Allocate the site for housing within the Revised LDP.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd has been instructed by Mrs K Fakes, Mr D James, Mr E
Roberts and Mr G Jones (the Land Owners) to prepare and submit an Alternative Site
Report for the allocation of land off Waterloo Road, Penygroes for the purposes of
residential development in the forthcoming replacement Carmarthenshire Local
Development Plan.
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 Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

2.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to a parcel of land measuring just over 1.7ha, edged in
red on the plan and photograph below.
Plan A
Photograph 1
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
2.1.2 The Site consists of three undeveloped enclosures that are in part laid to rough grass,
as illustrated in the photographs below.
Photograph 2 Photograph 3
2.1.3 As can be seen, the Site is gently sloping in nature and undeveloped. All of its
boundary features are well defined, consisting of a mix of hedgerows, stock proof
fencing and residential boundary treatments. The Site contains no water features
within it and ground composition we understand has good drainage qualities.
2.1.4 In terms of access, the Site can be accessed via two points. The first is directly off
Waterloo Road at the south western corner of the Site, which is also where a Public
Footpath dissects part of the proposed Site. The second then is directly off Spien
Road, which runs along the Site’s northern edge.
2.1.5 Under the provisions of the current Carmarthenshire Local Development Plan, the
site adjoins the Development Limits for the settlement of Penygroes, as illustrated in
the plan below.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
Plan B
2.1.6 As can be seen, a small part of the Site lies within the existing defined Development
Limits, with the remainder in essence being almost completely encapsulated by them.
Its position and proposed use therefore represents 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 settlement and form of
Penygroes. The existing built form and pattern of the settlement follows key access
routes, with then further development leading off these in depth, such as the
development of Spein Road to the north of the Site and that of Brynglas to the south.
The larger town of Ammanford is then located a short distance to Penygroes’ south
east and Cross Hands to the north west.
2.2.2 The Site is also located a short distance from the settlement’s core and within walking
distance of all of its community facilities and local services, as well as those offered
by the nearby settlement of Capel Hendre, all of which are marked by the blue circles
on the map below.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
Plan C
2.2.3 Access to further facilities in the larger towns of Ammanford, Llanelli and Cross
Hands can then be gained by regular bus services (including numbers 128 and 129),
a number of stops for which are within a short walk of the Alternative Site (marked by
the red circles on Plan C). The strong sustainable position of Penygroes should
therefore be given full consideration when considering potential future growth options.
2.2.4 In terms of planned growth put forward by 2nd Deposit LDP currently under
consultation, the settlement of Penygroes forms part 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:
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
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
2.2.5 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 Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, this
Report 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 and demonstrates that it
is capable of delivering 33 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 Alternative Site be allocated in the forthcoming replacement
LDP for the purposes of 33 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 Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
3.1.2 As illustrated above, the site is also capable of accommodating a mix of unit sizes
and types, with the associated density – 33 units – having therefore taken into
consideration this potential mix, as well as striking a balance of being reflective of the
existing form and density of residential development in the immediate locality.
3.1.3 With regards then to access, it is proposed that the Alternative Site would be served
by two points of access off the existing local highway network – one off Waterloo
Road and one of Spien Road. The proposals would make provision for the existing
Public Footpath without the need for a diversion, as well as accommodating a speed
table (or similar) as illustrated to act as a form of natural traffic calming.
3.1.4 It is also envisaged that a small area of the site (as shown) could be used to extend
the existing equipped area of play located at the north eastern corner of the site. It is
also recognised and supported that an element of the proposed units would be
affordable in nature, which under the provisions of the current LDP would be in the
region of 12%.
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 either lie within the
site or in the adjoining stretch of aforementioned newly constructed estate road
serving the adjoining residential development.
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.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 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 hedgerow features
forming part of the Land Owners wider ownership.
4.1.2 The site does not form part of any local or national nature conservation designation.
In the wider content, there are then 8 further SSSI designations and 1 SAC
designation within 3km of the Alternative Site (red star on Plan E), who’s locations
are illustrated on the plan below.
Plan E
4.1.3 In view of the above, it is considered that due to the separation distance from these
designations and the Alternative Site, together with intervening topography (including
existing residential development) that these factors will ensure that its development
would have no detrimental impact on any local or national designation.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
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
4.2.1 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 Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
Plan G
(Development Advice Maps)
Plan H
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature and agricultural use, the Alternative Site has no ground
contamination related constraints.
4.3.3 Whilst many areas in the locality have been the subject of mining in the past, Plan F
below (obtained from the Coal Authority) shows that the Alternative Site (marked with
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
a red star) has no known surface or underground workings, or mine entries or
associated ventilation shafts within it.
Plan I
4.3.4 As a result, the Site has no ground stability related constraints to its proposed
development
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

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 £1,150 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.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

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 33 units, with 4 units being made available on an affordable basis (based
on 4 three bed units).
Costs Cost Per Unit/Metre No. Units/Metres Total
Four Bed Dwelling 239200 8 1913600
Three Bed Dwellings 161805 17 2750685
Three Bed Bungalow 131963 8 1055704
Shared Drive Construction 400 134 53600
Road Construction 1200 300 360000
Utility Connections 5000 33 165000
Professional Fees - - 184355
Sprinklers 3500 33 115500
Parks and Education Cont. 5000 33 165000
Total 6598444
Sales
Four Bed Dwelling (Open
Market) 320000 8 2560000
Three Bed Dwellings (Open
Market) 280000 13 3640000
Three Bed Bungalow (Open
Market) 300000 8 2400000
Three Bed Dwelling
(Affordable) 79,380 4 317520
Total 8917520
Developers Profit Total 1337628
Residual Land Value 981448
Table 2
5.1.1 Based on the above figures, it is considered that in-principle, the development of the
site would be financially viable.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is
viable. Furthermore, there are no ownership or physical constraints preventing the
Site’s delivery.
5.2.2 In terms of a delivery timescale, with a developer secured, it is envisaged that the site
could be capable of being completed within 3-4 years from the adoption of the
replacement LDP, as well as in a phased manner within this time period.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

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 Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

7.0 CONCLUSION
7.1.1 Although currently undeveloped, the Alternative Site forms a logical extension to the
existing settlement, being well related to and encapsulated by it, as well as being
positioned at a location within the wider landscape to not form a prominent or logical
part of the surrounding open countryside.
7.1.2 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, which
will ensure it makes a positive contribution to both national and local sustainable
development objectives.
7.1.3 From a wider sense, the Site also benefits from well served excellent public transport
links to the nearby settlements, the larger towns of Ammanford and Cross Hands,
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. In tandem to this, the development of the Site will in turn ensure a deliverable
source of future housing for the settlement and Principal Centre in which it lies, 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.
7.1.4 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.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
7.1.5 In view of the above it is considered that in its current form, the 2nd Deposit LDP fails
to adheres to the Tests of Soundness as a number of the currently proposed
residential allocations will fail to be delivered. In contrast, the Alternative Site
presented herein does satisfy all Tests, and so it is respectfully requested that the
Alternative Site in question be allocated for residential development.