Amend Plan to include the site

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr J Morris to prepare and submit
an Alternative Allocation Report for the allocation of land adjoining Waunfarlais Road,
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/082/002), but the Council
determined to exclude the Site for the following reasons:
“Development of the site would result in a ribbon pattern of development contrary to
general planning principles. Furthermore, the access roads to the site falls within the
C2 flood zone as identified in the TAN15 Development Advice Maps.”
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 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 (submitted at the Candidate Site
Stage), as well as a sustainability assessment undertaken in-line with the Authority’s
requirements.
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to land measuring approximately 1.1ha in area in total,
edged red on the plan and the photograph below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
2.1.2 As can be seen from the aerial photograph above and the accompanying information,
the Alternative Site consists of two parcels of semi-improved grassland, each strongly
defined by mature hedge lines and trees. In terms of topography, the sites slopes
gently downwards in its southern portion, leading then to its more level element in its
northern half.
2.1.3 Access to the site is currently gained via an existing farm entrance lane (Photograph
2), but any future development of the Site would gain access directly off Waunfarlais
Road, which runs along the Site’s eastern boundary.
Photograph 2
2.1.4 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 Llandybie.
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 the
existing development limits extending along its frontage on the opposite side of the
road to the east, and beyond to the south.
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
Plan B
2.1.5 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 north west 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
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
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 nearest of which to the Alternative Site is at the junction of
Waunfarlais Road/McKays with Bonllwyn Road to the east. 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 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:
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
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 April 2023
Land off Waunfarlais Road, Llandybie

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 7 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 7 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 off Waunfarlais Road, Llandybie
3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 7 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 a single point of access serving a short section of adopted highway. From this
then would be further private shared drives as required.
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 April 2023
Land off Waunfarlais Road, Llandybie

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.
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
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 As detailed above, in their assessment of the Site at the Candidate Site Stage, the
Council justified its exclusion of the Site as a housing allocation, in part, due to in its
view “…the access roads to the site falls within the C2 flood zone as identified in the
TAN15 Development Advice Maps.”. Below therefore are extracts of the current
Development Advice Maps or those produced by Natural Resources Wales, with the
Alternative Site edged red.
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
Plan F
(Development Advice Maps)
Plan G
(Flood Maps for Planning)
4.3.2 Based on the above plans, the Council’s stance is somewhat confusing. As can be
seen, no element of the Site – access road or otherwise – lies within any defined
flood risk zone in terms of either the DAM or the Flood maps for Planning. On this
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
basis alone, the Council’s assessment of the site is erroneous and quite clearly
inconsistent when compared with other allocations it has put forward for the
settlement (e.g. PrC3/h21 – Maespiode). In summary, flood risk would not prevent
the delivery of the Alternative Site.
4.3.3 In terms of ground conditions, due to its greenfield nature, the Candidate Site has no
ground contamination related constraints.
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie

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 (200 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 April 2023
Land off Waunfarlais Road, Llandybie
 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 7 units, based on an affordable housing level being a financial contribution
of £41.98 per square metre of internal floorspace.
Costs Cost Per Unit/Metre No. Units/Metres Total
5 Bed semi (200
sqm) 270000 7 1890000
Utility Connections 5000 7 35000
Road and Access 1200 50 60000
Professional Fees - 55020
Sprinklers 3500 7 24500
Affordable Hsng.
Cont. 58772
Parks and
Education Cont. 5000 7 100000
Total 2223292
Sales
5 Bed semi(200
sqm) 500000 7 3500000
Total 3500000
Developers Profit Total 630000
Residual Land Value 646708
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 off Waunfarlais Road, Llandybie
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 April 2023
Land off Waunfarlais Road, Llandybie

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 off Waunfarlais Road, Llandybie

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. Its inclusion within the development limits would also represent a logical
rounding off of the current built form, providing a defensible boundary with respect to
the surrounding open countryside beyond the Alternative Site.
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.
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
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.