Amend Plan to include the site as a mixed use site instead of a reserve site.

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy SG2 are of particular interest to our Client. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.

Our clients made a formal Strategic Candidate Site Submission in August 2018, which was
referenced SR/086/077, seeking the allocation of their land for future mixed development
within the defined settlement limits of Llangennech as part of the Replacement Local
Development Plan, with the area and mix of uses put forward illustrated in the plan below.

Plan A

The Strategic Candidate Site comprised of a range of enclosures, both greenfield and
brownfield in nature, with it having a number of access points off the A4318 running along its
northern boundary and Pontardulais Road running along its north western boundary. The
site is also within close proximity of Junction 48 of the M4 motorway. The site therefore
represents an extremely sustainable location for a strategic form of development, as well as
a location for a park and ride facility to assist with the Councils strategic sustainable
transport objectives.

Following its due consideration, the Council then excluded the Site from the proposed
development limits for Llangennech in its 1st Deposit LDP, published in January 2020 (Plan
B).

Plan B

In explaining its decision to exclude the site and not allocate it for residential purposes, the
Council advised in its ‘Site Assessment Table’ (January 2020) as follows:

“There is sufficient land available for development within the settlement to accommodate its
growth requirements. However, the site may be considered at the revised LDP policy review
subject to the performance of the Plan. The site will remain outside of the development
limits.”

At the time of publication of the 1st Deposit LDP therefore, the principle of development at
the location in question was considered acceptable by the Council, but unnecessary at the
point of the Plan’s adoption. However, as regular review of the Plan may identify shortfalls,
the Council advised that the Site would be allocated under the provisions of Policy SG2
(Allocation SG2/1) as a reserve site, stating that:

“The site’s potential strategic contribution incorporating employment and residential based
proposals is within the context of Swansea Bay and Llanelli’s position within the emerging
National Development Framework.”.

As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission. We note that our Client’s land was considered
as part of this process and as a result the Council concluded as follows:

“There is sufficient land available for development within the settlement to accommodate its
growth requirements. However, the site may be considered at the revised LDP policy review
subject to the performance of the Plan. The site will remain outside of the development
limits.”

As can be seen, the rationale of the Council for the exclusion of the Site as an allocation in
the LDP has remained the same and so in turn the Site continues to be allocated under the
provisions of Policy SG2 as a ‘reserve site’
The Policy sets out that such Reserve Sites will be released for development should other
allocations (identified under Policies HOM1, EME1 and SG1) fail to contribute as expected to
the delivery of the Plan’s strategy. In our view, as detailed in separate submissions made in
relation to such current allocations, we consider that a number of these sites will not be
delivered and so we would fully support the allocation of our Clients land as a Reserve Site
under the provisions of Policy SG2, but would respectfully suggest in view of the evidence
submitted that it perhaps should in fact be allocated under the provisions of Policy SG1.

We therefore welcome the decision of the Authority to concur with the representations
previously made in relation to our Clients land. We can also confirm that the land continues
to not face any ecological, flood risk related, highway, infrastructure or land ownership
constraints that would restrict its ability to be delivered during the Plan period as a Reserve
Site. In fact, our Clients have already been approached by a number of parties expressing a
keen interest in developing the site should it be made available. We therefore fully support
the decision of the Authority to include the land as a Reserve Site as part of the Deposit
LDP.