Include the site within the Revised LDP development limits at Aberlash Road, Ammanford.

We are instructed by Mr & Mrs M. Lloyd to a make a formal representation to the
“soundness” of the Deposit Draft of the Carmarthenshire Local Development Plan.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/004/019, seeking inclusion of their land for future residential development within the
defined settlement limits of Ammanford within the Replacement Local Development Plan.
The Candidate Site comprised two parts, being the frontage part of a grazing field off the
northern side of Aberlash Road, and the majority of an open field fronting the southern side
of Aberlash Road.

We have noted that the northern part of the Candidate Site is included within the draft
settlement limits. Our clients are very satisfied with this inclusion and wish to express their
support and gratitude to the Council. They intend to seek planning permission for detached
houses upon this area within the new limits immediately after LDP adoption.

However, the southern field has not been included within the Second Draft settlement
limits, despite formal representations made to you following publication of the First Draft of
the LDP in March 2020. This formal Representation to the Second Draft relates solely to the
unsuccessful part of the Candidate Site.
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
settlement limits of Ammanford, as contained within the Second 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), with reasons for
non-inclusion reported as follows:
Development of the southern part of the site would be likely to impact upon trees subject to
Tree Preservation Orders and access to the site is likely to be gained through an area which
falls within the C2 floodzone 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 Second Draft settlement limits for Ammanford, 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 for Ammanford, 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
- Location and indicative site layout plan
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Impact upon trees subject to Tree Preservation Order

1.1 The Council consider that the inclusion of the site within defined settlement limits
would be likely to impact upon trees which are the subject of a Tree Preservation
Order. The TPO in question is “E48”, which is shown below, being an extract from the
Council’s on-line record of Tree Preservations Orders in Carmarthenshire.

Figure 2 – Extract of Tree Preservation Order record for Aberlash locality

1.2 The Order amounts solely to two individual mature specimens, one set on the road
frontage of the field, whilst the other lies near the eastern field perimeter with existing
dwellinghouses at Ffrwd -y-Felin. The specimens in question are graphically shown
by the Google Earth image reproduced below as Figure 3.

Figure 3 – Extract from Google Earth (April 2021) illustrating two protected
mature tree specimens

1.3 Both trees are well defined with equi-concentric crown spreads from respective
central trunks, and as such an indicative site layout plan can easily be adapted to
illustrate a form of residential development which can effectively preserve each
specimen and ensure their future health and well-being, allowing existing root
protection areas to be designated and thereafter maintained.

1.4 The original Candidate Site indicative site layout plan has been subsequently revised
to account for this issue, and is reproduced below as Figure 4. It illustrates for only
four detached dwellinghouses set fronting the southern flank of Aberlash Road, and
thus also 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, northern flank of Aberlash Road.
TPO
specimens

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 “Flood Zone
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 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 new draft “Flood Map for Planning” which is due to supersede the
DAM map in 2023/24 also repeats the same extent of flood zone east of the site.

Figure 5 – DAM map illustrating extent of flood zone

Figure 6 – extent of Flood Map for Planning

2.2 In response, our clients would point to that contractors acting on behalf of Natural
Resources Wales have recently begun the implementation of flood alleviation works
to this section of the River Lash, as part of their capital expenditure programme for
the town of Ammanford. The Alleviation Works are considered by NRW to be “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. We
submit that following the completion of these works, it will lead to a revision of the
Development Advice Map, and consequential redrawing of the flood zone
designation.
Notwithstanding this, existing and proposed residents at Aberlash also have the
option to egress the locality by travelling north to Waunfarlais Road and back to the
A483 AND along Waunhafog Road west towards the B4556 Llandybie to Penygroes
road. Neither of which are, nor would be, affected by flooding.

2.4 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. ALL ABERLASH ROAD RESIDENTS WILL HAVE A
LOGICAL MEANS OF EVACUATION as required by TAN15 Guidance.
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 Aberlash Road
properties, which given the limited headroom of the railway bridge have to travel
along Waunfarlais Road to access Aberlash Road properties.

3.0 Overall Housing Supply at Ammanford with Deposit Draft

3.1 The proposals under this Representation merely seek the addition of four residential
units to the overall housing supply of Ammanford. Aberlash 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, and revised the indicative site layout proposals to ensure
any future houses avoid incursion into the root protection zones of two mature protected
trees, and; will 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 Aberlash Farm.
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 Aberlash 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 realigned to include the
Representation Site in the Proposals Map of the adopted Local Development Plan.