Amend Plan to include the site

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Ms A Morgan and Mrs I Wright to
prepare and submit an Alternative Allocation Report for the allocation of land at
Glynderi, Tanerdy, 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, as well as a sustainability assessment undertaken in-line with the
Authority’s requirements.
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy

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 3.5 acres in
area, edged red on the plan and image below.
Plan A
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy
Photograph 1
2.1.2 The site currently consists of a sloping grassed enclosure, as shown in Photograph 2
and 3.
Photograph 2 Photograph 3
2.1.3 The site is surrounded by strongly defined boundaries. Its north-western boundary is
defined by an area of mature trees, its southern by a number of residential properties,
while its western and eastern boundaries by existing hedgerows.
2.1.4 As detailed above, vehicular access is obtained directly off Glynderi at the southern
boundary of the site, via an existing hammerhead access located between existing
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy
dwellings. The road is constructed to adoptable standards and therefore provides a
good level of visibility for vehicles entering and leaving the site, as illustrated below.
Photograph 4 Photograph 5
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site presently lies at
the northern edge of the defined Development Limits of the settlement of Tanerdy.
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 south, with its
northern boundary presenting a very strong and defensible boundary to the much
more open landscape to the north of the site (Photograph 6).
Plan B
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy
Photograph 6
2.1.6 As can be seen, the Alternative Site is therefore well related to the existing defined
Development Limits for Tanerdy and the settlement’s built form as a whole when
existing residential development directly to its south 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 Tanerdy. The existing built form and pattern of the settlement follows key access
routes, with then further development leading off those along roads such as Glynderi.
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
settlements of Tanerdy and Carmarthen have to offer, with such facilities and
services being within walking distance of the site (in part due to its position near an
existing Public Footpath to the south of the site – pictured below with the site
indicated by a red star), as well as being accessible via regular bus services.
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy
Plan C
2.2.3 The following table then provides a summary of some of the key facilities and
services present nearby, together with their approximate walking distance.
Facility/Service Distance from Candidate Site
Nearest Bus Stop 200m
Primary School 1 mile
Secondary School 2.8 miles
Hospital 0.8 miles
Shopping Area 1.3 miles
Place of Worship 0.8 miles
Table 1
2.2.4 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.
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy
2.2.5 In terms of planned growth, the proposed Alternative Site forms part of one of the 3
identified Principal Centres within the 2nd Deposit LDP Within these areas, the
majority of the County’s growth (particularly with regards to housing) is expected to
be accommodated within the Plan period. However, 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:
Ref. No. Site Name Units
PrC1/h4 Land off 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
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 March 2023
Land off Glynderi, Tanerdy

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 20 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 20 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 March 2023
Land off Glynderi, Tanerdy
3.1.2 As illustrated above, the site is capable of accommodating a mix of unit sizes and
types, with the associated density – 20 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 Candidate Site has an
existing point of vehicular access directly off Glynderi that benefits from excellent
visibility in both directions. The Candidate Site would therefore be served by an
adoptable highway off this point, with footway connections to the site also created.
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 3 of these units would be affordable in nature, being a mix of social
rent and intermediate in terms of tenure.
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 March 2023
Land off Glynderi, Tanerdy

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 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. The nearest designation is the River Tywi
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 March 2023
Land off Glynderi, Tanerdy
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 March 2023
Land off Glynderi, Tanerdy
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 March 2023
Land off Glynderi, Tanerdy

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 20 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 March 2023
Land off Glynderi, Tanerdy
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 20 units, with 3 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) 108000 6 648000
3 bed bungalow (100sq
m) 120000 14 1680000
Road Construction 1200 300 360000
Utility Connections 5000 20 100000
Professional Fees - 105600
Sprinklers 3500 20 70000
Parks and Education
Cont. 5000 20 100000
Total 3063600
Sales
3 Bed semi(90 sqm) (Aff.) 78286 3 234858
3 Bed semi(90 sqm) 260000 3 780000
3 bed bungalow (100sq
m) 290000 14 4060000
Total 5074858
Developers Profit Total 913474.44
Residual Land Value 1097783.56
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 March 2023
Land off Glynderi, Tanerdy
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. Tanerdy 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 March 2023
Land off Glynderi, Tanerdy

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 March 2023
Land off Glynderi, Tanerdy

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 Principal Centre 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 March 2023
Land off Glynderi, Tanerdy
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.