Allocate the site for housing within the Revised LDP.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr M Ingram to prepare and
submit an Alternative Allocation Report for the allocation of land adjoining Rhosdeg,
Rhosmaen for the purposes of residential development in the forthcoming
replacement Carmarthenshire Local Development Plan (LDP).
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, as well as an integrated sustainability
assessment undertaken in-line with the Authority’s requirements.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to land measuring approximately 2.7 acres in area in
total, edged red on the plan and the photograph below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
2.1.2 AS can be seen from the aerial photograph above, the Alternative Allocation forms
part of a larger agricultural enclosure, which currently consists of improved grassland,
used historically for a mix of grazing or silage/hay purposes. The Site’s south
western, southern eastern and north eastern boundaries are all well defined by a mix
of domestic fencing and established hedgerows. Its remaining north western
boundary is then currently undefined, leading on to the remainder of the
aforementioned agricultural enclosure.
2.1.3 Access to the site is currently gained via an existing agricultural gateway leading
directly onto the adjoining A40, with good levels of visibility in both directions as
illustrated below.
Photograph 2 Photograph 3
2.1.4 Under the provisions of the current Carmarthenshire LDP, as illustrated in the plan
below, part of the Site’s frontage currently lies within the defined development limits
for Rhosmaen, with its remainder then lying beyond.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
Plan B
2.1.5 Notwithstanding the above, as can be seen, the Site (outlined in red) adjoins the
current built form of the urban area directly to the south west, south east and north
east and so is well related to the settlement’s existing built form as a whole. 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
Rhosmaen, which forms part of the wider urban area of Llandeilo and Ffairfach (Tier
2 – Service Centre). As a result, the Site is within walking distance of a number of its
community facilities and local services, including the following:
 Primary School
 Secondary School
 Several Retail Units (A1 and A3)
 Several Public Houses (A3)
 Several Places of Worship
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
2.2.2 From an accessibility perspective, Rhosmaen is within walking distance of a station
on the Heart of Wales line, is located on a main transport artery in the form of the A40
Trunk Road, as well as having very well served bus stops, the nearest of which to the
Alternative Site is less than 100m to the south west. The bus services serving the
settlement are numbers 280 and 281, which provide regular access to many
settlements in between and including Llandovery and Carmarthen. The strong
sustainable position of Rhosmaen should therefore be given full consideration when
considering potential future growth options.
2.2.3 As detailed above, Rhosmaen forms part of a Service Centre 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 5 in the Settlement Framework, with the table below providing an
indication of the proposed allocations in the 2nd Deposit LDP for the cluster.
Ref. No. Site Name Units
SeC15/h1 Land to north of Dan y Crug, Llandovery 61
SeC15/h2 Land adjacent to Bryndeilog, Tywi Avenue, Llandovery 8
SeC16/h1 Llandeilo Northern Quarter, Llandeilo 27
SeC17/h1 Land opp. Llangadog C.P School, Llangadog 16
SeC17/h3 Ger yr Ysgol, Llangadog 21
SuV49/h1 Ael y Mynyd, Llanfynydd 13
SuV51/h1 Opp. Village Hall, Cwmifor
Table 1
2.2.4 The above provides a worrying picture with regard to housing supply in the cluster in
question. Despite being the largest and most sustainable Service Centre of Cluster 5,
Llandeilo/Rhosmaen/Ffairfach has a far lower level than the smaller settlement of
Llandovery and less than half the number allocated for Llangadog, despite the
settlement being half the size of Llandeilo.
2.2.5 The above is even more worrying when the deliverability, or the ability to deliver the
assigned number of units of some of the above allocations are in serious question
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
(SeC17/h1 and SuV51/h1), as well as some sites despite being allocated for over 30
years, still having not delivered as single unit (SeC15/h1)
2.2.6 As a result of the above, separate objections have been made in relation to a number
of the aforementioned allocations and it is therefore important that alternative more
deliverable sites should be identified, to ensure the Plan can be regarded as being
‘sound’ in targeting new housing development at the most sustainable location.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen

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 31 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 31 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 adjoining Rhosdeg, Rhosmaen
3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 31 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 directly off the A40. From this then would be a new
adoptable estate road, with private shared drives where required.
3.1.4 As illustrated on the plan above, provision would also be made for a Local Equipped
Area of Play, a facility that is not currently present in the settlement of Rhosmaen.
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. Due to the Site falling within the River Tywi
SAC catchment, the scheme would also include provision for on-site foul water
treatment infrastructure to adhere to current phosphate regulations, as illustrated on
the accompanying drawings.
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 adjoining Rhosdeg, Rhosmaen

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 Rhosmaen 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 SAC is within 1km of the site,
due to the intervening distance and topography, the development of the Alternative
Site will not have any detrimental impact on this features.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
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 Below 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 adjoining Rhosdeg, Rhosmaen
Plan F
(Development Advice Maps)
Plan G
(Flood Maps for Planning)
4.3.2 Although a very small portion of the Site’s north eastern edge lies within an area
determined as being at risk of flooding, as can be seen, this would not prevent its
delivery for the proposed number of new housing units. Nor would it prevent access
to the Site during an extreme flood event. In summary therefore, flood risk would not
prevent the delivery of the Alternative Site.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
4.3.3 In terms of ground conditions, due to its greenfield nature, the Alternative Allocation
has no ground contamination related constraints.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen

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 £1150 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 adjoining Rhosdeg, Rhosmaen
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 31 units, with 4 three bed units being affordable.
Costs Cost Per Unit/Metre
No.
Units/Metres Total
2 Bed (90 sq m) 103500 10 1035000
3 Bed (115 sq m) 132250 16 2116000
4 Bed (145 sq m) 166750 5 833750
Road Construction 1200 140 168000
Utility Connections 5000 31 155000
Professional Fees - 153192
Sprinklers 3500 31 108500
Parks and Education
Cont. 5000 31 100000
Total 4669442
Sales
3 Bed (115 sq m)
(Aff) 78286 4 313144
2 Bed (90 sq m) 170000 10 1700000
3 Bed (115 sq m) 245000 12 2940000
4 Bed (145 sq m) 300000 5 1500000
Total 6453144
Developers Profit Total 1161565.92
Residual Land Value 622136.08
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 adjoining Rhosdeg, Rhosmaen
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 3 years from the adoption of the Replacement Local Development
Plan.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen

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 adjoining Rhosdeg, Rhosmaen

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 wider settlement group it
forms part of. From a wider sense, the Site will also benefit from well served excellent
public transport links to the nearby conurbations of Llandovery, Ammanford 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 adjoining Rhosdeg, Rhosmaen
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.