Include site within Plan

LAND PART OF SARNAU,
GLANDY CROSS, CARMARTHENSHIRE


1.0 INTRODUCTION
1.1 Mr & Mrs S. Davies (the Land Owner) have instructed Evans Banks Planning Limited
to prepare and submit an Alternative Site Supporting Statement for the inclusion
within defined settlement limits of land part of Sarnau, Glandy Cross,
Carmarthenshire for the purposes of residential development in the forthcoming
Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents
entitled Revised Carmarthenshire Local Development Plan: Guidance Note and
Revised Carmarthenshire Local Development Plan: Candidate Site Assessment
Methodology. The contents of this Statement therefore address the set criteria,
determining the issues and each qualifying point raised within these documents.
Consideration has also been given to ensuring that this formal submission complies
with the guidance and requirements of Planning Policy Wales (Edition 11), in relation
to the preparation of development plans and the allocation of land for residential
purposes as part of that preparation process.
1.3 The contents of this Statement therefore provide a comprehensive case for the
inclusion of the land for residential development purposes within the defined
settlement limits of Glandy Cross, and it should also be read in conjunction with the
accompanying supporting information and indicative site layout plan.

2.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to a parcel of undeveloped agricultural pasture which is
set off the northern flank of a farm access track, off the A478 Road within the village
of Glandy Cross. The entire field parcel is rectangular in shape and extends to a
gross area of 3.4 acres (1.78 hectares). It has a continuous boundary around its
perimeter consisting of hedgerows and mature trees, with the western perimeter
flanking the A478 road.
2.1.2 The Alternative Site is modest, being only approximately 0.36 hectares (0.88 acres)
in overall size, and has a frontage to the surfaced access lane, extending for a length
of 90 metres to a two-storey established property known as Sarnau. That dwelling
benefits from a domesticated garden to its western, front curtilage and also an
irregular shaped enclosure off the southern, opposite side of the access track.
Grazing fields extend to the north and east, with a large pond to be found to the
immediate east of the property. The southern perimeter of the access track and
Sarnau property lies off the rear gardens of bungalow properties set about a cul-sesac known as “Bro Deirian.” Some 10 individual properties encircle a hammerhead
road layout, with traditional rear garden space backing onto the Alternative Site.
2.1.3 The western flank of the A478 Road comprises of more established, older residential
properties set fronting that highway, and with a modest field enclosure set allocated
for further residential development within a triangular-shaped enclosure to its
immediate north, which will have the effect of extending the village northwards. The
Alternative Site should therefore be considered as a logical addition to Glandy Cross
settlement, being directly opposite that allocated field, and which will mirrors that
proposed development, but located to the east of the A478 extending north to an
equivalent distance.

2.1.4 The parcel of land is identified in red by Plan A, which illustrates its wider position
within the settlement of Glandy Cross and shows the existing consolidated form of
modest estate and frontage development to the A478 Road. Plan B provides a
detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – wider setting of Glandy Cross with site highlighted
Plan B – detailed OS Plan of Alternative Site

2.1.5 Photographs of the Alternative Site are reproduced below, showing its current March
2023 condition and form. The Alternative Site is relatively level, and its long frontage
to the A road is equipped with an agricultural field access set just to the north of a
wide public bus top with its associated lay-by. A wide grassed verge lies off the back
edge of pavement, with a linear hedgerow to the site frontage. The Site itself is
relatively level, without any discernible differences in ground or contour levels.
Photo 1 – view of level field from adjacent A478 highway
Photo 2 – view of wide access track from A478 road
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
6
Photo 3 – view to left (south) from existing access onto A478 road illustrating
excellent visibility
Photo 4 – view to right (north) from existing access onto A478 road illustrating
excellent visibility

2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN THE CURRENT ADOPTED
LOCAL DEVELOPMENT PLAN & SECOND DEPOSIT DRAFT (FEBRUARY 2023)
2.2.1 Under the provisions of the current adopted Carmarthenshire Local Development
Plan, the proposed land adjoins the Settlement Limit of Glandy Cross. The site is
shown edged in red at Plan C below, with the Second Deposit Draft Plan extract
shown as Plan D.
Plan C – 2014 Adopted LDP plan for Glandy Cross

Plan D – Second Deposit Draft of Glandy Cross
2.2.2 The Alternative Site adjoins and is well related to the existing defined Development
Limits of Glandy Cross. At present the development limits are drawn tightly about the
existing settlement form at Bro Deirian. The Alternative Site seeks to mirror the
development proposed on the opposite side of the A478.
2.2.3 The Alternative Site’s position and proposed use represents a natural and logical
location for the settlement’s expansion ensuring that development is produced evenly
throughout. Indeed, the property known as Sarnau together with the southern
triangular-shaped enclosure were included within the settlement limits of the
Carmarthenshire Unitary Development Plan. Outline planning permission was
granted in 2006 for a new dwellinghouse within this southern enclosure.
2.2.4 Glandy Cross is a popular location particularly to new homeowners due to its
accessibility to the nearby settlements of Clunderwen, Llandissilio and town of
Narberth and Crymych, and its links via the A478 Penblewin to Cardigan Road.

2.2.5 In terms of the Sarnau Site, it is located within easy driving distance of all community
facilities and local services present provided within Glandy Cross and Efailwen
settlements. Access to further facilities in the town of Narberth to the south and
Crymych to the north can be gained by regular bus services where stops are located
near the village crossroads upon the A478 road.
2.2.6 Transition from Adopted Local Development Plan (2006-21) – Allocation Status
In terms of planned growth, the proposed Alternative Site is located within the
identified SC4 Settlement Cluster within the current LDP, adopted in December
2014. Glandy Cross and Efailwen are regarded by the Council as sustainable
settlement communities several kilometres north of Clunderwen and Narberth within
Pembrokeshire. Within these areas, those settlements are regarded as
accommodating a range of services providing a modest degree of sustainability to the
local community.
2.2.7 A number of the housing allocations within the LDP have yet to be delivered after 8
years since the Plan’s adoption. Glandy Cross appears to now been assessed as a
separate settlement from Efailwen for the purposes of developing the Second Draft of
the Replacement LDP. The new Inset Map identifies two residential allocations.
Plan C above provided an extract from the 2014 Proposals Map for Glandy Cross. It
indicates two residential allocation sites in Glandy Cross, being SC4/h1 at “Maesglas”
and SC4/h2 at “Cross Roads”. The Council have chosen to retain those sites within
the Replacement LDP. Maesglas is now allocated as SuV55/h1 for a total of 9 units,
whilst “Cross Roads” is no longer allocated but continues to lie INSIDE new draft
settlement limits. Plan D below provides an extract of the 2014 adopted LDP extract
for Glandy Cross.
In considering, the formulation of a new Plan, the Council have examined four
Candidate Sites put forward in August 2018. In 2023, the Council provides an
Assessment Report evaluating those Candidate Sites, and in the case of Maesglas
indicates that it should continue as an allocation based upon “Outline Application
pending on this site. Site to remain as an allocation with reference SUV55/h1.” That

application is referenced W/38320 which was granted in May 2021. However, only
outline planning permission was granted, and in the subsequent two years, no
submissions for Approval of Reserved Matters have been made. It therefore remains
questionable as to whether the development of that site will be brought forward.
In terms of SC4/h2 at Cross Roads, the Council’s online application records reveal
that no applications for planning permission have been submitted in the 8 years since
adoption, and therefore it must be questioned why the land remains within settlement
limits?
2.2.8 The net result is that despite the Settlement Community continuing to have good
provision of community facilities, local services and public transport connections to
Crymych and Narberth, its ability to grow and capitalised on these sustainable
attributes has been prevented through a lack of delivery of existing allocations. More
deliverable residential opportunities are required. The deliverability of the remainder
of the longstanding allocations are clearly in doubt, so, in order to re-address this
deficit in provision and capitalise on the sustainability of the Sustainable Community,
more deliverable residential allocations are required.
2.2.9 Second Deposit Draft LDP (February 2023)
The Council published a Deposit Draft in February 2023, which is now subject of
public consultation. Within the Second Deposit Draft, the following sites are allocated
for housing provision within Glandy Cross.
Table 1 – 2023 Second Deposit Draft Allocations

2.2.10 It is noted that the level of allocation in Glandy Cross has remained consistent. The
Maesglas site is evident, as is a new allocation at “land north of Cross PH.” That site
is allocated as SuV55/h2 for 6 units. It is noteworthy given its position lying directly
opposite Sarnau off the opposite, western flank of the A478 road.
We consider that it is clear that there is a need for an additional minor site within the
proposed Replacement LDP. Sarnau is located across the main road from SuV55/h2
and possesses the same physical and locational characteristics as that site. In the
case of Sarnau it benefits from being located off an established vehicular access lane
off the A478 road and has an established residential dwelling located within the
Alternative Site.
2.3 Settlement Facilities
2.3.1 The Alternative Site lies upon the A478 Penblewin to Cardigan main highway, only
some 5 miles south of Crymych. Public bus stops are located immediately adjoining
the Glandy Cross crossroads, only two minutes’ walk from the Alternative Site. Main
public bus services call at these stops, particularly the 430 service (Cardigan to
Narberth) which calls at Crymych to the north and Clunderwen and Llandissilo to the
south.
2.3.2 The Sarnau Site is a short 5 minutes’ drive from Clunderwen railway station which
has services to Cardiff and Swansea to the east and Haverfordwest and Milford
Haven to the east.
2.3.3 It lies within a one-minute walk from the Glandy Cross petrol filling station and
general store whilst Ysgol Beca Primary School is a two-minute drive away at
Efailwen.
2.3.4 Narberth town centre is located a short 15 minutes’ drive away with its associated
comparison shops, high street banks, public houses/cafes, offices, industrial estate,
library, and leisure/recreation facilities.

3.0 THE PROPOSAL
3.0.1 This Statement is accompanied by an indicative layout for a potential residential
scheme that could be development on the site. It should be emphasised that the
accompanying layout is for illustrative purposes only, and that other design solutions
for the site could be reached. Notwithstanding this, the accompanying layout drawing
has taken into account all potential assets and constraints of the site and
demonstrates that it can deliver 4 units in a deliverable and sustainable manner.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Alternative Site be allocated in the forthcoming replacement
LDP for the purposes of a combined total of 4 residential units. As detailed above, the
accompanying illustrative layout demonstrates that the site can accommodate this
number in a deliverable and sustainable manner. Plan E illustrates the indicative site
layout for the Alternative Site, as edged in red, extending off the A478 highway,
proposing a mirrored and balanced development to that to the west of the highway
and Bro Deirian to the immediate south.
Plan E – Site Layout

3.1.2 As illustrated above, the site is capable of accommodating detached bungalows to
replicate and being reflective to the existing form of the development to the south at
Bro Deirian.
3.1.3 With regards to access, it is proposed that the Alternative Site would be served by an
improvements and widening of the existing access track adjoining the A478 highway.
Vehicle speeds are consistent with the 40mph speed limit, and thus visibility splays of
2.4m x 59m can easily be achieved where the accesses adjoin the A478 road.
3.1.4 The Alternative Site proposals can fully retain all existing boundary treatments being
established tree perimeter and hedgerows about the existing house.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Development of the Alternative Site for residential units would be served by mains
water, public sewer and electricity connections.
3.2.2 A new estate road is proposed within the development. This will be equipped with
roadside gullies and drainage which aid discharge run-off from the carriageway. The
proposed accesses to the site could connect to the existing highways drainage.
3.2.3 The Alternative Site comprises of former agricultural pasture and domestic curtilage.
There are no areas of significant marshy grassland or water-logging evident, and
therefore at first inspection, it appears that the site benefits from good ground
percolation of rainwater.
3.2.4 Soakaways would be the most sustainable means of disposing of surface water from
individual properties. If required, attenuation measures can be deployed on site to
control surface water run-off during extreme storm events, which could also allow for
additional capacity, making allowances for climate change. Such features can be soft
engineered in the form of attenuations basins and / or swales, thus adhering to the
principle of Sustainable Urban Drainage Systems (SUDS).

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Alternative Site has been assessed against data held on the “Data Map Wales”
website which details statutory and non-statutory National and Local sites of
ecological importance. Plan F below provides an extract of those records applied to
the Glandy Cross locality. The red star denotes the position of the Alternative Site.
Plan F – Extract from Data Map Wales detailing any known ecological interests
4.1.2 The records reveal that the Alternative Site does not include or adjoin any national or
local nature conservation designation. The Eastern Cleddau SSSI lies several
kilometres west of the village.
Any biodiversity assets that may be present or adjoining the Sarnau Site have been
given full consideration with regards to exploring its potential for residential
development. This has included the proposed retention and management of existing
boundary trees. It is envisaged that the entirety of mature tree lines could be retained
and managed further for uninterrupted biodiversity gain.

4.1.3 It is considered that any statutory and non-statutory designations are significantly
distant from the site, which will ensure that its development would have no
detrimental impact upon them.
4.2 HISTORICAL ASSETS
4.2.1 The Alternative Site has been assessed for any proximity to known and designated
Historic Assets, using the “Cof Cymru – National Historic Assets of Wales” from
CADW’s website. An extract from Cof Cymru Assets map for Glandy Cross is
reproduced below as Plan G. The red star denotes the position of the Sarnau Site.
Plan G – Extract from Cof Cymru Historic Assets website
4.2.2 The extract reveals a multitude of Scheduled Ancient Monuments in the locality;
however, none are to be found within the Alternative Site field enclosure and are
located south-west and north-east of the village.

4.3 ENVIRONMENTAL CONSTRAINTS
Potential for Risk from Flooding
4.3.1 The Alternative Site has been assessed against the Flood Map for Planning,
prepared by Natural Resources Wales, and as referred to within the Welsh
Government’s revised / draft “Technical Advice Note 15: Development and Flood
Risk”. An extract from the Flood Map for Planning is reproduced below as Plan H,
with the site denoted by a red star.
Plan H – Extract from NRW’s Flood Map for Planning
4.3.2 The above plan extract revels that no part of the Alternative Site lies within the
designated flood zones, and thus the potential development of the site is not at risk
from either fluvial or tidal flooding.
4.3.3 An examination has also been made of NRW records relating to potential surface
water flooding, as shown by purple tone in the above plan. The red star again
denotes the positioning of the Alternative Site and reveals there to be no potential for
pooling of surface water upon the site.

Past and Present Potential for Ground Contamination and Coal Mining Activity
4.3.4 The Candidate Site comprises a modest former agricultural field. Due to its greenfield
nature and agricultural use, the field as no history of known past ground
contamination related constraints.
4.3.5 The records of The Coal Authority have been examined and reveal no history of coal
mining in this part of the County.
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 aspects inherently poses risks that the Plan may be unsound and so in turn fails
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
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 4 units
on the Alternative Site in question. It is based very much on its greenfield status and
uses values 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 land
value for the scheme.
Costs
• Dwelling construction costs are based on an absolute minimum of £1300 per
metre given that bespoke four bed detached bungalows (160 sq.m.), with a medium grade of internal finishing, and formation of accesses to the highway
are likely to be the preferred house type.
• Estate road carriageway costs are placed at £1200 per linear metre
• Connections for all utilities include water, foul water and electric.
• Developer’s Profit based on minimum RICS guidelines (18%)
• Professional Fees include planning application fee, associated professional
fees, estate agency fees (1%) and LABC Warranty fee.
Sales Values
• Sale Prices based on LPAs “Affordable Housing” Supplementary Planning
Guidance, market research and Welsh Government “Acceptable Cost
Guidance” figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the
proposed 4 units, based on an affordable housing level being a financial contribution
of £75.00 per square metre of internal floorspace.
Costs Cost Per Unit/Metre
No.
Units/Metres Total
Four Bed Bungalows 208,000 4 832,000
Road Construction 1200 100 120,000
Utility Connections 5000 4 20,000
Professional Fees - - 40,000
Sprinklers 3500 4 14,000
Affordable Housing 75 640 48,000
Contribution
Total 1,074,000
Sales
Four Bed (Open M’kt) 400,000 4 1,600,000
Developers Profit Total 288,000
Residual Land Value 238,000
Table 2
5.1.3 Based on the above figures, it is considered that in-principle, the development of the
site would be financially viable. The residual land value of £238,000 for a site consisting of four development plots (£59,000 per plot) is consistent with evidence
gathered over recent years by the District Valuer in examining residential site
transactions within Carmarthenshire. The DV discovered land values on completed
and on-going sites to be averaging £245,000 per net residential acre of land, based
on 2020 values.
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, with a developer secured, it is envisaged that the site
could be capable of being completed within 2 years from the adoption of the
replacement Local Development Plan. Glandy Cross remains an attractive part of the
cluster of villages about the Cardigan to Penblewin Road, benefitting from its semirural location, but easy access to Crymych and Narberth by road and the nearby
schools, shops, services and community facilities.
5.2.3 The presence of modern, detached houses and bungalows adjoining and located
immediately alongside at Bro Deirian is testament to this market need and the desire
for home buyers to seek out such forms of modest residential development.

6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.1 In the preparation of any development plan, consideration must be given to national
planning policy and guidance. At present, this takes the form of Planning Policy
Wales and a series of Technical Advice Notes (TAN) that deal with a variety of topic
areas.
6.2 With regards to residential development, or housing, the overarching requirements
and principal guidance set by national policy can be found at Paragraph 9.2.3, which
reads as follows:
“Local planning authorities must ensure that sufficient land is genuinely available
or will become available to provide a 5-year supply of land for housing judged
against the general objectives and the scale and location of development provided for
in the development plan. This means that sites must be free, or readily freed, from
planning, physical and ownership constraints, and economically feasible for
development, so as to create and support sustainable communities where people
want to live. There must be sufficient sites suitable for the full range of housing types.”
6.3 At present, Carmarthenshire County Council’s housing supply figure is below the
required 5-year level therefore, it is imperative that this is addressed as quickly as
possible to avoid further deterioration of communities and the facilities and services
they have to offer.
6.4 Dealing specifically with the Alternative Site subject of this Report, it is evident that its
inclusion within the Replacement LDP would adhere to the requirements of PPW, in
that it is free from any planning, physical, or ownership constraint. In addition, as
shown in Section 5 of this statement, the site is also economically viable in
deliverability terms.

7.0 CONCLUSION
7.1 The Alternative Site is modest in overall size, with an established dwellinghouse
located within a modest side curtilage and southern enclosure, backing onto Bro
Deirian. That property and southern enclosure was set within the 2006 Unitary
Development Plan and benefitted from outline planning permission to site a
new dwellinghouse in this enclosure. At that time, the Council saw no reason
to consider this site as one not otherwise conforming to the spatial and
consolidated form of the village.
7.2 The Site lies within close proximity and walking distance to the existing community
and local services of Glandy Cross and Efailwen 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 nearby settlements, specifically the town of Crymych and
Narberth, together with other locations within and adjoining the County. In tandem to
this, the development of the Site will in turn ensure a deliverable source of future
housing for the Sustainable Community in which it lies, which has seen both allocated
sites fully developed leading to an under supply 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 recognises the suitability and deliverability of modest
sites if it is to continue to realise the contribution villages such as Glandy Cross make
to the housing land supply.
7.4 With the Alternative Site having no access, ground condition, flood risk, hydrological,
ecological, archaeological or land ownership constraints, its delivery if included within
settlement limits is assured. Combined therefore with its locational characteristics, the
Site in question represents a sustainable alternative for future housing development.
7.5 In view of the above and the information provided within this Statement, it is
respectfully requested that the Alternative Site in question be included within limits for
a modest residential development.