Include site within Plan

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Gwili Developments Ltd to
prepare and submit an Alternative Site Report for the allocation of land at Bronwydd
Arms, 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 approved drawing
package, as well as an integrated sustainability assessment undertaken in-line with
the Authority’s requirements.
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire

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 2.2 acres in
area, edged red on the plan and image below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
2.1.2 The site currently consists of a single enclosure of semi improved grassland with a
mixed topography. All its boundaries are currently well established, being defined by
a mix of mature hedgerows and treelines, agricultural and domestic fencing, with the
latter leading on to existing residential development on its eastern, southern and
northern edges.
2.1.3 Access (red arrow in Photograph 2) to the Site is currently gained directly off the
A484 at a point with excellent visibility, as illustrated below.
Photograph 2
2.1.4 It should be noted that the Alternative Site currently benefits from outline planning
permission for 15 houses (LPA ref. No. W/20622) and our Client and their Design
Team are currently working up a scheme for the submission of a reserved matters
application.
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site is allocated for the
purposes of residential development, as illustrated in the plan below.
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
Plan B
2.1.6 It is recognised that the allocation has yet to be developed, but this is due to the fact
that although the aforementioned application was submitted in 2009 and was
conditionally approved in 2013 by the Council’s Planning Committee, the local
planning authority took a further 9 years to issue the outline planning permission in
2022, through no fault of the Applicant our Client.
2.1.7 The Alternative Site is therefore well related to the existing built form of the settlement
of Bronwydd as a whole when existing residential development directly to its south,
east and north is taken into consideration. Its position and proposed use therefore
continues to 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 Bronwydd. The existing built form and pattern of the settlement is elongated in
nature, principally following and spurring off the A484 and B4301 that runs through it.
However, the settlement does include some ‘in-depth’ examples of residential
schemes, such as Bron y Glyn opposite the Alternative Site, Maes y Dderwen, Gelli
Aur, Bro Celynin and Troed yr Ynys.
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
2.2.2 In terms of community facilities and local services, the settlement includes a village
hall, cricket club and pitch, public house and chapel. It also has a number of very well
served bus stops regularly visited by the 460 and 215 services.
2.2.3 As a result of 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 settlement of Bronwydd forms part of Cluster 1 as
defined by Policy SP3, being designated as a Tier 3 – Sustainable Village. However,
despite this status, the settlement contains only 1 housing allocation, designated for
the delivery of only 6 units. This in itself is surprising and concerning in view of the
sustainable attributes and position of the settlement of Bronwydd in the County’s
settlement network.
2.2.5 In addition to the above, we have undertaken a comprehensive review of the
proposed allocations put forward by the 2nd Deposit LDP for Cluster 1 and 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
PrC1/h4 Land of Parc y Delyn 17
PrC1/MU1 West Carmarthen 700
PrC1/MU2 Pibwrlwyd 247
SeC1/h4 Cae Canfas, Heol Llanelli, Pontyates 8
SuV4/h1 Adjacent Fron Heulog, Cynwyl Elfed 6
SuV12/h1 Adj. Gwyn Villa, Llanpumpsaint 20
Table 1
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
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 at Bronwydd Arms, Carmarthenshire

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 a copy of the approved site layout for the proposed
residential scheme for the Alternative Site. With the approval of the Council, this
layout therefore demonstrates that the Site is capable of providing 15 units in a
deliverable and sustainable manner. The following information therefore expands on
this approved scheme.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Candidate Site be allocated in the forthcoming replacement
LDP for the purposes of15 residential units, in line with the current planning consent.
As detailed above, the accompanying layout (reproduced below) demonstrates that
the site is capable of accommodating this number in a deliverable and sustainable
manner.
Plan C
3.1.2 As illustrated above, the site is capable of accommodating a mix of unit sizes and
types, with the associated density – 15 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
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
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 Site has an
existing point of vehicular access directly off the A484, which in turns represents the
currently approved point of access. The Alternative Site would therefore be served by
an adoptable highway off this point, with footway connections to the site also created.
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 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 at Bronwydd Arms, Carmarthenshire

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, as per the existing outline planning permission.
4.1.2 The Alternative Site 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
Carmarthen 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 near any national or local designations. In addition, it is sufficient distance from
the nearest designation to ensure that it will not have any detrimental impact on this
feature.
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
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 at Bronwydd Arms, Carmarthenshire
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 at Bronwydd Arms, Carmarthenshire

5.0 VIABILITY
5.1.1 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.
5.1.2 In terms of the Alternative Site, no less than two viability appraisals have been
prepared and produced for the proposed development put forward by this report, with
the most recent accompanying this submission. As can be seen from the
accompanying Appraisal – which was fundamental in granting outline planning
consent – the scheme put forward has been demonstrated to be viable.
5.1.3 In terms of deliverability, we note the comments of the Council in their Site
Assessment document with regards to the Alternative Site (as an existing allocation).
The Council expressed the view that “There are concerns regarding the deliverability
of the site. The site represents a longstanding residential allocation.”. However, it
should be noted that the failure to deliver any new units on the Site has not been at
the fault of our Client, but that of the Council in taking 13 years to issue a planning
consent.
5.1.4 With the consent now issued, our Client has begun undertaking further detailed
design work with the aim of preparing a reserved matters application due course, as
the Site is clearly a viable and deliverable form of residential development.
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire

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 at Bronwydd Arms, Carmarthenshire

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. These are in fact views shared by the Council due to it finally recently
issuing an outline planning permission for the Site’s development.
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 also benefits 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 settlement and wider Cluster 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 April 2023
Land at Bronwydd Arms, Carmarthenshire
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.