Include the site for housing within the Revised LDP.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/082/002, seeking inclusion of their land for future residential development within the
settlement limits of Llandybie in the Replacement Local Development Plan. The Candidate
Site comprises of part of a grazing field fronting the eastern side of Waunfarlais Road.
We have noted that the settlement limits within the Second draft Proposals Map have
encircled the existing built development of Waunfarlais Road, which essentially comprises
road frontage development off both flanks of the minor road, extending south from the
railway level crossing of that highway to residential properties about Aberlash.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Ammanford, as contained within the Deposit Draft.
We note that the submission successfully passed through Stage 1 (site compatible against
the location of future growth presented in the Preferred Strategy) and Stage 2A (Initial
Detailed Site Assessment) of the Council’s site assessment. However, it was rejected at
Stage 2B (further detailed site assessment), for reasons reported as follows:
“Development of the site would result in a ribbon patter of development contrary to general
planning principles. Furthermore, the access roads to the site falls within the C2 flood zone
as identified in the TAN15 Development Advice Maps.”
Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the
tests for “soundness,” in that the Plan “is not appropriate,” and “will not deliver,” as defined
by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the draft settlement limits for Llandybie, as defined
under Policy SD1 “Settlement Limits”, should be amended to include the land as edged
in red upon the extract of the Proposals Map, as reproduced below in Figure 1.
Figure 1 – Extract from Proposals Map with Representation site edged in red
This formal representation letter supplements the following documents which comprise a
complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Location plan and Indicative Site Layout plan
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits
1.0 Perception of Ribbon Development
1.1 The Council consider that the inclusion of the site within defined settlement limits
would be likely to result in a ribbon pattern of development, contrary to general
planning principles. In response, our clients would point to the prevailing spatial
pattern of development at Waunfarlais Road. We consider that the setting of the draft
limits to encompass the established form, which is “ribbon development” in character.
1.2 Waunfarlais Road includes for two groupings of frontage dwellings, the respective
settlement limits of each are literally separated by only some 20 metres, as shown in
Figure 1 above.
However, there are instances where the Council have allowed for the settlement
limits to cross to the opposite, undeveloped flanks of the minor highway, and beyond
the end of each grouping of properties. Such breaks from the established form have
allowed the respective landowners of those undeveloped parcels to seek planning
permission for further residential properties. We have noted that since the Candidate
Site consultation stage completed in August 2018, two detached houses have been
constructed with planning permission granted off the opposite flank of the minor road.
Their presence is shown in the current version of Google Earth dated April 2021 at
Figure 2 below.
1.3 The new development appears stark in contrast to the pre-development appearance
of that field frontage, which took a form as that displayed at the Candidate Site.
Google Earth from June 2018 illustrates the locality at Waunfarlais at the time of the
Candidate Site stage (Figure 3).
The completion of those two new houses has dramatically reduced the gap between
the two clusters of built development at Waunfarlais to a level where the further
development proposed by the Candidate Site will mirror that experienced opposite,
and not lead to any detrimental effects, in the form of ribboning, as suggested by the
Council.
Figure 2 – Google Earth – April 2021
Figure 3 – Google Earth – June 2018 – pre-development off the western flank of
Waunfarlais Road
1.4 An indicative site layout plan has been prepared to illustrate for 5 detached
dwellinghouses across the site frontage, and is reproduced below as Figure 4. The
setting of detached dwellinghouses set fronting the eastern flank of Waunfarlais Road
will be complementary in form to adjacent established forms of residential
development along this highway and particularly the exisiting and proposed form of
frontage development off the opposite, western flank of Waunfarlais Road.
New Housing
completed since
Candidate Site stage
Figure 4 – Indicative site layout plan of proposed Representation Site
2.0 Proximity to Zone C2 Flood Zone & Means of Emergency Access / Egress
2.1 The Council indicate that the Candidate Site fails to be included within defined
settlement limits as access to the site is likely to be gained through a “C2 flood zone
as identified in the TAN15 Development Advice Maps.” The Council are referring to
the designated flood zone of the River Lash as reproduced below as Figure 5.
The newly compiled “Flood Map for Planning” (Figure 6) also shows that extreme
fluvial flood waters are predicted as flowing over the public carriageway of Aberlash
Road, where that highway underpasses the Heart of Wales railway line. The Afon
Marlais is also predicted to overtop its natural banks in an extreme event, and partly
flow over the Waunfarlais highway.
Figure 5 – Extract from NRW DAM map for Waunfarlais / Aberlash locality with
the Representation site edged in red
Figure 6 – Flood Map for Planning
2.2 Our clients would point to the recent implementation by Natural Resources Wales of
their flood alleviation works to this section of the River Lash, as part of their capital
expenditure programme for the town of Ammanford. NRW concluded that “a
combination of measures is needed to reduce the risk of flooding. We believe that the
best option is to construct a series of flood defence embankments and walls in
several areas in the town to contain flood water in the River Loughor, and installation
of Property Flood Resilience (PFR) measures to houses on Aberlash Road.”
2.3 We therefore submit that flood prevention matters are being put into place by NRW to
effectively manage the effects of flood waters during such extreme events.
Furthermore, we submit that the land subject of this Representation remains within
Zone A, and as such is not subject to flood risk. In accordance with TAN 15
advice, new residents could remain in their properties, as a place of safe refuge, and
await those extreme floodwaters to recede. We submit that in any extreme event the
depth of floodwaters at this point and are of a depth so as to not to prevent
emergency vehicles from accessing Waunfarlais Road properties.
2.4 The nearby presence of a flood plain did not prevent planning permission
being granted for two new dwellinghouses opposite the Representation Site as
shown above in Figure 2. Planning Permission E/34695 in May 2017. New
residents and visitors to those new houses will have to travel “through
floodwaters” as suggested by the Council, in response to this Candidate Site
submission. However, no objections were received from Natural Resources
Wales as to any potential risks to people or property as a result of nearby flood
risk. The Council’s argument in relation to flooding at our clients’
representation site is therefore tantamount to being complete inconsistency
when applied formally at Waunfarlais Road.
3.0 Overall Housing Supply at Ammanford with Deposit Draft
3.1 The proposals under this Representation merely seek the addition of five residential
units to the overall housing supply of Ammanford. Waunfarlais forms part of the
principal service centre centring upon the Ammanford Cluster as defined within the
Second draft LDP.
3.2 The new Draft Proposals Map reveals that the Council have allocated a total of 8
sites at Ammanford as shown below.
3.3 The above eight alocated sites proposed for Ammanford reveal a combined total of
292 units, howeve upon analysis it is clear Wind Street, Llys Dolgader, Gwynfryn and
Yr Hen Felin have already been constructed, totalling 49 dwellings.
3.4 Of the other four Ammanford allocations, it is immediately noteworthy that they are
predominately “roll-overs” from earlier Development Plans with those sites showing
no commitment whatsoever to commit to the implementation of a planning
application. We would comment on the two largest of those sites as follows:
Site PrC3/h4 - Tirychen Farm, Dyffryn Road, Penybanc - for 150 units.
Planning permission was last granted in 2014 for 289 dwellings, under Application
E/21633. However, that permission was only granted in outline form. It
subsequently lapsed, and the landowners sought to vary conditions upon that
permission to extend the validity of the outline permission. That Variation of Condition
application was finally approved in October 2019, under Application E/38686.
The recently approved Variation of Condition permission does little to display any real
progress in the deliverability of the site. It merely amounts to the landowners seeking
to continue to benefit from an outline planning permission at the site. Full planning
permission was granted as far back as 1992 (D6/19332), which subsequently lapsed.
The Land continued to be allocated within the Dinefwr Local Plan (1996), and
subsequent Carmarthenshire Unitary Development Plan (2003). No progress was
made in bringing the site forward, and yet it was allocated within the Local
Development Plan in 2014. Consequently, thirty years of Development Plan
allocations have elapsed without any signs of delivery of this site. Clearly, there is
no historic demand for a site of this scale in this part of the Ammanford area. More
physically challenging sites, such as the re-development of the Betws Colliery site at
Betws and Cae Pound at Cross Hands West Tip have come forward long before
Tirychen, and yet still the Council is prepared to allocate the site once again in a new
Development Plan.
The decision to retain Tirychen Farm after a period of 30 years within the LDP is
shown to be inconsistent, as does not sit with LDP Procedural Guidance which
encourages Local Planning Authorities to only re-allocate sites based upon firm
evidence of deliverability.
Figure 7 – wider view of Ammanford draft Proposals Map
3.5 Site Prc3/H36 - Betws Colliery – for 66 units
Outline planning permission was first granted for residential development on the
allocation as far back as 2005 (Application E/09584), with reserved matters being
granted in 2011 (Application E/24724). A Non-Material Amendment (Application
PL/04568) has been granted in September 2022 for the ‘Removal of chimneys and
raising the height of window sills’.
The site was allocated in the Carmarthenshire Local Development Plan (2014) as
part of a larger allocation (GA3/h9), and Allocation PDB27 of the Carmarthenshire
Unitary Development Plan (2006), which included the land south of Ffordd y Glowyr,
which has been developed.
However, the northern element continues to be allocated for 66 units in the Second
Draft LDP. This is despite having almost 20 years of support for the principle of
residential development at the historic allocation from the Council, with not a single
housing unit has been delivered to date.
In conclusion, this Representation to the Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-inclusion of a Candidate Site. It has successfully
addressed two technical issues. The new dwellings’ occupants will be able to access the
A483 Ammanford Road via Aberlash Road where the NRW have embarked upon a series of
flood prevention measures, with the aim to lessen the effects of fluvial flooding upon the
locality. The site itself nevertheless remains flood-free.
This Report has also painted an inconsistent rationale applied by the Council in continuing to
allocate historic allocations in the LDP, without the majority of those units having been
brought forward over the last 20 years. Their continued retention within the Plan renders the
Plan as undeliverable, contrary to Planning Policy Wales guidance. Those sites should be
omitted, and more modest alternatives included such as that promoted at Waunfarlais Road.
Our clients have presented their indicative proposals to promote a frontage development of
only four additional dwellinghouses. The proposals will be compatible with existing and
proposed development along both flanks of Waunfarlais Road, and thus ensuring that future
development respects the character and setting of the locality.
We respectfully request that this Representation be given careful examination, and
consequently the defined settlement limits of this part of Ammanford /Llandybie realigned to
include the Representation Site in the Proposals Map of the adopted Local Development
Plan.