and Education Cont. 5000 6 100000
Total 1553800
Sales
4 Bed semi(169 sqm) 425000 6 2550000
Total 2550000
Developers Profit Total 459000
Residual Land Value 537200
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.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
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.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
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.
Alternative Allocation Report March 2023
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, as well
as an element of the larger conurbation of Cross Hands to the south east. This will
then ensure it makes a positive contribution to both national and local sustainable
development objectives.
7.3 From a wider sense, the Site will also benefit from well served excellent public
transport links to the adjoining larger conurbation of Cross Hands and indeed
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.
7.4 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 are 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.
7.5 With the Alternative Site having no access, ground condition, flood risk, hydrological,
ecological, archaeological or land ownership related constraints, its delivery if
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
allocated is assured. Combined therefore with its locational characteristics, the Site in
question represents a sustainable candidate for future housing development.
7.6 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.