Include site within the Plan

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr K Davies to prepare and
submit an Alternative Allocation Report for the allocation of land at Pludds Meadow,
Laugharne, Carmarthen for the purposes of residential development in the
forthcoming replacement Carmarthenshire Local Development Plan (LDP).
1.2 This statement has been prepared in line with the Authority’s published site
assessment and selection documents. The contents of this Statement 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 Statement 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 and Transport Statement, as well as a sustainability assessment undertaken
in-line with the Authority’s requirements.
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Candidate Site relates to a parcel of land measuring approximately 2.8 acres in
area, edged red on the plan and image below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
2.1.2 The site currently consists of a level field that is currently laid to grass, as illustrated
by the photographs below.
Photograph 2 Photograph 3
2.1.3 All boundaries of the Site are currently well defined by existing features,
predominantly mature hedgerows. The exception to this is a post and wire fence
along its northern boundary, which it shares with an adjoining development
compound.
2.1.4 Access to the Site is currently obtained via the aforementioned compound and
adjoining enclosures to the south, also in our Client’s ownership. However, any new
access to serve the proposed development would be at the Site’s south western
corner in the manner indicated on the accompanying plans.
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site presently lies at
the south western edge of the defined Development Limits of the settlement of
Laugharne. 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
and is in effect positioned between two existing housing allocations in the settlement.
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
Plan B
2.1.6 As can be seen, the Alternative Site is therefore well related to the existing defined
Development Limits for Laugharne and the settlement’s built form as a whole when
existing residential development directly to its east, west and north 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 Laugharne. The existing built form and pattern of the settlement follows key access
routes, with then further development leading off those along roads such as the
adjoining development of Pludds Meadow.
2.2.2 Due to this position and close association with the existing built form, the Alternative
Site has excellent access to the range of community facilities and local services the
settlement of Laugharne has to to offer, with such facilities and services being within
walking distance of the site, as well as being accessible via regular bus services.
Such facilities and services include the following:
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
 Nursery
 Primary School
 Several Retail Units (A1 and A3)
 Several Public Houses (A3)
 Sports Clubs
 Several Places of Worship
 Community Hall
2.2.3 In addition to the above, the Alternative Site is also within a short distance and bus
journey from the nearby larger settlement and centre of Carmarthen, which includes a
wider range of community facilities and local services. 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, the proposed Alternative Site forms part of one of Service
Centre’s, as defined by the 2nd Deposit LDP, where second only to Principal Centres,
the Council expects a large portion of the planned growth in the County to take place
due to their sustainable attributes. In turn, the Service Centre then forms part of a
group of settlements defined as Cluster 6 in the Settlement Framework and having
undertaken a comprehensive review of the proposed allocations put forward by the
2nd Deposit LDP for the Cluster 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
SeC18/h1 Adjacent to Brittani Terrace, St Clears 60
SeC18/h3 Land adjacent to Cefn Maes, St Clears 100
SuV60/h1 Land at College Bach, Llangynog 6
SuV61/h1 Land at Nieuport Farm, Pendine 10
SuV63/h1 Land at Woodend, Llanmilow 28
Table 1
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
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 Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne

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 17 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 17 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
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
3.1.2 As illustrated above, the site is capable of accommodating a mix of unit sizes and
types, with the associated density – 17 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. The
positioning of the proposed units has also taken into account the topography of the
site.
3.1.3 With regards then to access, as detailed previously, the Alternative Allocation will be
served by a new access road leading from the existing public highway running
alongside its western boundary. This will then lead into the Site and be to full
adoptable standards.
3.1.4 It is recognised and supported that an element of the proposed units would be
affordable in nature, with the level of provision forming part of the review of the
current LDP. For the purposes of the accompanying viability assessment however, it
is proposed that 2 of these units would be affordable in nature.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Candidate 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 April 2023
Land adjacent to Pludds Meadow, Laugharne

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 site boundary
features.
4.1.2 The Alternative Allocation has been assessed against data held on the “Magic”
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 Laugharne locality. The red star denotes 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 adjacent to any national or local designations. The nearest designation is the
River Taf Estuary SSSI/SAC, but due to the intervening distance and topography, the
development of the Alternative Site will not have any detrimental impact on this
feature.
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
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 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 April 2023
Land adjacent to Pludds Meadow, Laugharne
Plan F
(Development Advice Maps)
Plan G
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature, the Candidate Site has no ground contamination related
constraints.
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne

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 Candidate 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 17 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 Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
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 17 units, with 2 units being made available on an affordable basis (based
on 3 two bed units).
Costs
Cost Per
Unit/Metre
No.
Units/Metres Total
3 Bed semi(90 sqm) 103500 8 828000
3 bed bungalow (110sq m) 126500 4 506000
4 bed det. (160sq m) 184000 5 920000
Road Construction 1200 150 180000
Utility Connections 5000 17 85000
Professional Fees - 95718
Sprinklers 3500 17 59500
Parks and Education Cont. 5000 17 100000
Total 2774218
Sales
3 Bed semi(90 sqm) (Aff.) 78286 3 234858
3 Bed semi(90 sqm) 285000 5 1425000
3 bed bungalow (110sq m) 325000 4 1300000
4 bed det. (160sq m) 350000 5 1750000
Total 4709858
Developers Profit Total 847774.44
Residual Land Value 1087865.56
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 April 2023
Land adjacent to Pludds Meadow, Laugharne
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 2-3 years from the adoption of the Replacement Local Development
Plan, as Laugharne remains an attractive part of Carmarthen given its panoramic
views over the surrounding landscape and good access to nearby schools, shops,
services and community facilities.
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne

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 April 2023
Land adjacent to Pludds Meadow, Laugharne

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, which
will 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 town of 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 Cluster is 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
allocated is assured. Combined therefore with its locational characteristics, the Site in
question represents a sustainable candidate for future housing development.
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
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.